Affordable Housing Planning and Appeals Act (AHPAA) Update

Following the passage of our AHPAA reform bill (PA 103-0487) during the 2023 General Assembly session, the Illinois Housing Development Authority (IHDA) released the updated Statewide Affordability List. IHDA updates and publishes this information every 5 years as part of its administration of the Affordable Housing Planning and Appeals Act (AHPAA). This law requires any municipality with a population of 1,000 or more to have at least 10% of its housing be affordable (1) or to have a plan in place to achieve that goal. 

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We’d like to point out several things, both about the AHPAA, as well as the new processes and requirements: 

1) The 10% threshold for affordable housing stock is the minimum that any municipality should be expected to meet, since, according to Census data, 40% to 50% of households throughout north suburban Cook County are paying more than 30% of their incomes on housing and need more affordable housing.    

2) Out of the 1,298 municipalities in the state, only 44 do not meet the required 10% threshold for affordable housing stock. But of those 44 municipalities, 14 are in Cook County, and 15 are in Lake County. This means that 65% of the towns and cities that do not meet the 10% requirement are in our north region of the state. 

3) Only about a fifth of the housing in Evanston and in Skokie is considered affordable (19.7% and 21.8%, respectively). While it is encouraging that they meet the minimum amount set by AHPAA, there is a greater need in both municipalities for more affordable housing than what is currently available. The surrounding municipalities are providing even less, with Wilmette at 4.8% and Lincolnwood at 6.7%. That is why Connections for the Homeless often must seek housing in other municipalities to help people find affordable options—47.2% of the housing in Chicago is affordable, 40.9% in Des Plaines, 35.7% in Niles, and 75.1% in Waukegan.  

4) Our AHPAA reform bill, signed into law by Governor Pritzker in June 2023, strengthened the planning requirements for non-exempt municipalities (those that don’t meet the 10% requirement). In previous years, non-exempt municipalities simply had to create and submit an affordable housing plan, with some only a paragraph in length. Now, municipalities on the 2023 non-exempt list will have to provide a detailed affordable housing plan and submit a timeline that they must follow for implementation.  
 
Joining Forces counts advocacy around AHPAA as one of its long-term goals. We will be advocating over time to: 

• Increase the required affordable housing threshold to meet the true affordable housing needs of the state. 
• Provide incentives for municipalities that create plans and achieve the goals set in those plans. 
• Ensure that IDHA has the funding it needs to provide oversight and ensure that municipalities receive the technical assistance they need, as well as feedback when they are not in compliance. 
• Engage organizations like the Illinois Municipal League, Chicago Metropolitan Agency on Planning, the Mayors Caucus, and others to provide additional technical assistance and encouragement to municipalities. 
• Strengthen the Affordable Housing Appeals Board under AHPAA that allows for appeal of municipal decisions against affordable housing developments. 

Because we were successful in working with our advocacy partners last year in making some important technical changes to AHPAA, further updates to the law are not part of our legislative agenda this year, as IHDA works to implement those changes. However, it is on our advocacy agenda, particularly with the municipalities that have not yet achieved the 10% threshold of affordable units. 

If you are interested in participating in this advocacy, please contact our State Policy Coordinator, Max Seeley.   ​

Footnotes

1. According to IDHA's Strategic Planning and Reporting Department, their mandated calculation of the portion of a community’s total year-round occupied housing units are affordable to:

• Homebuyers at 80% of area median household income
• Renters at 60% of area median household income (click here for AHPAA handbook) (2).

2. According to HUD's FY 2023 Income Limits, 80% of the Chicago-Joliet-Naperville Metro Area's AMI is $88,250, and 60% of the AMI is $67,380.