ERC Comments and Testimony Lend Fair Housing Expertise to D.C. Government  

By: Nick Adjami and Susie McClannahan
March 12, 2024 

The D.C. Council holds annual Performance Oversight Hearings for all city agencies, allowing District residents and organizations to provide feedback on how well the agencies are meeting the needs of our communities. Each year, the ERC testifies at hearings for multiple agencies that are relevant to our work. By doing so, we hope our civil rights expertise can help the D.C. Council to better understand and address the urgent fair housing issues facing the city. We also recently provided comments on the city’s draft Consolidated Annual Performance and Evaluation Report (“CAPER”), a report submitted to HUD detailing how D.C. progressed on goals related to affordable housing and community development. Read our full comments at the links below.

ERC Senior Fair Housing Rights Program Manager testifies to D.C. Council via Zoom. She appears in one box below Councilmember Robert White and another box displaying a timer.

ERC Senior Fair Housing Rights Program Manager Susie McClannahan testifies to D.C. Council via Zoom at the DCHA Performance Oversight Hearing on February 22, 2024.

Office of Human Rights Performance Oversight Hearing

The D.C. Office of Human Rights (OHR) enforces local human rights laws, including the D.C. Human Rights Act, and investigates individual complaints of discrimination, including housing discrimination. The ERC frequently assists clients who live in the District to file housing discrimination complaints through the agency. The ERC testified urging OHR to address the backlog of discrimination complaints and streamline the complaint process, accept disparate impact claims to tackle more pernicious forms of discrimination, and use director’s inquiries to confront systemic source of income discrimination.

D.C. Housing Authority Performance Oversight Hearing

The D.C. Housing Authority (DCHA) is tasked with providing affordable housing to low-income families in the District and administers programs like public housing and the Housing Choice Voucher Program. The ERC testified urging DCHA to improve its rent reasonableness determination process and make it more transparent for program participants, prioritize the rehabilitation of substandard public housing units instead of privatizing buildings, overhaul the agency’s reasonable accommodations process to effectively serve people with disabilities, and improve communication with program participants.

Office of the Attorney General Performance Oversight Hearing

The D.C. Office of the Attorney General (OAG) is the chief legal office for the District, tasked with enforcing the city’s laws, including the D.C. Human Rights Act, and protecting the interests of D.C. residents. The ERC has worked closely with the OAG, especially as part of our efforts to combat rampant source of income discrimination in the District, and we submitted testimony commending the agency’s commitment to upholding fair housing.

Draft CAPER Comments

Each year, D.C. submits a Consolidated Annual Performance and Evaluation Report (CAPER) to HUD. The report documents how HUD funds were spent, and measures progress made toward the city’s Consolidated Plan goals, which relate to housing and community development needs. The ERC commended the draft report’s focus on affordable housing, but urged the District to commit more fully to Affirmatively Furthering Fair Housing.


The ERC is a civil rights organization that identifies and seeks to eliminate unlawful and unfair discrimination in housing, employment and public accommodations in its home community of Greater Washington DC and nationwide. The ERC’s core strategy for identifying unlawful and unfair discrimination is civil rights testing. When the ERC identifies discrimination, it seeks to eliminate it through the use of testing data to educate the public and business community, support policy advocacy, conduct compliance testing and training, and, if necessary, take enforcement action. For more information, please visit

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