Executive Summary
The Affordable Housing Planning and Appeal Act (AHPAA), passed in 2003, is a state law that provides incentives and consequences for municipalities with high housing costs to increase their stock of affordable housing.
The law focuses on proactively planning for additional affordability and provides an appeal mechanism for affordable developments that have been blocked by local governments. However, Illinois’ affordable housing production is not strong enough to reach AHPAA’s implied affordability goals even absent any local frictions in delivering housing.
The Illinois Housing Development Authority (IHDA) administers both AHPAA and the Low Income Housing Tax Credit (LIHTC) program, Illinois’ largest affordable housing production program. Since 2008, IHDA has used its LIHTC award policy to encourage proposals and awards in high cost communities, but on average less than one award per year is given to an AHPAA-subject municipality.
As a result, Illinois and AHPAA-subject communities face two challenges in reaching the affordability targets set by the law: First, the gap between what AHPAA targets and the state’s capacity to produce affordable housing; and second, how to place what resources do exist in high-housing-cost municipalities.
One or both of these challenges could be addressed by:
- Finding ways to strengthen the focus on making LIHTC awards in AHPAA-subject communities;
- Implementing policies that “grow the pie” of subsidized housing production in ways that both do and do not require ongoing state appropriations; and
- Creating new zoning policies that can reduce barriers to the creation of
both subsidized and unsubsidized affordable housing.

