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TAMPA-HILLSBOROUGH COUNTY REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE PY 2018-2022

SUBMITTED BY: HOUSING COALITION, INC.

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Signature Page

The City of Tampa, Hillsborough County, and Tampa Housing Authority certify that to the best of their knowledge and belief, the statements and information contained herein are true, accurate, and complete and has developed this AI in compliance with the requirements of 24 C.F.R. §§ 91.225(a)(1), 570.601, and guidance provided by the U.S. Department of Housing and Urban Development.

The program participants will affirmatively further fair housing and take appropriate actions to overcome the effects of the impediments identified in this AI in accordance with the requirements in 24 C.F.R. §§ 91.225(a)(1), 570.601, and all other applicable laws.

______(Print Name) (Program Participant/Title) (Signature) (date)

______(Print Name) (Program Participant/Title) (Signature) (date)

______(Print Name) (Program Participant/Title) (Signature) (date)

Nancy Y. Takemori

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Table of Contents

Signature Page ...... ii List of Tables ...... iv List of Figures ...... vii I. Executive Summary ...... 1 II. Community Participation Process ...... 17 III. Assessment of Past Goals, Actions and Strategies ...... 34 IV. Fair Housing Analysis ...... 45 A. Demographic Summary ...... 45 B. General Issues ...... 55 i. Segregation/Integration ...... 55 ii. Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) ...... 88 iii. Disparities in Access to Opportunity ...... 96 iv. Disproportionate Housing Needs ...... 188 C. Publicly Supported Housing Analysis ...... 215 D. Disability and Access Analysis ...... 246 E. Fair Housing Enforcement, Outreach Capacity, and Resources Analysis ...... 272 V. Fair Housing Goals and Priorities ...... 282 VI. Appendices ...... 318 APPENDIX A – List of Acronyms ...... 319 APPENDIX B – Glossary of Terms ...... 323 APPENDIX C – Contributing Factors Descriptions ...... 328 APPENDIX D – Summary of Fair Housing Survey Results ...... 341 APPENDIX E – Proof of Publication ...... 367

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List of Tables

Table 1: City of Tampa Public Meetings ...... 17

Table 2: Hillsborough County Public Meetings ...... 18

Table 3: Tampa Housing Authority Resident Advisory Council Meetings ...... 18

Table 4: Tampa Housing Authority Resident Meetings ...... 19

Table 5: City of Tampa and Hillsborough County Stakeholder Meetings ...... 19

Table 6: City of Tampa and Hillsborough County AHAC/AHAB Meetings ...... 20

Table 7: City of Tampa, Hillsborough County, and THA AI Public Display Locations ...... 21

Table 8: Agency Consultation List ...... 24

Table 9: City of Tampa – Previous Fair Housing Goals ...... 34

Table 10: Hillsborough County – Previous Fair Housing Goals ...... 36

Table 11: Race/Ethnicity ...... 45

Table 12: Race/Ethnicity Trends ...... 46

Table 13: National Origin ...... 48

Table 14: National Origin Trends ...... 49

Table 15: Limited English Proficiency Language ...... 50

Table 16: Limited English Proficiency Trends ...... 51

Table 17: Disability Type ...... 51

Table 18: Population by Sex ...... 52

Table 19: Population by Sex Over Time ...... 52

Table 20: Population by Age ...... 53

Table 21: Population by Age Over Time ...... 53

Table 22: Families with Children ...... 54

Table 23: Families with Children Over Time ...... 54

Table 24: City of Tampa – Racial/Ethnic Dissimilarity Index ...... 55

Table 25: Hillsborough County - Racial/Ethnic Dissimilarity Index ...... 56

Table 26: City of Tampa - R/ECAP by Race/Ethnicity ...... 90

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Table 27: City of Tampa – R/ECAP by Family Type ...... 91

Table 28: City of Tampa – R/ECAP by National Origin ...... 91

Table 29: Hillsborough County – R/ECAP by Race/Ethnicity ...... 92

Table 30: Hillsborough County – R/ECAP by Family Type ...... 92

Table 31: Hillsborough County – R/ECAP by National Origin ...... 93

Table 32: School Proficiency Index ...... 96

Table 33: Florida Department of Education Lowest Performing Schools ...... 107

Table 34: Jobs Proximity Index ...... 109

Table 35: Labor Market Index ...... 111

Table 36: Transit Index ...... 129

Table 37: Low Transportation Cost Index ...... 131

Table 38: Low Poverty Index ...... 153

Table 39: Environmental Health Index ...... 165

Table 40: Uninsured Individuals in Hillsborough County ...... 177

Table 41: City of Tampa - Demographics of Households with Disproportionate Housing Needs ...... 189

Table 42: City of Tampa - Demographics of Households with Severe Housing Cost Burden ...... 190

Table 43: Hillsborough County - Demographics of Households with Disproportionate Housing Needs ...... 191

Table 44: Hillsborough County - Demographics of Households with Severe Housing Cost Burden ...... 192

Table 45: City of Tampa – Publicly Supported Housing by Program Category – Units by Number of Bedrooms and Number of Children ...... 200

Table 46: Hillsborough County - Publicly Supported Housing by Program Category – Units by Number of Bedrooms and Number of Children ...... 201

Table 47: City of Tampa - Homeownership and Rental Rates by Race/Ethnicity ...... 202

Table 48: Hillsborough County - Homeownership and Rental Rates by Race/Ethnicity ...... 202

Table 49: Hillsborough County - Mortgage Application and Originations by Race ...... 204

Table 50: Tampa-St. Petersburg-Clearwater, FL - Mortgage Application and Originations by Race ...... 206

Table 51: Loan Application Denials by Race/Ethnicity ...... 207

Table 52: Hillsborough County - Mortgage Application by Income Level ...... 209

Table 53: Tampa – St. Petersburg – Clearwater, FL – Mortgage Applications by Income Level ...... 210

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Table 54: Publicly Supported Housing Residents by Race/Ethnicity ...... 216

Table 55: Hillsborough County - Publicly Supported Housing Residents by Race/Ethnicity ...... 217

Table 56: Tampa-St. Petersburg-Clearwater Region - Publicly Supported Housing Residents by Race/Ethnicity ...... 218

Table 57: City of Tampa - R/ECAP and Non-R/ECAP Demographics by Publicly Supported Housing Program Category ...... 230

Table 58: Hillsborough County - R/ECAP and Non-R/ECAP Demographics by Publicly Supported Housing Program Category ...... 232

Table 59: City of Tampa - Demographics of Publicly Supported Housing Development, by Program Category ...... 233

Table 60: Hillsborough County - Demographics of Publicly Supported Housing Development, by Program Category ...... 236

Table 61: City of Tampa – Disability by Type ...... 246

Table 62: Disability by Type ...... 249

Table 63: City of Tampa- Age of People with Disabilities ...... 252

Table 64: Hillsborough County – Age of People with Disabilities ...... 254

Table 65: City of Tampa -Disability by Publicly Supported Housing Program Category ...... 259

Table 66: Hillsborough County -Disability by Publicly Supported Housing Program Category ...... 259

Table 67: Unresolved Housing Discrimination Cases ...... 272

Table 68: Housing Discrimination Closure Log (2011-2016) ...... 276

Table 69: Fair Housing Cases Closed by Year ...... 277

Table 70: Fair Housing Case Resolutions ...... 278

Table 71: Housing Discrimination Testing Results ...... 279

Table 72: Contributing Factors Prioritization and Justification...... 282

Table 73: Fair Housing Goals ...... 305

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List of Figures

Figure 1: City of Tampa – Race/Ethnicity ...... 58

Figure 2: City of Tampa – National Origin ...... 59

Figure 3: City of Tampa – LEP population ...... 60

Figure 4: Hillsborough County – Race/Ethnicity ...... 62

Figure 5: Hillsborough County – National Origin ...... 63

Figure 6: Hillsborough County – LEP Population ...... 64

Figure 7: City of Tampa – Race/Ethnicity Trends (1990) ...... 67

Figure 8: City of Tampa – Race/Ethnicity Trends (2000) ...... 68

Figure 9: City of Tampa – Race/Ethnicity Trends (2010) ...... 69

Figure 10: Hillsborough County – Race/Ethnicity Trends (1990) ...... 71

Figure 11: Hillsborough County – Race/Ethnicity Trends (2000) ...... 72

Figure 12: Hillsborough County – Race/Ethnicity Trends (2010) ...... 73

Figure 13: City of Tampa – Housing Tenure by Renters ...... 76

Figure 14: City of Tampa – Housing Tenure by Owners ...... 77

Figure 15: Hillsborough County – Housing Tenure by Renters ...... 79

Figure 16: Hillsborough County – Housing Tenure by Owners ...... 80

Figure 17: City of Tampa Community Redevelopment Areas ...... 83

Figure 18: Hillsborough County Redevelopment Areas ...... 84

Figure 19: Location of R/ECAPs ...... 89

Figure 20: City of Tampa – School Proficiency and Race/Ethnicity...... 100

Figure 21: City of Tampa – School Proficiency and National Origin ...... 101

Figure 22: City of Tampa – School Proficiency and Familial Status ...... 102

Figure 23: Hillsborough County – School Proficiency and Race/Ethnicity ...... 104

Figure 24: Hillsborough County – School Proficiency and National Origin ...... 105

Figure 25: Hillsborough County – School Proficiency and Familial Status ...... 106

Figure 26: City of Tampa – Job Proximity and Race/Ethnicity ...... 114

Figure 27: City of Tampa – Job Proximity and National Origin ...... 115

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Figure 28: City of Tampa – Job Proximity and Familial Status ...... 116

Figure 29: Hillsborough County- Job Proximity and Race/Ethnicity ...... 118

Figure 30: Hillsborough County – Job Proximity and National Origin ...... 119

Figure 31: Hillsborough County – Job Proximity and Familial Status...... 120

Figure 32: City of Tampa – Labor Market and Race/Ethnicity ...... 122

Figure 33: City of Tampa – Labor Market and National Origin ...... 123

Figure 34: City of Tampa – Labor Market and Familial Status ...... 124

Figure 35: Hillsborough County – Labor Market and Race/Ethnicity ...... 126

Figure 36: Hillsborough County – Labor Market and National Origin ...... 127

Figure 37: Hillsborough County- Labor Market and Familial Status ...... 128

Figure 38: City of Tampa – Transit Trips and Race/Ethnicity ...... 134

Figure 39: City of Tampa – Transit Trips and National Origin ...... 135

Figure 40: City of Tampa – Transit Trips and Familial Status ...... 136

Figure 41: Hillsborough County – Transit Trips and Race/Ethnicity ...... 138

Figure 42: Hillsborough County – Transit Trips and National Origin ...... 139

Figure 43: Hillsborough County – Transit Trips and Familial Status ...... 140

Figure 44: City of Tampa – Low Transportation Cost and Race/Ethnicity ...... 142

Figure 45: City of Tampa – Low Transportation Cost and National Origin ...... 143

Figure 46: City of Tampa – Low Transportation Cost and Familial Status ...... 144

Figure 47: Hillsborough County – Low Transportation Cost and Race/Ethnicity ...... 146

Figure 48: Hillsborough County – Low Transportation Cost and National Origin ...... 147

Figure 49: Hillsborough County – Low Transportation Cost and Familial Status ...... 148

Figure 50: City of Tampa – Poverty and Race/Ethnicity...... 156

Figure 51: City of Tampa - Poverty and National Origin ...... 157

Figure 52: City of Tampa – Poverty and Familial Status ...... 158

Figure 53: Hillsborough County – Poverty and Race/Ethnicity ...... 160

Figure 54: Hillsborough County – Poverty and National Origin ...... 161

Figure 55: Hillsborough County – Poverty and Familial Status ...... 162

Figure 56: Percentage Change in the number of people living in poverty ...... 164 viii

Figure 57: City of Tampa – Environmental Health and Race/Ethnicity ...... 168

Figure 58: City of Tampa – Environmental Health and National Origin ...... 169

Figure 59: City of Tampa – Environmental Health and Familial Status ...... 170

Figure 60: Hillsborough County – Environmental Health and Race/Ethnicity ...... 172

Figure 61: Hillsborough County – Environmental Health and National Origin ...... 173

Figure 62: Hillsborough County – Environmental Health and Familial Status ...... 174

Figure 63: Location of Uninsured Individuals in Hillsborough County ...... 178

Figure 64: Medically Underserved Areas ...... 179

Figure 65: Medically Underserved Areas and R/ECAPs ...... 180

Figure 66: Location of Family Childcare Homes ...... 182

Figure 67: Location of Licensed Childcare Centers ...... 183

Figure 68: USDA Food Deserts in Hillsborough County ...... 185

Figure 69: Grocery Store Leakage Rate ...... 186

Figure 70: City of Tampa – Housing Burden and Race/Ethnicity ...... 195

Figure 71: City of Tampa – Housing Burden and National Origin ...... 196

Figure 72: Hillsborough County – Housing Burden and Race/Ethnicity...... 198

Figure 73: Hillsborough County – Housing Burden and National Origin ...... 199

Figure 74: Hillsborough County - Comparison of loan originations to population by Race/Ethnicity ...... 205

Figure 75 - Tampa-St. Petersburg-Clearwater CBSA - Comparison of loan originations to population by Race/Ethnicity ...... 207

Figure 76 – Single-family Home Purchase Denial Rate ...... 208

Figure 77 – Residential Lending in Hillsborough County ...... 211

Figure 78 – Hillsborough County Bank Branches ...... 213

Figure 79: City of Tampa – Publicly Supported Housing and Race/Ethnicity ...... 223

Figure 80: Hillsborough County -Publicly Supported Housing and Race/Ethnicity ...... 225

Figure 81: Distribution of Publicly Supported Housing Developments in Tampa by Population Served ...... 227

Figure 82: Distribution of Publicly Supported Housing Developments in Hillsborough County by Population Served ...... 229

Figure 83: City of Tampa – Disability and Type ...... 247

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Figure 84: City of Tampa – Disability by Type ...... 248

Figure 85: Hillsborough County – Disability and Type ...... 250

Figure 86: Hillsborough County – Disability and Type ...... 251

Figure 87: City of Tampa – Disability by Age Group...... 253

Figure 88: Hillsborough County – Disability by Age Group ...... 255

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I. Executive Summary Summarize the fair housing issues, significant contributing factors, and goals. Also include an overview of the process and analysis used to reach the goals.

Background

The Fair Housing Act (FHA) requires that the U.S. Department of Housing and Urban Development (HUD) administer its housing and urban development programs in a way that affirmatively furthers fair housing. On July 16, 2015, HUD published a final rule on Affirmatively Furthering Fair Housing (AFFH rule) that clearly defined what it means to affirmatively furthering fair housing and created a new process for fair housing planning. The AFFH rule defines affirmatively furthering fair housing as “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics”. Meaningful actions must: • address significant disparities in housing needs and in access to opportunity; • replace segregated living patterns with integrated and balanced living patterns; • transform racially or ethnically concentrated areas of poverty into areas of opportunity; and • foster and maintain compliance with civil rights and fair housing laws.

The new fair housing planning process, the Assessment of Fair Housing (AFH), was meant to assist local governments, public housing agencies (PHAs), States, and Insular Area that receive HUD funding meet their obligation under the FHA to affirmatively further fair housing by providing a standardized process for them to identify fair housing issues facing their jurisdiction and region.

On January 5, 2018, HUD published in the Federal Register at 83 FR 683, its Affirmatively Furthering Fair Housing: Extension of Deadline for Submission of Assessment of Fair Housing for Consolidated Plan Participants notice (the Notice). The Notice immediately extended the deadline for submission of AFHs by program participants to their next AFH deadline that falls after October 31, 2020. The Notice also advised that program participants are still required to meet their statutory requirement to affirmatively further fair housing under the FHA which means that they are required to meet the federal regulatory requirements that existed prior to the new AFFH rule, that is, 24 CFR 91.225(a)(1)(2014) and 24 CFR 5.160 (a)(3)(2017). These regulations require program participants conduct an Analysis of Impediments to Fair Housing Choice (AI). The AI is an analysis of fair housing issues that program participants, must conduct every five years. Program participants include entitlement jurisdictions that receive community and planning development (CPD) funding under the Community Development Block Grant (CDBG), HOME Investment Partnership (HOME), Housing Opportunities for Persons with AIDS (HOPWA), and Emergency Solutions Grant (ESG) programs. The AI must identify impediments to fair housing choice within the jurisdiction, take appropriate actions to overcome the effects of any impediments identified through the analysis, and maintain records reflecting the analysis and actions taken.

At the time of the publication of the Notice, preparation of this document was underway. The Notice, as well as subsequent HUD Guidance (Frequently Asked Questions on the Notice published on January 16,

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2018) clarified that program participants that were in the process of preparing an AFH could continue to do so and could continue to utilize the AFH format. HUD also encouraged the preparation of regional AIs. The program participants involved in the preparation of this document opted to use the HUD AFH Assessment Tool (AFH format) to conduct this AI.

Participants in the AI

This AI is a collaboration between the City of Tampa (City), Hillsborough County (County), and the Tampa Housing Authority (THA). THA is the lead entity of the collaboration. THA’s service area encompasses the City and the County. The City of Tampa’s Housing and Community Development Division (HCD) and Hillsborough County’s Affordable Housing Services Department (AHS) are responsible for coordinating fair housing planning in their jurisdictions. This AI serves as an update to the City’s 2012 AI and the County’s 2013 AI and covers the period October 1, 2018 – September 30, 2022.

In addition to the program participants, a variety of individuals and organizations including citizens, housing providers, non-profit agencies, lending institutions, fair housing agencies, and regional organizations, also participated in the AI process by providing valuable input, knowledge, and data, during the development of the AI.

Fair Housing Act

The FHA (the Act), passed in 1968 prohibits discrimination in housing based on race, color, religion, sex, and, national origin. The Act was amended in 1988 to include protection for families with children (familial status) and persons with disabilities. The Act covers the sale and rental of housing, mortgage lending, real estate advertising, homeowners’ insurance, housing appraisals, newly constructed multifamily dwellings, and vacant land use. There are some exemptions to the Act including the exclusion of owner-occupied buildings with no more than four units, single-family housing sold or rented without the use of a broker, and housing for older persons is exempt from the prohibition against familial status.

In addition to the Act, the State of Florida, City of Tampa, and Hillsborough County have all adopted and enforce local fair housing laws. The Florida Commission on Human Relations (FCHR) is the state agency charged with enforcing the state’s civil rights laws. It is against Florida law to discriminate on the basis of race, color, religion, sex, pregnancy, national origin, disability, marital status or familial status. It is also unlawful to discriminate in land use decisions or in the permitting of development based on the source of financing of a development or proposed development. The Florida Fair Housing Act applies to the sale and rental of housing. The Tampa Office of Human Rights (TOHR) participates in the Fair Housing Assistance Program (FHAP) under contract with HUD and enforces local, state, and Federal fair housing laws. In the County, the Equal Opportunity Administrator’s Office is responsible for investigating housing discrimination complaints filed by County residents. Both the City and County fair housing ordinances include additional protected classes beyond the groups protected under the Federal and state fair housing laws. The additional protected classes are age, sexual orientation, gender identity or expression, marital status, and retaliation.

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Methodology Used

The methodology used for the development of this AI followed the AFH planning approach prescribed in the AFFH rule. The process consisted of the following elements:

1. Community Participation

The City, County, and THA encouraged participation from diverse groups, including persons with disabilities, during the development of the AI. A variety of means including several non-traditional methods were utilized to reach the broadest audience possible.

The community participation process began in August 2016 by making HUD-provided data that is included in the AI available to the public. HUD developed a web-based application, referred to as the AFFH Data and Mapping Tool, for program participants to utilize during the preparation of the analysis. The Data and Mapping Tool is also available to the public and includes maps and tables that provide information to conduct the required fair housing analysis. The Data and Mapping Tool can be accessed at https://egis.hud.gov/affht. Version AFFHT0003 of the data, was utilized for the preparation of this AI. Links to the HUD maps and tables were posted on each of the participant’s website to enable residents and other interested parties to view the data.

