Fair Housing Center presents Analysis of Impediments; recommends certificates, zoning changes and stronger enforcement

Noah Woods, a staff attorney at the Fair Housing Center, presented the organization’s Analysis of Impediments (AI) to fair housing, a companion document to the Consolidated Plan that identifies local barriers and recommends an action plan for the next five years.

Woods described the AI as the product of community outreach, public meetings at library branches, online surveys and analysis of demographic and lending data. He said the full AI is available on the Fair Housing Center’s website and on the city’s site.

The AI identifies 14 priority barriers. Among those Woods highlighted were:

- Criminal-history screening and reentry barriers: Woods said disparate outcomes in the criminal justice system can follow people into housing markets and cited disparities in arrest rates: “black men are arrested at 5 and a half times the rate as their white counterparts,” he said. The AI recommends using the Certificate of Qualification for Housing (CQH) program to reduce landlord liability concerns and expand housing access for people with prior records.

- Access to homeownership: The AI calls for more homeownership fairs, incentives to encourage banks to expand lending in underserved neighborhoods, and targeted programs to increase mortgage access in historically marginalized communities.

- Accessibility and ADA compliance: The city’s older housing stock predates some federal accessibility standards; the AI recommends stronger enforcement and compliance with state and federal accessibility requirements.

- Source-of-income discrimination and voucher mobility: Woods noted the City of Toledo has a local source-of-income protection ordinance; he said source-of-income discrimination (for example, against Housing Choice Voucher holders) continues to limit mobility and housing choice. The AI urges the city to work with Lucas Metropolitan Housing to increase voucher-holder mobility and address landlord practices that limit transfers.

- Zoning and infill development: The AI recommends updating zoning to enable sustainable infill housing development and adopting measures to incentivize healthier local retail options (e.g., limiting small-box stores in food deserts and encouraging urban agriculture) to improve neighborhood access to groceries.

- Other priorities: The AI calls for combating discrimination against LGBTQ+ residents, improving tenant access to code enforcement for substandard housing conditions, addressing transportation barriers and better policing of utilities reselling practices.

Woods emphasized enforcement and education: the AI pairs each identified impediment with concrete action steps and enforcement recommendations. He encouraged readers to review the AI’s executive summary and action plans and noted the full document is about 167 pages.

“The analysis of impediments…provides an action plan for identifying the key barriers,” Woods said. “We begin with doing community outreach through a variety of online surveys as well as public outreach meetings.”

The Fair Housing Center recommended the city incorporate the AI’s action steps into the Consolidated Plan and prioritize measures that expand voucher mobility, enforce accessibility and source-of-income protections, increase homeownership outreach and roll out CQH certificates in coordination with reentry partners.