Liddell v. The Board of Education of the City of St. Louis, Missouri Plan Submitted Pursuant to Court Order

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IN the united states district court for the
EASTERN DISTRICT of MISSOURI 

eastern division

CRATON LIDDELL, et al.,
Plaintiffs,

VHE l?OARD OF EDUCATION 
OF THE CITY OF ST. LOUIS, 
MISSOURI, et al.,

Defendants .

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CiVIL ACTION NO. 72-100-C (C)

p,ft„ SUBMITTED pursuant to paraurafh 12(H) 
of THIS COURT’S ORDER OF. HAY _2_1_,_1980-----

On 21, 1930 this Court directed the state defendants, the
United States and the St. hours Board of Education, infer alia.

To develop and :;ub:nit to the Court by

I i m’
ij i ■’.-r of

Nov..mber 1, 1980, in conj unction with

the C( ./liiii’n i ■Ly r »vei. e ,„oiit .Ajeicy of the

To u i s, enmp'ilrd olan forCity of St. a

int:nr ing < h t the opt;’ration of federally-

C. J *2iuted housing ;’ I o in the St. T • s

;.\0 1a epol it.-.n . l e a i '1 1 f.iciliL-.tc 'he

C C:1, ol <h ju, gut:i on ordered herein.

( . ;v ch 12(e))

Pi *!«:‘i- of D.,i;:.i. ..her 17 ( p'FO, thin Court ext-

Lho ' , i • i< n of •'i i s . 1 t o Nov. Ii'.ber \7, 1-
4.

.*0 V  • 1?, n»' o, ; *.e, Pi I I I  t. exit l.d.-d ' ' >1 )■ •

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The United States hereby submits the enclosed plan, (attached 
as Appendix A ) prepared by the Department of Housing and Urban Develop­
ment, in consultation with the Department of Justice, to comply « U h
l ;;-,t provision of the Court's Order and requests that this plan b|

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approved by the Court.

Robert Kingsland 
United States Attorney

Respectfully submitted,
Drew S. Days H I  Assistant Attorney General

Joseph Moore 
Assistant U.S. Attorney Robert J. Re 

Denise Z. Field 
Craig M. Crenshaw, Jr. 
AttorneysU.S. Department of Justice 
Washington, D.C. 20530 
(202) 633-4718



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CERTIFICATE OF SERVICE
I, Denise Z. Field, hereby certify that I have served the

foregoing on defendants by mailing a copy of same to defendants-

counsel at the following addresses:
Joseph S. McDuffie 
William P. Russell 
408 01 ive St m e t  
St. T.ouis, Missouri 63102
John H. Lashly 
Paul B . Rav aLashly» Caruthers, Thies,

Rava & Hamel 
/14 Locust Street 
St. Louis, Missouri 63101
Larry Marshall Assistant Attorney General 
Supreme Court Building 
Jefferson City, Missouri 65101
Th < -m n s A. Connelly, City Counselor
Robert Dierker, Asst. City Counselor
City Hall, Room 314
12th & Market Streets
St. Louis, Missouri 63103

An ’• hony J. Fes 1 r i c 
1015 Toost street 
Suite 601
St. Louis, Missouri 64101

v; i 1 1 i. m E. Cn 1c .ell
O; i L d B • F ields

i r.e r & S jt 1 ,i1. .a on
525 Commet'ce Title
;• i;.his, 'Riin. a s e e
Ch-Ll.-S h . SI •pies
■r>. 1 8 olive St.
Suite 647
St. r • u i s , usu’ir i

l" . ' I * ' ; >lies
r ■ •. -',-l

Bui Id'ng 
38103

b 3101

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M. Peter Fischer 
818 Olive Street 
Suite 940St. Louis, Missouri 63101
Edward T. Foote Desegregation Monitoring 

& Advisory Committee 
522 olive (2nd Floor)
St. Louis, Missouri 63101
Dr. Gary Orfield 
Associate Professor 
Dept, of Political Science 
362 Lincoln Hall 
University of Illinois 
Urbana, Illinois 61801