The community participation process continued throughout the development of the AI and all three participants engaged in numerous outreach activities. The purpose of the outreach activities was to inform residents, stakeholders, and interested parties about the AI process as well as to provide an opportunity for the public to share their views and recommendations on affirmatively furthering fair housing in the housing and community development programs in the City and the County. The outreach activities included: • Eight public meetings held throughout the City and County where residents, including low- and moderate- income individuals and persons residing in disadvantaged neighborhoods, could participate. • Two Resident Advisory Council meetings and two public housing resident meetings conducted by THA at public housing development sites. • Two stakeholder meetings, one targeting social service providers and the other geared towards real estate professionals, lenders, property managers, and landlords. • Several meetings and presentations to the City’s Affordable Housing Advisory Committee (AHAC), the County’s Affordable Housing Advisory Board (AHAB), the Tampa Hillsborough Homeless Initiative (THHI), the Hillsborough Area Regional Transit Authority (HART), and other key government boards, commissions, and departments. • Direct key person interviews with representatives from the public, private, and non-profit sectors to gather input on specific fair housing issues. • A web-based and paper-based survey in English and Spanish for residents, real estate professionals, lenders, landlords, and social service providers. • Public hearings held before the proposed AI was published for comment. • Publication of the AI to receive comments from residents and interested parties.

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2. Assessing Fair Housing Issues

The program participants utilized the HUD-provided data as well local data and local knowledge to assess the fair housing issues that are affecting protected classes in the City, County, and the Tampa-St. Petersburg-Clearwater region (region). The fair housing issues that were analyzed include: • Patterns of segregation and integration; • Racially or ethnically concentrated areas of poverty; • Disparities in access to opportunity; • Disproportionate housing needs; • Publicly supported housing; • Disability and access; and • Fair housing enforcement, outreach capacity, and resources.

While the HUD-provided data was the primary source of information utilized in the analysis, the program participants supplemented the HUD data with information collected from several other sources including demographic data from the U.S. Census Bureau, American Community Survey (ACS), Shimberg Center for Housing Studies, and the Hillsborough Community Atlas. Home Mortgage Disclosure Act (HMDA) data was used to evaluate lending practices in the County and the region. A review of public policies and practices was conducted by examining reports that relate to fair housing and access to housing including the previous AIs prepared by the City and County, THA’s 5-yr PHA and annual plans, Tampa 2025 Comprehensive Plan, the Comprehensive Plan for Unincorporated Hillsborough County, Community Redevelopment Agency (CRA) plans, each jurisdiction’s Consolidated Plan and Annual Action Plans, previous Consolidated Annual Performance and Evaluation Reports (CAPERS), and each jurisdiction’s zoning and land use regulations. An evaluation of the nature of the fair housing complaints in the City and the County was also conducted based on case data and testing results from the local and state fair housing enforcement organizations.

3. Identifying Contributing Factors

As part of the fair housing analysis, the program participants determined the significant contributing factors for each fair housing issue. The AFFH rule defines contributing factors as “a factor that creates, contributes to, perpetuates, or increases the severity of one or more fair housing issues”. HUD provides a list of suggested contributing factors for each fair housing issue analyzed and the program participants selected the contributing factors from the HUD list but also identified other contributing factors that were not on the list but determined to be a significant issue in the City, County, or the region.

4. Prioritizing Contributing Factors

Once the contributing factors were identified, the program participants prioritized and justified each contributing factor. The AFFH rule gives flexibility in how contributing factors are prioritized but mandates that the highest priority be given to factors that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance. The City, County, and THA opted to prioritize contributing factors as either priority or non-priority items. A non-priority contributing factor does not

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indicate that the factor is not significant but rather that there are other factors that have greater effects on fair housing choice and access to opportunity and that priority factors will likely need to be addressed first.

5. Setting Fair Housing Goals

Based on the findings of the fair housing analysis and the prioritization of the contributing factors, the program participants identified goals to address the effects of the priority contributing factors and the fair housing issues. Each goal addresses one or more contributing factors and includes metrics and milestones to measure progress in overcoming the contributing factors during the five-year period covered by the AI. A description of each contributing factor is included as Appendix C.

Conclusions

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

1 Increase the production and Community Opposition Segregation/Integration City of Tampa preservation of affordable housing units in a range of Land use and zoning R/ECAPs Hillsborough sizes within high laws County opportunity areas and Disparities in Opportunity R/ECAPs Location and type of Tampa Housing affordable housing Disproportionate Housing Authority Needs Displacement due to economic pressures Publicly Supported Housing Lack of access to opportunity due to high housing costs

Loss of affordable housing

Availability of affordable units in a range of sizes

Deteriorated and abandoned properties

Lack of affordable, accessible housing in a range of unit sizes

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Lack of private investments in specific neighborhoods, including services or amenities

Lack of public resources for investment in specific neighborhoods, including services or amenities Metrics, Milestones, and Timeframe for Achievement: • Within 5 years, utilize land use ordinances in the City and the County that strongly encourage workforce housing be built concurrently by the private sector under certain circumstances when land use permits for new construction or redevelopment are approved.

• Within 5 years, identify additional opportunities to amend existing City and County land use and zoning codes to encourage a variety of housing types including lower-income housing.

• Within 5 years, amend the City and County zoning codes to allow ADUs ‘as-of-right’ in all single-family residential districts for the purpose of creating additional affordable rental units.

• Within 2 years, provide support to a community land trust that operates throughout Hillsborough County.

• Within 5 years, ensure the development of new affordable rental housing in high opportunity areas (near public transit, good schools, and job centers) through strategies such as continued partnership with THA to create mixed-income developments, inclusionary zoning, local housing trust fund, and leveraging federal, state, and local public funding with private sector funding.

• Within 5 years, develop a mapping system that identifies sites in high opportunity areas in the City and County that are suitable for affordable housing development. If publicly owned, make these sites available through a surplus land program.

• Within 5 years, preserve existing affordable housing by encouraging owners of subsidized developments to preserve units likely to be lost from the affordable housing inventory.

• Over the next 5 years, continue to rehabilitate housing units throughout the City and County, including LMI areas and R/ECAPs.

• Over the next 5 years, hold workshop(s) to educate elected officials, local government staff, and for- profit/non-profit developers on avoiding or overcoming NIMBY opposition to affordable housing development in high opportunity neighborhoods.

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Discussion: The housing market in the City and County has tightened, with sharp increases in home and rental prices. Lower income households are facing a wide financial gap between the supply of affordable housing and the quantity demanded. Although affordable housing is not the same as fair housing, it relates closely to and overlaps with fair housing because persons that benefit from low-cost housing are disproportionately protected class members including minority households and persons with disabilities. Equal and free access to residential housing (housing choice) is fundamental to meeting essential needs and pursuing personal, educational, employment, or other goals.

The City and County will undertake a balanced approach to addressing the lack of affordable housing, one that improves overall living conditions in R/ECAPs while expanding affordable housing options in higher opportunity areas. Both the City and County should study the feasibility of inclusionary zoning as a strategy to increase the supply of mixed-income communities. There is a strong development market with substantial amounts of new construction and low vacancy rates. Inclusionary zoning will encourage developers to create below market rental or homeownership units in connection with proposed market-rate development projects.

Inclusionary zoning is just one strategy that the City and County can use to expand affordable housing options in higher opportunity areas. The City and County will need to continue to provide developer incentives to ensure the feasibility of projects affected by the inclusionary zoning policy, including density bonuses, impact fee relief, and reduced parking requirements. The City and County should also identify other strategies that will also result in the production of affordable housing units. While exploring these options, the City and County should continue to undertake the review of proposed policies, procedures, ordinances, and regulations to identify any financial impact on affordable housing and to identify policies that limit the feasibility of providing low-cost housing, such as minimum lot sizes requirements in the County.

Accessory dwelling units (ADUs) are another strategy that the City and County can utilize to help meet the need for affordable housing. Both the City and County permit ADUs in residential zoning districts as a conditional use which requires a special use permit and public hearing. This process can deter homeowners from building ADUs due to costs as well as the unpredictability of the development review process. Another potential barrier to ADU development in the City and County is requiring that the primary dwelling be owner- occupied. This requirement should be flexible to at least allow the owner to occupy the ADU and lease the primary dwelling. Allowing flexibility in living arrangements could increase the interest in ADUs.

Community land trusts (CLT) are another mechanism to not only increase affordable housing development but also to ensure the units are not lost after subsidy expiration. A CLT ensures permanent affordability by restricting the resale price of a home through a 99-year ground lease. A CLT also provides homeownership opportunities for minorities and low- and moderate-income households that would otherwise be unable to qualify to purchase a home on the conventional market. The City and County could partner with an existing CLT in the surrounding geographic area or establish a new CLT. Either way, in order for the CLT to be successful, the City and County will need to support the organization by providing funding, donating land, and through developer incentives.

Regarding the preservation of affordable housing, the City and County will continue to allocate state and federal funding for housing rehabilitation programs to improve the quality of the existing affordable housing stock. Investing in R/ECAPs through rehabilitation, reconstruction of replacement housing, or demolition of vacant, dilapidated homes, will help to transform these areas and attract commercial and employment 7

opportunities. The City and County will also explore ways to encourage owners of multifamily rental developments that have expiring subsidies to keep the units affordable. This includes providing funds to rehabilitate the units and extending the affordability period.

NIMBYism is an obstacle to producing affordable housing. To overcome community opposition to the placement of certain types of housing in certain neighborhoods, the City and County should use strategies such as reviewing zoning codes to ensure they include adequate land development regulations that eliminate unnecessary public hearings for affordable housing projects. Also, the City and County should encourage developers to meet with neighbors ahead of any public hearings to address questions and concerns about proposed developments. The City’s Office of Human Rights and the County’s Equal Opportunity Administrator Office will continue to offer technical assistance, workshops, and PSAs to educate the public on fair housing law.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

2 Increase the supply of Lack of affordable, Disability and Access City of Tampa affordable, accessible accessible housing in a housing in integrated range of unit sizes Disproportionate Housing Hillsborough settings for persons with Needs County disabilities including Lack of access to individuals who need opportunity due to Publicly Supported Tampa Housing supportive services high housing costs Housing Authority

Loss of affordable housing

Lack of assistance for housing accessibility modifications

Lack of affordable, integrated housing for individuals who need supportive services

Lack of affordable in- home or community based supportive services

Access to publicly supported housing for persons with disabilities

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Lack of assistance for transitioning from institutional settings to integrated housing

Private discrimination Metrics, Milestones, and Timeframe for Achievement: • Within 5 years, revise programmatic policies that limit eligibility of applicants for accessibility modification assistance in owner-occupied and rental housing.

• Within 5 years, direct the taskforce on accessible housing and supported living a to develop an action plan for meeting the unmet housing needs of persons with disabilities by reviewing the current support system, identifying needs for supported living services, reviewing current segregated populations, and resolving funding constraints.

• Within 5 years, develop and implement a public relations campaign with the purpose of removing barriers to accessible housing and making homes accessible for all residents with disabilities.

Discussion: Persons with disabilities represent 12.5% of the population in the City and 11.7% percent in the County. Persons with disabilities are often segregated or prevented from living in their community of choice because a great deal of housing is inaccessible, supportive services are not available, or because they experience a high rate of discrimination.

Goal #1, above, addressed the need to increase the supply of affordable housing throughout the City and the County in general. However, there is also a need to increase the number of units in those developments that are accessible. Publicly supported housing developments are already required to be physically accessible and programmatically accessible – subscribe to policies and procedures that increase housing options for persons with disabilities and their families such as special population preferences, waitlist procedures, and reasonable accommodation procedures. The City, County, and THA will continue to fund and develop housing projects that include accessible units and features, including permanent supportive housing.

To increase the number of accessible units for individuals with disabilities who require housing accessibility modifications to use and enjoy their dwelling, both the City and the County fund rehabilitation/barrier removal programs. These programs are limited to homeowners, and homeowners must have owned the homes for a minimum of two years to receive assistance. The City and County will explore revising the policies for these programs to address barriers that prevent otherwise eligible applicants from participating. Potential actions include reducing or eliminating the minimum time the applicant must own the home to receive assistance and making funds available for modifications to privately-owned rental housing. Landlords are required to permit reasonable modifications to a housing unit at the recipient’s expense, but where the cost of the modifications is prohibitive to the tenant, the City and County may provide assistance to make those units accessible to persons with disabilities and their families.

In addition to increasing the supply of affordable, accessible housing units, there needs to be increase in the provision of supportive services for persons with disabilities who are able to, and choose to live independently. There are several agencies that provide supportive services in the City and County. However, 9

the lead agency in Florida providing persons with disabilities with housing and supportive services, Florida Agency for Persons with Disabilities (ADP), has a statewide waiting list of over 20,000 individuals which affects persons with independent living difficulties in the City and the County. Medicaid is the main source of funding available to provide one-on-one care for persons outside of institutional settings and the deficient funding of Medicaid services has resulted in thousands of persons with disabilities who do not have the support needed to live in residential settings that is the least restrictive. To address this issue, the City and the County should assign a taskforce or committee to assess the need for supportive services. The taskforce should assess existing supportive housing programs, the cost of these services, and funding constraints. The City and County should develop a plan to assist individuals with disabilities with receiving community-based services, improve coordination between housing and disability service agencies, remove any programmatic barriers that prevent individuals with disabilities from accessing mainstream housing, and fund programs that help special needs populations meet their housing needs, such as tenant-based rental assistance programs and supportive housing.

Another barrier to persons with disabilities accessing affordable housing is discrimination. Housing discrimination cases based on disability accounted for a significant portion of the complaints investigated by the fair housing enforcement agencies in the City and the County. Even with training and guidance for the public, developers, and landlords, there is still overt discrimination against persons with disabilities or refusal to make reasonable accommodations or modifications. To address this, the City’s ADA Coordinator and Office of Human Rights, and the County’s Equal Opportunity Administrator’s Office will continue to educate the public on ADA and reasonable accommodation law.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

3 Increase access to Lack of local or regional Segregation/Integration City of Tampa opportunity for persons cooperation residing in R/ECAPs or low R/ECAPs Hillsborough opportunity areas Availability, type, County frequency, reliability of Disparities in Access to public transportation Opportunity Tampa Housing Authority Educational Disproportionate Housing Attainment Needs

Lack of private Publicly Supported investments in specific Housing neighborhoods

Lack of public resources for investment in specific neighborhoods, including services or amenities

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Metrics, Milestones, and Timeframe for Achievement: • Within 5 years, enhance coordination between local government agencies, Hillsborough County Public Schools (HCPS), Hillsborough Area Regional Transit Authority (HART), THA, and housing developers to ensure proper planning of growth areas to improve access to affordable housing, public transportation, and quality education.

• Within 5 years, increase access to transportation in rural and unincorporated Hillsborough County through enhanced coordination with HART in planning processes.

• Within 5 years, support education and employment training programs that are available to residents of low opportunity neighborhoods and provide employment, job readiness skills, job placement, and job counseling.

• Within 5 years, provide or support rental counseling programs that improve overall financial health of residents by improving financial literacy, credit standing, knowledge of tenant rights and affordable housing options, and money management skills to prevent delinquency or eviction.

Discussion: The City is heavily segregated by race and ethnicity and members of the protected classes have lower incomes, higher unemployment rates, and higher poverty rates. County residents face similar challenges but to a lesser extent than the residents of the City in some cases. Improving fair housing choice and reversing segregation are essential to creating access to opportunity for everyone because where a person lives determines one’s access to a range of opportunities and impacts life outcomes around education, employment, health, and wealth.

The involvement (input and cooperation) of governmental agencies, community and business organizations, and other non-governmental entities, can greatly assist in the elimination of fair housing impediments in areas such as sales and rental of housing, lending, employment, education, social services, and transportation.

Interdepartmental cooperation, communication, and coordination in planning and executing housing, transportation, education, and community services is key to transforming R/ECAPs and low-income areas into neighborhoods of opportunity with access to good schools, healthy foods, affordable and reliable transportation, and good jobs. The City and the County will work towards improving coordination of policies and procedures through existing boards and committees to remove barriers to accessing opportunity for members of the protected classes.

Transportation services are essential where employment opportunities are not located near lower-income housing and this AI shows the need to link job centers with lower income housing locations in the County. While HART has determined that it is fiscally unsound to provide service to rural parts of the County, the provision of public transportation services can improve access to jobs, training opportunities, and housing and community services for minorities, families with children, and persons with disabilities. As HART and other transportation agencies in the County consider options to make public transit more accessible to the broader area, the City and County housing departments should be involved in future transportation development and planning and prioritize linking job centers with lower income neighborhoods and with affordable housing developments. This includes, reaching out to education and transportation stakeholders during the development of Consolidated Plans and fair housing planning documents. 11

Given the educational attainment gap and relationship between racially concentrated areas of poverty and employment, minorities in the City and County experience higher unemployment rates than Whites. To address this, the City and the County will continue to fund public service and economic development activities and THA will continue to assist residents with identifying employment and training opportunities within the community. Potential public service activities that the City and County may fund include employment training to increase self-sufficiency, literacy, independent living skills, and job training; housing counseling for renters, homeowners, and/or potential homebuyers; assistance to microenterprises and for- profit businesses for job creation/retention; and capacity building for the non-profit organizations that will provide these services.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

4 Increase homeownership Lending discrimination Segregation/Integration City of Tampa opportunities and improve equal access to credit and Access to financial R/ECAPs Hillsborough financial services for services County minorities and low-and Disparities in Access to moderate-income persons Lack of private Opportunity Tampa Housing investments in specific Authority neighborhoods Disproportionate Housing Needs Impediments to mobility Metrics, Milestones, and Timeframe for Achievement: • Within 1 year, establish a community reinvestment review committee, made up of appropriate City and County government departments and community-based organizations in the community and economic development field, to conduct an assessment of lenders’ performance, analyze the degree to which lenders are meeting community needs, and monitor reinvestment needs and CRA performance.

• Over the next 5 years, conduct an annual assessment of lenders’ performance in the County/region.

• Over the next 5 years, hold an annual public forum, with community-based organizations and leading banks in the region, to discuss bank performance in the City and County.

• Over the next 5 years, continue to utilize federal and state resources for homebuyer education and downpayment assistance programs.

• Within 5 years, increase the number of THA residents purchasing homes in high opportunity neighborhoods by encouraging participation in the FSS Homeownership Program.

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Discussion: A review of HMDA data revealed that Black/African-American and Hispanic households in the County were denied home mortgage loans at a rate of 33.4% and 26.8% respectively, compared to a denial rate of 18.8% for Whites. Additionally, an analysis of bank branch locations coupled with input from the community, showed gaps in banking and financial services in minority areas. Racial and ethnic disparities in access to credit perpetuate racial segregation and limit access to opportunity and homeownership.

The goal is to improve conventional lending and banking service in neighborhoods that are underserved, especially for Blacks/African-Americans and Hispanics, by strengthening agreements with banks and other lending institutions subject to CRA. By taking the proposed actions, the City and County will ensure that private investments are expanded in low-and moderate-income areas. Equal access to credit will also stimulate economic growth.

The City and County will conduct meetings with the leading banks, financial regulators, community-based organizations, and other relevant stakeholders to present findings of lenders’ performance and encourage them to establish policies and guidelines to ensure fair lending practices. Specifically, the committee will review mortgage and small business lending, community development lending and investments, services such as branch locations and staffing, and philanthropic commitments. This can be accomplished at the annual regional Fair Housing Symposium held during Fair Housing month (April) which the City and County are partners in planning. This convening may also involve discussions about the intersection of community development with other topics such as health, transportation, aging in community, and workforce development.

In addition to engaging financial institutions to increase home purchase loans to LMI households, the City and the County will continue to provide homebuyer education, fair housing workshops, and downpayment assistance programs. THA can collaborate with the City and County using existing purchase assistance programs to increase the homeownership rate of THA residents.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

5 Increase awareness of Lack of awareness Fair Housing Enforcement, City of Tampa Federal, state, and local fair about fair housing laws Outreach Capacity, and housing laws and practices and enforcement Resources Hillsborough programs County Publicly Supported Admissions and Housing Tampa Housing occupancy policies and Authority procedures, including preferences in publicly supported housing

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Metrics, Milestones, and Timeframe for Achievement: • Within 1 year, review existing fair housing outreach and education efforts and ensure materials include new HUD guidance and rules on criminal background checks, victims of domestic violence and sexual assault, gender identity, and NIMBY concerns related to fair housing.

• Over the next 5 years, conduct an annual forum to educate landlords and lenders on various sources of income and programs for affordable housing to ease landlord and lender concerns related to source of income.

• Over the next 5 years, continue to implement fair housing awareness programs on an on-going basis in both the City and the County and participate in regular education and outreach efforts by providing training /workshops on fair housing-related topics.

• Within 1 year, THA will post information and include information in all relevant documents on how residents can file housing discrimination cases locally.

Discussion: There is a lack of understanding by the public about the role housing discrimination plays in the inequalities that are evident in the City and County as well as a lack of awareness of how to overcome discriminatory practices.

