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4 <br /> <br />In 2017, federal entitlement jurisdictions in the Twin Cities region as well as other regional cities <br />and counties, operating through the Fair Housing Implementation Council (FHIC), sponsored the <br />creation of an Addendum to the 2014 Regional Analysis of Fair Housing Impediments (RAI). A <br />prominent theme that surfaced in the Addendum was a recognition that when lower income <br />households (often households of color) are involuntarily displaced, that presents a Fair Housing <br />issue. This is because protected class groups face restrictions on housing choice—in this case, <br />the choice to remain in their housing.In response, the FHIC sought proposals on the development <br />of strategies on housing displacement prevention. The Housing Justice Center (HJC) was <br />awarded a contract to do this work.1 This report is the result of that work. <br /> <br />The report addresses some strategies that the FHIC voiced a particular interest in, as well <br />as additional strategies or policies HJC has identified in the course of this work. Most of the <br />strategies or policies relate to cities as they most often touch on traditional areas of local <br />government activity such as land use. In some cases counties are relevant as well, however, and <br />we have tried to identify those instances, while acknowledging that the level of county <br />involvement in housing varies considerably across the seven county metro area. <br /> <br />This report comes out as the Twin Cities region faces an unprecedented threat to its <br />supply of affordable housing, and in particular, to its supply of naturally occurring affordable <br />rental housing, often referred to by the shorthand NOAH. The erosion in affordability of the <br />supply of NOAH housing due to an accelerated rate of acquisitions and repositioning of <br />buildings has been well documented.2 Many of the strategies discussed below relate to this <br />threat to NOAH housing, though the strategies address other displacement threats as well. <br /> <br />Because a number of these strategies are new policy innovations, the legal landscape <br />around these ideas is not always settled. Below we briefly touch on some of the most significant <br />legal issues. In many cases HJC has conducted more detailed legal research and analysis which <br />we will share upon request. <br /> <br /> <br />ASSISTING PRESERVATION BUYERS IN ACQUIRING NOAH PROPERTIES <br /> <br />One of the proven strategies for preserving the affordability of NOAH housing is through <br />the acquisition of these properties by mission driven nonprofit and for-profit housing providers <br />committed to keeping these properties affordable over the long term. The Twin Cities has been <br />fortunate to benefit from the decision of affordable housing providers like Aeon and <br />CommonBond to target the acquisition of at-risk NOAH housing, as well as through the <br />development of lower cost financing through the NOAH Impact Fund, developed by Greater <br />Minnesota Housing Fund. <br /> <br />In addition, some local public agencies have been actively attempting to purchase NOAH <br />properties. Both the Carver County CDA and the CAP Agency for Scott County have been <br /> <br />1 The Housing Justice Center is a Minnesota based public interest law firm dedicated to preserving and expanding <br />the supply of affordable housing. For more information, see www.hjcmn.org. <br />2 Cite to MHP reports: ATTICUS JARAMILLO & CHIP HALBACH, MINN. HOUSING PARTNERSHIP, <br />SOLD OUT (2016), http://www.mhponline.org/images/Sold_Out_final_revised_small.pdf.