Ur.NISE Z. FIELD t
AttorneyGeneral Litigation Section 
t'ivil Fights Division
n.s. n pt * ..eul of d-:: Lice 
Oa- hiu j Lon, D.C. 20530



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Cn May 21, 1930 the U.S. District Court for the Eastern

District of Missouri ordered the United States in conjunction 
with the State of Missouri, the St. Louis City Board of 
Education, and the St. Louis CDA to develop "a suggested plan for 
insuring that the operation of federally-assisted housing 

Pi-c-.rar.s in the St. Louis Metropolitan Area will facilitate the 

s.Lool desegregation" required in the City of St. Louis. The 

following plan and strategies have been developed in response to 
that order. They embody three objectives: 1) to assure that

assisted housing programs support ongoing efforts to desegregate 

schools; 2) to establish methods whereby state and local 
officials can utilize Federal programs related to housing and 

urban development to assist in school desegregation; and 3) to 
specify the actions the Department of Housing and Urban 

Develop: ,c-nt (HUD) will take in connection with its assisted 

housing programs to facilitate and augment the efforts of state 

and local officials to expand housing opportunities throughout 

the St. Louis Metropolitan Area.

The United States r.cc.nizcs that racially concentrated 

residential .neighborhood patterns affect the racial composition 

of ,f h c o 1 s in the St. izuis ’-'el ropol i t a n Area. Seuool 
desegregation is a goal which can be promoted by the cyisU-r.ee of 

integrated neighborhoods, and assisted housing is a ..,_..ns 

p; ..vicing increased housing opportunities for lc - ,r-income 
f -.il-tcs in neighborhoods which are not .-dally concentrated, 

g” 0 M.iited States also cc'. nrwl edges that the current supply of

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a ] a o ac'.n ' -'1



•assisted housing in the St. Louis Metropolitan Area outside 

racially impacted areas is limited. (For the purpose of this 

plan "racially impacted areas" are elementary school attendance j  ̂

zones with a predominately minority student population. ^Where aty 
elementary school attendance zone includes two or more separate # 

geographic areas, each such area shall be considered separately 

in identifying "racially impacted areas.")

In considering the potential role of housing, and assisted 

housing in particular, to assist school desegregation, however, 

several factors must be kept in mind. First, existing 

residential patterns cannot be easily cr rapidly changed.

Second, assisted housing development is a complex process 

involving assessment of need, identification and acquisition of 

sites, construction and occupancy. This process requires 

supportive actions by public and private sectors over several 

y„ars. Third, appropriated funds available for assisted housing 

development are very limited in relation to the needs of lower

income persons nationally; thus, funds available to any 
particular locality are also limited. Fourth, substantial, long 

t -rn, commitments must be made by the Federal, state, local and 

private sectors in order to expand housing opportunities outside 

raciaUy impacted arras and to assure a long-term elfective 

r it :-nt to expand housing opportunities in a manner which will 

complement school desegregation efforts. F.l’D can provide sore

.• ounces subject to certain federal const i a i at s and :.-eo

.->< i . tegies for use of itf housing and community development 
r U J v.ns to p m o t e  incrc -.red housing opportunities. However, 

.m -:c ■■• d rivate -.o’ /..•» must mobilise urd cooperate in’■ 1 •• e :1 mrs U S t !V b j1i/e .: u d ec



order to provide additional housing and to select and implement 

strategics to promote equal housing opportunities.

Finally, at the same time that expanded housing . -n

opportunities are sought outside racially impacted areas,. . 

minority communities in the St. Louis Metropolitan Area in need 

of housing assistance to revitalize or preserve their 
neighborhoods or to replace or rehabilitate dilapidated units, 
must continue to have opportunities to secure such assistance.

HUD has taken into account both of these obligations in proposing 

the following Plan regarding the use of Federal housing and 

community development programs in the St. Louis Metropolitan 

Area. This plan is based upon four basic administrative 
Principles. They provide a framework for specific actions to be 

taken by HUD in conjunction with state and local officials.

Those principles are designed to expand housing opportunities in 

a m ■ user that enhances the effort to achieve school integration.

