Comprehensive Housing Policy Racial Equity Audit Report – Part II:

Christine Campbell of TDA Consulting presents the findings of the Comprehensive Housing Policy Racial Equity Audit during the Housing and Homelessness Solutions Committee meeting, Dec. 14. – The Dallas Examiner screenshot/City of Dallas video

Reducing racial disparities and housing inequality


The Dallas Examiner


“One of the things that we found is that the current Comprehensive Housing Policy – while trying to create a steady state – it was silent on equity, said Christine Campbell of TDA Consulting as she read the Housing Policy Equity Analysis. “And what we have is a document and a policy that lists the housing programs available to us, the administrative rules of the road and what we can use to be able to build affordable housing.”

The consultant agency conducted the analysis as a result of the housing audit. Campbell presented the findings during the Housing and Homelessness Solutions Committee meeting held Dec. 14.

Campbell said her group also noticed that the policy basically had no process in place that would address the impact of previous policies and practices that have upheld segregation and inequality.

“We learned from you, as well as from the Comprehensive Housing Policy, that there were still structures in place that have the impact of having a segregated Dallas,” she continued. “And we know that’s not what the goal is.”

She said the goal is to reduce racial disparities and address housing inequality.

Noting the historical baggage that has placed some Black and Latin communities at a disadvantage, she talked about the need to have policies that level the playing field and policies that reverse previous policies and practices that held back people of color.

To make this happen, she said it was important to ask, “How do we have planning that accounts for some of the local impediments? How do we have planning that acknowledges significant differences from community to community both culturally as well as structurally in costs of property, in infrastructure, in zoning? How do we move to ensure that all areas of the city are developing in a way that makes sense for them?

What complicated the issue further is the fact that what one underserved part of the city needs in terms of equity, may be different from what another underserved area needs. There are some areas that need serious infrastructure development, while other parts need various types of housing development and others need anchors to attract developers.

“We note that there was not a really an evaluation framework for the Council to be able to use as projects were coming before the council,” Campbell explained. “How do you know whether or not that project is actually gonna move [the city] closer to your desired goals? And then we also noted that the city staff is so dedicated to this work and wanting to make this a successful affordable housing system, however, they did not have the ability to move nimbly; in terms of: Should there be changes in the market? Should there be changes in systems that would need to be able to adjust the tactics, not the plan, on being able to adjust their tactics in being able to address and achieve their goals? So, somehow empowering your staff to do what needs to be done to actually achieve the goals?

She said one of the crucial components in tackling race equity is the ability to share power. One of the things she said the staff needed was the power to be able to “act nimbly” in regard to the city’s housing goals. The group also noticed that there was not a committed funding stream to do the work and reach some of the targets that have been established. Yet, to create a successful policy, it was essential to have adequate funding dedicated advance equity in affordable housing system.

“There are examples of this across the country of cities that have been able to do this, and we are here in Dallas,” she pointed out. “We don’t have to reinvent the wheel. We can look at somewhere some cities subsidies we’ve done, creating those dedicated funding streams to making this work.”


Equity blind spots

She said the agency then took what they were referring to as equity blind spots. She also noted that the goals did not demonstrate an overall desired state.

“What is it that Dallas is trying to build as we do race equity work?” she asked. “One of the things we talk about is dismantling racist systems that promote segregation. And what we also need to talk about is, as we dismantle that, what is it that we’re trying to build? … We know and there are references in the comprehensive public housing policy to the other plans that are important in the city.”

The group also noticed that all of those plans needed to work together. Therefore, the key is to discover a strategy for coordinating all of the different plans.

She said the city’s discussion about reinvestment strategy areas and what they are, were tools for how to build an equitable Dallas.

“If we can show how these reinvestment strategies move us towards equity, that needs to be delineated out in your policy,” Campbell stated. “Your policy has some production goals, but again, without a vision of what we’re trying to build, they’re not necessarily anchored against anything in in particular.”

She said the city’s comprehensive policy had a list of incredible programs that the consulting team believed would be the tools that implement the policy, not necessarily the policy itself.

She advised that instead of every project being approved by the City Council, it should be observed more at the system’s level, or what’s moving forward or what’s coming before the Council.

In other words, once a plan has been approved by the by the City Council, each of the details didn’t necessarily have to be brought before the council. This would move it closer to the goals that have been set, according to the report.


Neighborhood investment zones

Campbell then discussed the neighborhood investment zones section in the report and how to connect the dot in a way that made sense in order to move us city forward.

Again, she emphasized the need for a dedicated funding source. The funding may need to come from multiple sources that work together.

“To move you forward on your goal right now your policy lists what was available but doesn’t really discuss how they’re supposed to work together and whether or not it actually meets the needs that are laid out in your goals,” she reported.

This means having a funding strategy with each goal having resources attached to it.

