In Part I, we traced the path that led Northbrook to its current framework.
In Part II, we examined how the 2020 framework actually works and why its economics are so difficult.
In May 2021, a longtime Trustee — and a vocal supporter of Northbrook’s new affordable housing plan — was sworn in as Village President following the municipal election. A few months later, on September 1, the Village also welcomed a new Village Manager after nine years in the same role in Oak Park.
That background is worth briefly noting. Oak Park has been on IHDA’s exempt list since the inception of the Act in 2003 and stood at 23.4 percent affordable housing in 2023, up from 22.6 percent in 2018. Yet even there, the Village was re-evaluating its own 2019 inclusionary housing ordinance in 2024 after every developer had opted to pay the in-lieu fee and no new affordable units had been produced. There are no doubt lessons from Oak Park, but its starting position and housing conditions are dramatically different from Northbrook’s.
Highland Park is the more relevant comparison. It was the standard bearer Northbrook repeatedly looked to while developing its own affordable housing framework in 2019 and 2020. Highland Park’s modern strategy dates back more than two decades. A 2001 study from the University of Illinois at Chicago examined the loss of economic diversity as rising land values and teardowns began reshaping the city, and the report recommended three core tools that would shape Highland Park’s housing strategy: a Housing Trust Fund, a Community Land Trust, and employer-assisted housing.
Highland Park eventually gave those ideas real teeth. It created a Housing Trust Fund funded in part by a demolition tax on residential teardowns and adopted a strict inclusionary housing ordinance requiring developments of five or more units to provide 20 percent affordable housing, paired with density bonuses, fee waivers, and by-right allowances designed to keep projects viable. Those policies helped Highland Park build a reputation as one of the region’s most proactive communities on affordable housing. In 2003, it was the highest-ranked non-exempt municipality in Illinois, at 9.3 percent affordable housing. But the more recent record is less impressive than the reputation suggests. Between 2018 and 2023, Highland Park lost roughly 290 affordable units, falling from 8.7 percent to 6.3 percent affordable housing, and between 2019 and 2022 only 20 affordable units were approved across five developments.
The broader economic volatility of the decade also made implementation harder. After the brief pandemic slowdown of 2020, residential construction surged nationally as low interest rates, remote work, and strong housing demand pushed builders to ramp up activity. That environment changed abruptly beginning in 2022, when the Federal Reserve began aggressively raising interest rates to combat inflation. Borrowing costs for real estate development climbed sharply, construction financing became harder to obtain, and many projects across the country were delayed or abandoned as the economics no longer made sense.
Illinois was already struggling even before that shift. Between 2019 and 2024, the state ranked second-to-last in the nation for new housing units approved per capita, ahead of only Rhode Island. By 2024, the Chicago metropolitan area ranked last among major U.S. metros for new home construction, authorizing just 4.5 new homes per 1,000 existing units. Recent estimates indicate Illinois already faces a housing shortage of roughly 142,000 units and would need to build about 227,000 homes over the next five years just to keep pace with demand. Publicly available data shows that supply has not kept up: active listings of new homes have fallen sharply, vacancy rates for both rental and owner-occupied housing have reached historic lows, and home values across Illinois have risen substantially since 2019.
Even against that backdrop, Northbrook’s own results in the first half of the 2020s are hard to call encouraging. The Village’s affordable housing stock stood at 5 percent in 2025 — down on a percentage basis since the new policy was enacted and flat on an absolute basis since the inception of the Act. More concerning, Northbrook’s current affordable housing stock is forty-eight units lower than the IHDA reported in 2018.
At the same time, several of the properties most likely to meaningfully increase Northbrook’s housing supply remained mostly dormant. Redevelopment of Northbrook Court — the single largest potential housing opportunity in the Village — remained stalled. At the former Grainger headquarters site, the Village donated one portion to HODC for a supportive housing project serving low-income households and persons with disabilities, with all units affordable to households earning less than 60 percent of AMI. That donation came shortly after the Village’s proposed $10.5 million sale of the property fell through, and nearly seven years after the Village had acquired the site. The rest of the property remains under Village ownership, with no public sign that residential redevelopment is close at hand. And the Green Acres Country Club site, after several attempts by developers to assemble workable plans, was ultimately sold to the DuPage County Water Commission rather than redeveloped for housing.