Private fair housing organizations and government agencies and programs make up the framework that tackle housing discrimination and the City and County. Both the City and County will continue to provide public education regarding the protection under local and federal fair housing laws. This will involve the development of new material for outreach and education, and information programs and activities in collaboration with other fair housing organizations in the region on new protections and changes/clarification in HUD policy.

THA staff and housing counselors will continue to attend periodic fair housing training to stay informed of current policies. Additionally, THA will assess and disclose any fair housing complaints involving the housing authority and assess the effectiveness of new or revised procedures on how public housing residents can make fair housing complaints to the City, County, or local fair housing organizations.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

6 Increase potential for Lack of state or local Segregation/Integration City of Tampa minorities, persons with fair housing laws disabilities, and other R/ECAPs Hillsborough protected groups to move Private discrimination County to areas of high opportunity Disparities in Access to Source of income Opportunity Tampa Housing discrimination Authority Disproportionate Housing Impediments to Needs mobility 14

Publicly Supported Housing

Fair Housing Enforcement, Outreach Capacity, and Resources

Metrics, Milestones, and Timeframe for Achievement: • Within 1 year, propose a local fair housing ordinance to prohibit discrimination based on source of income to improve access to opportunity for voucher holders.

• Within 5 years, THA will enhance its mobility counseling program, to include support for Section 8 voucher holders as well as participants in the FSS Homeownership Program.

Discussion: The disproportionate representation of protected classes in public housing and the Section 8 HCV program indicate a lack of affordable housing options for these households in the private sector as well as private discrimination. There is a reluctance by landlords to rent to persons utilizing housing vouchers in the City and County. This discrimination keeps minority households within R/ECAPs thereby intensifying racial segregation and limiting access to opportunity.

Currently, source of income is not protected under federal or local fair housing law. Local fair housing agencies have only been able to pursue these discrimination cases based on race/ethnicity because of the demographic composition of participants in the HCV program. However, by amending the local fair housing ordinances to prohibit housing discrimination based on source of income, it will be unlawful to refuse to rent based on a household’s source of income including housing choice vouchers, disability payments, and other public subsidies. Once adopted, the City, County, and THA should educate voucher holders about source of income protections and provide them with accurate information about what to do it they experience it.

THA will continue to follow its deconcentrating policy and work towards removing other impediments to mobility. THA’s mobility counseling program seeks to increase the housing choice of Section 8 voucher holders by assisting voucher holders to find suitable rental units throughout the City and County and extending the lease up period allowed to voucher holders that have encountered difficulty finding an available unit, due to low vacancy rates or discrimination, to prevent voucher holders from losing their vouchers. THA will also enhance the mobility counseling program to provide assistance to public housing residents and voucher holders who experience discrimination when attempting to purchase a home. THA will collaborate with the City, County, and member banks to support the FSS program.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

7 Increase public investment Lack of private Segregation/Integration City of Tampa and encourage private investments in specific investment to address neighborhoods R/ECAPs

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disparities in housing, Lack of public Disparities in Access to Hillsborough proficient schools, resources for Opportunity County employment opportunities, investment in specific and services neighborhoods, Disproportionate Housing Tampa Housing including services and Needs Authority amenities Publicly Supported Housing

Metrics, Milestones, and Timeframe for Achievement: • Over the next 5 years, develop/review community redevelopment plans for neighborhoods in R/ECAPs to coordinate investments in the area and attract private investment, strengthen educational attainment, emphasize economic development, and financial institution engagement.

• Over the next 5 years, continue to allocate CDBG funding for public facilities and infrastructure improvements, economic development, and public services in R/ECAPs and low-income areas. Discussion: In order to revitalize neighborhoods and attract private invest, the City and County must develop a comprehensive redevelopment strategy that promotes coordination and cooperation among the public and private sectors in carrying out housing and community development activities. This includes Consolidated Planning, Comprehensive Planning, neighborhood planning documents, and plans for other types of place- based investment strategies or programs. Without sufficient public and private investment in declining and deteriorated neighborhoods, residential areas decline rapidly and small, neighborhood businesses also suffer. The lack of investment means the absence of jobs, inadequate schools and services, and limited opportunity.

Federal and state programs, including CDBG, can be used for a broad range of community development programs and HOME funds can be used towards to the provision of affordable housing. However, one of the most important factors in addressing distressed communities is the presence of residential and commercial investment by banks and other financial institutions in low-income and minority neighborhoods. The City and County can also offer incentives for housing developers, businesses, investors, and other interested entities to assist in the revitalization effort.

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II. Community Participation Process 1. Describe outreach activities undertaken to encourage and broaden meaningful community participation in the AI process, including the types of outreach activities and dates of public hearings or meetings. Identify media outlets used and include a description of efforts made to reach the public, including those representing populations that are typically underrepresented in the planning process such as persons who reside in areas identified as R/ECAPs, persons who are limited English proficient (LEP), and persons with disabilities. Briefly explain how these communications were designed to reach the broadest audience possible. For PHAs, identify your meetings with the Resident Advisory Board and other resident outreach.

The City, County and THA made every effort possible to facilitate a robust and meaningful community participation process during the development of the AI. The three program participants implemented a comprehensive and all- inclusive public participation strategy. This strategy incorporated community and stakeholder outreach, publications in newspapers of general circulation, website and social media announcements, press releases, and extensive outreach to key committees and other stakeholders identified as being critical partners in the development of the AI.

Outreach Activities

Public Meetings The City and County each held a total of four public meetings located throughout their jurisdictions. Each of these meetings was held in a different part of the City or County, to ensure residents across the area had the opportunity to attend a nearby meeting. Resident meetings were held in the evenings, after normal business hours, to provide an opportunity for interested members of the community to attend. A list of the public meetings, locations, target residents, and dates and times are presented in Tables 1 and 2.

Table 1: City of Tampa Public Meetings City of Tampa Public Meetings # Location Target Date Time Attendee residents Count 1 Library West Tampa 9/26/16 6:00 PM 3 2 United Methodist 9/27/16 6:00 PM 0 Church 3 University Area Community 9/28/16 6:00 PM 11 Development Corporation1 4 Cyrus Greene Community 9/29/16 6:00 PM 3 Center

1 The University Area Community Development Corporation community meeting was a joint meeting of the City of Tampa and Hillsborough County.

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Table 2: Hillsborough County Public Meetings Hillsborough County Public Meetings # Location Target residents Date Time Attendee Count 1 Town & Country Town N Country 9/26/16 6:00 PM 4 Regional Public Library 2 Bruton Memorial Plant City 9/27/16 6:00 PM 1 Library 3 Hillsborough County Ruskin 9/29/16 6:00 PM 7 Southshore Community Resource Center 4 Wimauma Bethel South County 12/8/16 6:00 PM 20 Campus, Women’s Opportunity Center

While involved in the City and County’s community participation process, THA made additional outreach efforts as it pertains to public housing residents.

THA engaged with its Resident Advisory Council on two separate occasions, one in August 2016 and a second in October 2016. During these meetings, presentations were made on the fair housing planning process. The presentations provided an overview of the fair housing issues to be analyzed, instructed the audience on the HUD-provided data tables and maps, discussed initial findings, and ensured all in attendance knew how to be involved in the process going forward. Table 3 provides the locations, dates, and times of the meetings.

Table 3: Tampa Housing Authority Resident Advisory Council Meetings Tampa Housing Authority Resident Advisory Council Meetings # Type Location Date Time 1 Resident Council 8220 N Florida Avenue, 8/31/16 10:00 AM Elected Leaders Tampa FL 2 Resident Council Moses White Estates 10/18/16 10:00 AM Elected Leaders Tampa, FL

THA also hosted two resident public meetings to discuss the AI process and the draft analysis in January 2017. Both public meetings were held at the public housing site, the next development slated for conversion under Rental Assistance Demonstration (RAD) as part of THA’s visioning plan. As shown in Table 4, the meetings were held at separate times, one during the afternoon and one in the evening, to accommodate resident schedules and ensure residents had the best opportunity to attend.

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Table 4: Tampa Housing Authority Resident Meetings Tampa Housing Authority Resident Meetings # Type Location Date Time Attendee Count 1 Resident Robles Park 1/19/17 2:00 PM 14 Outreach 2 Resident Robles Park 1/19/17 5:00 PM 18 Outreach

Stakeholder Consultation Participants reached out to a broad range of stakeholders with unique perspectives on fair housing issues in the region. Stakeholder interviews were conducted with various housing and community revitalization organizations with the intent to gather specific input on fair housing barriers. Further, participants conducted outreach to non-housing organizations and key partners to ensure depth and thoroughness of the stakeholder outreach process.

Stakeholders were identified by their expertise in topics related to the fair housing issues, and participants either e-mailed or called each stakeholder directly to solicit their views and recommendations. Additionally, each stakeholder was encouraged to attend a stakeholder meeting.

The City and County conducted two stakeholder meetings on Wednesday, September 28, 2016. Invitations were sent through EventBrite, a free event registration service. The first stakeholder meeting targeted social service agencies serving residents of the City and County and the second stakeholder meeting was geared towards real estate professionals, lenders, property managers, and landlords. Table 5 summarizes the dates, times and locations, and attendee count for the two stakeholder meetings.

Table 5: City of Tampa and Hillsborough County Stakeholder Meetings City of Tampa & Hillsborough County Stakeholder Meetings # Location Date Time Attendee Count 1 The Children’s Board – 1002 East Palm 9/28/16 10am – 12pm 33 Avenue, Tampa FL 33605 2 CareerSource – 9215 North 9/28/16 2pm – 4pm 5 Florida Avenue, #101 Tampa FL 33612

Community/Committee meetings The City contacted City agency leads responsible for coordinating communication with each of the City’s CRA committees. These agency leads were informed of the AI process, the dates, times and locations of public meetings and public hearings, the web-based survey for collecting input on fair housing issues, and were informed of the online HUD data and mapping tool. In addition to this outreach, the community

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meetings held by the City were located in venues adjacent to or nearby CRA boundaries in the City, to enable residents of the CRA communities to participate in the meetings.

Further outreach to key stakeholders with both the City and County included presentations and discussion with the City’s AHAC and the County’s AHAB. Table 6 provides details on both meetings.

Table 6: City of Tampa and Hillsborough County AHAC/AHAB Meetings City of Tampa & Hillsborough County AHAB/AHAC Meetings # Location Date Time Attendee Count 1 City of Tampa, Affordable Housing 10/13/16 9:00 am 13 Advisory Committee (AHAC) 306 East Jackson Street, Tampa, FL 33602 2 Hillsborough County, Affordable Housing 12/5/16 9:00 am 10 Advisory Board (AHAB) 601 East Kennedy Blvd, Tampa FL 33602

Web-Based and paper-based Surveys A survey was developed in an online, web-based format through SurveyMonkey, to solicit input on possible fair housing issues in the region. The survey provided an additional opportunity for interested parties to participate in the development of the AI if they were unable to attend the public meetings and public hearings.

The survey included questions specific to a variety of respondents, including residents, real estate professionals, lenders/mortgage bankers, landlords, and social service providers. The resident survey was available in English and Spanish. Participants also made paper-based surveys available for persons that do not have access to a computer. Paper-based surveys were distributed at the public meetings, community events, workshops, and at THA offices.

Residents and interested parties were notified of the survey via public notices, press releases, social media, and through direct solicitation based on contact lists provided by the City, County, and THA. Outreach efforts for encouraging responses to the survey were successful, resulting in 811 responses, including 14 responses to the Spanish survey.

Community Events Representatives from the City, County and THA hosted a fair housing tent on January 21 and 22, 2017 during the Black Heritage Festival in Tampa. Representatives were on hand to answer any questions about fair housing, distribute flyers on fair housing rights and anti-discrimination legislation, help festival attendees complete the fair housing survey, and otherwise raise awareness of fair housing rights and the development of the AI.

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Government Departments and Boards/Commissions Participants reached out to representatives from key government boards, commissions and departments and solicited input on fair housing issues in the region.

Public Hearings In addition to the public meetings to discuss the AI process, the program participants held public hearings to discuss the proposed AI.

Media Outlets

Participants used traditional media and internet-based media to reach diverse audiences and encourage wide-ranging community participation.

Advertisements in Newspapers of General Circulation The City and County provided notice of the public meetings and public hearings in local and regional newspapers of general circulation as identified below: • Tampa Tribune (Tampa/Hillsborough County) • La Gaceta Newspaper (Tampa/ Hillsborough County) • CentroTampa (Tampa/Hillsborough County) • Florida Sentinel Bulletin (Hillsborough County)

Website Notices The City, County, and THA posted announcements for public meetings on their respective websites. Announcements were posted prior to scheduled public meetings ensuring reasonable notice to the public.

Posted in Public Spaces – Libraries, Government Offices, THA Corporate Office The City, County, and THA made copies of the draft AI available during the public comment period in public spaces, including libraries and government offices, and at the THA Corporate Office. Additionally, participants made final versions of the document available at the same public spaces. Table 7 provides details on the locations where the AI was displayed.

Table 7: City of Tampa, Hillsborough County, and THA AI Public Display Locations City of Tampa, Hillsborough County, and THA AI Public Display Locations City of Tampa Location Location Type Address Housing and Community Government 306 East Jackson Street, 3rd Floor, Tampa Development Office FL, 33602 City Clerk’s Office Government City Hall, Third Floor, 313 East Kennedy Office Blvd, Tampa FL 33602 Robert Saunders Library Library 1505 North Nebraska Avenue, Tampa FL, 33602

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City of Tampa, Hillsborough County, and THA AI Public Display Locations Hillsborough County Hillsborough County AHS Government 601 East Kennedy Blvd, Tampa FL 33602, Office 24th Floor 78th street Community Library 7625 Palm River Road, Tampa FL 33619 Library Jimmy B. Keel Library Library 2902 West Bearss Ave, Tampa FL 33618 Ruskin Library Library 1 Dickman Drive SE, Ruskin, FL 33570 Bruton Memorial Library Library 302 McLendon Street, Plant City, FL 33563 University Area Community Community 14013 22nd Street Tampa, FL 33613 Center Center Tampa Housing Authority Corporate Office Government 5301 West Cypress Street, Tampa FL Office 33607

Social Media Announcements Both the City and County used its respective social media outlets to advertise the AI and the public meetings for comment. These announcements were made throughout the week leading up to the community meetings, for the web-based survey, and prior to public hearings.

Email Announcements The County maintains an interested parties list of contacts for individuals/agencies that have indicated interest in announcements from the Affordable Housing Services Department. Individuals/agencies on this list were contacted and provided notice of public meetings related to the AI. The City also emailed notice of the public meetings and the survey to its contacts.

Radio Announcement To broaden its outreach to the Hispanic community, County staff facilitated a public service announcement on a local Spanish radio station. The announcement, made on WQBN radio on December 5, 2016 at 4:15pm, provided listeners with an overview of the fair housing planning process and gave details on a Wimauma community meeting that was held on December 8, 2016.

Public Signage County staff placed public notice boards in public spaces and near public facilities throughout the region. These boards advertised public meeting times and locations throughout the County.

Written Invitations to all Resident Council Leaders THA staff ensured all Resident Advisory Council leaders were aware of meetings to discuss the AI process, the draft AI, and all public meetings specific to the AI. THA staff delivered both e-mail and written notifications by U.S. mail to all council leaders to ensure each community leader was aware of these meetings.

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Efforts to Reach Underrepresented Populations

Persons residing in R/ECAPs Recognizing the critical importance of reaching out to residents and community members living within the racially and ethnically concentrated areas of poverty (R/ECAPs) across the region, every effort was made to engage with these residents. Program participants hosted community meetings in targeted neighborhoods nearby or adjacent to the R/ECAPs. Additionally, THA encouraged active resident meetings, particularly by hosting informational meetings at the Robles Park public housing site which is located in a R/ECAP.

Persons with Limited English Proficiency The City, County, and THA took every opportunity to meet the needs of persons with limited English proficiency. During community meetings, the City provided sign language interpreters to assist an individual who requested the service. The City also provided translation services at several of the community meetings, in the event that an individual with limited English proficiency attended. For County meetings, no individual officially requested translation services prior to, or during community meetings. However, if requested, the Office of the County Administrator would have made reasonable efforts to ensure that the public meetings and outreach activities were meaningfully accessible to those who do not speak English proficiently.

In addition to services offered at the community meetings, the participants also developed a Spanish language version of the online web-based survey. A link to this version of the survey was included in all public notices, in materials distributed during the community meetings, and advertised in newspapers of general circulation.

Persons with Disabilities All meetings were held in physically accessible locations and upon request, auxiliary aids and services were available in order to effectively communicate with individuals with disabilities.

2. Provide a list of organizations consulted during the community participation process.

Program participants contacted nearly 2,000 individuals and organizations in the region and invited those individuals to attend two stakeholder meetings. These invitations included a brief description of the fair housing planning process, a link to both the English and Spanish language surveys, and included locations, dates and times of the community meetings held across the region. In addition to the broad outreach described above, program participants also consulted directly with the organizations shown in Table 8.

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Table 8: Agency Consultation List Agency Consultation List

Organization Type Agency for Community Treatment Services (ACTS) Health Service Providers Alpha House of Tampa Social Service Agencies APD Suncoast Field Office Assisted Housing Providers Bay Area Apartment Association Assisted Housing Providers Bay Area Legal Services Fair Housing Organizations Bay Area Regional Veterans Network Social Service Agencies Baycare Behavioral Health Inc Social Service Agencies BET Investments (property mgmt.) Other Boley Centers Assisted Housing Providers CAIR Florida Fair Housing Organizations CAPREIT Other Catholic Charities Social Service Agencies CDC of Tampa Assisted Housing Providers Champions for Children Social Service Agencies Children's Board of Hillsborough County Social Service Agencies City of Tampa Community Partnerships & Neighborhood Regional/Local Government Engagement Agency City of Tampa Housing and Community Development Regional/Local Government Agency Crisis Center of Tampa Bay Social Service Agencies CrossRoads of Tampa Assisted Housing Providers DACCO Health Service Providers Disability Rights Social Service Agencies CRA Community & Regionally Based Agencies East Tampa Business and Civic Association Community & Regionally Based Agencies East Tampa CRA Community & Regionally Based Agencies Eckerd Social Service Agencies Feeding America Social Service Agencies First Steps Forward Social Service Agencies Florida Homes Partnership Other Florida Human Relations Commission Fair Housing Organizations Francis House Social Service Agencies Greater Tampa Realtors Association Other GTE Financial Other Habitat for Humanity of Hillsborough County Assisted Housing Providers 24

Agency Consultation List

Hillsborough Area Regional Transit Authority (HART) Regional/Local Government Agency Hillsborough County Affordable Housing Services Regional/Local Government Agency Hillsborough County Equal Opportunity Administrator's Office Fair Housing Organizations Hillsborough County Homeless Services Adjacent Local Governments Hillsborough County Public Schools Adjacent Local Governments Hillsborough County Sheriff's Office Adjacent Local Governments Hillsborough Education Alliance for Citizens with Disabilities Other Hillsborough Parks, Recreation and Conservation Department Adjacent Local Governments Hispanic Professional Women Social Service Agencies Hispanic Service Council Social Service Agencies Homeless Helping Homeless Assisted Housing Providers Housing and Education Alliance Assisted Housing Providers HUD FHEO Fair Housing Organizations Invictus Development Assisted Housing Providers JP Morgan Chase Other Mary and Martha House Social Service Agencies Mayor's Alliance for Persons with Disabilities Community & Regionally Based Agencies Mayor's Hispanic Advisory Council Other Metropolitan Ministries Social Service Agencies Miracles Outreach Social Service Agencies NAACP Fair Housing Organizations National Association of Hispanic Realtors Other New Beginnings Assisted Housing Providers Pasco County Housing Authority Public Housing Authorities Plan Hillsborough Regional/Local Government Agency Plant City Advisory Council Adjacent Local Governments Plant City Housing Authority Public Housing Authorities Project LINK Social Service Agencies Project Return Assisted Housing Providers Rebuilding Together Tampa Bay Community & Regionally Based Agencies

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Agency Consultation List

ROOF Community & Regionally Based Agencies Safe & Sound Community & Regionally Based Agencies Safe and Sound Hillsborough Social Service Agencies Salvation Army Social Service Agencies Self-Reliance Assisted Housing Providers Sky Internal Realty Other Society of St. Vincent de Paul Social Service Agencies State Advisory Council - Veteran Peer Representative Jail Regional/Local Government Diversion Trauma Related OEF/OIF Agency Neighborhood of Promise Community & Regionally Based Agencies Sunrise Community Other Tampa Bay Youth Outreach Social Service Agencies Tampa Family Medical Center (Medical Data) Social Service Agencies Tampa Hillsborough Homeless Initiative Continuum of Care Tampa Housing Authority Public Housing Authorities Tampa Housing Authority Program and Property Services Public Housing Authorities Tampa Housing Authority/Assisted Housing Public Housing Authorities Tampa Housing Authority/Public Housing Public Housing Authorities Tampa Lighthouse for the Blind Assisted Housing Providers Tampa Office of Human Rights Fair Housing Organizations Tampa Police Department Regional/Local Government Agency The Center for Women Social Service Agencies The Children's Home Social Service Agencies The Spring Assisted Housing Providers Third Federal Other U.S. Department of Justice Fair Housing Organizations United for Human Rights Fair Housing Organizations University Area CDC Social Service Agencies Veteran's Affairs Health Service Providers Veteran's Hospital Health Service Providers Wells Fargo Other West Coast AIDS Foundation Social Service Agencies West Tampa CRA Community & Regionally Based Agencies Wimauma Community Development Corp. Community & Regionally Based Agencies

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3. Describe whether the outreach activities elicited broad community participation during the development of the AI. If there was low participation, or low participation among particular protected class groups, what additional steps might improve or increase community participation in the future, including overall participation or among specific protected class groups?