Here’s the crux of the matter here. This is what we found in your plan … you have plans and you have information that has laid out some of these concerns around equity before. It’s up to the council to decide whether or not you’re going to do something different this time,” she said, “A priority is addressing housing through a race equity lens, such that you really want to move forward. So will you create that strategic roadmap that really sets a course towards redressing that North/South divide? … And do you want to do something different about it? Will you address the legacy of race-based policy choices that have saddled Southern Dallas, in particular with enormous deficit in basic infrastructure, which the development of mixed income neighborhood depends?”

The report addressed the need to take a different approach in addressing some of the city’s basic infrastructure needs that allow for development in Southern Dallas. It also noted, in talking to people in various communities, there’s a legacy in some of the Freeman neighborhoods that’s very important to them. However, in speaking with some of the elders in those communities, there was a need to make the area more attractive so that people will want to live there.

However, Campbell said that running water, electricity and sidewalks was key to ensuring that underserved areas could be developed in a way that would allow people to thrive in their historic areas.

“And we actively work to level the playing field that has been tilted in favor of predominantly White areas to the North, making significant investments in Southern Dallas. So here’s again, where we talk a little bit about that equity,” she noted.

“We can not only write policies for the move forward, addressing some of those inequitable practices, but are we going to undo some of the historical pieces that have really prevented communities from thriving.”



Campbell concluded with recommendations, saying that first and foremost, the city needed a creative vision statement articulating how affordable housing can be played out in Dallas and how it can close the North/South divide.

“Interesting enough, so many cities across the country have this North/South divide,” she noted. “It’s really interesting how that that still continues to be part of that legacy.”

Secondly, she said the city needed to create a comprehensive citywide strategic roadmap that would enable the use of the tools in Neighborhood Empowerment zones – in communities and partnerships – that can address the various needs discussed in the report. This should be implemented with smart goals and objectives that are measurable, that hold everyone accountable as the city moves forward with the plan.

Third, was that the city should strengthen the connections between its housing policy and the Neighborhood Revitalization Strategies that leverage infrastructure improvements, economic revitalization and mixed-use master planning to build a foundation for increasing generational wealth in historically Black and Latin communities.

“One of the things that we’ve seen and we’ve noted and was shared with us, is that in some of the White communities there is a legacy of generational wealth, of properties passed from generation to generation. And it’s not just properties, its thoughts and values that are passed from generation to generation of the expectation to succeed,” she stated. “We need to also create that in Black and Brown communities as well. That starts with making sure that though their communities have the infrastructure that they have the anchors in those neighborhoods, that they’ve been designed in such a way that reflects the community.”

The fourth was focused on the reducing the city’s massive infrastructure deficit, which would also need dedicated funding in order to be successful. Along with that, the city would need to tackle NIMBYism – meaning “Not in my back yard” – across all 14 districts. Otherwise, nothing would move forward until there were plans and resources identified for all of it to move forward.

“What tends to happen is … if there is a commitment that nothing is moving forward until all areas can move forward, we move forward together and we don’t leave anyone behind,” she added.

The fifth recommendation was for the city to create a dedicated revenue stream that is scaled to the magnitude of the Dallas affordable housing shortage.

The sixth recommendation was to expand and refine programs to prevent displacement. Campbell said part of the work would be acknowledging the fact that one of the key elements of gentrification is that people get displaced. As communities begin to change, intentionally and direct plans need to be in place to prevent displacement.

“Too many communities have waited until after the plan has been implemented. ‘Oops, all of those folks have been displaced. That was not what we intended to do.’ We’re saying ‘No,’ they knew that upfront,” she said.

She went on to say that all city staff policymakers and the public should be educated about racial equity, what it means, its benefits, how it can sometimes feels unfair to some people, but how it moves the ball forward.

Then they need to addresses some of the storable barriers that have been in place to ensure that the entire city can thrive.

“However, if this policy is going to be successful, everyone needs to be grounded in what equity means, and what it means in the context of affordable housing and community development,” Campbell stated.

The seventh recommendation was in regard to the Low Income Housing Tax Credits.

“There was a lot of discussion about whether or not Low Income Housing Tax Credits could or should be used in different parts of the city – when they are used as one of the tools and they are strategically used in both high and low high Opportunity Areas, as well as those with low poverty rates,” she explained. “That is when they’re the most beneficial, but they need to be used strategically as a tool.”

The last recommendation was that the housing policy dispels myths about affordable housing, which fuels NIMBYism. She said affordable housing that is used as a strategy throughout every community increases property values and decreases crime rates.

“So we really want to make sure we dispel those myths about affordable housing –that ‘We don’t want that kind of project in my neighborhood,’ when in essence, that’s part of part of the work of revitalizing communities, having a successful affordable housing program there,” she concluded.

The committee will host four citywide community town hall meetings to present the report, Jan. 17 through Jan. 21. The meetings will be listed on


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