It would be unfair to place all of those struggles at the feet of the affordable housing policy. But it would be equally foolish not to ask whether the policy itself became part of the problem. It is also worth noting that while Northbrook’s affordable housing strategy relied on taxing private development, the Village’s clearest recent success in expanding affordable housing came through the opposite move — giving away land to make the project work.
By 2024, the Illinois Housing Development Authority again classified Northbrook as a non-exempt municipality under the Affordable Housing Planning and Appeal Act and required the Village to submit an updated affordable housing plan by June 2025. Notably, a 2021 clarification made clear that home rule status had no bearing on whether a municipality had to comply with the Act, and a 2023 amendment allowed IHDA to refer noncompliant communities to the Illinois Attorney General. In other words, there was no longer a serious question about whether Northbrook had to comply, and the consequences of noncompliance had perhaps become more meaningful.
As the Village contemplated updates to its plan for the June 2025 submission, some might point to COVID and its aftermath as reason to describe the 2020 affordable housing policy as an unproven work in progress. That feels exceedingly generous given Northbrook’s results, Highland Park’s results, and the broader housing results across Illinois.
After eighteen months of detailed public hearings culminating in the codification of Northbrook’s affordable housing ordinance in 2020, one would reasonably expect those results to prompt concern, reflection, and vigorous debate on the Village Board as the resubmission deadline approached.
The opposition slate in the 2025 Village election made affordable housing a core part of its platform. It argued that the issue was too complex for blanket slogans, that Northbrook’s current affordable housing requirements had become a barrier to development, and that the Village should revisit — not eliminate — those requirements to better align with neighboring communities such as Wheeling, Deerfield, and Glenview. It also argued that less restrictive requirements could attract more development while still creating housing opportunities for those in need.
By contrast, the Caucus candidates did not address affordable housing in their official platform.
The Caucus candidates won the election, albeit by narrow margins and with turnout of only about 30 percent. After the election, the re-elected Village President said the result showed both “support for the direction we are heading in” and “a need for more engagement and dialogue.” She also said that going door to door had reinforced that residents wanted to “be part of the conversation.” Taken at face value, that would seem to call for exactly the kind of open discussion one might expect around the re-submission of Northbrook’s affordable housing plan — particularly after the issue had become a central point of contrast in the election.
That did not happen. The only public forum I could find in the lead-up to the Village’s resubmission of the plan was a meeting of the Housing Committee — one of the Board’s eight work committees intended for deeper discussion of key policy areas. It was attended by four Trustees and three members of Village staff and lasted forty-six minutes. If there was any detailed analysis of how well the policy was working, it was not captured in the meeting minutes.
The updated plan was then included with twelve other items on the consent agenda of the next Village Board meeting. Items on the consent agenda — if not specifically removed by a Trustee or member of the audience — are voted on as a block, without discussion of the individual items, and typically pass unanimously, as this one did.
Despite a net decline in Northbrook’s affordable housing stock since the 2020 policy changes — and following the closest Village election in recent history, where the opposition slate made the policy a central campaign issue — the updated plan advanced with no meaningful debate.
A useful illustration sits just across Northbrook’s border. The Residences at Charlie Court, a forty-unit duplex development at 2660 N. Pfingsten Road in Glenview, was approved in 2025 on an eight-acre site immediately adjacent to Northbrook and is well on its way to completion. The project — built by a well-regarded Northbrook developer — contains no affordable housing component because Glenview does not require one.
If the same project had been built a few hundred feet north in Northbrook, the Village’s ordinance would have required six of the forty units to meet the state’s affordability standards. Would that have made the project financially untenable? I don’t know. Would a five-percent requirement have made it financially viable? Possibly, I have no idea. But the fact that the development next door contains zero affordable units illustrates a broader reality – we look less attractive than our neighbors for development.
