Spring 2024

Lena Zennia, "Exclusionary Zoning and the Affordable Housing Crisis"

Abstract
         To conduct this research, I formulated the following research question: how have exclusionary zoning practices perpetuated the affordable housing crisis in the United States? Such inquiry challenges the relationship between exclusionary zoning and the economics of purchasing living spaces for the lower class and addresses an increasingly pressing issue in which the lower class, in the United States, is struggling to find affordable housing and questions what practices have caused and further perpetuate such problem. I hypothesized that if exclusionary zoning is prevalent in a given area, then the price of housing increases and the affordable housing crisis is exacerbated. In order to execute this research, I undertook a synthesized analysis of maps and models of the city of Chicago and the Washington, D.C metropolitan area, in addition to the Supreme Court case, Village of Euclid v. Ambler Realty, data to understand the relationship between exclusionary zoning practices and the affordable housing crisis. In the research conducted, I found that exclusionary zoning perpetuates the affordable housing crisis by stifling economic growth for underserved communities, limiting opportunities for homeownership for low-income households, and expanding urban sprawl and limitations on multi-tenant housing, thus raising the costs of housing. The results of the research conducted affirmed my hypothesis that if exclusionary zoning is prevalent in a given area, then the price of housing increases and the affordable housing crisis is exacerbated.
Introduction

          In the United States, the lower and middle classes often struggle to find affordable housing in safe and accessible areas that have been effectively zoned for them and their families. With the booming global population, more people are entering metropolitan areas while zoning practices and policies are prioritizing expensive, single tenant/family housing over dense, mixed- use and multi-tenant buildings. For the purpose of this investigation, I developed the following inquiry to guide my research: how have exclusionary zoning practices perpetuated the affordable housing crisis in the United States? This question addresses an increasingly pressing issue in which the lower class, in the United States, is struggling to find affordable housing and questions what practices have caused and further perpetuate such problem. My inquiry challenges the connection between exclusionary zoning and the economics of purchasing living spaces for the lower class. The term “exclusionary zoning” refers to policies, practices, and laws that exclude and prohibit certain types of land uses. For this paper's purposes, exclusionary zoning is defined as the exclusion that allows for multi-tenant and mixed-use land usage. The affordable housing crisis refers to the nation-wide dilemma in which individuals and families of low income are struggling or unable to afford housing for themselves and/or their families. This question is relevant because as urbanization increases parallel to socio-economic inequality, solutions must be configured for the population’s most basic needs, such as housing, to be met. With this question as the focus of my work, I have created a hypothesis that outlines the expected outcomes of the relationship between exclusionary zoning practices and the affordability of housing. After analyzing the current relevant literature, I predict that if exclusionary zoning is prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated. The results of exclusionary zoning practices show that the hypothesis attempts to predict occurrence between the independent and dependent variables. In this research design, the independent variable is the practice of exclusionary zoning, and the dependent variable is the affordability of housing. These variables are reflected in the included theoretical model (Figure 1).


          This paper's sections include a literature review in which I synthesized a comparative review of the current relevant literature using scholars' works in urban policy, urban planning, economics, and more relevant practices. Next in this paper, I have provided a methodology section that outlines how I synthesized three case studies using maps and models of the city of Chicago and the Washington, D.C metropolitan area, in addition to the Supreme Court case, Village of Euclid v. Ambler Realty, to answer my research question. Then, I engage in an analysis of the data, in which I am able to affirm my hypothesis and connect the current relevant literature to assert that exclusionary zoning practices perpetuate the affordable housing crisis by expanding urban sprawl and limitations on multi-tenant housing, limiting economic potential for people of color, Black people in particular, and stifling the development of subsidized housing. Finally, I offer conclusions by reviewing the process in which I conducted the research. I assert that until zoning ordinances change to prioritize smart growth and the inclusion of affordable housing for low- and middle-income communities, it can be expected that the affordable housing crisis will continue to be exacerbated.

Literature Review

Introduction:
          In the United States, the lower and middle classes have been struggling to find affordable housing in safe and accessible areas that have been effectively zoned for them and their families. I am challenging the relationship between zoning practices and the affordable housing crisis with the following question: how have exclusionary zoning practices perpetuated the affordable housing crisis in the United States? After synthesizing the current relevant literature, I hypothesize that if exclusionary zoning is prevalent in a given area, then the price of housing increases and the affordable housing crisis is exacerbated and I argue that exclusionary zoning perpetuates the affordable housing crises by expanding urban sprawl and limitations on multi- tenant housing, limiting economic potential for people of color, Black people in particular, and stifling the development of subsidized housing.

Background:

