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CITY of SOUTH GATE Draft Analysis of Impediments to Fair Housing Choice (AI)

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CITY of SOUTH GATE Draft Analysis of Impediments to Fair Housing Choice (AI) CITY OF SOUTH GATE Draft Analysis of Impediments To Fair Housing Choice (AI) Community Development Department July 14, 2020 SECTION I INTRODUCTION SECTION I INTRODUCTION A. FORMAT OF THE AI REPORT The U.S. Department of Housing and Urban Development (HUD) has not issued regulations defining the scope of analysis and the format to be used by grantees when they prepare their Analysis of Impediments to Fair Housing Choice (AI). In 1996, HUD published a Fair Housing Planning Guide which includes a “Suggested AI Format.” Because this Guide is the only official guidance provided by HUD to grantees on how to prepare and organize an AI, South Gate’s AI conforms to the format suggested by HUD. Section I Introduction: The Introduction presents the AI report format; South Gate’s regional setting, purpose of the report, fair housing definition, lead agency, funding, and progress made toward implementing the 2015-2020 AI. Section II Fair Housing Action Plan: Section II describes the conclusions and recommendations resulting from the AI analysis. It identifies impediments to fair housing choice and the actions that will be taken to remove or ameliorate impediments during the FY 2020/2021 to FY 2024/2025 time period. Actions to affirmatively further fair housing also are described in the Fair Housing Action Plan. Section III Fair Housing Legal Status: This Section discusses fair housing complaints and compliance reviews and other information pertaining to South Gate’s fair housing legal status. Section IV: City Background Data: HUD advises grantees to include in the AI “jurisdictional background data” on demographics, income, employment, housing and other relevant data. This information is presented in Section IV. Section V Fair Housing Protected Groups: This Section includes detailed demographic data on the fair housing protected groups – race/color; sex; national origin; familial status; and handicap/disability. Section VI Private Sector Impediments Analysis: Section VI presents an analysis of practices prohibited by the Federal Fair Housing Act (FFHA) and the California’s Fair Employment and Housing Act (FEHA). It also identifies the practices that create impediments to fair housing choice. Section VI describes impediments such as housing discrimination and discriminatory lending practices. Section VII Public Sector Impediments Analysis: This Section presents information on the planning and zoning policies, practices and regulations that impact fair housing. Section VIII Private/Public Sector Impediments Analysis: Section VIII describes potential and actual impediments that overlap the private and public sectors such as the location of affordable multifamily rental housing and gentrification. B. SOUTH GATE’S REGIONAL SETTING South Gate is located approximately ten miles to the southeast of downtown Los Angeles and 13.5 miles north of the Port of Long Beach. The City is bounded by the cities of Huntington Park, Cudahy, and Bell Gardens on the north; unincorporated county areas to the west; Lynwood and Paramount on the south; and Downey to the east. I-1 SECTION I INTRODUCTION The City and hosts a diverse mix of residential, commercial, industrial, and public buildings and land uses. The I-105 freeway is to its south, the I-110 freeway is approximately three miles from its western border, and the City is bisected by the I-710 freeway and several freight railroad lines. The South Gate is 7.5 square miles. The City had a population of almost 97,000 residents as of January 2019. The population density is almost 13,000 persons per square mile. Major physiographic features in the area include the Los Angeles River, which extends in a north-south orientation through the eastern portion of the City, and the Puente Hills, located approximately 9.5 miles to the northeast. Exhibit I-1 shows South Gate’s regional location. Exhibit I-2 shows the boundaries of the City limits. C. PURPOSE OF THE REPORT The City of South Gate annually receives funds from the Federal Community Development Block Grant (CDBG) program and HOME Investments Partnership HOME) program. In FY 2020/2021, the City expects to receive CDBG and HOME funds in the amounts of $1,487,150 and $664,918, respectively. An Affirmatively Furthering Fair Housing (AFFH) certification is required of cities and counties that receive funds from the CDBG program. The AFFH certification states that the grantee receiving HUD funds: …will affirmatively further fair housing … by conducting an analysis to identify impediments to fair housing choice within its jurisdiction, taking appropriate actions to overcome the effects of any