Feedback on the New Draft of the EE45 Comprehensive Plan

A Joining Forces team met on February 22, 2025, to review and discuss the Comprehensive Plan in preparation for the Land Use Commission meeting to be held on Wednesday, February 26. We reviewed just the chapters with explicit content related to housing and have summarized our observations and recommendations below.  ​

Bottom Line:  

• The new draft supports the types of action and change, including zoning, that will allow for increased housing affordability and equity, without including provisions that are likely to preserve existing barriers or create new barriers.  
• However, because the plan is high level and necessarily addresses intersecting and sometimes opposing community priorities in generalities, it will be open to interpretation and will likely be used both to support affordability and equity efforts and to oppose them.  
• Our primary recommendation is that the case for prioritizing equity and affordability be made more explicit throughout the plan so that decision-makers have the clearest possible direction when they use the comprehensive plan as a guide in their work.  

 
Chapter 1: Introduction 
No comments at this time 
 
Chapter 2: What We Heard 
No comments at this time 
 
Chapter 3: Evanston Today 
 
“Segregation and Housing Inequity”: The plan states “While the Fair Housing Act of 1968 banned explicit redlining, its impact continues to be felt through long-standing inequality in housing access, zoning policies, and economic opportunity.” This theme is not reinforced in the rest of the plan’s descriptions of the city, as noted below. 
 
 “Who We Are Today”: The plan provides descriptions that do not include any value statements, assessments or acknowledgement of needs. For instance: 
 

• The lead-in paragraph to the section notes that the census typically undercounts “hard-to-count populations.” However, it does not address the ramifications of this phenomenon or how the city can address those. 
• “Race and Ethnicity”: The plan does not mention how the racial and ethnic make-up of Evanston has been changing in a relatively short period of time. This is an important factor that should be acknowledged, given Evanston’s reputation for and pride in its diversity. 
• “Household Income”: The plan does not mention the Gini score, which indicates a very high disparity in Evanston between high- and low-income households—which greatly impacts the needs for housing, infrastructure, and services. 
• “Housing: Bedrooms”: The plan does not include important data that owner-occupied housing has the overwhelming number of larger units, while rental housing has the overwhelming number of smaller units, making it difficult for singles to find home-ownership opportunities and for lower-income families with more than 3 people to find affordable options with enough bedrooms. We note that this is mentioned later in the Housing chapter. 

 
“Key Metrics”: Interpretation of some of the metrics should be provided, along with a more specific description of the goals. Those related to housing include the following: 
 

• Race and ethnicity: Instead of just listing the % of people of color in Evanston, the plan should list population percentages by race both now and 10 and 20 years ago, since the loss of the Black population in Evanston is of concern. 
• Income distribution: The Gini coefficient used for this metric needs to be explained. Additionally, the significance of this metric should be acknowledged, as Evanston was the municipality with the 10th worst income inequality in the country in 2022 (according to this article). This metric has implications for housing goals.
• Life expectancy: Evanston’s E-Plan shows a disparity in life expectancy metrics by ward. The comprehensive plan should show this in its assessment of Evanston Today, as this has implications for what the plan’s goals should be. 
• Housing cost burden: A definition of this metric should be provided. 

 
Chapter 4: Evanston Tomorrow 
 
“A Vision of Evanston in 2045” and “Vision Statement”: Explicit statements that housing options for people at all income levels should be included. 
 
“Foster a Healthy Community”: We appreciate that housing is included. Throughout the plan, some reviewers questioned the use of “attainable” as a descriptor for “affordable housing,” considering it a euphemism that potentially obscures what the real need is. 
 
“Increasing Housing Diversity”: The plan should include a more definitive statement that more housing options for people at all income levels are needed. Preservation of existing affordable housing and support for landlords of affordable units should also be included. 
 
“Creating Equitable Opportunities for All”: Consider including more ways for a greater diversity of citizens to participate as members of the Land Use Commission and in all the processes related to land use and housing decisions at the municipal level. 
 
Chapter 5: Neighborhoods and Places 
 
Evanston’s Wards: The plan describes the assets throughout the wards of the City but does not differentiate the wards from each other in ways that pertain to land use, nor does it define the deficits. The comprehensive plan should identify things like the racial and socio-economic segregation that exists in Evanston, the differences in density across wards, and the other differences documented in the City’s E-Plan. These are all pertinent to what the goals of the plan should be. 
 
“Key Challenges and Opportunities,”  “Residential,” “Mixed Use,” and “Downtown”: Housing affordability is not discussed. It should be. This is a serious omission. 
 
Chapter 6: Community Systems 
No comments at this time 
 
Chapter 7: Getting Around 
 
It doesn’t appear that the comprehensive plan is recommending the elimination of parking minimums in new developments. This does not mean that this isn’t a strategy that could be introduced in the zoning code, but it is troubling that, while it is discussed as an option, it is not an actual recommendation. 
 
Chapter 8: Environment 
No comments at this time 
 
Chapter 9: Parks, Recreation, and Open Space 
No comments at this time 
 
Chapter 10: Housing 
 
“Introduction”: Increasing affordability or decreasing housing cost burden should be a goal. 
 
“Existing Conditions”: This is the best description of where the housing inequities in Evanston exist. More of this should be included throughout the plan in pertinent sections. 
 
“Housing Stock”: While this section quantifies the subsidized affordable and permanent supportive housing units in Evanston, these numbers are meaningless without information about the existing need and the size of the waiting lists. This information should be shared as well. 
 
“Housing Costs”: This section has excellent information on housing cost burden. This information should be referred to in many other sections of the plan. 
 
“Housing Insecurity”: This section should include information about the number of households with low incomes experiencing housing cost burden—these households should be counted among those who are unstably housed, along with those who are already homeless. 
 
“Student Housing”: This section should provide information on the shortage of housing for students and the predatory nature of some landlords who are profiting off of students. Students regularly have to pay security deposits in January for apartments that they won’t move into until September because the competition for units is so intense. Student housing is a critical need. 
 
“Increase the Housing Supply”: This statement should be modified: “Additionally, new market-rate developments with inclusionary housing units options for households of all income levels.” The IHO has not yet yielded units that are options for people within incomes under 50% of the AMI. The plan acknowledges in the following paragraph that there are insufficient options, and few opportunities to create more options, to provide housing for these households, but the statement about the IHO should be corrected. 
 
”Combat Displacement”: This section is extremely vague. It should include some examples of displacement strategies and communicate the intention to create an anti-displacement plan with measurable steps and accountabilities. 
 
“Policies and Actions”: This section addresses many of the concerns above and more. It is a solid list of strategies. 
 
Chapter 11: Health and Wellbeing 
No comments at this time except that we appreciate the integration of housing and health in this chapter. 
 
Chapter 12: Economic Development 
No comments at this time 
 
Chapter 13: Arts and Culture, Community-Building, Placemaking, and Connection Making
No comments at this time

Chapter 14: Preservation 

“Key Challenges and Opportunities” / “Balancing Historic Preservation and Development Needs”: This sub-section includes interesting and hopeful ideas to use preservation as a mechanism to encourage investment in such a way as to prevent displacement. 

“Policies and Actions”: These include anti-displacement measures as well that could off-set the probability of excluding people from historic neighborhoods who cannot afford the costs normally associated with historical preservation. 

Chapter 15: Implementation 
This chapter appears to be incomplete. Without seeing more of the City’s Strategic Housing Plan, or having that described in this chapter, it is difficult to assess what should be here.