Fhi'iCIPLE 1 . AJMTNJSTSATIM CF „EM'15A"S_ANC_AOJM.U£S_EELATEE
to housing ANt>„ce:-;Mu».\i7Y_ r.FVfio?:••>:nt

Pursuant to Title V,i. of the Civil Bights Act of 1968 HUD
, r, ■ — development in the s related to housing and c.....jmty

in a ner to
: re

• t he a J "inist e •edSt. !.■■■>' s ;Vh re,- :•] it an a ' 
effectively and vigorously further fair housing objectives. 

Trior to the approval of projects and activities in programs

re. Clod to housing ... eo.unity develop out all a p p M - M s  and

- nts will be itN'iired to dcron-t rnte hew tne oject
.ill r e f e r  fo-so objectives, rtdte and local public; 1 i t y . i 11



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■v-spcies which arc applicants or recipients in Federally assisted 

t_, r -j5i-e:ns in the Ft. Louis Metropolitan Area also shall be 

required to take appropriate steps to assure that projects and ^
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activities"related to housing and community development expand 

minority housing opportunities and encourage the development of 

integrated neighborhoods in the Area. In reviewing applications 

,;ade to the HUD St. Louis Area Office HUD will take into account 

‘he i-.pact of '-uch projects or activities on the achievement of 

fair housing objectives and will consider comments from the City 

of Ft. Louis School Foard regarding the impact of the project or 

activity on equal educational opportunity objectives. HUD also 

will periodically review the recipient's efforts and results in 

identifying and reducing discriminatory barriers in the housing 

market. The failure of any applicant or recipient of Federal 

program assistance to make efforts to identify and reduce 

discriminatory barriers in the St. Louis housing market or to 

otherwise comply with the requirements of this paragraph shall be 

a basis for the initiation of procedures for the imposition of 

administrative sanctions provided in the program or activity or 

for the referral of the matter to the Department of Justice for

appropriate action.

;:,e obligation to a ’ .Sntster all programs relating to
. * « 4 • ^ 1 »t - nt in p***• cr 3 f*f*ipir.iv01 y o:,g «. :*,j g and urfc-n d v r  ,< nt in a re..

' .‘b.-r the p rms of Title VI IT <’xt • m's to oil Federal

. oies. Ui.d r D  ot b n  3C:(d) of Title V111 all agencies are 
:• 1o ,;r ,.to with the F. cr. t ary of nUD to fuither such



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purposes. HUD will take steps to advise Federal agencies of 
their Title VIII responsibilities and will coordinate Federal 

efforts to pro-note the achievement of equal housing opportunities 

in the St. Louis Metropolitan Area.

Further, H-JD and the Ce; artment of Justice will coordinate 

Federal efforts to assure no :vl iscri~ination in pre«i>«*» of 
Federal financial assistance in the St. Louis Metropolitan Area. 

In any case involving discrimination taped on race, color or 

national origin in connection with the administration of Federal 

assistance programs prompt action will be taken to invoke the 

sanctions provided under Title VI of the Civil Bights Act of

196*4.

PRINCIPLE 2. ACMINI_FI?AXIQN. OF. A5SI STH2_ HOUSING. PKOGR AMS

Co-: i - lent with the statutory objectives to provide a 

decent home and suitable living environment for every American, 

cnd in furtherance of KUD's obligation to promote equal housing

upper*' unity, hUD will review and -niton the administration of
n ie st. * -juis Metropolitan Areaits a s s i s1 c d housing ..* 'n -ho -u . -

to assure C a t  overall they support state and local efforts to

d : -e..'e:. m.a schoole -.i , . ' nu-e the attain .cut of e.jual 
-. .31 obj. d  iv.*s in the a.

