City of Roanoke, VA
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Analysis of Impediments to Fair Housing Choice (AI) Summary of Impediments And the Fair Housing Action Plan
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City of Roanoke, VA March 5,2012
9
No. I
Satisfies requirements of the Housing and Community Development Act of 1974, which requires that communities receiving CDBG and HOME funds certify to HUD that they will affirmatively fu jher fair housing Communities receiving CDBG funds are required to: Examine and attempt to alleviate housing discrimination in their jurisdiction Promote fair housing choice for all persons Provide opportunities for all persons to reside in any given housing development Promote housing that is accessible to and usable by persons with disabilities Comply with the non-discrimination requirements of the Fair Housing Act I
All of the above can be achieved through the preparation of an A I .
Began in July 2011 Lead Agency - Division of HUD Community Resources Interviewed variety of stakeholders Questionnaires completed by stakeholders
Stakeholder outreach Relative presence of protected classes Language groups Housing and demographic trends Degree of segregation Areas of racial, ethnic, economic concentration
Location of affordable housing resources Jobs and housing connections Real estate practices Local fair housing organizations Fair housing complaints Mortgage loan denials
Review
Public
RRHAACOP and Section 8 Admin Plan Site selection Zoning Building codes Local procedure for processing FH complaints Tax policies .Public transit
Housing for special needs populations Immigrants and persons with LEP Composition of appointed boards and commissions Newspaper advertising
Affirmatively Furthering Annual certification by CDBG entitlement grantees Going out of the way to make something happen that wouldn't ordinarily happen on its own An obligation to do more than simply refrain from discrimination An obligation to prevent increases in housing segregation Fair Housing filter on internal processes and funding decisions
Goal : Balance revitalization with de-concentration and
.
Revitalizing public housing and residential neighborhoods is a necessary and appropriate preservation strategy:
"Improve my neighborhood so that others will want to move in"
Providing affordable housing in nonimpacted neighborhoods is also important: "Give me a choice of living in a neighborhood that is closer to jobs, has better schools, better parks and a sense of security and well-being"
d Findings "L,.
&
a*-
The City's population continues to diversify Minorities represent 35.8% Largest single minority group: Blacks (28.5%). Hispanics represent 5.5% of the population
2,333 persons spoke English less than "very well" 1,203 were native Spanish-speakers
Roanoke is moderately segregated but becoming more integrated Dissimilarity index for WhitesIBlacks decreased from 68.3 in 2000 to 60.4 in 2010
MHI among Blacks equal to 67.lo/o of Whites Poverty rate among Blacks significantly higher than among Whites
Selected Findings Black households are disproportionately represented among public housing & Section 8 tenants and waiting list applicants 65% 57% 68% 69%
of RRHA tenants of RRHA waitlist of Section 8 voucher holders of Section 8 waitlist
35.7% of persons with a disability were living in poverty compared to 15.8% of persons without a disability Female-headed households with children accounted for over 6Oo/o of all families living in poverty
Finding Home ownership varies widely: Hispanics 32.2% Blacks 45.3% Asians 59.7% Whites 62.9%
Cost burden is highest among households with incomes below $35,000 Nearly 62% of these households were paying more than 30% of their income on housing costs, equivalent to more than 7,500 households
Mortgage denial rates higher among minorities: Black applicants 16.7% Hispanic applicants 27.3% White applicants 5.8%
Areas of
Fair Housing Action Plan The following Fair Housing Action Plan (FHAP) has been developed and is based on the identified potential impediments to fair housing choice listed in the AI. The FHAP will help the City to complete Annual Plans and CAPERS, both of which are submitted annually to HUD. These documents must include goals and accomplishments related to affirmatively furthering fair housing.
on Plan IMPEDIMENT: The City's increasingly diverse minority population may req,uire language accommodations to ensure that all residents can access City programs and services. Proposed Action: Conduct the four-factor analysis to determine the extent to which the translation of vital documents is necessary to assist persons with limited English proficiency (LEP) in accessing City services and programs.