          With the booming global population, more people are entering metropolitan areas while zoning practices and policies are prioritizing expensive, single tenant/family housing over dense, mixed- use and multi-tenant buildings. For this literature review, exclusionary zoning is defined as the exclusion of zoning that allows for multi-tenant and mixed-use land usage. The affordable housing crisis refers to the nation-wide dilemma in which individuals and families of low income are struggling or unable to afford housing for themselves and/or their families.
          There are several reasons for the rise of exclusionary zoning, the most prominent being racial bias. Whittemore introduces the subject by mentioning that “Scholars have detected a relationship between high levels of metropolitan racial segregation and local zoning practices that restrict the construction of denser, multi-family housing” (Whittemore, 2018). It is important 
to note the connection made by White Americans between the race of a person and their “orderly conduct.” Shertzer, Twinam, and Walsh claim that “the origins of comprehensive land use regulation in Chicago were rooted in public demand for “orderly” urban development, in particular, the prevention of industrial and commercial encroachment on residential neighborhoods” (Shertzer, Twinam, & Walsh, 2016). The literature supports the idea that White people viewed and can continue to view Black people as “disorderly.” Shertzer, Twinam, and Walsh continue to write that “White residents were concerned by the arrival of blacks from the South, seeing them as ignorant and rough-mannered, entirely unfamiliar with the standards of conduct in northern cities” (Shertzer, Twinam, & Walsh, 2016). Similarly, Whittemore also discusses the arrival of Chinese immigrants and how local governments implemented zoning practices that prevented the new immigrants from flourishing. Whittemore writes that “in the 1880s, cities in California began to limit the areas where laundries could operate for the stated purposes of protecting property values and preventing fires. Many laundries owned by Chinese newcomers to California also served as social venues for the new immigrants (Whittemore, 2018). In addition, “white immigrants were also concerned about competition for jobs from newly arrived African Americans and viewed the prospect of Negro neighbors as a ‘catastrophe equal to the loss of their homes’” (Shertzer, Twinam, & Walsh, 2016). Both sources of literature agree that White people feared that the influx of people of different ethnic and racial backgrounds served as a threat to their community, thus disrupting their “ecosystem.” Despite such discomfort sustained by white communities described by Shertzer, Winam, Walsh, and Whittemore, due the US Supreme court case Buchanan v. Warley, racial zoning (zoning policy and practice that explicitly discriminated against certain races from living in each area) was determined illegal in 1917. However, the case was decided based on morality and the treatment of racial minorities, it was decided to favor White land-owning men. Whittemore writes “The US Supreme Court overturned racial zoning in Buchanan v. Warley (1917) because it had prevented a White Louisville man from selling his property in a White zone to an African American buyer (Sager, 1969). Nevertheless, some southern cities pursued racial zoning into the 1940s (Silver, 1991). While most northern cities did not pursue racial zoning, racial and ethnic hatreds motivated their zoning of land uses (Whittemore, 2018). The literature indicates that the origins of exclusionary zoning correlate to existing racial tensions.
 Urban Sprawl and Limitations on Multi-Tenant Housing
         
Exclusionary zoning complements urban sprawl because of its ability to uniformly regulate sprawl. Since the ignition of the affordable housing crisis, there has been a lot of controversy surrounding the causes and consequences of urban sprawl. Urban sprawl being the expansion of low-density housing and single use zoning practices outside of dense, urban spaces. It is commonly believed that because of the cheap cost of suburban development, urban sprawl has mitigated the affordability of housing. However, despite its direct effects, current literature argues that urban sprawl indirectly exacerbates the affordable housing crisis. Hamidi and Ewing assert that “urban sprawl has been proved by previous studies to be a driver of housing affordability. Previous studies, however, were structurally flawed because they considered only costs directly related to housing and ignored the transportation costs associated with a remote location” (Hamidi & Ewing, 2015). Bhatta contrasts Hamidi and Ewing’s take on the common perception, but ultimately agrees that “sprawl is usually accepted as being inordinately costly to its occupants and to society” (Bhatta, 2010). Hamidi and Ewing’s findings were consistent with ideas that density can lead to lower costs of living, even if housing prices may be higher. They write, “perhaps the most notable finding was that the combined cost of housing and transportation decline as the compactness score rises. As metropolitan compactness increases, transportation costs decline faster than housing costs rise, causing a net decline in household costs” (Hamidi & Ewing, 2015). Bhatta takes on the idea that “sprawl requires more infrastructures, since it takes more roads, pipes, cables and wires to service these low-density areas compared to more compact developments with the same number of households” (Bhatta, 2010). Interestingly, Kushner signifies the importance of considering affordable housing as the sort of infrastructure that Bhatta discusses. Kushner asserts that “affordable housing should be viewed as infrastructure with an adequate supply assured through planning and implementation just as communities assure the availability of adequate retail, office, industry, schools, or streets” (Kushner, 2010). Bhatta compliments that idea by saying “urban sprawl often occurs in peripheral areas without the discipline of proper planning and zoning; as a result, it blocks the ways of future possible quality services” (Bhatta, 2010) because such quality services can be regarded as infrastructure. Furthermore, Kushner discusses public services and their decline with the rise of urban sprawl. Kushner argues that “public services in the city declined as suburban services improved with the support of their enhanced tax base. As public schools were faced with broad desegregation remedies, whites increasingly left the city causing the further decline of the structure and tax base” (Kushner, 2010). Kusher directly associates the rise of suburbs with the concentration of poverty by asserting that “as suburbs increased access costs through regulation, inflated demand pushed land prices, exclusionary zoning and growth management, the suburbs and city became distinguished from one another by class. The poor became concentrated in the city and the affluent in the suburbs” (Kushner, 2010). The current literature supports my argument that exclusionary zoning perpetuates the affordable housing crisis through urban sprawl because urban sprawl is unable to facilitate an economy necessary for affordable housing to exist on all sides of the income spectrum.
          Literature supports that a commonly proposed solution to the affordable housing crisis is to increase the quantity of multi-tenant, also known as multi-family, housing. However, because exclusionary zoning prioritizes the development of single-family housing, developers oftentimes are unable to or have no incentive to construct affordable, multi-tenant housing. Marantz and Zheng define “zoning, which entails the division of territory into zones with specified permitted land uses, enables local governments to limit the construction of affordable types of housing, such as apartments and townhomes. This use of local regulatory authority to thwart projects affordable to low- and moderate-income (LMI) households is commonly described as exclusionary zoning” (Marantz & Zheng, 2018). Similarly, Span argues that “exclusionary zoning techniques, such as mandating minimum lot size and banning multi-family housing, have the effect of spreading housing out and contributing to urban sprawl. Such spreading out, in turn, raises the per unit cost of municipal infrastructure. Insofar as these costs are passed on to developers through development exactions, the cost of housing is further increased because developers either pass the costs on to homebuyers or build fewer units because of the greater cost” (Span, 2001). Span continues to say that “general prohibitions on multi-family housing made in the name of bona fide zoning goals have a disparate impact on those who cannot afford single-family housing” (Span, 2001). Nelson, Pendall, Dawkin, and Knaap cite multi-family housing as a solution to the problems outlines by Spand, Marantz, and Zheng by outlining that “since multi-family housing is often rented, and since black and Hispanic residents depend heavily on rental housing to gain entry into a jurisdiction, urban growth boundaries and adequate public facilities ordinances may have "inclusionary" benefits that help balance any tendency they may have to raise housing prices” (Nelson, Pendall, Dawkin, & Knaap, 2002). The current literature supports the argument that because exclusionary zoning prevents the development of multi-tenant housing, which serves as affordable housing for many low- and moderate-income families, exclusionary zoning perpetuates the affordable housing crisis.