A. Assisted Ileus lug Outside facially Unas. HCC will
mask to assure a net m .  c u e  in the .r : t ..r of ;.l-u.ity v M !  h-n

J i 7 i •: g u * - 5 d c

' ' s

I •. • <:' a ] 1 y .' d w us s a i ..-suit of the use of

In 14 - l ri 'g its p • s ■: h.*. t h provide



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assistance for family housing, HUD will encourage, through 

Notices of Fund Availability (NOFAs) and project selection 

criteria, proposals, projects and plans for assisted family 

housing which increase opportunities for school integration. All ^  

proposals will be reviewed by HUD for compliance with program 

requirements applicable including HUD Project Selection Criteria 

(2*1 CFR section 200.700) and Site and Neighborhood Standards (See 

2H CFR section 880.2C6 and section 881.206). Project selection 

criteria for the St. Louis Metropolian Area will be revised to 

include impact on school integration as a ranking factor for 

preliminary approval. HUD will advise localities in the 

St. Louis Metropolitan Area about ways of using block giant funds 

to encourage proposals in areas which present opportunities for 

school integration. Permissible uses of these funds to support 

housing development are set forth in CPD Notice 80-18.

In addition, HUD will not approve proposals in the St. Louis 

Metropolitan Area for assisted family housing (units with more 

id.an one brir-m) in racially impacted areas whicn would result . 

in placing in such areas ore than 60* of the UUD-assi*trd family 

units provided in any one year under all of HUD's assisted new 

c rsti'uci i, n , 1 v Labi litat men and existing housing i Pogroms.

I'iCl uded in this ec"pu‘. ati on -ill te family units, allocated 

pursuant to Section 213 of the Housing and Community Development 

,‘et of 197*1 and i r.p V  ... nt i ng i-cgnl ‘tiuts (2*1 CFR i Jit °9D. 

p r . v •" 1 •: d through <?• • .unity Develop:, nt Flock <V:-nt (t-:db)
?1, , . . - 3  r d : r ! < • r Title I of the Mousing and Community



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Development Act of 197*1 and rehabilitated with loans made under

Section 312 of the Housing Act of 196*1. Rehabilitation of family ^
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housing units with HUD assistance shall be counted in the -

computations under this paragraph except when it is clearly 

established that the household occupying the rehabilitated 

housing is already residing in the elementary school attendance 

area in which the rehabilitated unit is located.

HUD will review annually the impact of its prcgi ns on the 

school population in the St. Louis Metropolitan Area. Bused on 

information provided by state and local officials and the local 

coordinating committee, HUD will adjust the requirements in this 

paragraph when necessary to assure that the overall impact of its 

programs results in a net increase of minority children living 

outside racially impacted areas and does not result in a net 

increase in the number of families residing in racially impacted 

areas. In connection with its annual review of the impact of its 

programs HUD will monitor the location of assisted existing 

housing units and will consider the impact that such housing .

..units have had on the school population in the St. Lcuis 
Metropolitan Area. If necessary to facilitate the achievement of 

-he jecU.es of this ;mrv.-a.-h, HUD will i d e a t e  specific 

areas in which units would be eligible for fusing a s s i g n e e  

under Section 8 of the United States Housing Act of 1937 

{ U.S.C. sect5 on 1^37 ) .

• • C*4 L 1 ",r .. < i ilPi'l * * \ •"* ̂ • 01 ! J C C d S • liJ0P. ;s5htrd i!jjsing 3 n Stably —  w



8t-

court has defined a stably integrated neighborhood as "one which 
his residential public school student population which has been

between 25 and 60% minority for at least two years--- ” Students'

in schools in such areas will not be reassigned. HUD will 

approve row construction or the substantial rehabilitation of 

units for families in such neighborhoods only if it can be 

established that such action will not significantly alter student

population ratios and will contribute to retaining or rcinfoicing 

the integrated residential character of the neighborhood.

C. Affirmative Marketing Peviews and Monitoring. HUD will take 

stp;s to assure that the marketing of all HUD subsidized and 

unsubsidized housing projects is designed to provide equal 

housing opportunities and to promote the establishment of 

integrated housing patterns in the St. Louis Metropolitan Area. 