IMPEDIMENT: Members of the protected classes, including persons with disabilities, minorities, and females, are under-represented on City boards and commissions that address housing issues.* Proposed Action: Annually, the City should schedule a recruitment period for new board and commission applicants with an emphasis on recruiting members of the protected classes.
* Boards studied as part of this analysis include the Roanoke Redevelopment and Housing Authority Board, the Roanoke Planning Commission, the Roanoke Fair Housing Board, the Roanoke Board of Zoning Appeals, and the Roanoke Human Services Advisory Board.
Fair Hous
ion Plan
IMPEDIMENT: There is an inadequate supply of affordable rental housing that is accessible to persons with disabilities. Proposed Actions:
The Fair Housing Board should work with disability advocates to sponsor workshops and other educational opportunities. Ensure that all housing projects financed with City HOME funds are constructed to Section 504 accessibility standards. Partner with Blue Ridge Center for Independent Living to visit completed dwelling units constructed under Section 504 to verify accessibility features were built as designed.
Fair Ho IMPEDIMENT: Members of the protected classes tend to experience higher rates of unemployment and have lower incomes, thereby encountering greater difficulty in securing affordable housing. Proposed Actions: Continue the City's Downpayment Assistance Program targeting LMI and minority households. Fund homeownership counseling and financial management education for lower income households, particularly minority households. Adopt a Section 3 policy to ensure that employment and other economic and business opportunities generated by HUD assistance, to the greatest extent feasible, are directed to public housing residents and other LMI residents, particularly persons receiving government housing assistance, and business concerns that provide economic opportunities to low and very low income residents.
n Plan IMPEDIMENT: The City's supply of decent, affordable housing remains inadequate. Proposed Actions: Continue the City's Target Area policy where CDBG- and HOME-funded projects are focused in a designated area for at least three years. Continue the City's systematic Rental Inspection Program in the older LMI neighborhoods. Give a higher preference for new affordable housing projects that include three or more bedroonis. Develop and adopt a Site and Neighborhood Standards policy. These standards address the site location requirements for both rehabilitated and newly constructed rental units financed with HOME funds.
on Plan IMPEDIMENT: The majority of fair housing complaints filed through the Virginia Fair Housing Office involves race and disability as the alleged bases for discrimination. P r o ~ o s e dActions:
-
Budget at least 1% of the City's annual CDBG entitlement grant for fair housing activities. Contract with an experienced HUDdesignated fair housing organization to perform paired testing for race and disability in rental housing.
on Plan IMPEDIMENT: There is an absence of fair housing organizations that provide housing complaint investigation and enforcement. Proposed Actions: Continue the Fair Housing Board's integrated media campaign. Contact the VFHO to schedule a staff person for providing specific training to the Roanoke Fair Housing Board. Continue the Board's extensive ongoing semi-annual fair housing training seminars and workshops.
tion Plan IMPEDIMENT: Mortgage loan denials and high-cost lending disproportionately affect minority applicants, similar to national trends. Proposed Actions:
The City should engage HUD-certified housing counselors to target credit repair education through existing advocacy organizations that work extensively with minorities. Engage in a communication campaign that markets home ownership opportunities to minorities, including middle and higher income minorities.
n Plan IMPEDIMENT: The Roanoke Times does not appear to be in compliance with the Fair Housing Act, as the publisher's notice was difficult to locate on the newspaper's website and was noted to be deficient in its listing of the protected classes for which harassing language was prohibited. Proposed Actions: The City will work with The Roanoke Times to ensure that its real estate advertisements are published in accordance with the Fair Housing Act.