Economic Limitations for People of Color

          Devers and West seek to link exclusionary zoning as a causal mechanism for homelessness, a major effect of the affordable housing crisis. The authors explicitly assert that the lack of affordable housing, caused by exclusionary zoning practices and policies, have led to the influx of homelessness. Devers and West write that “homelessness is, among other things, a housing problem; therefore, barriers to the availability of low-income housing for the homeless should be removed” (Devers & West, 1990). Devers and West simultaneously argue that barriers to housing should be removed, and that exclusionary zoning is a barrier to housing, especially for the homeless. It is imperative to explicitly address which groups are most affected by homelessness that Devers and West describe. According to Jones, “Black persons remain substantially overrepresented in the U.S. homeless population, comprising roughly 40.4 percent of the total U.S. homeless population, but only 12.5 percent of the overall population” (Jones, 2016). Furthermore, Devers & West assert that “Lower-income families are economically excluded from certain areas of cities through ordinances prohibiting construction of apartments, use of mobile homes, and conversion of single-family dwellings into multifamily dwellings” (Devers & West, 1990). The literature suggests that many Black people are stuck in a perpetual cycle of homelessness and by synthesizing the work of Devers and West with that of Jones, it can be said that homeless people, who are overwhelmingly Black, are the most harshly affected by the affordable housing crisis that is caused by exclusionary zoning. Because exclusionary zoning exacerbates homelessness by limiting low-income housing, exclusionary zoning, by default, perpetuates the affordable housing crisis.
          As previously discussed, exclusionary zoning segregates people of color because “lower- income families are economically excluded from certain areas” (Devers & West, 1990). Primary and secondary education are imperative components of a child’s development. However current literature supports the idea that the location of a child’s residence immensely impacts their quality of education because public education funding relies on property taxes. Chetty and Friedman state that “property taxes that are set and collected at the school-district level accounted for 34 percent of funding for public schools in 2007” (Chetty & Friedman, 2010) and that “richer communities not only have larger property tax bases, but many have higher tax rates. These financing arrangements have led public school expenditures, as well as public school quality, to vary dramatically across cities and states” (Chetty & Friedman, 2010). Porter discusses such variation in school quality, that Chetty and Friedman allude to, by suggesting that “since income groups tend to be somewhat segregated geographically the trend towards greater income inequality among families should result in greater differences in average earnings across school districts” (Porter, 1993). Cashin further pushes this discussion to say that “the cost of real estate is significantly higher in the predominantly White suburban areas” (Cashin, 2004), thus costing taxpayers more money in property taxes (thus leading to a higher quality of education), and that in reference to poor minority students, “because of the status of these schools, the students are not able to develop the skills they need to be successful in the world. This, in turn, leads to a high incidence of unemployment and widespread degradation within the neighborhoods they call home (Cashin, 2004). Similarly, Chetty and Friedman write that “if richer families sort into school districts that spend more to produce higher quality education, and quality of education has a causal impact on children’s incomes, then local financing of public schools may propagate income inequality” (Chetty & Friedman, 2010). The literature supports that because exclusionary zoning causes segregation and that segregated communities have less access to high quality education, thus leading to income inequality, children of color who have fallen victim to exclusionary zoning may not be able to afford housing as adults, thus exacerbating the affordable housing crisis.
          Another effect of exclusionary zoning practices is that they limit job accessibility for low-income workers, who are disproportionately minorities. Serkin and Wellington argue that “traditional exclusionary zoning-as practiced at the municipal level-is not the only form of residential exclusion. At the regional level, lower-income households need the ability to move to employment opportunities” (Serkin & Wellington, 2013). Similarly Kawabata discusses suburbanization, an outcome of exclusionary zoning, and brings up public transportation by writing “suburban jobs are often beyond the reach of public transportation, job dispersion may put low-skilled workers without automobiles at a significant disadvantage in securing employment” (Kawabata, 2002) and pushes the idea further by citing John F. Kain by mentioning that “Kain's hypothesis states that a combination of housing segregation and job suburbanization reduces employment opportunities for African-Americans in inner cities and lowers their employment outcomes (Kain, 1968)” (Kawabata, 2002). Alongside Kawabata’s discussion, Seeking and Wellington point out that “that cars are expensive to own and operate, and that the absence of public transportation options can effectively exclude lower-income workers from a neighborhood” (Serkin & Wellington, 2013). Serkin and Wellington challenge
exclusionary land use controls by noting that there is “some evidence that inter-regional mobility is on the decline, and some further evidence that one cause may be land use controls-particularly 
land use controls enacted in higher-income states. This is troubling as an economic phenomenon and poses significant challenges to lower-income workers unable to access regions with higher wages. As a result, regional income convergence has slowed, due at least in part to residential restrictions limiting access to these more economically vibrant parts of the country” (Serkin & Wellington, 2013). The results of Kawabata’s study pose a solution for the assertion of Serkin and Wellington regarding “restrictions limiting access to these more economically vibrant parts of the country” (Serkin & Wellington, 2013), by concluding that “improved transit-based job accessibility significantly augments both the probability of being employed and the probability of working 30 hours or more per week for
auto less workers in San Francisco and Los Angeles” (Kawabata, 2002). The work of Serkin and Wellington agrees with that of Kawabata’s by suggesting that “greater density-at least in certain contexts-can lead to greater availability of services, from public transportation…” (Serkin & Wellington, 2013). Because exclusionary zoning practices limit job accessibility, low-income workers are unable to form stable careers, which limits them from being able to afford adequate housing for themselves and their families, thus aggravating the affordable housing crisis.