H!'D supports the development of inn ov a t i e marketing strategies 

for HUD subsidized and unsubsidized housing projects in the 

St. Louis Metropolitan Area, including the advanced marketing of 

units to particular segments of the popul «tion which "ill 

facilitate the achievement of equal housing did educational 

opportunities in the tenanting of projects. HUD will intensify 

-i.d d its Affirmative F'jir He using Marketing r ? an rev:o-s

and will increase monitoring of compliance with appro.'e-d plans in 

the St. Louis Metropolitan Area during initial sale or rent-up of 

•■nils under recently published Affirmative Fair Housing *•<= meeting 

Cc p 15 ance Prcc ad .res ( 2t) CFR Fart 10s). Sales or i c r.t a 1 i ■ , crts 

t h r..np- ot to units lorded in the A. on shall be in



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writing by the St. Louis Area Office FHAEO Division and copies of 

the evaluations shall be forwarded to the Regional Director of 

FH\FC in Kansas City. -nt<£.
Compliance meetings and reviews will be scheduled as 

required and shall be given priority by the Regional FH&EO 

Director. Tn the event a finding of non-compliance with an 

approved affirmative marketing plan or with HUD affirmative 

marketing regulations is made by the Assistant Secretary for Fair 

Housing and Equal Opportunity pursuant to 2-’4 CFR C1GB.^5, 

appropriate sanctions shall be promptly sought by the Department. 

Such sanctions may include referral of the case to the Department 

of Justice for appropriate action.

In addition, where there is substantial evidence that, 

notwithstanding affirmative efforts to attract persons to 

projects, the sale or rental of units in a project will result in 

the denial of equal housing and educational opportunities, HUD 

and the Department of Justice will consider the imposition of 

sales and occupancy restrictions to the extent pcrmissible in the 

program in which assistance is made available to achieve the 

purposes of this plan. In eases who.e such restrictions are 

-UD to the ct- ut permitted by law, will consider 

requests for the provision of financial incentives, including 

proposals for additional es.i.Uncs to re m i t  persons Seating 
projects to troop a reified nr-l.r of m i l s  off the ~*rkct 

]\,r , Jinif.-d rcrioJ of tire ..here ot-ch incentives are carentlal



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to t:,e auiiicverr'iC.nt of equal housing and educational opportunities 

under this plan.

FSIh’CIPLE 3 . ARK A W IDF AND RFGIOKAL HOUSING FF FORTS IQ
PRCMf-TF F_QUAL_ F DUC ATIONAL OBJ F_CT1 VES

HUD will encourage and, where appropriate, help support 

srrawide or regional efforts to plan and allocate Federal housing 

assistance in order to enhance opportunities to attain school

desegregation objectives.

Local public policy relating to housing nd local public and 

private sector planning, investment and development decisions 

throughout the St. Louis Metropolitan Area have teen and will 

remain crucial factors in shaping the housing market in the Area. 

Accordingly, if housing development patterns are to reinforce 

soL • o 1 c*’-: -gregaticn efforts, cooperative and coordinated 

activities by all the St. Louis Metropolitan Area governments 

will be essential. HUD in conjunction with other Federal 
t - p -■ r. s wn i  f n courn re and, where appropriate, help support

wide -nd local buvu nmc-nt as well as private sector efforts 

to develop nr.d carry out such activities.

j:. c- ' -11 owing of rc ■ wice or regional activities can 

c  st.-iv.-te to sc-ool dc:. ..-rorstion. They con te pursued singly 

or os complementary activities.

A. Voluntary A;•

.Me r1 ’ ‘'-nirg

fusing Cp; ortunity PLuis. Foveral

,iVi: 3 thruuMout the ration, similar in



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structure and responsibility to the East West Gateway 
Coordinating Council, are now implementing Voluntary Areawide 

Housing Opportunity Plans (AHOPs). By coordinating local 

govt.nmenfand private sector efforts to expand housing 

opportunities outside of racially impacted areas, areawide 

organizations h.ve potential to aid state and local public 

agc-ncies in using housing programs strategically to rein^oice 

school desegregation efforts. The required contents of an AHCP 

are found at 2U CFR section 891.503- 7° general, an AHOP
allocates HUD assisted units in a manner designed to encourage 

regional housing planning, to increase housing choices outside 

racially impacted areas, and to facilitate efforts to increase 

the mobility of persons seeking housing throughout the AHOP area

Dcvel op ;erit and implementation of an AHCP would facilitate a

'--:n-e of strategies among the localities in the St. Louis 
Metropolitan Area to improve low and moderate income minorities' 

iccc-ss to assisted units. Such strategies could include 

-eei procal acceptance of certificates of participation in the 

turning assist nee payments program for existing housing under 

recti on 8 of the United States Housing Act of 1937, as amended 
- 2  U.S.C. action 1^7), and acquisition of mattered site units 

outside racially i . ^ c L d  areas in jurisdictions participating in

AHOP.