impediments identified through the analysis, and maintaining records reflecting the analysis and actions in this regard. HUD interprets the broad objectives of the requirement to affirmatively further fair housing choice to mean that recipients must: Analyze and eliminate housing discrimination in the jurisdiction; Promote fair housing choice for all persons; Provide opportunities for inclusive patterns of housing occupancy regardless of race, color, religion, sex, familial status, disability, and national origin; Promote housing that is structurally accessible to, and usable by, persons with disabilities; and Foster compliance with the nondiscrimination provisions of the Federal Fair Housing Act. Source: U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Memorandum on Compliance-Based Evaluations of a Recipient’s Certifications that it has Affirmatively Furthered Fair Housing, March 5, 2013, page 4 I-2 SECTION I INTRODUCTION Exhibit I-1 Regional Setting I-3 SECTION I INTRODUCTION Exhibit I-2 City Limits I-4 SECTION I INTRODUCTION Therefore, the fundamental purpose of the AI is to maintain the City’s compliance with the AFFH certification. In so doing, the City will promote fair housing and remove or mitigate the private and sector impediments that have been identified through the analysis. The time period of the AI is from FY 2020/2021 through FY 2024/2025, a time period that aligns with South Gate’s five-year Consolidated Plan. D. DEFINING FAIR HOUSING CHOICE HUD defines fair housing as: …a condition in which individuals of similar income levels in the same housing market have a like range of choices available to them regardless of race, color, national origin, religion, sex, handicap, or familial status. HUD draws an important distinction between household income, affordability and fair housing. Economic factors that impact housing choice are not fair housing issues per se. Only when the relationship between household incomes combined with other factors - such as household type or race and ethnicity - create misconceptions and biases do they become a fair housing issue. Tenant/landlord disputes are also not typically fair housing issues, generally resulting from inadequate understanding by the parties on their rights and responsibilities. Such disputes only become fair housing issues when they are based on factors protected by fair housing laws and result in differential treatment. Impediments to fair housing choice, according to HUD, are -- Any actions, omissions, or decisions taken because of race, color, religion, sex, disability, familial status, or national origin which restrict housing choices or the availability of housing choices. (Intent) Any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices because of race, color, religion, sex, disability, familial status, or national origin. (Effect) E. LEAD AGENCY AND FUNDING FOR THE AI The lead agency for preparation of the AI and Fair Housing Action Plan is the Community Development Department. Valuable input to the AI was provided by the following: Residents who responded to the Analysis of Impediments to Fair Housing Choice Survey Fair Housing Foundation Los Angeles County Office on Aging California Tax Credit Allocation Committee (CTCAC) California Department of Fair Employment and Housing (DFEH) California Department of Housing and Community Development (HCD) National Fair Housing Alliance (NFHA) I-5 SECTION I INTRODUCTION U.S. Department of Housing and Urban Development, Los Angeles Field Office U.S. Department of Housing and Urban Development – Fair Housing and Equal Opportunity (FHEO), San Francisco Regional Office CDBG funds were expended to complete the AI. CDBG funds paid for consultant assistance on the AI’s preparation and for staff time expended on the project. In addition, the FHF contributed to the AI by providing housing discrimination data, case summaries, activities accomplished with the City, and reviewing the AI recommended actions. The City uses CDBG funds to support the fair housing and landlord/tenant counseling services of the FHF. F. ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE SURVEY An “Analysis of Impediments to Fair Housing Choice Survey” was a component of community outreach. There were 217 responses to the Survey of which 177 were residents and 25 were persons who worked in the City. Eighty percent of the residents have lived in South Gate for 10 years or longer. A summary of the responses is given below: 88% of the respondents believe that “housing for the disabled” is either “important” or “extremely important.” 91% of the respondents think that “ADA accessibility improvements to public roads/facilities” is either “important” or “extremely important.” 21% of the persons answering the Survey think that they or someone they know has encountered housing
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