Lack of Subsidized Housing
          Government subsidies for affordable, multi-tenant housing can help ease the effects of the affordable housing crisis for the country’s most vulnerable victims. However, those that reap the benefits of exclusionary zoning and wish for their communities to remain homogenous, are often extremely opposed to the development of affordable housing for those of extremely low incomes. Leopold, Getsinger, Blumenthal, Abazajian, and Jordan discuss the high importance of subsidized housing, while Danielson provides accounts of the reason why such subsidized housing isn’t being developed: white suburbanites. Leopold, Getsinger, Blumenthal, Abazajian, and Jordan state that “Since 2000, rents have risen while the number of renters who need low- priced housing has increased. These two pressures make finding affordable housing even tougher for very poor households in America. Nationwide, only 28 adequate and affordable units are available for every 100 renter households with incomes at or below 30 percent of the area median income” (Leopold, Getsinger, Blumenthal, Abazajian, & Jordan, 2015). Despite the grave need for subsidized housing, local officials have dismissed such urgency to prioritize white suburbanites. Danielson provides an account “in another Connecticut suburb where SAI took an option on eleven acres for the purpose of building 6o units of federally subsidized housing, the mayor told the press that "everyone I've spoken to is wholeheartedly opposed to the project"; and the local planning board refused to rezone the land in question” (Danielson, 1976). As previously discussed, those in the most need of affordable housing are minorities, particularly people of color. Danielson says that “another important factor is the suspicion of suburbanites that priority for local residents cannot be maintained if the barriers to the construction of lower-cost housing are lowered” (Danielson, 1976). It can be argued that white suburbanites are afraid that residents of subsidized housing may not resemble other white suburbanites. Danielson makes references to “the bad image of subsidized housing” (Danielson, 1979) and “fear of community change” (Danielson, 1979). Exclusionary zoning practices promote such ideas and the appeal of exclusivity. However, the lack of new developments of subsidized housing isn’t the only issue. Leopold, Getsinger, Blumenthal, Abazajian, and Jordan claim that “the stock of non-subsidized housing that is affordable to ELI renters has steadily declined. Thirteen percent of unassisted units with rents at or below $400 in 2001 had been demolished by 2011. Half (46 percent) of the remaining units were built before 1960, putting them at high risk of demolition (JCHS 2013)” (Leopold, Getsinger, Blumenthal, Abazajian, & Jordan, 2015). So not only are subsidized, multi-tenant housing buildings not being built, but existing ones are also being destroyed. Leopold, Getsinger, Blumenthal, Abazajian, and Jordan assert that “without subsidies, it is nearly impossible to build and operate rental housing that is affordable to ELI renters in most markets (JCHS 2014)” (Leopold, Getsinger, Blumenthal, Abazajian, & Jordan, 2015), therefore, without subsidized housing, the affordable housing crisis is exacerbated. It is evident that the attitudes created by exclusionary zoning practices have directly perpetuated the affordable housing crisis by preventing the development of affordable housing for low-income Americans.

Gaps in the Literature

          Although literature on housing affordability, the affordable housing crisis, and exclusionary zoning are prevalent, there remain gaps in the literature. I found that there was not a substantial amount of literature written directly about how exclusionary zoning practices directly affect the price of rent for people of moderate socioeconomic statuses. Much of the affordable housing crisis can be attributed to the increase of monthly rental prices, especially in metropolitan areas, so it would be beneficial for the literature surrounding this subject to expand to best understand the crisis.

Theory and Argument

          The current literature relevant to my research question supports my hypothesis that if exclusionary zoning is prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated (Figure 1). The literature supports my argument by highlighting the components of exclusionary zoning that exacerbate the affordable housing crisis such as the expansion of urban sprawl and limitations on multi-tenant housing, limitations, economic potential for people of color, Black people in particular, and stagnation of the development of subsidized housing.
          My hypothesis is supported by various literary sources. The current literature regarding my inquiry investigates the prioritization of the comfort of the affluent class, which is often composed of White Americans, over housing the middle and lower classes. The basis of my hypothesis is explored in the article by Ellickson, where he asserts that cities and suburbs impose exclusionary zoning policies to prevent less affluent people from living in desirable areas. Cities and suburbs perpetuate the affordable housing crisis when they allow for zoning that excludes people who can’t afford to reside in such areas. In addition, relevant literature supports the idea that exclusionary zoning serves as a prominent causal mechanism for homelessness, a drastic effect of the affordable housing crisis. Current literature supports my hypothesis by attributing the increasing cost of housing to exclusionary zoning, leading to homelessness and segregation.

Methodology

Introduction:
          To effectively investigate the relationship between exclusionary zoning practices and the affordable housing crisis in the United States, I’ve undertaken a synthesis across three case studies using maps, models, and a Supreme Court case that each contextualize my research question: how have exclusionary zoning practices perpetuated the affordable housing crisis in the United States? As aforementioned, I hypothesize that if exclusionary zoning is prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated.
          The case studies selected for this work each support my hypothesis and are supported and complemented by the current relevant literature through various means. The selected approach works best for this research because it provides reasoning, historical analysis, and data analysis to answer the given inquiry.

