In this well-written book, Mara Sidney skillfully utilizes the “policy design” approach developed by Anne Schneider and Helen Ingram (Policy Design for Democracy, 1997) to elucidate the relationship between national policy decisions and local political struggles surrounding the implementation of the Fair Housing Act of 1968 and the Community Reinvestment Act of 1977. The 1968 Act made housing discrimination against individuals because of race, creed, color, and national origin illegal. The 1977 Act was aimed at preventing credit discrimination (redlining) against geographical areas within cities. Sidney argues that the type of local groups that emerge to influence enforcement, and the strategies they utilize, are shaped by the resources built into the legislation's policy design, as well as by local political conditions. Case studies of two cities—Minneapolis and Denver—illustrate the impact of policy design in different local circumstances.

Through the author's discussion of the passage of each measure, we see how proponents developed positive images of the intended beneficiaries and negative images of those who would be sanctioned, in order to marshal support for its passage. Opponents, of course, developed conflicting images in order to defeat it. As each proposal advanced, the rewards and sanctions that were built into its policy design were the result of the images used to sell it, as well as the efforts of opponents to modify the design so as to protect their interests.

The Fair Housing Act was passed during the turbulent year of 1968 over the strong opposition of the real estate and housing industries. According to Sidney, proponents sold it as a way for law-abiding, middle-class African Americans to escape the ghetto and to achieve the American Dream of home ownership. Therefore, it focused on sanctioning individual discriminatory acts rather than broad patterns of segregation. Its powerful opponents succeeded in weakening its enforcement mechanism, allowing the federal government only a mediation role and placing the burden of redress on the individual. (Enforcement was strengthened in the 1988 amendments.)

In contrast, the Community Reinvestment Act (CRA) passed with little controversy, in the context of widespread concern with the continuing decline of urban neighborhoods. The target was lenders' discrimination against whole neighborhoods, not against individuals. The enforcement mechanism was the review process carried out by banking regulators, during which mergers or acquisitions could be blocked if a bank's CRA record was not good. The Home Mortgage Disclosure Act, passed earlier, gave community groups data that could be used to challenge a bank's record. Again, the weakness of the enforcement mechanism was the result of resistance by the powerful banking industry.

Sidney predicts that these policy designs will attract different kinds of local advocacy groups, in spite of the considerable overlap between the problems of individual and neighborhood discrimination. Fair housing advocates will be specialists in the complex legal strategies necessary to pursue individual discrimination cases. Fair housing will tend to be their exclusive concern, rather than other housing issues, and their focus will be on the private housing market, rather than government actions. In contrast, CRA advocates will be groups with an interest in all kinds of housing and neighborhood problems. Rather than legal action, they will utilize research and publicity to call attention to banks' lack of investment in certain neighborhoods. Their advocacy will be episodic, emerging when banks seek approval to merge and subsiding at other times.

Through in-depth interviews with local actors and reviews of public records in Minneapolis and Denver, Sidney finds that local advocacy generally reflects the federal policy designs, but that important deviations from these expectations result from local conditions. For example, fair housing groups in Minneapolis became heavily involved in the issue of creating more affordable housing, not just enforcement, in response to a growing minority population in the Twin Cities that could not find affordable housing, even with reduced discriminatory barriers. A similar broadening of focus did not occur among fair housing advocates in Denver.

In reviewing Sidney's application of the “policy design” approach, one is at first tempted to ask what this approach adds that is new to policy analysis. Scholars have long recognized that both policy formulation and policy implementation are shaped by a complex dance among legislators, bureaucrats, and the constituencies most affected by a policy. However, on further reflection, it becomes clear that this approach does improve our understanding by increasing our awareness of the cognitive dimension of policymaking. Decision makers form mental images of who has been wronged, what the injustice is, and who the perpetrators are, and these images shape their decisions as to appropriate remedies. These images, formed during the political struggle over the passage of legislation, are carried forward to strongly shape the outcomes of implementation.

Sidney carries this approach a step further by showing how policy design shapes local advocacy. Local groups forge their strategies around the weapons that the legislation places in their arsenal, no matter how inadequate they may be. At the same time, they adapt their strategies to unique local conditions. Her subtle analysis accurately captures this interplay of local and national forces.

In a longer book, Sidney might have included more cities as case studies, in order to provide stronger empirical support for her argument. Also, she might have looked in more detail at how the interests of local government actors affect enforcement. For example, the federally required “Analysis of Impediments to Fair Housing” that she mentions is imposed on agencies administering the Community Development Block Grant (CDBG) program. These are often entirely separate from the agencies that enforce fair housing laws. This writer's experience suggests that CDBG agencies view the “Analysis” as routine paperwork, to be dispensed with as quickly and quietly as possible, rather than as a clarion call to action!

However, the lean, economical nature of Unfair Housing makes the basic structure of Sidney's argument quite clear, and the two case studies chosen are appropriate. The book's clarity is further enhanced by her excellent writing style. It is to be hoped that her approach will guide further empirical investigation into the complex process of policy implementation by actors at all levels of government.