The IHDA lists Glenview’s Affordable Housing submission, approved by the Glenview Village Board last May and submitted in September, as non-compliant, though it is not clear why. If the state Attorney General has taken action against the village, it has not been widely reported in the press.
Another example lies to our north. Deerfield has a 254-unit apartment project well underway behind Deerbrook Mall, just off Lake Cook Road, with a pedestrian connection to the Lake Cook Metra station. It includes 25 affordable units under Deerfield’s 10 percent requirement. In Northbrook, the same project would have carried a higher affordable housing requirement — 38 units rather than 25. Like Glenview, the IHDA lists Deerfield’s Affordable Housing Plan submission — approved by the Deerfield Village Board last June — as non-compliant. Again, though, it is not clear from the public posting why and there are no public reports of action from the state AG.
Meanwhile, in Northbrook, the proposed project at the former Maurice Sporting Goods warehouse site at 1825 Shermer is a useful contrast because it shows how difficult it can be to get housing approved here, even on a long-vacant site that would seem to be a logical redevelopment candidate. In March 2022, preliminary plans for an eight-building, 53-unit Lexington Homes townhouse development were already being reported publicly. By February 13, 2024, the project was before the Village Board for preliminary review.
Several trustees made clear in 2024 that simply paying a fee in lieu was not enough; they wanted actual affordable units built on site. As one trustee put it, “If we don’t start to build places that have affordable housing, just giving us money is not going to create more affordable housing in Northbrook, so we need to start building it.”
That raises an obvious question: why did Northbrook create an in-lieu option and an Affordable Housing Fund to receive those payments if using that option is treated as unacceptable when a real project comes forward? The fund is supposed to “expand inclusionary housing alternatives for all” and is financed through demolition taxes and in-lieu payments.
The FY27 proposed budget shows a balance of $937,500 in the fund, which is likely too small to make a meaningful impact. That budget also reverses all planned FY26 in-lieu payments of $675,000 and more than half of projected FY26 interest income. At a minimum, that suggests some daylight between the Board’s 2024 rhetoric about fee-in-lieu and the assumptions reflected in the 2026 budget process.
Returning to the Lexington Homes proposal at the former Maurice site, the Board concluded the February 2024 meeting with a unanimous vote to hold a joint meeting with the Plan Commission because of the affordable housing issue. I could not find evidence that such a meeting ever took place.
Eighteen months later, in September 2025, the affordable housing structure was still being negotiated before the Housing Committee. The applicant was now offering to build all eight affordable units on site, but was seeking exceptions that would place all eight in Tier II rather than split them evenly between Tier I and Tier II, as Northbrook’s ordinance contemplates, and would cluster them within the same building types. After Housing Committee feedback, the proposal was revised to include one Tier I unit and seven Tier II units. The Plan Commission then unanimously recommended approval.
At the November 2025 Village Board meeting, with both members of the Housing Committee absent, the Board again deliberated over the affordability structure. The discussion centered on whether to approve the applicant’s request for only one Tier I unit instead of the four called for under Northbrook’s ordinance, with some discussion of whether a compromise at two Tier I units and six Tier II units might be more appropriate. One long-serving trustee opened by acknowledging the obvious tension: the preference was to be closer to the ordinance, but the land had been vacant for a long time and it was time to get moving. Trustees who followed expressed variations of the same view. They wanted more affordability and, at the same time, clearly did not want to risk the project over it.
Yet even with all of that equivocation — clearly signaling, as the Village President observed in real time, a willingness to accept the plan as submitted — the matter was sent back to the applicant to evaluate a revised submission with two Tier I units and six Tier II units, with the President concluding that the applicant needed to “sharpen their pencils.”
This is not an example of Northbrook saying no. It is an example of Northbrook taking so long to say yes that, functionally, the distinction starts to matter less. It is hard to imagine other developers watching this process and concluding that Northbrook is an especially attractive place to do business.