 

Data Selection and Justification:

          The selected methodology is best suited for the research conducted because it seeks and identifies the relationship between the given independent and dependent variables. For this research, I selected three areas in the United States that have each experienced the effects of exclusionary zoning in different ways. In order to conduct this research I have selected the historically influential Supreme Court case, Village of Euclid v. Ambler Realty, a map from “Mapping Inequality: Redlining in New Deal America” that visually displays redlining and segregation in Chicago, and finally a chart and map from the National Land Cover Dataset that demonstrate the relationship between land development and density in the Washington, D.C metropolitan area. By synthesizing these data sets, I can extensively investigate the relationship between the independent and dependent variables by examining one of the first major cases of exclusionary zoning (in Village of Euclid v. Ambler Realty), how exclusionary zoning has been and continues to segregate people of color (using the “Mapping Inequality: Redlining in New Deal America” map), and how exclusionary will further exacerbate the affordable crisis in the future (using chart and map from the National Land Cover Dataset).
          These three components, in conjunction with one another, effectively support my hypothesis and provide a clear representation of the relationship between exclusionary zoning and the affordable housing crisis.

Village of Euclid v. Ambler Realty:

         
The Ambler Realty Company owned 68 acres of land in the village of Euclid, Ohio, a suburb of Cleveland. On November 13, 1922, the village council passed a zoning ordinance dividing the village into several districts (Oyzez). After the Supreme Court case, Euclidean zoning became a norm in American cities. Euclidean zoning is defined as “the separation of land uses by type— residential, commercial, retail, industrial, etc.—each into their own zones or areas within a given city” (Planetizen). Throughout the 20th century and contemporary, Euclidean zoning has been utilized to form America’s suburbs and prevent the mix of race, ethnicity, and income differences in desirable areas. Like the residents of the Village of Euclid, the literature supports the idea that White people viewed and can continue to view Black people as “disorderly” (Shertzer, Twinam, & Walsh, 2016).
On November 13, 2022, Ambler Realty filed suit against the village, claiming the ordinance violated the Fourteenth Amendment's protections of liberty and property described in the Due Process and Equal Protection Clauses. In a 6-3 opinion authored by Justice George Sutherland, the Court concluded that the speculative damages claimed by Ambler Realty were insufficient to invalidate an otherwise valid exercise of the village's police power. While Ambler 
had standing to sue, the Court rejected its arguments on the constitutionality of the zoning ordinance, which it found neither arbitrary nor unreasonable. Applying a deferential standard of review, as the Court typically applies to constitutional challenges to economic regulations, the Court held the ordinance did not exceed the local government’s police power. Zoning regulations, the Court explained, will generally be upheld as long as there is some connection to public welfare (Oyez).
          The Village of Euclid v. Ambler Realty case is useful for the research conducted because it contextualizes how exclusionary zoning came to be. Exclusionary zoning practices have been permitted to take place because of the Village of Euclid v. Ambler Realty case and the establishment of Euclidean zoning. This case gave precedence to future zoning ordinances and set an example for what a “desirable” America is supposed to look like. Because of Village of Euclid v. Ambler Realty, mixed-use zoning has struggled to exist and as supported by the current relevant literature, the lack of mixed-use zoning has exacerbated the affordable housing crisis.
          The Village of Euclid v. Ambler Realty supports my hypothesis that if exclusionary zoning is prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated because it contextualizes the existence of exclusionary zoning and has led to the increase in cost of housing.

Redlining in Chicago:
          In an article from Chicago Mag titled “How Redlining Segregated Chicago, and America” by Whet Moser, Moser provides a map from the Homeowners Loan Corporation that visually demonstrates how the city of Chicago has been redlined to effectively segregate the city by dividing wealthy, white Chicagoans, and poor, black Chicagoans. For the purposes of this research, redlining is operationalized as a practice in which a mortgage lender denies loans or an 
insurance provider restricts services to certain areas of a community, often because of the racial characteristics of the applicant's neighborhood (Britannica). As previously mentioned, the current relevant literature suggests that there is an evident relationship between high levels of metropolitan racial segregation and local zoning practices that restrict the construction of denser, multi-family housing (Whittemore, 2018). Redlining goes hand in hand with exclusionary zoning because they are often used in tandem with one another or used when one option can’t be undertaken. The HLOC “attempted to figure out the creditworthiness of properties within wide swaths of American cities. Given the period, its metrics for creditworthiness were heavily based on the racial composition of neighborhoods—white flight meant that the presence of non-whites, particularly African Americans, brought the specter of housing-value collapse—and for a lot of reasons, these calculations were grounded in the work of Chicago economists and real estate professionals” (Moser, 2017).

 
Figure 2:  Source: Mapping Inequality: Redlining in New Deal America – Map portraying redlined communities in Chicago

          The map above depicts the “North Shore and Suburbs” in the 1930s. According to “Mapping Inequality: Redlining in New Deal America,” the areas colored in green are considered “Best,” areas colored in blue are “Still Desirable,” areas colored in yellow are “Definitely Declining” and areas colored in pink are “Hazardous.” Each area is given a grade, A through D, A being “Best” and D representing “Hazardous.” Grade A represents 4% of the map, grade B represents 17%, grade C represents 50%, and grade D represents 29% of the map.
          This map illustrates how people in Chicago have been excluded from desirable areas like those of grades A and B. This map is useful in my research because it demonstrates how those who are forced to live in undesirable areas aren’t afforded the same opportunities as those in more desirable areas. As previously mentioned in the literature, those who have access to better education and job access are more likely to live in places that have been zoned against poor people and people of color who are already underserved. Because the city of Chicago has notoriously high costs of housing in desirable neighborhoods or grade A areas, this map supports my hypothesis that if exclusionary zoning is prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated.