The A1 will be submitted to HUD The Fair Housing Action Plan (FHAP) will go into effect, upon which the City's progress towards affirmatively furthering fair housing will be based The City will report annually on its progress towards affirmatively furthering fair housing in its CAPERS and update its fair housing-related goals in its Annual Plans, both of which are submitted to HUD
ons
Analysis of Impediments to Fair Housing Choice (AI) Summary of Impediments And the Fair Housing Action Plan
.,,. 6y 9$ .? ,?. n
Z@7
City of Roanoke, VA March 5,2012
9
No. I
Satisfies requirements of the Housing and Community Development Act of 1974, which requires that communities receiving CDBG and HOME funds certify to HUD that they will affirmatively fu jher fair housing Communities receiving CDBG funds are required to: Examine and attempt to alleviate housing discrimination in their jurisdiction Promote fair housing choice for all persons Provide opportunities for all persons to reside in any given housing development Promote housing that is accessible to and usable by persons with disabilities Comply with the non-discrimination requirements of the Fair Housing Act I
All of the above can be achieved through the preparation of an A I .
Began in July 2011 Lead Agency - Division of HUD Community Resources Interviewed variety of stakeholders Questionnaires completed by stakeholders
Stakeholder outreach Relative presence of protected classes Language groups Housing and demographic trends Degree of segregation Areas of racial, ethnic, economic concentration
Location of affordable housing resources Jobs and housing connections Real estate practices Local fair housing organizations Fair housing complaints Mortgage loan denials
Review
Public
RRHAACOP and Section 8 Admin Plan Site selection Zoning Building codes Local procedure for processing FH complaints Tax policies .Public transit
Housing for special needs populations Immigrants and persons with LEP Composition of appointed boards and commissions Newspaper advertising
Affirmatively Furthering Annual certification by CDBG entitlement grantees Going out of the way to make something happen that wouldn't ordinarily happen on its own An obligation to do more than simply refrain from discrimination An obligation to prevent increases in housing segregation Fair Housing filter on internal processes and funding decisions
Goal : Balance revitalization with de-concentration and
.
Revitalizing public housing and residential neighborhoods is a necessary and appropriate preservation strategy:
"Improve my neighborhood so that others will want to move in"
Providing affordable housing in nonimpacted neighborhoods is also important: "Give me a choice of living in a neighborhood that is closer to jobs, has better schools, better parks and a sense of security and well-being"
d Findings "L,.
&
a*-
The City's population continues to diversify Minorities represent 35.8% Largest single minority group: Blacks (28.5%). Hispanics represent 5.5% of the population
2,333 persons spoke English less than "very well" 1,203 were native Spanish-speakers
Roanoke is moderately segregated but becoming more integrated Dissimilarity index for WhitesIBlacks decreased from 68.3 in 2000 to 60.4 in 2010
MHI among Blacks equal to 67.lo/o of Whites Poverty rate among Blacks significantly higher than among Whites
Selected Findings Black households are disproportionately represented among public housing & Section 8 tenants and waiting list applicants 65% 57% 68% 69%
of RRHA tenants of RRHA waitlist of Section 8 voucher holders of Section 8 waitlist
35.7% of persons with a disability were living in poverty compared to 15.8% of persons without a disability Female-headed households with children accounted for over 6Oo/o of all families living in poverty
Finding Home ownership varies widely: Hispanics 32.2% Blacks 45.3% Asians 59.7% Whites 62.9%
Cost burden is highest among households with incomes below $35,000 Nearly 62% of these households were paying more than 30% of their income on housing costs, equivalent to more than 7,500 households
Mortgage denial rates higher among minorities: Black applicants 16.7% Hispanic applicants 27.3% White applicants 5.8%
Areas of
Fair Housing Action Plan The following Fair Housing Action Plan (FHAP) has been developed and is based on the identified potential impediments to fair housing choice listed in the AI. The FHAP will help the City to complete Annual Plans and CAPERS, both of which are submitted annually to HUD. These documents must include goals and accomplishments related to affirmatively furthering fair housing.
on Plan IMPEDIMENT: The City's increasingly diverse minority population may req,uire language accommodations to ensure that all residents can access City programs and services. Proposed Action: Conduct the four-factor analysis to determine the extent to which the translation of vital documents is necessary to assist persons with limited English proficiency (LEP) in accessing City services and programs.
