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Regional Analysis of Impediments to Fair Housing Choice (AI)

Since 2012, the Baltimore Metropolitan Council has been assisting local jurisdictions and public housing authorities (PHAs) -- the Baltimore Regional Fair Housing Group -- with regional fair housing planning and implementation.

Final 2020 Baltimore Region Fair Housing Analysis 

Building on more than 18 months of work with a consultant team led by Root Policy Research, including eleven meetings of a Regional AI Stakeholder Work Group, the Baltimore Regional Fair Housing Group has finalized its 2020 regional fair housing analysis, which will shape the programs of the participating jurisdictions and agencies for the coming five years. Appendix F is a summary of comments received during this past spring’s public comment period and jurisdiction/agency responses.

Download the Final 2020 Analysis of Impediments to Fair Housing Choice (AI):


AI Process

Six jurisdictions and five public housing authorities (PHAs) carried out this process, with assistance from the Baltimore Metropolitan Council and the Root Policy Research consultant team:

  • City of Annapolis and the Housing Authority of the City of Annapolis
  • Anne Arundel County and the Housing Commission of Anne Arundel County
  • City of Baltimore and the Housing Authority of Baltimore City
  • Baltimore County
  • Harford County and the Havre de Grace Housing Authority
  • Howard County and the Howard County Housing Commission

The participants relied on May 23, 2018 guidance and data that the U.S. Department of Housing and Urban Development (HUD) made publicly available at the time, as well as other locally available data, in carrying out this analysis. The participants voluntarily cooperated regionally and also voluntarily followed the template of the Assessment of Fair Housing created by HUD to implement the July 2015 HUD rule on affirmatively furthering fair housing, even though HUD’s May 2018 guidance withdrew that template as a required element of the analysis. In August 2020, HUD repealed the 2015 rule altogether.

The new AI replaces the 2012 AI, described below, that jurisdictions and PHAs have been implementing over the past several years. Local governments and PHAs have included action steps from the 2020 AI that pertain to their jurisdiction in their Consolidated Plans and PHA plans for using federal housing funds that began July 1, 2020.

If you have any questions, please send them to BMC’s housing policy coordinator Dan Pontious at dpontious@baltometro.org with “Fair Housing Analysis” in the subject line.

2012 Regional AI

In 2012, the Baltimore Regional Fair Housing Group finalized a new Analysis of Impediments to Fair Housing Choice (AI). The AI contained a Regional Section (Errata Sheet here) and local sections for Anne Arundel County, the City of Baltimore, Baltimore County, Harford County, and Howard County.

Funding from a HUD Sustainable Communities grant (creating the Opportunity Collaborative), combined with Community Development Block Grant funds from the local jurisdictions, enabled BMC to hire a housing policy coordinator to work with the jurisdictions and PHAs on carrying out the Action Plan in the AI's Regional Section. BMC and the jurisdictions have sustained the coordinator position beyond the close of the HUD Sustainable Communities grant.

BMC's Housing Committee, created through the Sustainable Communities program, continues to serve as a forum for the Fair Housing Group jurisdictions and PHAs to work through Action Plan implementation with stakeholders in the region. Each year the Fair Housing Group updated its year-to-year 2012 AI Implementation Plan with input from the Housing Committee. Click here to see the full Fiscal Year 2013-2020 Implementation Plan for the 2012 Regional AI.

See BMC's Fair Housing web page for additional results of 2012 Regional AI implementation.