Development and Density in the Washington, D.C Metropolitan Area:

          Over recent decades, the Washington, D.C metropolitan area population has been booming as job opportunities have increased. However, housing development hasn’t been able to keep up with the population and because the supply hasn’t met the demand, housing prices have increased disproportionately to household incomes. In 2019, the Metropolitan Washington Council of Governments issued a report stating that the region needs to add 320,000 more housing units between 2020 and 2030, and that at least 75% of this new housing should be 
affordable to low- and medium-income households. According to Brooks, Denoeux, and Schuetz, research shows that zoning laws impede housing construction in high-priced neighborhoods. Brooks, Denoeux, and Schuetz provide two figures to examine land development and land-use in concern with density.
(Figure 3) Source: NLCD – Graph depicting different land-use types in the D.C metropolitan area

          The figure above depicts the land-use type of the District of Columbia and its suburbs. The dark red represents land that is developed, and highly dense, dark orange represents developed and of medium density, orange represents developed and of low density, pale orange represents developed and of very low density, green represents underdeveloped, and blue represents open water. The x-axis depicts the share of land-use using the provided terms and the y-axis provides the DMV (D.C, Maryland, Virginia)’s most populated cities and counties. It has been demonstrated by relevant literature that the overall costs of living increase as urban sprawl becomes more prevalent (Hamidi & Ewing, 2015) and that can be demonstrated in the Washington, D.C metropolitan area.
 


(Figure 4) Source: NLCD – Map portraying depicting different land-use types in the District of Columbia

          Figure 4 depicts land-use types within the District of Columbia. The map utilizes the same color metrics as the first figure, representing the land-use type of the District of Columbia and its suburbs. The map illustrates that the district's land consists mostly of medium-density development. The most densely populated area is in downtown Washington, D.C. The district is unique in that much of the undeveloped land consists of parks, which comprises a major area of the city.
The two figures provided by the Metropolitan Policy Program at Brookings are useful for the research conducted because it shows where DMV planners have developed low-density housing and quantifies such metric. Using the figures above, I can examine where exclusionary zoning persists and how it exacerbates the already high cost of housing in the Washington, D.C metropolitan area, which supports my hypothesis that if exclusionary zoning is 
prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated.

Analytical Formula:
          Using the three case studies selected for this research paper, I am specifically analyzing the roots and origins of exclusionary zoning and how such practices have shaped American cities such as Chicago and the Washington, D.C metropolitan area. Then, by analyzing the internal structure, zoning policies, and density of areas within the two cities and suburbs, using the maps and charts provided, I determine the causal relationship between the exclusionary zoning practices and the affordability of housing in each respective city and suburbs. In my analysis, I am linking the racially charged sentiments and actions expressed in the Village of Euclid v. Ambler Realty case with the development and design of urban spaces such as Chicago and Washington, D.C. This process has affirmed my hypothesis that if exclusionary zoning is prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated, and the affordable housing crisis is further perpetuated. In addition, the literature supports the affirmation of the case studies by contextualizing the importance of mixed-use zoning, job accessibility, and access to high quality education. The literature also supports the affirmation by highlighting that race is a significant driver of exclusionary zoning because the comfort of white wealthy Americans is prioritized over the necessities of people of color, especially Black Americans.

Results
          In this section, I undertake a synthesized analysis of maps and models of the city of Chicago and the Washington, D.C metropolitan area, in addition to the Supreme Court case, Village of Euclid v. Ambler Realty, data to understand the relationship between exclusionary zoning practices and the affordable housing crisis. I seek to link the racially charged sentiments and actions expressed in the Village of Euclid v. Ambler Realty case with the development and design of urban spaces such as Chicago and Washington, D.C. because, as previously mentioned the current relevant literature suggests that there is an evident relationship between high levels of metropolitan racial segregation and local zoning practices that restrict the construction of denser, multi-family housing (Whittemore, 2018). In the research conducted, exclusionary zoning perpetuates the affordable housing crisis by stifling economic growth for underserved communities, limiting opportunities for homeownership for low-income households, and expanding urban sprawl and limitations on multi-tenant housing, thus raising the costs of housing. The results of the research conducted affirmed my hypothesis that if exclusionary zoning is prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated.

Village of Euclid v. Ambler Realty:
The Decision
          In the Village of Euclid v. Ambler Realty case, the United States Supreme court sided with the Village of Euclid thus establishing the precedence and legality of zoning ordinances in the United States. The U.S Supreme Court concluded that, as long as they are not arbitrary or unreasonable, zoning ordinances are constitutional under the police power of local governments if they have some relation to public health, safety, morals, or general welfare. While zoning ordinances are not inherently harmful, they become problematic when used to exclude groups of people out in the name of welfare. As the literature suggests, White people viewed and can continue to view Black people as “disorderly” (Shertzer, Twinam, & Walsh, 2016) which is why many are against zoning practices that would allow for Black people to reside in their communities. The Village of Euclid v. Ambler Realty decision provided a response to White people’s desire to live homogeneously. Because homogenous communities prevent others, who do not resemble the majority, from prospering in attractive areas, economic and social ascension is stunted. When people of color are overwhelmingly halted from economic success, the opportunity to accumulate the wealth necessary to have adequate housing is limited. Exclusionary zoning sustains such housing limitations over generations, thus perpetuating and prolonging the affordable housing crisis.