IMPEDIMENT: Members of the protected classes, including persons with disabilities, minorities, and females, are under-represented on City boards and commissions that address housing issues.* Proposed Action: Annually, the City should schedule a recruitment period for new board and commission applicants with an emphasis on recruiting members of the protected classes.
* Boards studied as part of this analysis include the Roanoke Redevelopment and Housing Authority Board, the Roanoke Planning Commission, the Roanoke Fair Housing Board, the Roanoke Board of Zoning Appeals, and the Roanoke Human Services Advisory Board.
Fair Hous
ion Plan
IMPEDIMENT: There is an inadequate supply of affordable rental housing that is accessible to persons with disabilities. Proposed Actions:
The Fair Housing Board should work with disability advocates to sponsor workshops and other educational opportunities. Ensure that all housing projects financed with City HOME funds are constructed to Section 504 accessibility standards. Partner with Blue Ridge Center for Independent Living to visit completed dwelling units constructed under Section 504 to verify accessibility features were built as designed.
Fair Ho IMPEDIMENT: Members of the protected classes tend to experience higher rates of unemployment and have lower incomes, thereby encountering greater difficulty in securing affordable housing. Proposed Actions: Continue the City's Downpayment Assistance Program targeting LMI and minority households. Fund homeownership counseling and financial management education for lower income households, particularly minority households. Adopt a Section 3 policy to ensure that employment and other economic and business opportunities generated by HUD assistance, to the greatest extent feasible, are directed to public housing residents and other LMI residents, particularly persons receiving government housing assistance, and business concerns that provide economic opportunities to low and very low income residents.
n Plan IMPEDIMENT: The City's supply of decent, affordable housing remains inadequate. Proposed Actions: Continue the City's Target Area policy where CDBG- and HOME-funded projects are focused in a designated area for at least three years. Continue the City's systematic Rental Inspection Program in the older LMI neighborhoods. Give a higher preference for new affordable housing projects that include three or more bedroonis. Develop and adopt a Site and Neighborhood Standards policy. These standards address the site location requirements for both rehabilitated and newly constructed rental units financed with HOME funds.
on Plan IMPEDIMENT: The majority of fair housing complaints filed through the Virginia Fair Housing Office involves race and disability as the alleged bases for discrimination. P r o ~ o s e dActions:
-
Budget at least 1% of the City's annual CDBG entitlement grant for fair housing activities. Contract with an experienced HUDdesignated fair housing organization to perform paired testing for race and disability in rental housing.
on Plan IMPEDIMENT: There is an absence of fair housing organizations that provide housing complaint investigation and enforcement. Proposed Actions: Continue the Fair Housing Board's integrated media campaign. Contact the VFHO to schedule a staff person for providing specific training to the Roanoke Fair Housing Board. Continue the Board's extensive ongoing semi-annual fair housing training seminars and workshops.
tion Plan IMPEDIMENT: Mortgage loan denials and high-cost lending disproportionately affect minority applicants, similar to national trends. Proposed Actions:
The City should engage HUD-certified housing counselors to target credit repair education through existing advocacy organizations that work extensively with minorities. Engage in a communication campaign that markets home ownership opportunities to minorities, including middle and higher income minorities.
n Plan IMPEDIMENT: The Roanoke Times does not appear to be in compliance with the Fair Housing Act, as the publisher's notice was difficult to locate on the newspaper's website and was noted to be deficient in its listing of the protected classes for which harassing language was prohibited. Proposed Actions: The City will work with The Roanoke Times to ensure that its real estate advertisements are published in accordance with the Fair Housing Act.
The A1 will be submitted to HUD The Fair Housing Action Plan (FHAP) will go into effect, upon which the City's progress towards affirmatively furthering fair housing will be based The City will report annually on its progress towards affirmatively furthering fair housing in its CAPERS and update its fair housing-related goals in its Annual Plans, both of which are submitted to HUD
ons
