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  • W3HJ

Comments on Draft DC Racial Equity Action Plan

01/31/2023


Ward 3 Housing Justice is a grassroots advocacy group organizing for truly affordable housing

and economic opportunity, particularly for Black and Brown DC residents. Given the District’s

long history of racial inequity, particularly in Ward 3, we appreciate the opportunity to comment

on ORE’s Draft Racial Equity Action Plan (REAP).

The plan is unlikely to effect significant change since it is largely focused on process, and the

outcomes are mainly counting the places and number of times the process gets done. This is an

indirect path to achieving racial equity and lacks the required urgency. The plan lacks any strong

commitments to concrete actions. Although the plan is intended "to identify and understand the

root causes of racial inequities” and to address those harms by “tailoring policy and

programmatic solutions to those most harmed by individual, institutional, and structural racism,”

there is not much, if anything, in the plan that does that. In large part, it is a collection of vague

generalities---a plan to plan.


1. The plan should evaluate current programs, policies and practices that cause or

do not repair racial inequities--a prerequisite to developing corrective strategies.


For example, although the Housing Production Trust Fund has been increased in recent years,

and the investment is included as a sample of the racial equity work currently being undertaken

by DMPED, decisions about what to fund have not been made with a racial equity lens. HPTF is

required by law to devote 50% to deeply affordable housing, which would benefit people of

color; instead, the fund has supported higher income residents who are disproportionately white.

In discussing REAP action and accountability, the draft plan states, “agencies will be required to

submit at least one strategic initiative with a racial equity focus and a related performance

measure every year.” In addition to focusing on new initiatives, ORE should do spot reviews of

existing significant agency actions and programs and evaluate their racial equity impact. In

addition, ORE, in consultation with impacted community members, should identify programs,

policies and actions with the most significant impact on Black and brown communities and

evaluate them with an appropriate racial equity tool. City officials should be required to apply a

racial equity lens to each major decision and develop measurable indicators of program

improvement, a task that the plan’s drafters have begun in the Appendix.


2. The plan focuses on process to the exclusion of outcomes.


Process requirements for training, development of assessment tools, interagency relationships,

etc. are not sufficient. The focus should be on results, applying a racial equity lens to every

major programmatic decision made by DC staff.


Goal 2 in particular does not have any strong commitments to actions that would eliminate racial

inequities. The sub goal is simply to finalize a list of indicators to track, not a commitment to

demonstrate change through the use of the tools at the Mayor’s disposal. If counting meetings

and participants is the measure, then an individual agency could declare REAP compliance

without changing a single thing in the programs it administers.


We recommend that for each of the 7 themes identified in the plan, the staff identify outcomes

that reflect an increase in equity and the indicators that reflect progress toward that outcome.

The indicators in the Appendix are a good start, but are too limited. In regard to housing, for

example, indicators should include not only percentage of households spending more than 30%

but also measures such as a decrease in the public housing vacancy rate, a reduction in the

number of maintenance complaints in public housing, and an increase in the percentage of

affordable units, including deeply affordable units, in every ward of the city, especially in areas

where historical exclusion has resulted in highly segregated neighborhoods.


Additionally, the city should identify areas of the city that warrant particular attention when

looking at racial equity by overlaying disaggregated data on census tracts to see how the data

coincides with demographic information on race and ethnicity. Overlaying indicators such as

highest unemployment rates and lowest access to health care would identify areas of the city

that need special attention with interventions to increase racial equity. These areas are places

where agencies should focus on producing equitable outcomes and measure results.


3. The draft’s community engagement provisions should be strengthened.


The plan’s measures of engagement are process-oriented rather than outcome-oriented. For

example, they assess how many working groups were created rather than how the working

group’s priorities were incorporated into the agency’s work. A number of District agencies have

the reputation of going through the motions with community members, proposing a limited

number of outcomes, asking for community input as to only those outcomes, and then going

ahead with their original proposals without modifying the original proposals in any meaningful

way, despite the comments they received.


Community Engagement should:


● Give community members a greater role in planning and budgeting from the outset

● Ensure that affected community members comprise the majority of the participants in

planning groups

● Involve a broader range of residents and community organizations in the engagement

process (in addition to ANCs), including grassroots organizations that represent and/or

are led by impacted community members, like Empower DC

● Develop and implement indicators that reflect how comments have been incorporated

and require ORE to assess whether a new or modified program or policy had meaningful

community engagement

● Compensate people on working groups


4. Although the draft REAP acknowledges the racial equity programs of other cities,

it does not adopt their most productive strategies.


For example, Seattle has developed a displacement risk index that includes factors that include

the risk of marginalized populations being displaced, e.g. income, education, percentage of

renters. This is important in applying a racial lens to land use decisions. Seattle also has

developed an access to opportunity index that includes factors that contribute to a

neighborhood’s social, economic and physical well being. This is important in assessing the

impact of decisions in all 7 areas identified by the plan. These types of indices should be

incorporated in the REAP.


5. The relationships between the master REAP and the agency REAPS should be

better defined.


Individual agency REAPs should model their work on the District’s overall REAP; however, as

noted above, the overall REAP lacks specificity. The requirements for individual agency REAPs

should be more demanding. For example, the DOEE pilot requires an REIA for each DOEE

division. This requirement should be required for all DC agencies annually and should begin

now.


As another example, it is commendable that DMPED and DMHHS address specific equity

programs within their respective jurisdictions, but the focus is on the increase in funding. The

increase is welcome, but the REAP should examine how the money will be spent to promote

racial equity. Each agency should submit a narrative description of how a proposed project will

further the goals of overcoming segregation and fostering inclusive communities. Budget

increases are not results unless they are likely to specifically address underlying inequities.


Finally, agency REAPs should be required of every agency, not just those in the pilot program,

and the Racial Equity Action Teams should be required to produce measurable results and

provide descriptions of changes made as they work toward racially equitable outcomes.


We commend the REAP drafters for their work on the draft plan and hope that these comments

and recommendations will be helpful in strengthening the plan’s provisions.

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