September 30, 2014
Jodi Gingiss
Community Development Administrator
500 W. Winchester Road, Unit 101
Libertyville, IL 60048
Dear Ms. Gingiss:
Open Communities commends Lake County and Applied Real Estate
Analysis on the thorough and thoughtful Analysis of Impediments. We
would like to stress the importance of this document and look forward
to the active implementation of the Action steps.
As I stated in my comments during the public hearing on Tuesday,
September 23, 2014, Impediment 17 identifies the problem that
protected classes may not have equal access to housing opportunities.
The review of testing results is identified as a recommended action. We
would also encourage continued testing throughout Lake County. Our
service area extends into the southern portion of Lake County, including
Highland Park, Highwood and Deerfield. We have done extensive
testing throughout this area and our experience shows time and time
again that testing is often the only way to find evidence of
discrimination. In many instances, people do not know that they have
been discriminated against and it is only through testing that the
practice is uncovered.
Open Communities’ recently released executive summary of our three
year HUD grant showed that while most complaints received by our
office were for disability discrimination, instances of discrimination from
our audit testing were most found to be based on race. We believe this
is because race discrimination is not obvious, and home seekers will not
know they are being steered or given different terms and conditions on
a lease unless their experience can be compared to that of other home
seekers. Members of protected classes will continue to will be treated
politely, and then turned away from the housing they are seeking.
Impediment 18 identifies the limited understanding of federal and state
protected classes, in particular, persons with a disability. Testing also
allows fair housing centers to look for fair and equal treatment in all