Efforts at eliciting meaningful community participation were largely successful, particularly in terms of survey responses and the involvement of social service providers and other stakeholders. Social service agencies were open to discussing fair housing issues, were actively engaged in the participation process and were eager to respond to the online survey. The stakeholder meetings in particular, where social service agencies were invited to provide specific input on their perspectives on fair housing choice, were well attended.

To generate interest in the stakeholder meetings, program participants delivered over 2,000 email invitations to a wide range of individuals and organizations in the region. This email invitation not only informed each recipient of the stakeholder meeting location, dates and times, but also provided a link to the online survey and provided some background on the fair housing planning process itself. This mass public awareness campaign contributed to active engagement and awareness of the AI process.

In addition to public notices posted in local newspapers, including Spanish language newspapers, wider circulation newspapers like the Tampa Bay Times wrote articles mentioning the AI process and community meeting locations and dates.

Additional steps could be taken to enhance community participation, particularly in the City and County R/ECAPs. Recommended additional steps, for future fair housing plans, could include outreach to specific neighborhood or community groups well in advance of public meetings. This outreach would facilitate a trusted partner dialogue between community groups and residents of hard-to-reach communities.

4. Summarize all comments obtained in the community participation process. Include a summary of any comments or views not accepted and the reasons why.

Fair Housing Survey: Summary of comments The participants conducted a fair housing survey targeted to residents, real estate professionals, lenders/mortgage bankers, landlords, and social service providers. Survey respondents raised many issues, including a severe lack of affordable housing and tenant screening policies as barriers to fair housing choice. Responses from housing and service professionals also provided insight on public and private-sector practices that promote or hinder fair housing choice in the City and the County. Highlights from the survey responses are listed below and a more detailed summary of the survey results is included as Appendix D.

• Most residents feel they are aware of their fair housing rights and have not experienced housing discrimination. However, a significant minority are unsure of their rights, have experienced discrimination, or feel that their choices of neighborhoods to live in is limited by their income or race. Residents who experience housing discrimination rarely report it.

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• When residents were asked which neighborhoods have concentrations of affordable housing or are undesirable, many of the same neighborhoods were mentioned repeatedly. Many of these neighborhoods are segregated and have high poverty rates.

• Private-sector housing professionals, including mortgage lenders and brokers, real estate professionals, and landlords and property managers, often consider themselves to be “Very Knowledgeable” or “Somewhat Knowledgeable” of fair housing laws and have access to fair housing training. Additionally, they collectively employ several practices that promote fair housing choice, including hiring bilingual individuals and advertising or conducting business in low-income and minority neighborhoods.

• Respondents from various public, private, and nonprofit housing and service industries have varying opinions about which factors constitute serious or moderate barriers to fair housing choice. Public and nonprofit housing and service providers were more likely than private-sector housing professionals to perceive barriers in the mortgage lending, real estate, and rental housing industries. However, housing and service professionals from all sectors widely agree that personal factors such as insufficient income and inadequate credit scores constitute a serious fair housing barrier.

• Small landlords and property managers (those who own or manage 10 or fewer units) tend to be less knowledgeable of fair housing laws and less likely to think that adequate fair housing information and training is available, compared to landlords and property managers who own or manage more than 75 units. Similarly, public and nonprofit social service providers are less knowledgeable about fair housing laws and less satisfied with available fair housing training.

Public meetings/Stakeholder meetings: Summary of comments

Affordable Housing • Limited supply of affordable housing not meeting demand and rising housing costs for rent. • There isn’t enough funding for affordable housing in rural areas, particularly for fast-growing communities, like Wimauma. • There are chronic quality concerns with housing that is affordable to residents in Wimauma. This affordable housing stock is affordable for a reason, often due to conditions in the unit or home. • There is significant demand for rental construction in South County and in Wimauma. Most housing being constructed is single-family homeownership on large lots. • Transitional housing programs for homeless persons have been defunded by HUD so there are fewer options for housing especially if the individual/family does not fit into a targeted subpopulation. • Need rapid rehousing programs for young adults (18-22 years) aging out of foster care and who are not self-sufficient. • Low income homebuyers do not want to live in LMI areas where housing may be poorly maintained, and the neighborhood conditions are substandard. However, developers have more access to funding to build in LMI areas.

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• When real estate professionals provide listings to a homebuyer in an area where they can afford, they do not want to live in those areas. • The inflation of rents at the time of lease renewal, by as much as $200-$300 by month, makes housing unaffordable. • Affordable housing is located in zip codes 33612, 33613, and 33610 i.e., the areas where people do not want to live because there is no access to quality childcare, poor performing schools, and high crime rate. • The affordable housing available in the region is substandard. • Tenants are afraid of reporting issues to code enforcement for fear of retaliation. • Zoning is restrictive and does not allow accessory dwelling units (ADU’s) in certain neighborhoods. • Zoning is a barrier for Low Income Housing Tax Credits (LIHTC) projects because funding is being allocated for projects located in areas of opportunity but the land in these areas are not zoned properly and a request for a zoning change is often met with opposition from neighbors. • Not enough funding for rental assistance for persons with disabilities. • Historic preservation/local historic districts impact the cost of housing development and makes housing unaffordable. • Lot size requirements - 5 acres/du – affects minorities and low-income persons that work in the Keystone area from purchasing/building homes in that area and they are forced to travel to the urban core to find affordable housing. • Lack of infrastructure (water/sewer lines) in parts of the County drive up the cost of housing development. • There is not enough land in the University Area for the development of single-family homes so homeownership levels are low. • Presence of lead-based paint in older housing stock. • Families are electing to double up to make ends meet. Overcrowding has become a concern in Wimauma. • There is a rapidly growing senior population, with very few housing options for those people. • Residents expressed a desire for more flexible design and zoning standards for the County, to encourage things like ADUs. • Residents mentioned application fees for applying for a housing unit. These fees are prohibitively expensive for low-income families. Some fees range as high as $100, just to be ultimately denied. • Residents stated that landlords do not publicize credit requirement thresholds. If these were publicized, they could save significant application costs by simply turning to a different apartment.

Public Housing and Housing Vouchers • Landlords are reluctant to participate in Section 8 Housing Choice Voucher program. They feel that a voucher recipient will damage their property. • THA waiting list has been closed since 2006 and has over 30,000 applicants on the waitlist. • THA has issues with the landlords enforcing the lease. Some landlords expect THA to play a larger role, other than making the payment on behalf of the tenant.

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• THA revised their criminal background screening policy from 5 years to 3 years. • Families are not taking advantage of the Family Self-Sufficiency Program and there are not that many lenders that want to accept vouchers because funds do not go directly to the lender to pay the mortgage. • Residents have trouble getting in contact with Plant City Housing Authority staff regarding status of application for housing assistance.

Tenant Screening • Leasing requirements are more stringent in this area compared to other places. • It is impossible to get into housing if someone has a criminal background. • A real estate agent stated that a landlord changed their guidelines on how far back they could do a criminal background check and a tenant was forced to move because of their criminal record. • LIHTC/publicly assisted housing developments are not accepting tenants based on their criminal backgrounds so it’s not surprising that private landlords are screening out tenants for criminal history as well. • The number of Syrian and Iraqi refugees are increasing especially in the University Area and they have a difficult time accessing housing because of limited or no income. Additionally, landlords inquire about where the applicants are from as part of their screening process. • Rental history/eviction is preventing tenants from accessing housing. • Landlords are subscribing to the ‘On-site’ tenant screening program and this can prevent tenants from renting because of their rental history.

Transportation

• Public transportation ends in the University Area and there is no public transportation into . This cuts off the Outlet Mall and other job opportunities in that area. • Housing choice is limited by access to transportation especially at late hours. If someone works the 3rd shift, they cannot get public transportation. • Reliable public transportation is not available in South Tampa. • People are reluctant to move to the suburbs because of lack of public transportation and school transportation. Schools are further away from housing in the suburbs and the neighborhoods are not walkable. The school district is stopping busing if children live within 2 miles of their school. • The cost of public and private transportation reduces the amount of income a household has available to cover their housing expenses. • There are limited transportation options for persons with disabilities. • Public housing residents need access to good quality, reliable public transportation, especially for those with a disability. • There need to be vouchers for public transportation made available to low-income families, because they are the ones who most need access to public transportation to get to jobs and services.

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Employment • It is difficult to locate and keep a job that pays enough to afford housing in the area. • Residents must leave their neighborhood to get decent paying jobs. • There is a lack of resources and activities (educational and vocational programs) in areas with concentration of affordable housing.

Childcare • The lack of affordable, quality childcare can prevent a person from being able to work or maintain employment. Often time people become or return to homelessness because they do not have reliable childcare. • There is a lot of funding for housing but no funding for childcare. • THA residents expressed frustration with access to quality child care services, particularly within walking distance and with hours reasonable for working adults.

Persons with Disabilities • Persons with disabilities cannot find affordable and accessible places to live and end up renting a room from a private landlord who is not required to make reasonable modifications. • Funding for ramps or accessible renovations is only available to homeowners.

Access to proficient schools • School buses not available to get children to school because the school district is stopping busing if children live within 2 miles of their school. • Schools in areas of opportunity are setup for more affluent families and they are harder to get into and more expensive because they require participation in more programs. • Need more afterschool programs because parents are not available to help their children with homework if they are working 3rd shift or multiple jobs. • The schools accessible to residents of Robles Park are of poor quality, and children suffer from discrimination daily. • Low literacy rates, low education levels, and absence of life skills is a fair housing issue.

Fair Housing Enforcement • Residents are not aware of the fair housing laws and how to report potential housing discrimination. • There is a perception that the City is biased in its investigation of potential housing discrimination cases at THA properties. • HUD’s continued funding of CPD programs and other federal programs even when the fair housing goals from previous AIs are not being achieved and communities are not AFFH has led to blight and displacement of residents in the area. • Criminal background checks are a recurring and insistent challenge for minorities in Wimauma and South County communities.

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• THA residents expressed concerns about repeated familial discrimination by private landlords. • THA residents noted that while fair housing training sessions are made available to them, they are often located far away from their apartments, or timed in the middle of the day when they are working or have other obligations.

Crime • THA residents expressed serious concerns related to crime in their neighborhood and especially in and around the Robles Park site. Residents are afraid to report criminal activity to the police for fear of retribution from gangs and violent neighbors.

Other • Veterans are having to relocate because of squatter’s rights. They invite friends who are homeless to visit their homes and although these persons are not on the lease, they refuse to leave and often time there is no recourse except for the tenant to move. • Veterans prefer to stay close to the VA, zip code 33612, because other veterans live there, and they feel connected and understood and because there is public transportation to the VA. • Inability of LMI persons to access affordable healthcare impacts credit scores and is related to accessing areas of opportunity.

Stakeholder Interviews: Summary of comments

Affordable Housing • Need more affordable housing to be built in areas near transit and in more affluent areas. NIMBYism is a problem with building affordable housing in affluent areas. • The low vacancy rate in existing rental housing allows landlords to use strict criteria, such as extensive credit and criminal background checks to turn applicants away. • Predominantly Black/African-American women with children are turned down for failing the credit check at apartments. They are not told what the criteria is before they pay a non-refundable application fee and the reason for rejection is not put in writing. • New affordable units are being constructed on the outskirts of the City and transportation becomes an issue. • New development and redevelopment projects, especially in desirable locations downtown, does not include affordable housing. • Lack of utilities and infrastructure in rural areas is a barrier to housing development.

Transportation • Public transportation provided by HART is inadequate to serve the very large county. The effort to raise taxes to fund transportation failed at the polls.

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Fair Housing Enforcement • Bay Area Legal Services is understaffed and apartment seekers trying to file a housing discrimination complaint are told to contact HUD and that there is no local HUD office. Tenants do not know where to file a complaint. • Property managers have not changed their policies about criminal background checks. They are going back three years instead of longer but are not accepting residents with a criminal background that is less than three years old regardless of type of crime.

Public Housing and Housing Vouchers • Veterans with VASH vouchers are turned down by reluctant landlords who prefer tenants that are not using housing vouchers. Landlords are afraid veterans may suffer from PTSD and they are turning away persons with disabilities. Approximately 30% of all the available units refused to accept VASH. • Residents are unable to find property owners willing to accept Section 8 housing choice vouchers or other rent assisted tenants. • THA has increased the time HCV holders have to locate a unit from 45 days to 180 days. Part of the issue is low vacancy rates and high rents and the other issue is discrimination or tenant screening policies. • The mixed-income communities that are replacing former public housing developments are not taking the tenants back that once lived there because those same tenants cannot pass the strict screening used by the redeveloped project. Redevelopment is forcing low-income, minority communities away from neighborhoods with access to transit into more rural areas.

Persons with Disabilities • Financial assistance is not available through the City or County for rehabilitation of manufactured housing.

Comments not accepted A participant at one of the community meetings stated that transportation to Brandon, South County, or east of Brandon does not exist. While residents may want to live in these areas, they are unable to travel to where the jobs are located. Concerns were expressed about rapid growth in South County, particularly the Wimauma area, and a lack of transportation options in response to that growth. This comment was not accepted because HART does provide some limited service to rural areas of the County. For instance, there is an express bus with limited service to Dover, Wimauma, and Bloomingdale.

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III. Assessment of Past Goals, Actions and Strategies

1. Indicate what fair housing goals were selected by program participant(s) in recent Analyses of Impediments, Assessments of Fair Housing, or other relevant planning documents:

City of Tampa The City adopted its most recent AI in September 2012. The AI identified six impediments to fair housing choice based on a review of affordable housing needs, a housing market analysis, input from a fair housing survey, and other local knowledge. Table 9 identifies the City’s previous impediments and the associated fair housing goal and strategies.

Table 9: City of Tampa – Previous Fair Housing Goals City of Tampa Previous Fair Housing Goals Impediment Fair Housing Goal Strategy #1 Lack of extensive Encourage Use the City’s amounts of redevelopment and redevelopment powers undeveloped land infill development in provided in the nine the City, particularly Community Redevelopment along established or Areas to identify, acquire, planned transit and develop sites for corridors. affordable housing. Particular emphasis will be for sites that are located along or near transit corridors. The City will work closely with THA to develop their vacant properties, as opportunities and resources become available, to create mixed- income communities. #2 High Development Fees Reduce costs in order to Continue efforts to facilitate the implement the findings of development of the AHAC. affordable housing projects. #3 Lengthy Turnaround Prioritize and thereby Continue efforts to time for permitting expedite permit and implement the findings of planning processes for the AHAC. affordable housing projects.

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City of Tampa Previous Fair Housing Goals #4 Unnecessary Improve policies, Continue efforts to regulations/procedures procedures, and implement the findings of regulations to alleviate the AHAC. the cost and time of affordable housing development. #5 Access to financing Improve the availability Continue its programs of and accessibility to providing first-time decent, affordable homebuyer assistance and housing for low- and owner-occupied moderate-income rehabilitation grant households. programs. #6 Language barriers and Reach out to the Community Affairs will cultural difference Hispanic community continue to strengthen and other ethnic groups their partnership with other via educational public civil and community information campaigns organizations and together and workshops in order will efficiently reach out to to promote programs in people in the community fair housing and also who will be given the will reach out to and opportunity to identify the network with impediments facing their community-based respective communities groups involved in and obtain housing related issues recommendations and who can provide solutions to the problems. additional assistance.

Hillsborough County The County’s most recent AI was originally adopted in July 2010 and later revised in February 2013. The geographic area covered by the AI includes unincorporated Hillsborough County and the cities of Plant City and Temple Terrace. The County’s AI identified five impediments to fair housing choice. The impediments were derived from jurisdictional data including housing and demographic data, information on fair housing programs and activities, public comments, survey results, and data on fair housing complaints and dispositions. Table 10 identifies the County’s previous impediments and the associated fair housing goals and strategies.

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Table 10: Hillsborough County – Previous Fair Housing Goals Hillsborough County Previous Fair Housing Goals Impediment Fair Housing Strategies Goal #1 Insufficient Increase a) Establish a Fair Housing Awareness Program knowledge knowledge using appropriate public service marketing about fair about fair techniques. housing law housing law. b) Create a Fair Housing webpage for the County’s website that provides clear information on what fair housing is and how to make a complaint if housing discrimination is suspected; the Fair Housing webpage will also include links to other housing resources, including links for both the general public and members of the real estate industry; the webpage will also have a Spanish language version. c) Include public service announcements on the County’s cable television network and prominent displays of Fair Housing Awareness materials in libraries and other public buildings throughout the County, Plant City, and Temple Terrace. d) Create a Fair Housing hotline for questions and complaints. e) Continue to collaborate in presentation of Fair Housing Workshops with the Fair Housing Partnership. #2 Insufficient Increase a) Make the Hillsborough County Human awareness of public Relations Ordinance and the Equal Human Rights awareness of Opportunity Administrator’s Office a Ordinance Human Rights prominent part of the Fair Housing (Ordinance Ordinance. Awareness Program. #00-37) b) Provide a link from the Equal Opportunity Administrator’s Office webpage to the Fair Housing Awareness Program webpage. c) Continue to include the Equal Opportunity Administrator’s Office in fair housing planning activities. #3 Possible Decrease a) Provide greater visibility for housing discriminatory potential for counseling services funded by the County. lending discriminatory b) Create a hotline for those who feel they practices may be a victim of discriminatory or 36

Hillsborough County Previous Fair Housing Goals lending predatory lending or a foreclosure practices. prevention scam. c) Create an identifiable foreclosure prevention scam awareness program with a memorable title and use this title in public service announcements and printed materials. #4 Insufficient Increase a) Make disability issues a part of the Fair public and public and Housing Awareness Program. professional professional b) Create a link to the Fair Housing Awareness knowledge knowledge Program webpage from the ADA Liaison about about webpage. disability disability c) Ensure that the Fair Housing Awareness issues issues. Program has ample information for residents and members of the real estate industry about how Fair Housing and ADA apply to disability issues, including requests for reasonable accommodation or modifications. d) Build working relationships with members of the real estate industry involved in the design, construction, rehabilitation, sale, and rental of housing through an outreach program that includes one or more workshops per year devoted entirely to disability issues; such a program would raise industry awareness that with the aging of the population, sensitivity to disability issues is not only the law, but also good business practice. #5 Insufficient Increase a) Continue to foster affordable housing supply of supply of through operation of County-administered affordable affordable programs funded by federal and state housing housing. housing programs. b) Continue efforts to create more affordable housing opportunities through planning and zoning.

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a. Discuss what progress has been made toward the achievement of fair housing goals.

City of Tampa Between PY 2012-2017, the City implemented numerous projects with its CPD funds as well as funds leveraged from other public and private sources. The paragraphs below provide a summary of the progress towards meeting each goal identified in the City’s most recent AI.

Goal #1: Encourage redevelopment and infill development in the City, particularly along established or planned transit corridors. The City supported several redevelopment and infill development projects with its non-profit partners, THA, and the City’s community redevelopment agencies. The City has continuously supported the efforts of THA in its redevelopment of Central Park, known as the Encore District. When complete, the development will be comprised of commercial space, office space, hotel, grocery store, and mixed income rental units. The City also assisted THA with securing funding through the Choice Neighborhood Grant. A portion of the funds was used for the development of The Tempo at Encore: a 203-unit multifamily development in which includes market rate units as well as units for occupancy by low- income households. The apartments will open in the Summer of 2018. The City has partnered with THA on several other projects throughout the community including the rehabilitation of existing affordable housing units at River Pines, the demolition of units at West River, and the construction of other housing units in the Encore District including a 2012 commitment of $2 million in HOME funds for the construction of The Trio.