Euclid’s Six Zones

          On November 13, 1922, an ordinance was adopted by the Village Council establishing a comprehensive zoning plan for regulating and restricting the location of trades, industries, apartment houses, two-family houses, single family houses, etc., the lot area to be built upon, the size and height of buildings, etc. (Ambler Realty Co.v.Village of Euclid, Ohio, 272 D.C. Ohio, [1924]). It was cited that the zoning ordinance's purpose was to keep industry out of residential areas. However, acting on behalf of the National Conference on City Planning, Alfred Bettman shifted his argument from industry and trade related nuisances to citing apartment buildings as nuisances. Because the surrounding industries were of high profit for the elites in the area, Bettman defended his shift by putting emphasis on rewarding the elites through “clean and safe” neighborhoods, by removing multi-tenant housing, rather than punishing their industries. Being successful in excluding apartment housing from desirable areas so that more single-family houses could be built, Bettman and the Supreme Court set legal precedent for exclusionary zoning to prevent lower-income peoples to reside in multi-tenant housing in desirable areas.
          The construction of affordable multi-tenant housing in sprawling areas is a primary solution to the affordable housing crisis. However, because exclusionary zoning prioritizes the development of single-family housing, developers oftentimes are unable to or have no incentive to construct affordable, multi-tenant housing. By default, multi-tenant housing has inclusionary benefits because it can house people of different backgrounds and income levels in a given plot. The Village of Euclid v. Ambler Realty decision to allow for zoning exclusion effectively continues to prevent the construction and development of multi-tenant housing and continues to enable practices and policies that perpetuate the affordable housing crisis, almost a century later. The case serves as an example of how the U.S systemically prioritizes the comfort of white elites over the needs of the common people. An influx in the development of affordable multi- tenant housing could dramatically change the system in which the U.S houses its people and could relieve some of the symptoms associated with the affordable housing crisis in low-income households. But until zoning practices and policies shift from focus exclusion to inclusion, the affordable housing crisis will continue to be exacerbated.

Redlining in Chicago:

Sectioning Chicago
          Figure 2 depicts the “North Shore and Suburbs” in the 1930s. According to “Mapping Inequality: Redlining in New Deal America,” the areas colored in green are considered “Best,” areas colored in blue are “Still Desirable,” areas colored in yellow are “Definitely Declining” and areas colored in pink are “Hazardous.” Each area is given a grade, A through D, A being “Best” and D representing “Hazardous.” Grade A represents 4% of the map, grade B represents 17%, grade C represents 50%, and grade D represents 29% of the map.
          By sectioning areas in cities based on an overtly subjective metric, the desire for exclusivity is amplified. However, in order to create a sense of exclusivity, groups of people must be selected to be undesirable so that they can be excluded. Historically, Black people, people of low-income, and minorities have been selected to be undesirable and excluded out of desirable affordances. Much of this stems from colonial attitudes and has yet to diminish. Since racially charged attitudes have been a driver for exclusionary zoning practices, Black communities have not been able to achieve the same level of financial and economic success as other racial communities have. Generational wealth serves as an indicator for potential future homeownership, therefore, communities that are not afforded the opportunity for generational wealth are more likely to fall victim to the affordable housing crisis, exacerbated by exclusionary zoning practices like those of Chicago.

Inequality to Mortgage Access

          In the United States it is common for prospective homebuyers to take on mortgage loans in order to finance their homes, as it can be incredibly expensive to purchase a home of any kind upfront. There are many factors that can influence whether a buyer is approved for a mortgage, such as income, debt-to-income ratio, and work history. However, the residence's location can serve as a major influence in the approval decision. The grades provided in the map suggest where and to whom mortgage loaners should and shouldn’t loan money to potential buyers. The HOLC described areas given the A grade as “‘hotspots’...where good mortgage lenders with available funds are willing to make their maximum loans-perhaps up to 75%-80% of appraisal”. On the contrary, the HOLC described areas given a D grade as “characterized by detrimental influences in a pronounced degree, under desirable population or an infiltration of it.” The HOLC recommended that lenders “refuse to make loans in these areas [or] only on a conservative basis.”
          It is evident that there is an apparent bias that favors those who are able to reside in desirable areas over those who can’t afford to do so. Because people depend on mortgages to reside in a home of their own, rather than renting which can be taxing on the renter in the long term, the need to be approved for a mortgage is dire. Mortgages allow for homeowners to build equity, something that underserved communities have not been able to achieve or afford on a generational scale. When undesirable areas are zoned to prioritize the exclusivity of desirable areas, potential homeowners are lost due to the location they are attempting to receive a loan in. The loss of potential homeowners due to exclusionary zoning perpetuates the affordable housing crisis because people who should be able to purchase homes aren’t afforded the opportunity to because the location of the home that they can afford to reside in is in an “undesirable” area. It is important to note that the people that live in such areas tend to be underserved people of color, who generationally haven’t been able to gain equity in the communities they reside in, and when such people continue to not be able to afford estate, the cycle of generational poverty is exacerbated thus prolonging the affordable housing crisis.
Development and Density in the Washington, D.C Metropolitan Area:
Booming Population and the Need for Highly Dense Residences
         