An AHCP 

h it an

n  :■ -.ted by the city and 

Area mould be eligible

localities in the St. Louis

to reck an av.ard of bonus



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funds, including section 8 assistance, pursuant to 2* CFR Part 

691 Subpart F. These units could also be used to complement 

schuol desegregation efforts and to reduce the need for busing. ^  

Communities required to develop Housing Assistance Plans (HAFs) t* i
in connection with participation in the Community Development 

Block Grant Program under 2* CFR section 570.306 could 

incorporate the goals contained in the AFC? in their HAFs and 

through their participation in the AHOP facilitate HAP 

implementation. The am-ard of bonus units to an AHOP under HUD 

regulations is based upon specified criteria, including priority 

criteria set forth as 2* CFR §891.606. A plan that demonstrably 

contributes to school desegregation will tend to meet several of 

the criteria for priority consideration depending on the scope 

and design of the plan. Further, if communities in the St. Louis 

J'etropcl it an Area develop an AHCP which meets the criteria

est a bl ’ s < in 2*I C .F .R . P art 891 and which reflects the

principles in this plan HUD will provide extra funding from its 

Section 701 program (*0 U.S.C. section *61) to the extent the

statute permits.

P. Efforts to Achieve Fair Housing. Local jurisdictions should 

..gr.,j fair housing programs in conjunction with private 

..-dor, nonprofit, and volunteer groups. Activities such as 

development of fair housing ordinances, development of

5-elusirnary zoning .id cli.-i: alien of *.;e) usi .-nery zoning, 
vet op merit of affirmative narkd d g  and c"'rc ch pi. ns -d 

• <r i.-dos are eligible o o t i v U d s  for c- ...unity dcvcl pm,nt and



1 3

block grant funding.

States and localities with fair housing laws which provide 

rights and remedies for discriminatory housing practices that ar« 
substantially equivalent to those provided in Title VIII of the 

Civil Rights Act of 1968 are eligible to apply for participation

and assistance in the HUD Fair Housing Assistance Program 

described at C'r'R Part 111. Through this program HUD provides 

technical and financial assistance to state and local agencies 

charged with administration of substantially equivalent fair 

housing laws to develop their capacity to handle complaints and 

to promote fair housing. The program is intended to build a 
coordinated intergovernmental enforcement effort to further fair 

housing and to provide incentives for states and localities to 

assume a greater share of the responsibility for administering 

fair heusing laws.

H’JD believes that enactment and enforcement 
fair housing laws is an effective element of an c 

to pj emote school integration efforts. •• JD will 

jurisdictions in the St. Louis Metropolitan Area 

eligibility for participation in its Fair Housing

of strong local 

verall strategy

encourage all 

to obtain 

A s s i s t a n c e

Program so that HUD can then ve ; 

applications for fair housing progr 

the .St. Louis Metropolitan * r c a .

. i t  e consider t * n to 
:n funds for such efforts in

The Depart :ent will also moot with .■* .■ re son* ntiv es of the 

a j-'idod i-'1 i or. 3 to <? •:j>1 "»5n and cneenr ge the e cl C.. .. unity



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Housing Pesource Boards (described in HUD Handbook 8021.2) to 
analyze the availability of housing for minority households in 

the St. Louis area and to assist in the development of a 
Voluntary New Horizons Program to provide comprehensive regional 
action plans and strategies to eliminate discrimination in 

housing throughout participating jurisdictions.

Under 24 CFP section 570.206(c), Community Development Block 

Grant funds may be used by states and units of local government 

for administrative costs incurred in carrying cut fair housing 

counseling programs and ether activities designed to promote 

greater choice of housing opportunities.

