The steady accretion of decades of social programs at the federal level leads to frequent violations of the duck test. For instance, just because a neighborhood’s subsidized housing might exhibit the same physical and social problems as distressed public housing, that doesn’t mean it’s public housing. It could be something else entirely--project-based Section 8, or tax credit units, or single-family homes with FHA-insured mortgages. These distinctions translate into different sets of governing rules, and disparate, disconnected options for promoting revitalization.

HUD’s proposed Choice Neighborhoods Initiative would take a different approach, promoting strategies that tackle concentrations of poverty arising from multiple types of HUD-subsidized housing, beyond public housing alone. Secretary Shaun Donovan outlined this in a July speech, recounting the challenges that multiple forms of HUD-subsidized housing posed to redevelopment of the Washington Highlands neighborhood here in D.C. in the early 1990s.  

But what do the numbers say?

This [rather inelegant] chart tells part of the story. It shows the current presence of three types of federally-subsidized housing--public housing, multifamily housing (e.g., project-based Section 8; section 202 elderly housing), and Low Income Housing Tax Credit units--in neighborhoods that had at least a 30 percent poverty rate in 2000, about two and a half times the national average (the picture looks similar in neighborhoods with poverty rates exceeding 40 percent). 

·    Most high-poverty census tracts in 2000 (77 percent--red bars) have some form of federally-subsidized, project-based housing.

·    Almost two-thirds of public housing units in high-poverty tracts (63 percent--blue bars) are co-located with some other type of project-based federally-subsidized housing.

 ·    The vast majority of--about five in six--HUD multifamily units (gold bars) and tax credit units (green bars) in high-poverty neighborhoods are located alongside other subsidized units. In such neighborhoods, 40 percent of both HUD multifamily and tax credit units are in locations that share all three types of federally-subsidized housing.

And this just represents the overlap between three project-based programs. It doesn’t recognize the location of other types of properties that Choice Neighborhoods might assist, such as distressed FHA-insured single-family properties, or private vacant and abandoned properties. 

This is more than an interesting academic argument for the Choice Neighborhoods approach. It also speaks to the need for a different sort of relationship between the federal government and its local partners, where resources target problems--without specific regard to which federal program helped create them—and promote local partnerships to address them in cross-cutting, comprehensive ways. It’s what distinguishes, for example, HUD’s proposed Sustainable Communities Initiative from the 30 different programs in the recovery act that focused on promoting energy efficiency.

This view faces an uphill battle, however. A recent hearing of the House Subcommittee on Housing and Community Opportunity examined issues with the public housing program and HOPE VI, with little attention to how the geographic overlap between distressed public housing and other forms of federally-subsidized housing affects revitalization efforts. While the Senate Banking Committee approved $250 million for the Choice Neighborhoods program (with certain provisos), the House instead approved $250 million to extend the existing HOPE VI program in the HUD appropriations bill.

This is all to say that as HUD and Congress consider how to tackle the relationship between federally subsidized housing and concentrated poverty, their view should not be confined to one type of housing. If it quacks, let’s call it a duck.