The City also works with non-profit partners like community housing development organizations (CHDOs) - private non-profit, community-based organizations that develop affordable housing for low- and moderate-income households – to acquire, demolish, and redevelop affordable housing on infill lots.

Additionally, the City maintains a list of real property owned by the City that is suitable for affordable housing. There are currently 120 parcels of land that the City will make available for the development of permanent affordable housing.

Goal #2: Reduce costs in order to facilitate the development of affordable housing projects. The AHAC is a committee appointed by the City Council to make recommendations on initiatives and incentives to encourage affordable housing. The AHAC’s recommendations are included in the City’s Local Housing Assistance Plan (LHAP) which is prepared every three years. The LHAP in effect at the time of the City’s 2012 AI, included recommendations to modify impact fee requirements. Specifically, the Committee recommended that the City: • Consider amending the Code to allow for a waiver of transportation impact fees for affordable housing projects city wide, not only in the three No Fee Zones. • Defer water/sewer impact fees (connection fees, installation fees, capacity fees) until C/O or sale, for affordable housing designated development, not at time of permit issuance.

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• Investigate providing incentives to builders and investors of affordable housing by reducing fees if rents/sales prices are limited and controlled (research alternative funding sources for the fees to provide grants and/or loans to investors). • Research revising the impact and/or connection fee schedule so that they do not exceed a percentage of the total cost to build each unit. The air-conditioned square footage of the structure should be included in the research. Additionally, in the review, consider green building (sustainable) practices or enhancements that are made to housing units. • Review the process for calculating fees if capacity already exists (fees are charged to upgrade existing system infrastructure). The AHAC recommendations were adopted by the City. The Housing section of the City’s imagine 2040 Tampa Comprehensive Plan which became effective in February 2016 includes a policy (HSG Policy 1.1.5) to provide incentives for affordable housing available to low- and moderate-income households. The incentives offered to developers include reduced development fees as well as other incentives to reduce the cost of housing development.

Goal #3: The City will prioritize and thereby expedite permit and planning processes for affordable housing projects. The City has a web-based permitting system and offers an expedited permitting process for affordable housing development and/or green housing. The system allows users to pay and search for permits online. The system is user-friendly and was developed with input from developers and other trade professionals.

Goal #4: The City will improve policies, procedures, and regulations to alleviate the cost and time of affordable housing development. This goal relates to Goals #2 and #3 to address policies in the City’s Building Code or permitting process that were increasing the cost of housing and adding time to projects. To address this impediment, the City offers the following incentives to developers of affordable housing: • Inventory of publicly owned land available for affordable housing development; • Alternative housing development standards; • Density bonuses; • Allowance of affordable accessory residential units; • Allowance of flexible lot configurations; • Modification of setbacks; • Reduction of parking requirements; • Sidewalk waiver; • Reduced development fees; and • Access to Federal, state or local funds. These incentives encourage the development of affordable housing, including mixed-income projects, and also reduces the cost of land and construction. Additionally, by encouraging affordable housing development on infill lots, developers are able to realize reduced fees as many of the impact costs are not applied when using existing infrastructure.

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The AHAC has become more active in recent years and has made several recommendations to review policies and practices that impact the development and facilitation of affordable housing. The status of the recommended incentive strategies is monitored by HCD. The City is in the process of updating its webpage to clearly identity the available affordable housing incentives, clarify any ambiguity, and institute procedures to provide a transparent and consistent process for applying incentives.

Goal #5: The City will improve the availability and accessibility to decent, affordable housing for low- and moderate-income households. HCD administers a CDBG and HOME funded Owner-Occupied Rehabilitation Program and a Mortgage Assistance Program (MAP) that provides downpayment and closing cost assistance to low- and moderate- income households.

Between FYs 2012-2015, the City set out to assist 198 households through the Owner-Occupied Rehabilitation and MAP programs. The proposed goal included 160 rehabilitation projects and 38 first- time homebuyers. The City was 10 households short of meeting its goal and was able to complete the rehabilitation of 174 units and assisted with the purchase of 14 homes.

Housing costs in the City have risen significantly in the last few years thus increasing the need for more affordable housing and financial products to facilitate homeownership. HCD continues to implement the MAP and Owner-Occupied Rehabilitation programs and is working with local financial institutions to expand the products available and investments in affordable housing development.

Goal #6: Community Affairs will reach out to the Hispanic community and other ethnic groups via educational public information campaigns and workshops in order to promote programs in Fair Housing and also will reach out to and network with community-based groups involved in housing related issues who can provide additional assistance. Since the preparation of the 2012 AI, TOHR which was a section of the Division of Community Affairs has been moved under the umbrella of HCD. This change in structure brings together the lead agency responsible for the preparation of Consolidated Plan and the AI and for administering the CPD programs with the local fair housing organization charged with enforcing the fair housing laws. This structure works well because the two have the same overarching goal of affirmatively furthering fair housing.

Over the course of the period covered by the 2012 AI, TOHR has participated in numerous outreach, training, and informational events including activities targeted to persons of Hispanic ethnicity and organizations and agencies that serve Hispanic populations. Some of the organizations TOHR has collaborated with include the League of United Latin American Citizens (ULAC), Mayor’s Hispanic Advisory Council, and Solita’s House. In addition to these year-round activities, TOHR also participates in the celebration of Hispanic Heritage month and partners with local organizations to provide educational seminars. TOHR also developed an outreach campaign to educate residents of the City about their rights under the fair housing laws and to provide information on the fair housing services offered by the City. The information was provided in both English and Spanish. TOHR is continuing its efforts to provide

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information about housing discrimination and fair housing laws to the Hispanic population and persons from other ethnic groups that reside in Tampa.

HCD also offers program information in English and Spanish and encourages all its housing partners to offer bi-lingual services or at a minimum to utilize the Florida Relay service. Florida Relay is a service available to residents of the State of Florida which assists with communication between callers who are deaf, hard of hearing, or speech disabled. Florida Relay also provides a Spanish Relay service which makes it easy for Spanish and English-speaking Florida Relay users to call one another by phone. Call types include Spanish to Spanish relay and Spanish to English translation. This service is available 24/7, 365 days a year.

Hillsborough County The paragraphs below summarize the County’s progress towards meeting each goal identified in its most recent AI.

Goal #1: Increase knowledge about fair housing law. The County established its Fair Housing Awareness Program which is led by AHS in partnership with the Equal Opportunity Administrator’s Office (EOA) and the County’s Communications Department. The Fair Housing Awareness Program disseminates information on individual’s rights under the fair housing laws and the process to file a housing complaint if a person believes they have been discriminated against. The County has used various methods to educate residents about fair housing including: • Updating the webpages of AHS and EOA to include links to information on how to file a complaint online, in person, or by telephone at the local and Federal levels. The webpages also have links to fair housing resources and directs users to the HUD FHEO website and the County’s ADA Liaison webpage for matters involving persons with disabilities. • Displaying fair housing materials in County libraries. • Operating a fair housing hotline and making the phone number available on both AHS and EOA’s webpages. • Participating in local fair housing events such as the annual Fair Housing Symposium held every April during Fair Housing Month and an annual disability awareness event held every July. • The cities of Plant City and Temple Terrace have posted information about fair housing as well as a link to the County’s AHS webpage on their websites.

Goal #2: Increase public awareness of Human Rights Ordinance. Educating County residents about the Human Rights Ordinance is a component of the aforementioned Fair Housing Awareness Program. The Human Rights Ordinance is posted to both the EOA and AHS webpages and a link between the EOA webpage and the AHS webpage has been established. In September 2016, the County launched a new user-friendly website making information on the fair housing related pages more accessible and easier to locate.

Goal #3: Decrease potential for discriminatory lending practices. HMDA data reviewed during the preparation of the 2011 AI indicated that lower income Blacks/African- Americans were more often denied access to financing to purchase a home than Whites. To curb this 41

barrier to fair housing choice, the County provides a link to HUD-certified housing counseling agencies on the AHS webpage to encourage homebuyers to improve their financial standing through credit counseling and financial literacy.

The County anticipated an increase in foreclosures due to high rates of predatory lending prior to the housing bubble burst. To prevent further predatory lending or foreclosure scams, the County provides links to available resources on its AHS webpage including links to the HUD Fair Lending website, Making Home Affordable website, and the Fannie Mae website. These websites provide information on foreclosure prevention and tips to avoid scams.

Goal #4: Increase public and professional knowledge about disability issues. The County’s goal regarding knowledge of disability issues was aimed at increasing awareness around requirements for reasonable accommodations and modifications for persons with disabilities. To achieve this, the County has included information about the rights of persons with disabilities in its fair housing materials and has implemented several campaigns highlighting this issue. This includes distributing information on services available to persons with disabilities and participating in events and presentations on ADA issues at the annual Disability Awareness event, the local Chamber of Commerce, at churches, and at semiannual landlord forums.

AHS has also utilized CDBG funds to assist several nonprofit agencies to remove architectural barriers and improve accessibility for low-and moderate-income households.

Goal #5: Increase supply of affordable housing. The County uses Federal, state, and local funding sources for the development and preservation of affordable homeownership and rental housing. The funding sources utilized during the period covered by the AI include CDBG, Neighborhood Stabilization Program (NSP), HOME, State Housing Initiative Partnership (SHIP), LIHTC, and the State Apartment Incentive Loan Program (SAIL).

The County also provides various incentive strategies to developers to encourage construction of affordable housing units. The incentives include expedited permitting, impact fee relief, flexible densities, ADUs, reduction in parking and setback requirements, and allowance for flexible lot configurations. b. Discuss how successful the program participant(s) has been in achieving past goals, and/or how it has fallen short of achieving those goals (including potentially harmful unintended consequences).

City of Tampa Most of the impediments identified by the City stem from the shortage of affordable housing. The City has continuously funded and supported the development of affordable housing units and the assessment of the past impediments shows that the City has been successful in addressing the goals identified in the AI by improving the policies and practices that were regulatory barriers to the development of affordable housing. By adopting or improving policies like fee waivers and expedited permitting, the cost of

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developing affordable housing has been reduced for developers including small scale developments that are being encouraged on infill lots.

While the City has been proactive in working to remove the constraints to developing affordable housing, there are several external factors that cause the issue to remain a major barrier to fair housing choice. External factors include (i) the increase in the need for additional affordable units, (ii) the lack of financing to develop viable projects, (iii) the reduction in public funding allocations for several programs that are traditionally accessed for affordable housing projects, and (iv) a strong housing market with low vacancy rates.

Hillsborough County The establishment of the Fair Housing Awareness Program was a major goal of the County in its previous AI. The County was able to implement all of the planned actions by improving the coordination between the various departments that handle fair housing issues or serve persons that are protected under the fair housing laws including AHS, EOA, Communications, and the ADA Liaison.

In regard to the goal of decreasing discriminatory lending practices, one of the County’s strategies was to create a dedicated hotline for persons to call in if they believed they were the victim of discriminatory or predatory lending or the victim of a foreclosure scam. The County was unable to perform this action because of the costs associated with creating the hotline. However, the County has continued to promote an existing telephone line to provide this service to residents.

Like the City, the lack of affordable housing was also an impediment to fair housing choice in Hillsborough County. The County has committed and expended millions of dollars over the last five years to increase the supply of affordable housing units. However, the shortage of affordable housing is still a fair housing issue that the County plans to continue addressing through this AI.

c. Discuss any additional policies, actions, or steps that the program participant could take to achieve past goals, or mitigate the problems it has experienced.

As mentioned above, both the City and Hillsborough County were successful in implementing the goals and strategies outlined in their respective AIs. The main goal from the AIs was to increase the supply of affordable housing and through rehabilitation and new construction projects the goal was accomplished however, the demand for affordable housing continues to outstrip the supply. Although affordable housing is still needed in the City and the County, it is not due to lack of action on the program participants part.

d. Discuss how the experience of program participant(s) with past goals has influenced the selection of current goals.

The City and County will continue to implement the strategies from the previous AI during the period covered by this analysis. However, to ensure that the policies and actions do meet the obligation to AFFH, the program participants will define the parameters for success more clearly in order to track progress 43

throughout the implementation period. This will allow for a better evaluation of the effectiveness of programs and actions to address the fair housing issues as well as to reassess conditions and identify any changes in the region that would warrant a revision to the AI. For example, rather than have a general goal of increasing the supply of affordable housing, the goal in this AI, gives priority to affordable housing projects that have the potential to transform disadvantaged neighborhoods into areas of opportunity and make high opportunity areas more inclusive.

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IV. Fair Housing Analysis A. Demographic Summary

1. Describe demographic patterns in the jurisdiction and region, and describe trends over time (since 1990).

Race/Ethnicity Table 11 shows the racial or ethnic composition of the City, County, and the region. The predominant race in all three areas is the White population, making up 67.53% of the population in the region compared to 56.48% in the County and 46.45% in the City. The other major racial/ethnic groups are the Hispanic and Black/African-American populations. The Hispanic population is the second largest racial/ethnic group in both the region and the County at 16.25% and 25.62%, respectively. However, in the City, the Hispanic population is 23.15% of the total population making it the third largest racial demographic in the City, after Blacks/African-Americans. Blacks/African-Americans comprise 24.57% of the City’s population, 12.17% of the County’s population, and 11.15% of the region’s population. Other racial/ethnic groups including Asians, Native Americans, multi-racial individuals, and persons who classify themselves as Other, make up approximately 5% of the population in all three areas. Of the three geographic areas, Tampa has the greatest racial and ethnic diversity overall, with a majority-minority population.

Table 11: Race/Ethnicity Tampa-St. Tampa, FL Hillsborough County, FL Petersburg- Clearwater, FL

Race/Ethnicity # % # % # %

White, Non-Hispanic 155,930 46.45% 504,635 56.48% 1,879,437 67.53%

Black, Non-Hispanic 82,483 24.57% 108,777 12.17% 310,357 11.15%

Hispanic 77,725 23.15% 228,910 25.62% 452,208 16.25%

Asian or Pacific Islander, 11,513 3.43% 30,518 3.42% 81,213 2.92% Non-Hispanic

Native American, Non- 768 0.23% 2,180 0.24% 6,733 0.24% Hispanic

Two or More Races, Non- 6,515 1.94% 16,280 1.82% 47,571 1.71% Hispanic

Other, Non-Hispanic 773 0.23% 2,219 0.25% 5,724 0.21%

Source: Decennial Census, 2010

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The racial and ethnic composition of the population at each geographic level became more diverse between 1990 and 2010, as shown in Table 12. This trend was mainly driven by an increase in the share of the Hispanic population. In Tampa, the White population decreased from 59.81% in 1990 to 46.45% in 2010 while all the minority racial/ethnic groups experienced growth. The Black/African-American population increased from 23.69% in 1990 to 25.64% in 2010 and the Hispanic population experienced even more significant growth, increasing from 14.81% in 1990 to 23.15% in 2010. Hillsborough County exhibited similar racial/ethnic trends with the White population decreasing from 79.39% in 2000 to 56.48% in 2010. Also, like the City and the region, the Black/African-American population grew but at a slower rate than the Hispanic population. In the County, the Black/African-American population increased from 7.15% in 1990 to 13.07% in 2010 while the Hispanic population increased from 11.75% in 1990 to 25.62% in 2010. Similar changes in racial/ethnic composition occurred in the region between 1990 and 2010. The region has seen a decrease in the White population from 83.11% in 1990 to 67.53% in 2010. The Black/African-American population increased from 8.75% in 1990 to 11.97% in 2010 and the Hispanic population increased from 6.71% in 1990 to 16.25% in 2010.

Table 12: Race/Ethnicity Trends Tampa, FL

1990 Trend 2000 Trend 2010 Trend Current

Race/Ethnicity # % # % # % # %

White, Non- 170,950 59.81% 155,953 51.27% 155,930 46.45% 155,930 46.45% Hispanic

Black, Non- 67,719 23.69% 78,791 25.90% 86,092 25.64% 82,483 24.57% Hispanic

Hispanic 42,335 14.81% 58,432 19.21% 77,725 23.15% 77,725 23.15%

Asian or Pacific 3,666 1.28% 7,807 2.57% 13,412 4.00% 11,513 3.43% Islander, Non- Hispanic

Native American, 682 0.24% 1,689 0.56% 1,607 0.48% 768 0.23% Non-Hispanic

Hillsborough County, FL

1990 Trend 2000 Trend 2010 Trend Current

Race/Ethnicity # % # % # % # %

White, Non- 435,348 79.39% 476,587 68.58% 504,635 56.48% 504,635 56.48% Hispanic

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Tampa, FL

1990 Trend 2000 Trend 2010 Trend Current

Race/Ethnicity # % # % # % # %

Black, Non- 39,219 7.15% 71,300 10.26% 116,785 13.07% 108,777 12.17% Hispanic

Hispanic 64,406 11.75% 121,183 17.44% 228,910 25.62% 228,910 25.62%

Asian or Pacific 7,080 1.29% 18,202 2.62% 35,718 4.00% 30,518 3.42% Islander, Non- Hispanic

Native American, 1,338 0.24% 4,201 0.60% 4,774 0.53% 2,180 0.24% Non-Hispanic

Tampa-St. Petersburg-Clearwater, FL

1990 Trend 2000 Trend 2010 Trend Current

Race/Ethnicity # % # % # % # %

White, Non- 1,718,794 83.11% 1,821,733 76.03% 1,879,437 67.53% 1,879,437 67.53% Hispanic

Black, Non- 180,890 8.75% 247,843 10.34% 333,068 11.97% 310,357 11.15% Hispanic

Hispanic 138,870 6.71% 248,429 10.37% 452,208 16.25% 452,208 16.25%

Asian or Pacific 21,826 1.06% 53,117 2.22% 95,610 3.44% 81,213 2.92% Islander, Non- Hispanic

Native American, 4,662 0.23% 14,414 0.60% 15,801 0.57% 6,733 0.24% Non-Hispanic

Source: Brown Longitudinal Tract Database (LTDB) based on decennial census data, 2010, 2000 & 1990

National Origin Table 13 shows the most common countries of origin for the foreign-born population for the City, County, and the region. At each geographic level, the most common country of origin is Cuba, accounting for 4.18% 47

of City residents, 3.30% of County residents, and 1.89% of residents in the region as a whole. Mexico is the second most common country of origin at each geographic level with 1.25% of the City’s population, 2.42% of the County’s population, and 1.45% of the region’s population. The other countries rounding out the top five most common countries of origin are Haiti, Colombia, Canada, India, and the Dominican Republic. Each geographic level also includes Jamaica, Vietnam, Honduras, Philippines, Peru, and Germany among the top ten countries of origin.

Table 13: National Origin

Tampa-St. Petersburg- Tampa, FL Hillsborough County, FL Clearwater, FL

National Origin Country # % Country # % Country # % #1 country of origin Cuba 13,454 4.18% Cuba 28,209 3.30% Cuba 50,330 1.89% #2 country of origin Mexico 4,025 1.25% Mexico 20,634 2.42% Mexico 38,561 1.45% #3 country of origin Haiti 2,505 0.78% Colombia 8,576 1.00% Canada 20,143 0.76% #4 country of origin India 2,352 0.73% India 7,532 0.88% Colombia 16,314 0.61% #5 country Dominican of origin Colombia 2,082 0.65% Republic 5,691 0.67% India 14,689 0.55% #6 country Dominican of origin Republic 2,050 0.64% Jamaica 5,268 0.62% Vietnam 12,504 0.47% #7 country of origin Honduras 1,913 0.59% Vietnam 4,259 0.50% Jamaica 11,150 0.42% #8 Dominica country n of origin Jamaica 1,708 0.53% Canada 3,821 0.45% Republic 10,886 0.41% #9 country Philippin of origin Vietnam 1,237 0.38% Philippines 2,854 0.33% es 10,340 0.39% #10 country of origin Canada 1,083 0.34% Peru 2,833 0.33% Germany 8,993 0.34% Source: American Community Survey (ACS), 2009-2013. (For variables on foreign born and foreign born by national origin, percentages using data from the American Community Survey (ACS), 2009-2013 are calculated using total population from the 2010 decennial census). 48

Table 14 shows trends in the foreign-born population in the City, County, and the region. The foreign-born population has steadily increased in all three areas since 1990. In the City, the foreign-born population more than doubled, increasing from 22,722 persons (7.95%) in 1990 to 53,263 persons (15.87%) in 2010. The County and the region also experienced similar growth in the foreign-born population. In the County, the population increased from 40,631 persons (7.41%) in 1990 to 141,126 persons (15.79%) in 2010 and in the region, the population increased from 146,003 persons (7.06%) to 353,095 persons (12.69%) for the same time period.