C. School Board Notification and review System. State and local 

housing and community development officials should be required to 
provide for advance notification and review by the City of 

St. Louis Board of Education of all proposals for projects 
involving Federally assisted family units for identification of 

those which might negatively affect St. Louis school 
desegregation efforts. HUD will neck comments cn any proposal 
not so submitted by local officials. Comments received from the 

Hoard of Fducaticn will be considered by the Area Office in
for technical proc-ssing pursuit to 24 C.YR

<,830.306(b), and during t echnical processing of a prepc-al, «s 

provided by 24 CFR <>3 5 0.3 0 6(c)(2 ) . Those comments will also be 

-d to rank prof -*ls for selection under 24 Cl R §c?0.s07.



/V—
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PRINCIPLE U. INC FF A SI N G JH0UJ5I NG_0 £PCR T l) N I U  F S _T0

RF_TNFORC£ EQUAL EDUCATIONAL 0PPOJiXILN1!U_FS.

The court has exempted certain neighborhoods (school 

attendance areas sore than 90 percent white) from student 

reassignment, if they obtain subsidized housing which increases 

the resident minority student population to at least 20 percent. 

HUD will assist relevant applicants and recipients to utilize the 

Department's programs to assist non-integrated neighborhoods in 

the St. Louis area qualify for an exemption by increasing 

resident minority enrollment. Project proposals which would 

assist neighborhoods to reach this exemption level will receive a 

priority ranking for site in determining projects to be approved 

under under §880.307(b). (The site ranking for projects involves 

an estimated 25 of the 110 points possible.)

In addition, HUD will cooperate with other Federal agencies 

and state and local officials in using Federally assisted 

programs related to housing and community development to enhance 

local efforts to increase housing opportunities outside racially 

impacted areas throughout the St. Louis Metropolitan Area.

The following activities can promote the availability of 

increased housing or port unities in the St. Louis -re a:

A. Mobility in Section R_Fxistin,t Program. Under 1 he Section 8 

Existing Housing Program <2* CFR Part ?8?>, a rent subsidy 

is provided to landlords leasing units to lowcr-income

re



16(' (  )

families li.oving to or residing in privately owned units that 

r.eet the program's housing quality standards. Rents for 

these units must fall within the range of fair market rents' 1 i « a - * J
as determined by HUD. Local public housing agencies 

administer the program, certify eligible tenants, inspect 

the units proposed by families, and provide the approved 

landlord with the approved assistance payment on behalf of 

the family. (Tenants execute separate leases with landlords 

to pay their share of the rent.)

1. HUD supports the establishment of policies and 

procedures in connection with the operation of its 

Section S Existing Housing Program by localities in the 

St. Louis Metropolitan Are3 to assist families now 

residing in racially impacted areas of the St. Louis 

Metropolitan Area to obtain housing outside such areas. 

Whi-re necessary HUD will consider waiving the 
provisions of HUD regulations in accordance with 2H CFP

$599.101 to facilit ate these el forts.

2. HUD encourages the development and submission of
* gp.t involve the designation of a privater 1 - i - "

entity or a public ,-cncy -.Coding a puMic housing 

agency with an Existing Housing Program to:

owners of rental units outside racially 

impacted ar-as who are willing to accept Section 8 

l. !-.1 s;



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Counsel persons eligible for the units on the 
nature of the Section 8 existing program and the -
benefits to be derived from moving to non-impacted
ureas; r ' ,--.r

Assist applicants on request in identifying units 
to meet their needs considering size and quality 

of the unit and proximity to shopping, transporta­

tion, employment, etc;

Provide information regarding equal housing 

opportunities under Title VIII of the Civil Rights 
Act of 196S and the rights provided persons who 
believe they have been discriminated against to 
file a complaint with HUD or initiate a civil 
action in Federal District Court;

Follow up with tenants after placement to assure 
that if additional counseling is needed it can be 
provided quickly.

Priority attention will be given to assist in the 

funding of such a proposal to the extent permitted by

I a w .

HL’D will approve proposals b° se  ̂ aside a percentage of 
the units allocated to jurisdictions in the St. Louis 

f'etr pclit^n Area to be pooled for inter jurisdictional 

HUD will ■’-c available in format 5 on regardingr ' e .



