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DHCD tells HRC Baltimore is ahead of VCA approval goals but faces construction and enforcement headwinds
Summary
DHCD staff told the Human Relations Commission the county has approved 1,102 units against a 2024 interim VCA goal of 970 units, but cautioned that approvals do not equal completed or leased units; staff also described federal guidance rollbacks that limit some testing and enforcement tools.
Deputy Director Sylvia Bolivar and DHCD policy staff briefed the Baltimore County Human Relations Commission on Nov. 13 about progress under the county’s Voluntary Compliance Agreement (VCA) with HUD and on fair housing outreach, testing and data collection plans.
DHCD policy director Milana Beyer summarized the VCA as a civil‑rights agreement between Baltimore County, HUD and complainants that aims to increase family housing in areas of opportunity. Beyer said the county’s 2024 interim approval goal was 970 hard units and that the county has reported 1,102 units "approved" (approved means financing approval, not completed construction or occupancy). The VCA runs through March 2028 and includes subgoals for households at 30% of area median income, three‑plus‑bedroom units, and accessible (UFAS/Wheelchair‑accessible) units.
DHCD cautioned that approvals are only the first step: the department must still track how many units are constructed, how many are leased, and whether accessible and family units meet the subcategory goals. Staff said post‑pandemic construction cost increases, labor shortages and supply‑chain gaps have delayed some projects and created funding gaps.
On enforcement, DHCD staff described recent federal changes that have rescinded several HUD guidances and focused enforcement on "clear" provable instances of discrimination. Staff warned that FHA‑funded Fair Housing Assistance Programs (FHAPs) may be restricted from using federal funds for some kinds of testing, including source‑of‑income testing, and that using certain federal funds for that work could risk a program’s FHAP certification. DHCD noted local and state protections (the HOME Act was cited as a 2019 local law and a 2020 state action) but said federal fund restrictions complicate how jurisdictions can conduct and fund testing.
DHCD reported contracted providers’ recent activity: Economic Action Maryland served 180 tenant households (431 residents) in the July 2024–June 2025 reporting year and the Equal Rights Center completed 46 rental/sales/lending tests covering source of income, disability, race and criminal‑records issues. DHCD said it will coordinate quarterly with contractors, present aggregate test data to the regional fair housing work group, and explore shared data collection to inform enforcement and outreach strategies.
DHCD also summarized the county’s regional five‑year fair housing assessment and local action goals. The department identified four impediments — lack of fair housing knowledge, insufficient affordable/safe housing, lack of accessible housing for people with disabilities, and gaps in financial education — and described actions such as outreach, housing counseling and single‑family rehabilitation funds.
Next steps: DHCD will share the regional fair housing plan link with commissioners and expects to meet quarterly with fair housing contractors; staff recommended data‑driven tracking of referrals and test results to support enforcement decisions.
Quote: "Just because we have units approved doesn't mean we don't have plenty more work to do to get to our goals," Beyer said. "Approved just means they have been approved for financing for funding. That is just the first step in the development process."