Table 14: National Origin Trends 1990 Trend 2000 Trend 2010 Trend Current National Origin # % # % # % # % Tampa, FL 22,722 7.95% 36,979 12.16% 49,094 14.62% 53,263 15.87% Hillsborough County, FL 40,631 7.41% 78,172 11.25% 132,014 14.77% 141,126 15.79% Tampa-St. Petersburg- Clearwater, FL 146,003 7.06% 233,907 9.76% 336,886 12.10% 353,095 12.69%

Source: American Community Survey (ACS), 2009-2013; Decennial Census, 2000; Decennial Census, 1990. (For variables on foreign born and foreign born by national origin, percentages using data from the American Community Survey (ACS), 2009-2013 are calculated using total population from the 2010 decennial census. Percentages using 2000 and 1990 decennial census data are also calculated using total population).

Limited English Proficiency LEP persons are persons who, as a result of national origin, do not speak English as their primary language and who have a limited ability to speak, read, write, or understand English. Table 15 shows the 10 most common languages spoken by LEP persons in the City, County, and the region. Spanish is the most common language spoken by LEP persons in all three geographic areas at 7.83% in the City, 8.08% in the County, and 4.97% in the region. Vietnamese is the second most common language in the County and the region and the third most common language in the City. French Creole is the second most common language in the City. Persons that speak Chinese round out the top three LEP languages in the County and the region.

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Table 15: Limited English Proficiency Language

Tampa-St. Petersburg- Tampa, FL Hillsborough County, FL Clearwater, FL

Limited English Proficiency (LEP) Language Language # % Language # % Language # % #1 LEP Language Spanish 25,216 7.83% Spanish 69,035 8.08% Spanish 132,298 4.97% #2 LEP French Language Creole 1,403 0.44% Vietnamese 3,030 0.35% Vietnamese 9,117 0.34% #3 LEP Language Vietnamese 982 0.30% Chinese 1,617 0.19% Chinese 3,968 0.15% #4 LEP French French Language Arabic 911 0.28% Creole 1,366 0.16% Creole 3,572 0.13%

#5 LEP Other Asian Other Asian Language Language 396 0.12% Language 1,041 0.12% Arabic 2,992 0.11% #6 LEP Language Korean 342 0.11% Portuguese 943 0.11% French 2,799 0.11% #7 LEP Serbo- Language Russian 267 0.08% Arabic 916 0.11% Croatian 2,658 0.10% #8 LEP Language French 252 0.08% Korean 751 0.09% Greek 2,574 0.10% #9 LEP Language Chinese 247 0.08% Tagalog 642 0.08% Portuguese 2,176 0.08% #10 LEP Language Thai 242 0.08% French 500 0.06% Polish 2,151 0.08% Source: American Community Survey (ACS), 2009-2013. (For variables on limited English proficiency, percentages using data from the American Community Survey (ACS), 2009-2013 are calculated using total population from the 2010 decennial census).

Table 16 shows trends in the LEP population. Naturally, as the foreign-born population has grown, so too has the LEP population. More significant growth in terms of the share of the population occurred between 1990 and 2000 in all the geographic areas. The share of LEP persons in the City remained steady between 2000 and 2010 at 9.49% and 9.83% respectively. In the County, the LEP population increased from 4.88% in 1990 to 9.48% in 2010. While in the region, the LEP population increased from 3.70% in 1990 to 6.74% in 2010.

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Table 16: Limited English Proficiency Trends 1990 Trend 2000 Trend 2010 Trend Current LEP # % # % # % # % Tampa, FL 17,792 6.22% 28,876 9.49% 32,991 9.83% 31,953 9.52% Hillsborough County, FL 26,771 4.88% 52,421 7.54% 81,117 9.08% 84,692 9.48% Tampa-St. Petersburg- Clearwater, FL 76,550 3.70% 136,128 5.68% 186,861 6.71% 187,539 6.74% Source: American Community Survey (ACS), 2009-2013; Decennial Census, 2000; Decennial Census, 1990. (For variables on limited English proficiency, percentages using data from the American Community Survey (ACS), 2009-2013 are calculated using total population from the 2010 decennial census. Percentages using 2000 and 1990 decennial census data are also calculated using total population).

Disability Regarding disability, according to the 2015 ACS, 12.5% of the City’s population and 11.7% of the County’s total population report having a disability. Federal law defines a person with a disability as ―any person who has a physical or mental impairment that substantially limits one or more major life activities; has a record of such impairment; or is regarded as having an impairment. As shown in Table 17, in the City, 6.96% of the population report having an ambulatory difficulty, 5.10% have a cognitive difficulty, 4.47% have an independent living difficulty, 2.96% have a self-care difficulty, and 1.76% have a vision difficulty. Like the City, the most common disability type in the County and region is ambulatory disability at 6.69% and 8.15%, respectively.

Table 17: Disability Type Hillsborough County, Tampa-St. Petersburg- Tampa, FL FL Clearwater, FL

Disability Type # % # % # %

Hearing difficulty 9,409 2.96% 26,551 3.14% 108,486 4.12%

Vision difficulty 9,377 2.95% 18,863 2.23% 66,629 2.53%

Cognitive difficulty 16,202 5.10% 39,497 4.67% 138,004 5.25%

Ambulatory difficulty 22,104 6.96% 56,633 6.69% 214,326 8.15%

Self-care difficulty 8,742 2.75% 22,987 2.72% 78,434 2.98% Independent living difficulty 14,192 4.47% 37,373 4.42% 138,974 5.28% Source: American Community Survey (ACS), 2009-2013. (For variables on disability, percentages are calculated based on the total population age 5 years and older).

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Sex Table 18 shows the mix of the male and female population in the City, County, and the region. In all three geographic areas, the ratio of males to females have been nearly equal with the female population being slightly higher in each area.

Table 18: Population by Sex

Tampa-St. Petersburg- Tampa, FL Hillsborough County, FL Clearwater, FL

Sex # % # % # % Male 164,016 48.86% 435,068 48.69% 1,347,513 48.42% Female 171,693 51.14% 458,449 51.31% 1,435,730 51.58% Source: Decennial Census, 2010

Table 19 indicates that since 1990, the mix of the male and female population has not changed significantly. For each geographic area, there are consistently more females than males. Since 1990, the female population in the City has decreased slightly, by less than 1 percentage point, and conversely, the male population increased. This same trend occurred in the region. In the County, the female population has steadily increased in size.

Table 19: Population by Sex Over Time Tampa-St. Petersburg- Tampa, FL Hillsborough County, FL Clearwater, FL

Sex Male Female Male Female Male Female

# 137,495 148,330 269,028 279,180 985,370 1,082,468 1990 Trend % 48.10% 51.90% 49.07% 50.93% 47.65% 52.35%

# 148,127 156,053 340,479 354,310 1,154,378 1,241,617 2000 Trend % 48.70% 51.30% 49.00% 51.00% 48.18% 51.82%

# 164,016 171,693 435,068 458,449 1,347,513 1,435,730 2010 Trend % 48.86% 51.14% 48.69% 51.31% 48.42% 51.58%

# 164,016 171,693 435,068 458,449 1,347,513 1,435,730 Current % 48.86% 51.14% 48.69% 51.31% 48.42% 51.58%

Source: Decennial Census, 2010; Decennial Census, 2000; Decennial Census, 1990

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Age

Table 20 shows a breakdown of the population for the City, County, and the region by age. The majority of the population in all three geographic areas is between the ages of 18 and 64. The City and the County have a relatively younger population than the region with seniors making up 10.98% of the population in the City and 12.13% of the population in the County, compared to 17.25% of the population in the region.

Table 20: Population by Age

Tampa-St. Petersburg- Tampa, FL Hillsborough County, FL Clearwater, FL Age # % # % # % Under 18 76,066 22.66% 218,142 24.41% 589,827 21.19% 18-64 222,773 66.36% 567,008 63.46% 1,713,312 61.56% 65+ 36,870 10.98% 108,367 12.13% 480,104 17.25%

Source: Decennial Census, 2010

In terms of trends in the age of the population, Table 21 shows that there was no significant change in the population breakdown by age since 1990 although the City and the region are becoming slightly younger. The senior population in the City decreased from 14.49% in 1990 to 10.98% in 2010. In the region, the senior population decreased from 21.53% in 1990 to 17.25% in 2010. During the same time period, the senior population in the County increased from 11.03% to 12.13%.

Table 21: Population by Age Over Time Tampa-St. Petersburg-Clearwater, Tampa, FL Hillsborough County, FL FL Under Age 18 18-64 65+ Under 18 18-64 65+ Under 18 18-64 65+ 1990 # 65,270 179,136 41,418 136,544 351,194 60,469 421,539 1,201,013 445,285 Trend % 22.84% 62.67% 14.49% 24.91% 64.06% 11.03% 20.39% 58.08% 21.53% 2000 # 76,673 189,568 37,939 181,917 431,374 81,498 536,712 1,398,726 460,558 Trend % 25.21% 62.32% 12.47% 26.18% 62.09% 11.73% 22.40% 58.38% 19.22% 2010 # 76,066 222,773 36,870 218,142 567,008 108,367 589,827 1,713,312 480,104 Trend % 22.66% 66.36% 10.98% 24.41% 63.46% 12.13% 21.19% 61.56% 17.25% # 76,066 222,773 36,870 218,142 567,008 108,367 589,827 1,713,312 480,104 Current % 22.66% 66.36% 10.98% 24.41% 63.46% 12.13% 21.19% 61.56% 17.25%

Source: Decennial Census, 2010; Decennial Census, 2000; Decennial Census, 1990

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Families with Children Table 22 shows the number of families with children in the City, County, and region. In the City, 46.93% of families have children, in the County 46.02% of families have children, and in the region, 40.28% of families have children.

Table 22: Families with Children Tampa-St. Tampa, FL Hillsborough County, FL Petersburg- Clearwater, FL Family Type # % # % # % Families with children 35,625 46.93% 105,361 46.02% 288,247 40.28%

Source: Decennial Census, 2010

Since 1990, there has been an increase in the share of families with children in the City and the region but a slight decrease in the County as shown in Table 23. In the City, 43.93% of families had children in 1990 and it increased to 46.93% by 2010. While in the County, 47.28% of families had children in 1990 and the proportion of families with children decreased to 46.02% by 2010.

Table 23: Families with Children Over Time 1990 Trend 2000 Trend 2010 Trend Current Family Type # % # % # % # % Tampa, FL 31,306 43.93% 27,313 47.43% 35,625 46.93% 35,625 46.93% Hillsborough 70,896 47.28% 67,622 48.31% 105,361 46.02% 105,361 46.02% County, FL Tampa-St. Petersburg- 219,279 37.86% 197,161 41.56% 288,247 40.28% 288,247 40.28% Clearwater, FL Source: Decennial Census, 2010; Decennial Census, 2000; Decennial Census, 1990

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B. General Issues

i. Segregation/Integration

1. Analysis

a. Describe and compare segregation levels in the jurisdiction and region. Identify the racial/ethnic groups that experience the highest levels of segregation.

Segregation is defined in the AFFH rule as a condition where there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area. Integration, on the other hand, means that there is not a high concentration of protected class persons in a particular geographic area when compared to a broader geographic area.

The level of residential segregation can be measured by a dissimilarity index. A dissimilarity index assesses the degree to which two groups are evenly distributed across the jurisdiction or region. The dissimilarity index value ranges from 0 to 100, where a higher number indicates a higher degree of segregation among the two groups being measured. Tables 24 and 25, depict the current and past race/ethnicity dissimilarity index values for the non-white/White, Black/White, Hispanic/White, and Asian or Pacific Islander/White populations in the City, County, and the region. Dissimilarity index values between 0 and 39 indicate low segregation, values between 40 and 54 indicate moderate segregation, and values between 55 and 100 indicate high segregation.

City of Tampa Based on the non-White/White dissimilarity index, the overall segregation level in the City and the region is moderate at 49.94 and 44.91, respectively. This represents a moderate degree of segregation between minorities and White individuals. Blacks/African-Americans are the racial/ethnic group experiencing the highest level of segregation in the City at 64.58 and in the region at 59.48. Hispanic individuals in the City and the region experience moderate degrees of segregation. Asian/Pacific Islanders experience a low degree of segregation in both the City and the region.

Table 24: City of Tampa – Racial/Ethnic Dissimilarity Index Tampa-St. Petersburg-Clearwater, Tampa, FL FL

Racial/Ethnic Dissimilarity 1990 2000 2010 Current 1990 2000 2010 Current Index Trend Trend Trend Trend Trend Trend Non-White/White 45.85 43.72 43.99 49.94 51.94 46.95 41.19 44.91 Black/White 63.37 59.41 55.98 64.48 69.75 63.52 54.32 59.48 Hispanic/White 40.03 41.58 44.50 46.26 45.32 44.39 40.67 42.89

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Tampa-St. Petersburg-Clearwater, Tampa, FL FL

Racial/Ethnic Dissimilarity 1990 2000 2010 Current 1990 2000 2010 Current Index Trend Trend Trend Trend Trend Trend Asian or Pacific 27.34 28.53 30.90 35.11 34.22 33.64 33.17 38.59 Islander/White Source: Decennial Census, 2010; Brown Longitudinal Tract Database (LTDB) based on decennial census data, 2010, 2000 & 1990

Hillsborough County Segregation levels in the County are lower than the segregation levels in the City for all the race/ethnic groups identified. The overall segregation level in the County is low and the segregation level for Hispanics and Asian/Pacific Islanders is also low at 36.36 and 33.85, respectively. The Black/White dissimilarity index value of 45.08 represents moderate segregation between Blacks/African-Americans and White individuals.

Table 25: Hillsborough County - Racial/Ethnic Dissimilarity Index Tampa-St. Petersburg-Clearwater, Hillsborough County, FL FL

Racial/Ethnic 1990 2000 2010 Current 1990 2000 2010 Current Dissimilarity Index Trend Trend Trend Trend Trend Trend Non-White/White 34.85 34.45 31.57 34.87 51.94 46.95 41.19 44.91 Black/White 55.84 48.67 41.95 45.08 69.75 63.52 54.32 59.48 Hispanic/White 31.87 34.99 33.66 36.36 45.32 44.39 40.67 42.89 Asian or Pacific 27.37 30.65 29.58 33.85 34.22 33.64 33.17 38.59 Islander/White Source: Decennial Census, 2010; Brown Longitudinal Tract Database (LTDB) based on decennial census data, 2010, 2000 & 1990

b. Identify areas in the jurisdiction and region with relatively high segregation and integration by race/ethnicity, national origin, or LEP group, and indicate the predominant groups living in each area.

City of Tampa To identify the areas in the City and the region with high segregation and integration, Figures 1, 2, and 3 were used to detect clusters by race/ethnicity, national origin, and LEP groups. Figure 1 shows the current race/ethnicity data and indicates that the City’s most prominent segregated areas are East Tampa, Old West Tampa, and the University Area, which are primarily Black/African-American. and South Tampa are heavily White, while Hispanics and Latinos are disproportionately located in the area between the airport and the Hillsborough River. The most integrated parts of the City appear to be west of the Hillsborough River and in the North Tampa area outside of the R/ECAPs.

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Figure 2 shows the geographic distribution of foreign-born residents from the five most common countries of origin for Tampa. The City has a sizeable Cuban population, which is primarily concentrated between the airport to the west and the Hillsborough River to the east and does not extend far into South Tampa. The City’s Mexican-born residents are mainly located in the area around the , East Tampa, and the University Area. The largest concentration of Haitian residents can be found in the East Tampa R/ECAP. The Indian-born population is more widely dispersed, with residents distributed from South Tampa to northwest Tampa. Colombian-born residents are mainly located in western Tampa, including parts of South Tampa.

Figure 3 shows LEP persons who speak the top five languages spoken among the City’s LEP residents. Spanish is the language spoken most frequently among LEP residents. Spanish-speakers are primarily located in western Tampa, central Tampa, and the area south of Fowler Avenue. It is likely that many of these Spanish speakers are Cuban, but the distribution of Spanish-speaking LEP residents is denser and extends further east than the distribution of Cuban-born residents. The largest group of French Creole speakers live in or near the East Tampa R/ECAP; many of these residents are likely from Haiti. Speakers of Vietnamese, Arabic, and other Asian languages mainly live in North Tampa, roughly between Fowler Avenue and Waters Avenue.

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Figure 1: City of Tampa – Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 1 Race/Ethnicity Description: Current race/ethnicity dot density map for City of Tampa and Region with R/ECAPs

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Figure 2: City of Tampa – National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 3 - National Origin Description: Current national origin (5 most populous) dot density map for City of Tampa and Region with R/ECAPs 59

Figure 3: City of Tampa – LEP population

Source: HUD AFFH Data and Mapping Tool Name: Map 4 – LEP Description: LEP persons (5 most commonly used languages) for City of Tampa and Region with R/ECAPs 60

Hillsborough County Figure 4 indicates that the areas of Hillsborough County outside of Tampa are more racially and ethnically integrated, with most of the University Area R/ECAP being predominantly Black/African-American. Elsewhere in northwest Hillsborough County, Hispanics are concentrated in the Town ‘N Country, Egypt Lake-Leto, and Carrollwood areas (which also include many White residents and some Black/African- American residents), while other areas are predominantly White. In eastern Hillsborough County outside of Tampa, there are concentrations of Black/African-American residents contiguous to East Tampa and in part of Plant City, while Black/African-American residents in the Brandon area tend to live close to I-75 (which is a fairly diverse area overall). The heavily agricultural Plant City area has a large Hispanic population, but also many White residents. In southern Hillsborough County, Sun City Center is a White enclave, while the neighborhoods to the east and west of it are heavily Hispanic and Latino.

Figure 5 shows the top five nationalities of foreign-born residents in Hillsborough County. The densest concentrations of Cubans are in the Town ‘N Country area and west of Egypt Lake-Leto, and Cubans are widespread in other northwestern Hillsborough County suburbs and the Brandon and Riverview areas. Mexican-born residents live primarily in a cluster in the University Area R/ECAP, the Plant City area, and southern Hillsborough County, but a few hundred Mexican residents also live in the Brandon area. Indian- born and Colombian-born Hillsborough County residents live mainly in the suburbs to the southeast and northwest of Tampa, although Colombians are much more numerous in the northwest suburbs.

Figure 6 shows residents who speak the top five languages spoken among the County’s LEP residents. The distribution of Spanish-speaking LEP residents overlaps heavily with that of Cuban-born residents but is larger and more extensive. Spanish-speakers are concentrated in the Town ‘N Country and Egypt Lake- Leto areas, and spread throughout northwest Hillsborough County, the Brandon and Plant City areas, and the I-75 corridor southeast of Tampa. Speakers of Vietnamese, Chinese, and other Asian Languages are mainly located in the suburbs, northwest of Tampa, but a few are also scattered in the Brandon area. Although French Creole is the fifth most common language spoken by LEP residents in the County, the French Creole-speaking population is small, with small clusters in the University Area R/ECAP and the Lutz and Riverview areas.

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Figure 4: Hillsborough County – Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 1 - Race/Ethnicity Description: Current race/ethnicity dot density map for Hillsborough County and Region with R/ECAPs 62

Figure 5: Hillsborough County – National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 3 - National Origin Description: Current national origin (5 most populous) dot density map for Hillsborough County and Region with R/ECAPs 63

Figure 6: Hillsborough County – LEP Population

Source: HUD AFFH Data and Mapping Tool Name: Map 4 - LEP Description: LEP persons (5 most commonly used languages) for Hillsborough County and Region with R/ECAPs 64

Region Areas of racial and ethnic segregation in the Tampa-St. Petersburg-Clearwater region outside of Hillsborough County include:

• South St. Petersburg, which is primarily Black/African-American and includes a R/ECAP. • A stretch of western Clearwater, which is largely Black/African-American and Hispanic/Latino. This area includes a largely Black/African-American R/ECAP. • A primarily Black/African-American and Hispanic/Latino R/ECAP in Dade City. • South Brooksville, which has a moderate concentration of Black/African-American residents.

Broadly speaking, the urban areas away from the coasts in the region outside Hillsborough County are racially and ethnically diverse, while the more rural areas are primarily White. Additionally, most neighborhoods along the coastlines of the Gulf of Mexico and Tampa Bay are primarily White enclaves.