1 8o

n.

demonstration efforts which have been undertaken to 

promote housing mobility.
•T>- ̂

Consistent with existing procedures provided in Z» CFH ^  
§888.102, HUD will review fair market rents in the
St. Louis Area and r.ake such adjustments as rr.ay be 

necessary to reflect present rental market rates in the

St. Louis Metropolitan Area.

E. Housing Counseling and Service Center. Local public
agencies or private entities should establish a housing 

counseling and service center for all housing in the 
St. Louis Metropolitan area. The center would be organised:

(a) to provide families living in racially impacted areas 

with information on both assisted and non-assisted housing 

opportunities outside such areas; (b) to assist persons 

choosing to move to manage their relocation; (c) to inform 

persons of their rights to equal housing opportunity 

Title VIII of the Civil Bights Act of (d) to counsel

persons moving into nonimpacted areas subsequent to the^
• i ~ k i o o -v •'nnitv services. ihe move; end (e) to secure available ..... y

center also would provide fir.iUr info.-tion

to now minority prisons with respect to
a v a i l a b l e  to tl.es which would facilitate school
d e s e g r e g a t i o n  efforts. HUD encourages u.e or Section 8 fees

• lent -•it’! "UD r-r -'.’Ir-itions tnd m l  es to cover the consistent ..itu 1
. c .. 1 H r for St-ction 8 fc.il is;n: stretive costs of a center lor



block grant funds may also be used to support this activity. 

(2H CFR §570.205(c)). In addition HUD will give priority 

consideration consistent with statutory requirements to ^ 
applications for discretionary funds under Section 107 of 
the Housing and Community Development Act of 197*1 for such 

efforts.

C. Concerted Revitalization Plans and Strategies. Local

jurisdictions should carry out targeted and concerted 

efforts to establish, stabilize and maintain integrated 

neighborhoods. Local strategies should entail conscious use 

of Federal housing assistance, community development and 

social services programs with local public and private 
sector programs to reinforce household characteristics 

associated with integrated neighborhoods (defined in 

relation to the court's definitions of integrated schools). 

HUD will consider applications for assistance from

neighborhood groups organized to promote the achievement of 

equal housing opportunity particularly in newly integrated 

areas, in areas attempting to obtain a busing exemption, and 

in areas experiencing transitions in occupancy patterns.

D. L.e, ntive Progrn-. As an incentive for the dv. e'lo, • e nt of 

an AHCP for the 5t. Louis Metropolitan Area, HUD will each 

year in the t -i-ir. of the initial .’HOP provide a minimum of 

100 AHOP bonus Section 8 existing housing certificates to 

< nocurege local jurisdictions to --oik with their e 1 <_ m.cnt ary



school districts to promote the development of integrated 

communities in the St. Louis Metropolitan Area.
Certificates will be awarded for use in communities which ™  
develop effective outreach programs to minority households - 

wishing to use HUC’s Section 8 existing program and which, 
through use of non-bonus allocated units, have made^ 

purposeful efforts to encourage the location of minority 

households with children in their area. Further, HUD will 
assign bonus units equivalent to PC? of the contract 

authority ordinarily allocated to the jurisdictions 

participating in the AHOP for use in the AHOP area.

Other Available Assistance. HUD will cooperate with state 

and local officials and private organizations and groups 

interested in promoting the achievement of equal educational

opportunity through use of HUD programs. HUD will provide 

such persons and groups with information regarding 
Department programs which could provide funding in support 

of their efforts in the St. Louis Metropolitan Area and 

indicate application requirements and selection criteria for



For the United States:
DREW S. DAYS III Assistant Attorney General

K M 1- A  ' r f e  .___
PCLEnT STEIN 
Chief
General Litigation Section

\ , & U -f.L’ilSE Z. FIELD

Attorneys
Cen.oral Litigation Section
Civil Fights Division
1J. S. Department of Justice
Va s'"’.’>* t on , D.C. 2Gb30 
(202-6 33-!WlS)

V  _______________
MARLA INA KINFR 
Deputy General Counsel 
U. S. Department of Housing 

and Urban Developnent 
Washington, D.C. 20M0

DATED: o v e r i b e r  2 0 ,  1980