According to an article from Greater Greater Washington, “The 2020 census found that the population of the Washington region (that is, the Washington-Arlington-Alexandria, DC-VA- MD-WV Metropolitan Statistical Area) grew by 726,000 people to a total of 6.4 million residents—larger than the population of Maryland—over the past decade” (Rowlands, 2021) and the population is continuing to grow as job opportunities expand. However, a concerning issue of population growth is housing. A significant portion of the D.C metropolitan area is zoned and developed for low-density, single-family housing. Figure 3 illustrates how the city of Falls Church has the greatest share of developed low-density land usage. The city is also known for its excessive cost of living and its housing crisis, similar to other cities in the D.C. metropolitan area. Rezoning Falls Church to include more high-density residences can aid in alleviating the effects of the affordable housing crisis. Similarly, Fairfax County has been experiencing its own housing crisis, but it is less urban and dense than Falls Church.
          In 2016, the Fairfax County Board of Supervisors approved a new zoning ordinance that increases the limit of a new building’s floor area ratio, or FAR. By increasing the FAR limit, buildings are able to be designed to be denser and more mixed-use. As aforementioned, the current literature supports the argument that because exclusionary zoning prevents the development of multi-tenant housing, which serves as affordable housing for many low- and moderate-income families, exclusionary zoning perpetuates the affordable housing crisis.
          Therefore, by implementing the new zoning ordinance that increases the FAR limit, it can be expected that more affordable housing will be available for low-income households in Fairfax County. Additionally, Fairfax County has a substantial amount of undeveloped land, and although substantial portions of the undeveloped land in the D.C metropolitan area is protected from development, there is a significant amount of land that can be used to develop high-density housing. With the new zoning ordinance, if developed properly, Fairfax County’s affordable housing crisis could be alleviated through the development of highly dense, affordable housing in the currently undeveloped land.
 
High Costs of Living in the D.C Metropolitan Area
          A major attraction of Washington, D.C is the job opportunities. The D.C metropolitan area is one of the richest areas in the United States and the incredibly high cost of living reflects that. However, the cost of living of the area deters some from moving there from more affordable areas. Figure 4 demonstrates an important theory in urban economics: Land values tend to be higher near job centers, encouraging higher-density development on that land (Brooks, Denoeux, & Schuetz, 2020). This theory, along with the map in Figure 4, shows the importance of high-density housing.
          As previously emphasized, high-density housing is the solution to the affordable housing crisis. In the metropolitan area, the places facing the highest levels of housing affordability issues are those that contain significant amounts of low-density housing. By increasing the quantity of affordable high and medium density buildings, the district can address pressing issues such as gentrification, which has been displacing residents, predominantly Black locals, in communities rich in their own history. Additionally, the jobs mentioned in the economic theory can hire residents of lower incomes, if the cost of housing decreases in such job centers, since there would be less barriers such as transportation to access these jobs. It is evident that when certain groups of people are excluded from desirable areas, the affordable housing crisis is exacerbated because such groups aren’t afforded the same opportunities and access to high quality housing. By dismantling exclusionary zoning practices and policies, the Washington, D.C metropolitan area can experience an increase in homeownership in low income and minority communities and job opportunities for such communities as well, thus alleviating the affordable housing crisis.


Conclusion:
         
In this section, I undertook a synthesized analysis of maps and models of the city of Chicago and the Washington, D.C metropolitan area, in addition to the Supreme Court case, Village of Euclid 
v. Ambler Realty, data to understand the relationship between exclusionary zoning practices and the affordable housing crisis. There is a clear link between the racially charged attitudes expressed in the genesis of exclusionary zoning and the zoning practices in urban areas such as Chicago and the Washington, D.C metropolitan area. In order to maintain the appeal of desirable areas, exclusionary practices take place to exclude “undesirable” groups, mostly consisting of low-income and Black communities. In the research conducted, I found that exclusionary zoning perpetuates the affordable housing crisis by stifling economic growth for underserved communities, limiting opportunities for homeownership for low-income households, and expanding urban sprawl and limitations on multi-tenant housing, thus raising the costs of housing. The results of the research conducted affirmed my hypothesis that if exclusionary zoning is prevalent in a given area, then the price of housing increases and the affordable housing crisis is exacerbated.
          In this research, I sought to understand the relationship between exclusionary zoning practices and the affordable housing crisis. To guide my research, I developed the following research question: how have exclusionary zoning practices perpetuated the affordable housing crisis in the United States and hypothesized that if exclusionary zoning is prevalent in each area, then the price of housing increases and the affordable housing crisis is exacerbated. To execute this research, I undertook a synthesized analysis of maps and models of the city of Chicago and the Washington, D.C metropolitan area, in addition to the Supreme Court case, Village of Euclid v. Ambler Realty, data to understand the relationship between exclusionary zoning practices and the affordable housing crisis. After synthesizing the current relevant literature, I hypothesize that if exclusionary zoning is prevalent in a given area, then the price of housing increases and the affordable housing crisis is exacerbated and I argue that exclusionary zoning perpetuates the affordable housing crises by expanding urban sprawl and limitations on multi-tenant housing, limiting economic potential for people of color, Black people in particular, and stifling the development of subsidized housing. Using the three case studies selected for this research paper, I analyzed the origins of exclusionary zoning and how such practices have shaped American cities such as Chicago and the Washington, D.C metropolitan area. Then, by analyzing the internal structure, zoning policies, and density of areas within the two cities and suburbs, using the maps and charts provided, I determined the causal relationship between the exclusionary zoning practices and the affordability of housing in each respective city and suburbs. Finally, I was able to conclude that exclusionary zoning perpetuates the affordable housing crisis by stifling economic growth for underserved communities, limiting opportunities for homeownership for low-income households, and expanding urban sprawl and limitations on multi-tenant housing, thus raising the costs of housing. The results of the research conducted affirmed my hypothesis that if exclusionary zoning is prevalent in a given area, then the price of housing increases and the affordable housing crisis is exacerbated. Exclusionary zoning practices have racist and discriminatory origins that continue to stifle underserved communities. Until zoning ordinances change to prioritize smart growth and the inclusion of affordable housing for low- and middle-income communities, it can be expected that the affordable housing crisis will continue to be exacerbated.
 
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