The most common national origins for foreign-born residents in the region outside of Hillsborough County are Cuba, Mexico, Canada, Colombia, and India. Residents from the three Latin American countries are mainly located in urban areas away from the coast. There are notable clusters of Mexican residents in South Highpoint, a southwest Clearwater neighborhood between Drew Street and Lakeview Road, and in an area around the Dade City R/ECAP. Additionally, there is a small cluster of Indian-born residents in northwest Largo. With the exception of the Dade City R/ECAP, which is largely Black/African-American and Hispanic, and has a cluster of Mexican residents, foreign-born residents in the region outside Hillsborough County are generally located in integrated areas.

The most common languages spoken by LEP residents in the region outside of Hillsborough County are Spanish, Vietnamese, Chinese, French Creole, and Arabic. These residents are mainly located in urban and built-up areas away from the coast. There are several clusters of Spanish-speakers in Clearwater, one in the Highpoint area, and one in the Dade City area, including in the R/ECAP. Vietnamese-speaking residents are somewhat clustered in the Pinellas Park and Lealman areas. With the exception of the Dade City R/ECAP, which is largely Black/African-American and Hispanic, and has a cluster of Spanish-speaking residents, LEP residents in the region outside Hillsborough County are generally located in integrated areas. c. Explain how these segregation levels and patterns in the jurisdiction and region have changed over time (since 1990).

City of Tampa Based on the data in Table 24, since 1990, overall segregation between Whites and non-Whites has increased in the City from 45.85 to 49.94, although it decreased slightly between 1990 and 2000 from 45.85 to 43.72. Following a similar pattern, Black/White segregation in the City decreased from 1990 to 2000 from 63.37 to 59.41, and then increased to 64.48. Hispanic/White segregation in the City has increased consistently, from 40.03 to 46.26. Segregation between Asians/Pacific Islanders and Whites increased during this time period from 27.34 to 35.11, but the dissimilarity index is less reliable for very small minority populations such as Asians and Pacific Islanders.

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For all racial/ethnic comparisons, the City had lower segregation levels than the region as a whole in 1990 but surpassed the region by 2010 in terms of non-White/White, Black/White, and Hispanic/White segregation levels.

Figures 7, 8, and 9 show the geographic distribution of Tampa residents by race and ethnicity in 1990 and 2000, respectively. In the City, between 1990 and 2000, the number of Black/African-American residents in Sulphur Springs and the University Area expanded, while western Tampa and South Tampa became more diverse as their Hispanic population increased. Additionally, a cluster of Asian/Pacific Islander residents emerged in South Tampa just north of MacDill Air Force Base.

Between 2000 and 2010, the concentration of Black/African-American residents increased slightly in East Tampa, and the concentrations of Black/African-American and Hispanic residents increased in the census tract encompassing Rogers Park Golf Course and in parts of North Tampa and . East Tampa and the Rogers Park Golf Course area were relatively segregated in 2010, while the New Tampa area remained relatively integrated, and the Temple Crest area became somewhat more segregated than in 2000. Additionally, the Hispanic population west of the Hillsborough River increased and coalesced into more concentrated clusters, making this area somewhat less integrated.

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Figure 7: City of Tampa – Race/Ethnicity Trends (1990)

Source: HUD AFFH Data and Mapping Tool Name: Map 2. Race/Ethnicity Trends Variation: Race/Ethnicity Trends, 1990 Description: Past race/ethnicity dot density map for City of Tampa and Region with R/ECAPs 67

Figure 8: City of Tampa – Race/Ethnicity Trends (2000)

Source: HUD AFFH Data and Mapping Tool Name: Map 2. Race/Ethnicity Trends Variation: Race/Ethnicity Trends, 2000 Description: Past race/ethnicity dot density map for City of Tampa and Region with R/ECAPs 68

Figure 9: City of Tampa – Race/Ethnicity Trends (2010)

Source: HUD AFFH Data and Mapping Tool Name: Map 2. Race/Ethnicity Trends Variation: Race/Ethnicity Trends, 2010 Description: Past race/ethnicity dot density map for City of Tampa and Region with R/ECAPs 69

Hillsborough County Table 25 shows that Non-White/White segregation levels have been fairly steady in Hillsborough County since 1990. Black/White segregation decreased substantially in the County from 55.84 to 45.08 while Hispanic/White segregation increased moderately from 31.87 to 36.36. Segregation between Asians/Pacific Islanders and Whites increased as well from 27.37 to 33.85.

Non-White/White segregation levels declined in the region from 51.94 in 1990 to 44.91 currently. As in Hillsborough County, Black/White segregation declined substantially during this period from 69.75 to 59.48, and Hispanic/White segregation decreased slightly from 45.32 to 42.89. Segregation between Asians/Pacific Islanders and Whites increased during this time period from 34.22 to 38.59.

The suburban areas of northwestern Hillsborough County became more diverse between 1990 and 2000 as their Hispanic populations increased, especially in the Egypt Lake-Leto area. During this same time period, the number of Black/African-American residents in the University Area increased as shown in Figures 10, 11 and 12. The Black/African-American population also increased east of the Tampa city limits and west of Brandon between 1990 and 2000, while the Hispanic population increased in the largely White Brandon area. The northwestern part of Plant City became more integrated as its Hispanic population increased, while the southeastern part of Plant City became more segregated as its Black/African- American population increased. The Wimauma area became more populated and segregated as its Hispanic population increased, while the area east of Wimauma depopulated and became primarily White as its Hispanic population largely disappeared.

Between 2000 and 2010 in northwestern Hillsborough County, the Hispanic and Latino population continued to increase, particularly in Town ‘N Country. Similar to the situation in western Tampa, Hispanics and Latinos in the suburbs of northwestern Hillsborough County became more clustered in certain neighborhoods—specifically in Town ‘N Country, Egypt Lake-Leto, and Carrollwood. The Black/African-American population continued to increase in the University Area, north of the Tampa city limits, as well as in the unincorporated areas to the east of East Tampa, making these areas more segregated. In the suburbs along I-75 extending southeast of Tampa, the Hispanic population increased between 2000 and 2010, increasing this area’s overall diversity, but also giving rise to notable Hispanic and Latino clusters in Ruskin and increasing the Hispanic concentration in Wimauma area. A cluster of Black/African-American residents developed in the Progress Village area, and the Brandon area became more diverse with a greater number of Black/African-American and Hispanic residents.

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Figure 10: Hillsborough County – Race/Ethnicity Trends (1990)

Source: HUD AFFH Data and Mapping Tool Name: Map 2 - Race/Ethnicity Variation: Race/Ethnicity Trends, 1990 Description: Past race/ethnicity dot density map for Hillsborough County and Region with R/ECAPs 71

Figure 11: Hillsborough County – Race/Ethnicity Trends (2000)

Source: HUD AFFH Data and Mapping Tool Name: Map 2 - Race/Ethnicity Trends Variation: Race/Ethnicity Trends, 2000 Description: Past race/ethnicity dot density map for Hillsborough County and Region with R/ECAPs

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Figure 12: Hillsborough County – Race/Ethnicity Trends (2010)

Source: HUD AFFH Data and Mapping Tool Name: Map 2 - Race/Ethnicity Trends Variation: Race/Ethnicity Trends, 2010 Description: Past race/ethnicity dot density map for Hillsborough County and Region with R/ECAPs 73

Region In Pinellas County, the numbers of Black/African-American residents increased between 1990 and 2000 in areas where there were already concentrations, including south St. Petersburg and areas of Clearwater near the Gulf of Mexico. Additionally, the numbers of Black/African-American, Hispanic, and Asian/Pacific Islander increased throughout much of Pinellas County in this period. Diversity increases were less pronounced in the Indian Shores/Seminole area and in northern Pinellas County. The racial and ethnic diversity of much of Pinellas County continued to increase between 2000 and 2010, with increases in the Hispanic and Asian/Pacific Islander populations also visible in the Indian Shores/Seminole Area. Parts of Clearwater had notable increases in the Hispanic population, particularly in one census tract that encompasses the southern portion of Stevenson Creek, making these areas more integrated. Additionally, the White population increased around the edges of the predominantly Black/African-American part of southern St. Petersburg, while the Black/African-American population near Clearwater Bay became somewhat less concentrated.

In Pasco and Hernando Counties, the Hispanic, Asian/Pacific Islander, and Black/African-American populations increased in the built-up areas along Highway 19 and in suburbs north of the Tampa city limits between 1990 and 2000, making these areas more integrated. Additionally, the Black/African-American and Hispanic populations increased somewhat in Brooksville and Dade City during this time period. Between 2000 and 2010, the populations of Pasco and Hernando Counties continued to become more diverse as they increased. The main increases in racial and ethnic minorities occurred in the Pasco County suburbs north of Tampa, including Zephyrhills, Wesley Chapel, and Land O’ Lakes, as well as along Highway 19 in Pasco and Hernando Counties. However, diversity increased in rural areas as well. The Black/African- American population increased in Dade City between 2000 and 2010, becoming the predominant racial/ethnic group in the downtown area. d. Consider and describe the location of owner and renter occupied housing in the jurisdiction and region in determining whether such housing is located in segregated or integrated areas, and describe trends over time.

In many cases throughout the City, County, and the region, areas with high homeownership rates are predominantly White, while areas with moderate to high rates of renter occupancy have higher concentrations of racial and ethnic minorities, as well as foreign-born and LEP residents. Some of the latter areas are racially or ethnically segregated, while others are relatively integrated. To some extent, the prevalence of protected class groups in areas with higher renter occupancy may reflect a need or preference of these residents to live in urbanized areas with access to jobs, services, and amenities. However, it may also reflect systematic exclusion of members of protected classes from homeownership opportunities.

City of Tampa Figures 13 and 14, show the location of owner-occupied housing and renter occupied housing in the City and region. In the City, some areas with high homeownership rates, such as South Tampa, Seminole Heights, and , are predominantly White. Others, including parts of New Tampa, a census tract

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south of Lowry Park and west of the Hillsborough River, and a West Tampa census tract south of I-275, are fairly integrated. Areas with a high proportion of rental housing tend to coincide with areas that have moderate to high concentrations of racial and ethnic minorities, including parts of East Tampa, Sulphur Springs, , the University Area, and West Tampa. However, some highly integrated census tracts in New Tampa have high rental rates.

Many foreign-born residents from Haiti are concentrated in areas of East Tampa with low to moderate homeownership rates, while residents from Cuba, Mexico, India, and Colombia tend to be in areas with moderate to high homeownership rates. Similarly, a number of LEP French-Creole speakers are clustered in East Tampa, while speakers of Spanish, Vietnamese, Arabic and other Asian languages are mainly located in areas with moderate to high homeownership rates.

Regionally, rural areas with high homeownership rates tend to be predominantly White, and the largely White areas of Indian Shores/Seminole and north Pinellas County also tend to have high homeownership rates. By contrast, many urban areas where racial/ethnic minorities, foreign-born residents, and LEP residents are most likely to live tend to have moderate to high rental rates. Some areas with concentrations of racial/ethnic minorities, including south St. Petersburg, the area south of Clearwater Bay, Dade City, and Brooksville, have higher rental rates. However, some areas that are relatively integrated, including some suburban Pasco County census tracts north of Tampa and a large census tract in south St. Petersburg, also have high homeownership rates.

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Figure 13: City of Tampa – Housing Tenure by Renters

Source: HUD AFFH Data and Mapping Tool Name: Map 16 - Housing Tenure Variation: Housing Tenure by Renters Description: Housing Tenure by Renters with R/ECAPs 76

Figure 14: City of Tampa – Housing Tenure by Owners

Source: HUD AFFH Data and Mapping Tool Name: Map 16 - Housing Tenure Variation: Housing Tenure by Owners Description: Housing Tenure by Owners with R/ECAPs 77

Hillsborough County Figures 15 and 16 demonstrate that in Hillsborough County, many areas with the highest homeownership rates are rural and predominantly White. By contrast, areas with moderate to high rental rates tend to be more urban and have higher concentrations of racial and ethnic minorities. The largest cluster of census tracts with high rental rates is in the predominantly Black/African-American and Hispanic University Area. However, some areas with high homeownership rates are relatively integrated, including parts of Brandon and especially the Riverview area.

Foreign-born Hillsborough County residents and those with limited English proficiency tend to live in urbanized areas with low to moderate homeownership rates. Most notably, many of the County’s Haitian residents and most of its French-Creole-speaking LEP residents live in the primarily renter-occupied University Area.

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Figure 15: Hillsborough County – Housing Tenure by Renters

Source: HUD AFFH Data and Mapping Tool Name: Map 16 – Housing Tenure Variation: Housing Tenure by Renters Description: Housing Tenure by Renters with R/ECAPS 79

Figure 16: Hillsborough County – Housing Tenure by Owners

Source: HUD AFFH Data and Mapping Tool Name: Map 16 – Housing Tenure Variation: Housing Tenure by Owners Description: Housing Tenure by Owners with R/ECAPS 80

e. Discuss whether there are any demographic trends, policies, or practices that could lead to higher segregation in the jurisdiction in the future. Participants should focus on patterns that affect the jurisdiction and region rather than creating an inventory of local laws, policies, or practices.

As the populations of racial and ethnic minorities, foreign-born persons, and people with limited English proficiency increase, they may become further clustered into specific neighborhoods, assuming that settlement patterns in the coming years are similar to those between 2000 and 2010. As discussed above, this has already occurred to some degree with Black/African-American and Hispanic residents in parts of Tampa and Hillsborough County between 2000 and 2010. The City and County should continue to monitor the demographic changes in neighborhoods within their geographic boundaries, and should intervene with policies to promote integration if areas with increased clustering of racial and ethnic minorities become segregated.

2. Additional Information a. Beyond the HUD-provided data, provide additional relevant information, if any, about segregation in the jurisdiction and region affecting groups with other protected characteristics.

Overall, families with children, seniors, and individuals with disabilities are not systematically segregated in certain parts of the City or County, nor is residential segregation on the basis of sex apparent. As Section C of this AI will show, publicly supported housing tends to be located in areas with higher minority populations, but developments serving seniors and people with disabilities are somewhat more widely distributed. b. The program participant may also describe other information relevant to its assessment of segregation, including activities such as place-based investments and geographic mobility options for protected class groups.

The City of Tampa’s Community Redevelopment Agency has designated nine Community Redevelopment Areas (CRAs) as shown in Figure 17. The CRAs are Central Park, , Downtown, Drew Park, East Tampa, Riverfront, West Tampa, I, and Ybor City II.

The Central Park, Drew Park, East Tampa, West Tampa, Tampa Heights Riverfront, and Ybor City CRAs are all in lower income areas where members of certain protected classes are concentrated. West Tampa, the City’s newest CRA, was designated in 2015. The CRA uses Tax Increment Financing to support infrastructure and streetscape improvements, small business development, cultural events, housing development, and other community development activities within the CRA districts. Notable accomplishments and ongoing activities among Tampa’s CRAs include:

• A Façade Improvement Grant Program in the East Tampa, Drew Park, and Ybor City CRAs. • A partnership between Tampa’s Neighborhood Enhancement Division and Environmental Crimes Unit to employ East Tampa youth to assist with debris and illegally dumped trash.

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• Development of The Trio at ENCORE!, a master-planned, urban mixed-use/mixed-income redevelopment venture between the Banc of America Community Development Corporation and THA. Spanning 12 city blocks and over 40 acres, ENCORE! is the catalyst for continuing redevelopment between Tampa’s Central Business District, Ybor City, Tampa Heights and other neighborhoods. The Ella and the Reed apartment buildings are in service and collectively house over 300 elderly households. The Tempo will open in August 2018 with 203 units serving all household types. Once complete, more than 2,500 people will call ENCORE! home.

• The Hillsborough County Small Business Development Center provides on-site counseling services and community workshops for small businesses in the East Tampa CRA. In addition to CRAs, the City has invested NSP funds in segregated areas. NSP-supported activities in segregated areas include:

• Development of homes for sale in Sulphur Springs, University Square, and Old West Tampa using NSP 1 funds. In Sulphur Springs specifically, NSP funds have supported the Nehemiah Project, where blighted homes were demolished and replaced with affordable homes for sale to low- and moderate-income households. In Phase I of the Nehemiah Project, which began in 2014, $1.4 million was invested to construct 12 homes on vacant lots. The groundbreaking for Phase II, which entails the construction of 24 homes, was held on September 10, 2016.

• A NSP-2 award to THA provided a layer of funding for THA’s ENCORE! developments in the Central Park CRA. The City regularly invests funds from multiple sources in segregated areas to maximize their collective impact. As shown above, West Tampa benefitted from NSP funds and was recently designated a CRA. Another notable element of Tampa’s place-based investment in segregated areas is that they support initiatives, such as youth and small business development, that may ultimately increase residents’ mobility.

While Hillsborough County has fewer segregated areas in need of investment, the County operates several programs that target or have the potential to disproportionately benefit these areas. For example, in 2016, the County developed a Redevelopment Incentives for Pilot Project Areas program, which targets business development incentives to selected low- and moderate-income areas with a primary objective of job creation, Figure 18. One of these designated areas is the University Area or Innovation Redevelopment Area, much of which is designated as a R/ECAP. The 56th Street Redevelopment Area is primarily Black/African-American, and the Palm River Redevelopment Area contains clusters of Black/African-American residents, as well as a large Hispanic population. The North Airport Redevelopment Area is sparsely populated but contains a mix of Hispanic and White residents.

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Figure 17: City of Tampa Community Redevelopment Areas

Source: City of Tampa

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Figure 18: Hillsborough County Redevelopment Areas

Source: Hillsborough County

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Development incentives in these designated Pilot Project Areas include:

• Expedited review for industrial development plans; • Assistance with permit, impact, and transportation (“mobility”) fees; • Demolition of blighted structures on lots suitable for redevelopment; • Assistance with infrastructure development; • Contaminated site assessment; • Building exterior and interior improvement; and • Small business façade improvements.

The County’s redevelopment incentives also include the Catalyst Project Incentive Program, which provides funds for significant development and redevelopment activities outside the designated Pilot Project Areas.

In addition to targeting economic development incentives to low-income and segregated areas, Hillsborough County invested NSP funds (from both NSP 1 and NSP 3) in a wide range of areas with lower incomes and/or relatively high concentrations of protected classes, including Orient Park, the University Area, Palm River/Clair Mel/Progress Village, Plant City, Town ‘N Country, and Gibsonton. NSP funds were used for purchase and rehabilitation, land banking, demolition, and redevelopment of dozens of properties in these target areas. Examples of the County’s NSP accomplishments include:

• 57 homes were purchased, rehabilitated, and sold to low- and moderate-income homebuyers in the Plant City area. Another 23 properties will be sold to low- and moderate-income homebuyers by fall 2017.

• 5 properties from the Riverview, Progress Village, Town ‘N Country, and Plant City areas were land banked for ultimate disposition to benefit low- and moderate-income households. The two Progress Village properties were transferred to Rebuilding Together Tampa Bay, a nonprofit developer, for single-family home construction. The Town ‘N Country lot is being transferred to Habitat for Humanity of Hillsborough County to develop 20 single-family homes.

• A property acquired near the James A. Haley Veterans’ Hospital in the University Area was redeveloped as the Haley Park Senior Apartments, an 80-unit multifamily development targeting veterans. The development is fully occupied.

THA offers an array of programs to help residents increase their self- sufficiency to the point that they will no longer rely on subsidized housing:

• The Resident Opportunity for Self-Sufficiency (ROSS) family program is a collaboration with local economic and community development nonprofits to provide employability skills training and job placement services to help public housing residents obtain living wage jobs. This program also connects public housing residents with supportive services, resident empowerment activities, and assistance in becoming economically self-sufficient.

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• The Family Self-Sufficiency (FSS) Program is designed to assist Project Based Voucher and Housing Choice Voucher residents in becoming economically independent and free from welfare assistance. The FSS program embraces the entire family structure with the supportive services offered to residents. These services are coordinated through various community agencies and programs to provide assistance to enhance education opportunities, job skills training, vocational training, remedial assistance, and opportunities for entrepreneurship and homeownership. Participants may accrue escrow as their income changes due to employment. THA establishes and maintains the escrow account for each participating resident until the resident completes their FSS goals and graduates from the program.

• The A+ Certification program provides training consisting of: basic electronics, basic computer technology, A+ Certification technology, Internship Program, Troubleshooting Technology and job placement assistance to THA residents.

• On-site case management and job and service fairs assist residents of Robles Park, Mary Bethune Hi-Rise residents, former Central Park Village residents, and former North Boulevard Homes residents in obtaining job training, employment, child care, transportation, and other services to help them become self-sufficient.

Additionally, THA offers programs to improve quality of life and access to opportunity for its program participants:

• The Elderly Services component of the Program and Property Services Department is designed to assist senior and disabled residents with their daily average living skills, social skills, clinical and health services.

