CONSOLIDATED PLAN
The Lake County Consolidated Plan for 2010–2014 identifies providing access to fair
housing for residents as a high-priority goal. The plan states:
All Lake County residents will be assured of equal, fair, non-discriminatory, and
open access to decent, safe, and sanitary housing choices. Everyone who is
eligible to participate in the Consortium’s housing programs as a developer,
owner, sponsor, or resident will have access to the benefits of the fair housing
laws, executive orders, and regulations.
The fact that the County has identified equal access to housing as a high-priority goal is
laudable. However, fair housing is a right not only for current residents of Lake County
but also for non-resident households who would like to relocate to the County, a subtlety
the Consortium can make more clear in subsequent Consolidated Plans and
County/City materials.
FUNDING APPLICATIONS
A central requirement of receiving CDBG and HOME funds is that entitlement
communities must affirmatively further fair housing. This responsibility flows down to
any subrecipient of funding. AREA reviewed the Lake County application for 2014
CDBG, HOME, and ESG funds to identify references to fair housing activities. Although
the County has a separate application for a contractor to manage its fair housing
program, the other applications for funds have no explicit references to fair housing.
Though the applicants are informed that they must comply with all applicable federal
laws, the application does not explicitly outline the funding applicants’ responsibilities for
affirmatively furthering fair housing.
The fair housing responsibilities of all the County’s funding recipients (“subrecipients”)
are clearly stated, however, in Lake County’s grant agreement that each subrecipient
must sign before receiving federal pass-through funds. The fair housing responsibilities
of the subrecipients stated in the grant agreement (signed by each subrecipient and the
Lake County Board chairman) include:
A) Compliance with Provision Governing Nondiscrimination in Housing
This Agreement is subject to Executive Order 11063 as amended by
Executive Order 12259 and the implementing Regulations of 24 CFR - Part
107 concerning nondiscrimination because of race, color, religion (creed),
sex, handicap, familial status or national origin, in the sale, leasing, rental, or
other disposition of residential property and related facilities (including land
to be developed for residential use), or in the use of occupancy thereof, if
such property and related facilities are, among other things, provided in
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APPLIED REAL ESTATE ANALYSIS, INC.
LAKE COUNTY, ILLINOIS