• The Neighborhood Networks Center provides an after-school program for youth, as well as job preparation activities for both youth and adults. These programs include the After-school Tutorial Program, Oaks at Riverview Community Center, Basic Computer Literacy Training, ABE/GED Classes, Basic Microsoft Office Instructions, Job search and life skills development, and Dress for Success. All programs are connected to the Tampa Bay Workforce Alliance Programs.

3. Contributing Factors of Segregation

Identify factors that significantly create, contribute to, perpetuate, or increase the severity of segregation.

• Community opposition • Displacement of residents due to economic pressures • Lack of private investments in specific neighborhoods • Lack of public resources for investment in specific neighborhoods, including services and amenities Land use and zoning laws • Lending discrimination • Location and type of affordable housing 86

• Loss of Affordable Housing • Private discrimination • Source of income discrimination • Educational Attainment

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ii. Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs)

1. Analysis a. Identify any R/ECAPs or groupings of R/ECAP tracts within the jurisdiction and region. The AFFH rule defines a racially or ethnically concentrated area of poverty as a geographic area with significant concentrations of poverty and minority concentrations. The HUD-provided maps include outlined census tracts that meet the criteria for R/ECAPs. R/ECAPs must have a non-White population of 50% or more and have an individual poverty rate (percentage of individuals living below the poverty line) of 40% or more or a poverty rate that is three or more times the average tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

City of Tampa Figure 19 shows that the City of Tampa has five groupings of R/ECAP tracts as follows: 1. East Tampa: This R/ECAP consists of several census tracts, and is bordered to the north by E. Hillsborough Ave., to the west by N. Tampa St., 40th St. to the east and Interstate Highway 4 to the south. 2. South Ybor: This R/ECAP, located to east of the Port of Tampa, between the Selmon Expressway and E. Broadway Ave., is primarily occupied by industrial and transportation uses. 3. West Tampa: This R/ECAP consists of a single census tract immediately west of the Hillsborough River and north of I-275. 4. Sulphur Springs: This R/ECAP includes two census tracts: one that encompasses Rogers Park Golf Course and is bound by E. Hillsborough Ave. to the south, and one that is bound by E. Busch Blvd. to the north and the Hillsborough River to the south. 5. University Area: This R/ECAP, which includes multiple census tracts, is largely within unincorporated Hillsborough County. It is located to the east of N. Nebraska Avenue and is bisected by E. Fletcher Ave. The one census tract in this R/ECAP that is located in the City lies south of E. Fowler Ave. and north of E. Bougainvillea Ave.

Hillsborough County There are two R/ECAP areas in the County: 1. University Area: This R/ECAP, which includes multiple census tracts, is largely within unincorporated Hillsborough County. It is located to the east of N. Nebraska Avenue and is bisected by E. Fletcher Ave. 2. Temple Terrace: This R/ECAP consists of one census tract east of the University of South Florida (USF) and south of E. Fletcher Ave. Region There are three main areas in the region with R/ECAPs: 1. Dade City has one R/ECAP area; 2. Clearwater has one R/ECAP along US-19 Alt north of Drew St., south of Marshall St., and east to N. Betty Lane; and 3. St. Petersburg has three R/ECAP tracts.

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Figure 19: Location of R/ECAPs

Source: HUD AFFH Data and Mapping Tool

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b. Describe and identify the predominant protected classes residing in R/ECAPs in the jurisdiction and region. How do these demographics of the R/ECAPs compare with the demographics of the jurisdiction and region?

City of Tampa

Table 26 shows the number and percentage of persons living in the R/ECAPS in the City and the region by race/ethnicity. The predominant race/ethnic group residing in the R/ECAPs in the City and the region is Black/African-Americans which make up 63% of the total population in R/ECAPs in the City and 55.14% of the R/ECAP population in the region. When compared to the data in Table 11, which shows the total population in the jurisdiction and region for each of the groups, the R/ECAPs are disproportionately Black/African-American. Only 24.57% of the City’s total population and 11.15% of the region’s total population is Black/African-American. Whites are underrepresented in the R/ECAPs, making up 46.45% of the population in the City and 67.53% of the population in the region as a whole but only 14.62% and 19.77% of the R/ECAP population in the City and region, respectively. The Hispanic population in the City and region are comparable to the population in R/ECAPs.

Table 26: City of Tampa - R/ECAP by Race/Ethnicity Tampa-St. Petersburg- Tampa, FL Clearwater, FL R/ECAP Race/Ethnicity # % # % 39,224 - 79,663 - Total Population in R/ECAPs White, Non-Hispanic 5,736 14.62% 15,752 19.77% Black, Non-Hispanic 24,712 63.00% 43,924 55.14% Hispanic 7,776 19.82% 17,343 21.77% 170 0.43% 870 1.09% Asian or Pacific Islander, Non-Hispanic 115 0.29% 193 0.24% Native American, Non-Hispanic Other, Non-Hispanic 46 0.12% 119 0.15%

Source: American Community Survey (ACS), 2009-2013

Table 27 shows the number of families living in the R/ECAPs and the percentage of families with children in the City and the region. The percentage of families with children in the R/ECAPs is higher than in the City and the region as a whole. According to Table 22, 46.93% of families in Tampa have children compared to 53.68% of families in the R/ECAPs. Regionally, 40.28% of families have children compared to 52.57% of families in the R/ECAPs.

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Table 27: City of Tampa – R/ECAP by Family Type Tampa-St. Tampa, FL Petersburg- Clearwater, FL R/ECAP Family Type # % # % Total Families in 8,381 - 16,003 - R/ECAPs Families with children 4,499 53.68% 8,413 52.57%

Source: American Community Survey (ACS), 2009-2013

In terms of the foreign-born population, Table 28 shows that Haitians are more prevalent in the R/ECAPs in both the City and the region making up 2.99% of the R/ECAP population versus 0.78% of the total population in the City. Haiti is not one of the 10 most common countries of origin in the region yet Haitians account for 2.56% of the region’s R/ECAP population. Cuba, the predominant country of origin in the City as whole with 4.18% of the foreign-born population is underrepresented in the R/ECAPs.

Table 28: City of Tampa – R/ECAP by National Origin Tampa, FL Tampa-St. Petersburg-Clearwater, FL R/ECAP National Origin Country # % Country # % Total Population in R/ECAPs 38,979 - 79,663 - #1 country of origin Haiti 1,167 2.99% Haiti 2,041 2.56% #2 country of origin Cuba 892 2.29% Mexico 1,835 2.30%

#3 country of origin Honduras 516 1.32% Honduras 1,182 1.48% #4 country of origin Mexico 253 0.65% Cuba 1,146 1.44% Dominican #5 country of origin Republic 204 0.52% Jamaica 599 0.75%

#6 country of origin Nigeria 167 0.43% Colombia 396 0.50%

#7 country of origin Colombia 143 0.37% Saudi Arabia 322 0.40%

#8 country of origin Jamaica 132 0.34% Dominican Republic 234 0.29% China excl. Hong Kong #9 country of origin Canada 84 0.22% & Taiwan 221 0.28% Other #10 country of origin Caribbean 70 0.18% Nigeria 203 0.25% Source: American Community Survey (ACS), 2009-2013

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Hillsborough County Blacks/African-Americans are the predominant race/ethnic group in the County’s R/ECAPs accounting for 35.04% of the total population in R/ECAPs as shown in Table 29. When compared to the population as a whole, Table 11 indicates that Black/African-Americans comprise 12.17% of the County’s total population. Hispanic persons are overrepresented in the R/ECAPs as well, making up 31.69% of the R/ECAP population and only 25.62% of the County’s total population. Like Tampa, Whites are underrepresented in the County’s R/ECAPs at 28.04% versus 56.48% countywide.

Table 29: Hillsborough County – R/ECAP by Race/Ethnicity Tampa-St. Petersburg- Hillsborough County, FL Clearwater, FL R/ECAP Race/Ethnicity # % # % Total Population in R/ECAPs 24,885 - 79,663 - White, Non-Hispanic 6,977 28.04% 15,752 19.77% Black, Non-Hispanic 8,720 35.04% 43,924 55.14% Hispanic 7,887 31.69% 17,343 21.77% Asian or Pacific Islander, Non-Hispanic 651 2.62% 870 1.09% Native American, Non-Hispanic 62 0.25% 193 0.24% Other, Non-Hispanic 54 0.22% 119 0.15% Source: American Community Survey (ACS), 2009-2013

There are more families with children residing in the County’s R/ECAPs than in the county as a whole. Table 30 shows that 56.65% of families in the County have children while 46.02% of families countywide have children. Table 30: Hillsborough County – R/ECAP by Family Type Tampa-St. Hillsborough Petersburg- County, FL Clearwater, FL R/ECAP Family Type # % # % Total Families in R/ECAPs 4,355 - 16,003 - Families with children 2,467 56.65% 8,413 52.57% Source: American Community Survey (ACS), 2009-2013

Mexico, Haiti, and Jamaica are the top three most common countries of origin in the County’s R/ECAPs as shown in Table 31. Mexicans are slightly overrepresented in the R/ECAPs making up 3.92% of the R/ECAP population versus 2.42% of the countywide population. Haiti is not one of the top 10 countries of origin in the County as a whole and Jamaica is sixth countywide. Cuba, the most common country of origin countywide is underrepresented in the R/ECAPs, barely making the top 10.

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Table 31: Hillsborough County – R/ECAP by National Origin Tampa-St. Petersburg- Hillsborough County, FL Clearwater, FL R/ECAP National Origin Country # % Country # % Total Population in R/ECAPs 25,130 - 79,663 - #1 country of origin Mexico 986 3.92% Haiti 2,041 2.56% #2 country of origin Haiti 635 2.53% Mexico 1,835 2.30%

#3 country of origin Jamaica 256 1.02% Honduras 1,182 1.48%

#4 country of origin Honduras 236 0.94% Cuba 1,146 1.44% China excl. Hong Kong #5 country of origin & Taiwan 118 0.47% Jamaica 599 0.75% Trinidad & #6 country of origin Tobago 104 0.41% Colombia 396 0.50% Saudi #7 country of origin Colombia 64 0.25% Arabia 322 0.40% Dominican #8 country of origin Canada 58 0.23% Republic 234 0.29% China excl. Hong Kong & #9 country of origin Philippines 57 0.23% Taiwan 221 0.28% #10 country of origin Cuba 52 0.21% Nigeria 203 0.25% Source: American Community Survey (ACS), 2009-2013

c. Describe how R/ECAPs have changed over time in the jurisdiction and region (since 1990).

Figures 7-12 show past R/ECAP boundaries with demographic changes for 1990, 2000, and 2010. There have been predominantly Black/African-American R/ECAPs in East Tampa and Old West Tampa since 1990, although the boundaries have shifted over time. Between 1990 and 2000, the borders of the East Tampa R/ECAP contracted and moved southward and slightly westward, merging with a small Old West Tampa R/ECAP that had been separate in 1990. Between 2000 and 2010, however, the East Tampa R/ECAP expanded and shifted eastward and northeastward, and a separate Old West Tampa R/ECAP re-emerged. Additionally, the Sulphur Springs R/ECAP expanded to include the census tract encompassing Rogers Park Golf Course. A R/ECAP in the University Area also emerged between 2000 and 2010, including one census tract within the Tampa city limits. 93

Between 1990 and 2000, there were no R/ECAPs In Hillsborough County. By 2010, the two R/ECAPs appeared in the County in the University Area and in Temple Terrace.

2. Additional Information

a. Beyond the HUD-provided data, provide additional relevant information, if any, about R/ECAPs in the jurisdiction and region affecting groups with other protected characteristics.

Families with children, religious minorities, elderly persons, and people with disabilities are not known to be concentrated in R/ECAPs. However, the publicly supported housing analysis (Section C of this AI) shows that publicly supported housing developments are located in R/ECAPs. Developments serving seniors and people with disabilities are less concentrated in and around R/ECAPs than those designated for general occupancy but are still prevalent in these areas. To the extent that these publicly supported housing developments are a substantial share of the affordable, accessible housing stock for seniors and people with disabilities, exposure of these groups to R/ECAPs is a concern.

b. The program participant may also describe other information relevant to its assessment of R/ECAPs, including activities such as place-based investments and geographic mobility options for protected class groups.

See the discussion under the Segregation analysis (above) regarding place-based investments in Tampa and Hillsborough County’s segregated areas, which include the R/ECAPs. The East Tampa and Ybor City CRAs cover much of the East Tampa R/ECAP, and the West Tampa R/ECAP is wholly included in the West Tampa CRA. Tampa’s NSP investments in Sulphur Springs and University Square also coincide with R/ECAPs. Hillsborough County targets economic incentives and has invested NSP funds in the University Area R/ECAP.

3. Contributing Factors of R/ECAPs

Identify factors that significantly create, contribute to, perpetuate, or increase the severity of R/ECAPs.

• Community opposition • Deteriorated and abandoned properties • Displacement of residents due to economic pressures • Lack of private investments in specific neighborhoods • Lack of public resources for investment in specific neighborhoods, including services and amenities • Land use and zoning laws • Lending discrimination • Location and type of affordable housing • Loss of Affordable Housing • Private discrimination 94

• Source of income discrimination • Educational Attainment

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iii. Disparities in Access to Opportunity

1. Analysis

a. Education i. For the protected class groups HUD has provided data, describe any disparities in access to proficient schools in the jurisdiction and region. Table 32 shows the school proficiency index in the City, County, and the region. The school proficiency index measures which neighborhoods have high-performing elementary schools nearby and which neighborhoods are close to lower performing elementary schools. A higher value indicates higher levels of school proficiency.

The school proficiency index captures academic achievement by 4th graders based on state exam scores. HUD uses 4th grade achievement because elementary schools collect students from a far more limited geography than do middle and high schools and elementary schools are more likely to have neighborhood- based enrollment policies. Therefore, elementary school proficiency is a better proxy for neighborhood opportunity than are middle and high schools.

Table 32: School Proficiency Index School Proficiency Index Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL Total Population White, Non-Hispanic 57.38 52.00 50.91 Black, Non-Hispanic 29.93 36.79 38.78 Hispanic 40.10 42.35 43.61 Asian or Pacific Islander, Non-Hispanic 61.02 54.05 50.16 Native American, Non- Hispanic 43.59 44.24 44.47 Population below federal poverty line White, Non-Hispanic 47.31 40.89 42.75 Black, Non-Hispanic 28.62 33.61 35.45 Hispanic 35.31 33.37 35.34 Asian or Pacific Islander, Non-Hispanic 59.13 38.31 41.86 Native American, Non- Hispanic 32.38 24.75 28.99 Source: Great Schools (proficiency data), 2013-14; Common Core of Data (4th grade enrollment and school addresses), 2013- 14; Maponics School Attendance Zone database, 2016 96

City of Tampa There are significant disparities in the school proficiency index, especially when considering the different races/ethnicities represented in the index. In Tampa, Asians/Pacific Islanders have the greatest access to quality schools, with an index value of 61.02. Second in terms of access to quality schooling is Whites, with a score of 57.38. These values stand in contrast to the Black/African-American index value at 29.93 and Hispanics at 40.10.

When examining index values in the City compared to values in the region, the Black/African-American and Hispanic populations have better access to proficient schools in the region than in the City. Conversely, the Asian/Pacific Islander and White populations have lower access to proficient schools in the region compared to the schools in the City.

Historically, differences in school quality are often attributed to the degree of wealth in the surrounding community – a high quality school with excellent test results, graduation rates, and programs can achieve results through increased spending and the relative wealth of its student families. On the other hand, underfunded schools generally exhibit lower student performance, increased rates of truancy and abandonment of neighborhoods by wealthy and stable families. Therefore, when examining school performance, it is reasonable to expect a connection between high poverty neighborhoods and poor school performance, and it is difficult to identify broad patterns of discrimination against the protected classes.

Table 32 also includes school proficiency index scores by race/ethnicity for populations below the federal poverty line. Regardless of race/ethnicity, persons living below the federal poverty level experience lower levels of school proficiency. However, after examining the difference in index values for populations above and below the federal poverty line, it becomes clear that Blacks/African-Americans in the City, County, and region experience the lowest difference in school quality based on the poverty threshold. Whites experience a 10.07-value difference between those out of poverty and those within, while Blacks/African- Americans experience only a 1.31-value difference between those in poverty and those above the threshold. These figures indicate that Black/African-American families live in communities with the lowest quality schools, and this disparity cannot be explained solely based on neighborhood wealth.

Hillsborough County When reviewing the school proficiency index scores in the County, the disparities are not as stark as those seen in the City. The difference between Whites and Blacks/African-Americans, for instance, is 15.21 compared to 27.45 in the City. This is certainly an improvement over disparities seen in the City, but still a noticeable difference. As with the City, both Blacks/African-Americans and Hispanics experience the lowest quality schools in the County, and Asians/Pacific Islanders and Whites experience access to the highest quality schooling.

When examining index values in the County compared to values in the region, the values are similar. For instance, Blacks/African-Americans have a value of 38.78 in the region compared to 36.79 in the County.

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Only Whites and Asians/Pacific Islanders have better access to proficient schools in the County compared to the region.

When examining the difference in index values for the County between populations living above the federal poverty line and those living in poverty, there is a noticeable improvement in values compared to the City. The difference for Blacks/African-Americans is 3.18 in the County, compared to the City’s value of 1.31. While this value still indicates the Black/African-American population in the County suffers from low access to proficient schools, regardless of income status, Blacks/African-American families with higher incomes in the County are more likely to access a proficient school compared to Blacks/African-Americans in the City. It is also important to note the dramatic difference in access to proficient schools for the County’s Asian/Pacific Islander population (15.74) compared to the difference for the same population in the City (1.89).

ii. For the protected class groups HUD has provided data, describe how the disparities in access to proficient schools relate to residential living patterns in the jurisdiction and region.

Figures 20 through 26 shows residential living patterns by race/ethnicity, national origin, and familial status compared to the location of proficient schools in the City and the County. The maps show values for the school proficiency index with shading at the neighborhood level. Darker shaded areas indicate better access to high proficiency schools and lighter shading indicates lower index values, with these neighborhoods being near lower performing elementary schools.

City of Tampa Figure 20 provides further evidence of disparities in access to quality schools in the City. In general, there are concentrations of Blacks/African-Americans and Hispanics in low-quality school neighborhoods compared to the quality of schools available to Whites. Many of these neighborhoods overlap with the R/ECAP areas. When looking specifically at R/ECAPs in the City, residents of these communities experience some of the poorest quality schools in the region. Minorities in general, especially Blacks/African- Americans, are concentrated in the City’s R/ECAP areas and left with few opportunities for accessing quality schools. Four neighborhoods in particular deserve specific attention: Sulphur Springs, , Tampa Heights, and the University Area.

There are current efforts to address school quality concerns in these communities. In Sulphur Springs, for instance, a collaborative effort called the Sulphur Springs Neighborhood of Promise (SSNOP) has been developed to help school quality concerns in the Sulphur Springs neighborhood. The collaborative reports on standard measures of school proficiency and quality of schooling each year, and has shown some progress on reading, math, and school grades according to the Florida Department of Education’s criteria (www.ssnop.org/reports/).

HUD also provides school proficiency maps for national origin and familial status. When examining the map of school proficiency by national origin, Figure 21, there is a large population of Cubans living in

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communities with poor quality schools. The Hillsborough Public School system should concentrate on ensuring schools in the West Tampa area have access to Spanish-fluent teachers, and individuals well- versed in cultural norms specific to Cuban-Americans.

While quality schools serve as a benefit for all households, access to quality schools is particularly important to families with children. HUD provides data on the location of families with children relative to neighborhoods with good quality schools as shown in Figure 22. After reviewing the data, it is difficult to determine any broad trends or conclusions specific to familial status and access to quality schools. Certain areas have excellent quality schools with a vast majority of families with children – South Tampa, for instance. Many of the lower scoring areas in terms of school quality have a relatively lower portion of families with children.

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Figure 20: City of Tampa – School Proficiency and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 7 - Demographics and School Proficiency Variation: School Proficiency and Race/Ethnicity Description: School Proficiency Index for City of Tampa and Region with race/ethnicity and R/ECAPs Note: Darker shaded areas indicate better access to high proficiency schools and lighter shading indicates access to lower performing schools 100

Figure 21: City of Tampa – School Proficiency and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 7 - Demographics and School Proficiency, Variation: School Proficiency and National Origin Description: School Proficiency Index for City of Tampa and Region with national origin and R/ECAPs Note: Darker shaded areas indicate better access to high proficiency schools and lighter shading indicates access to lower performing schools 101

Figure 22: City of Tampa – School Proficiency and Familial Status

Source: HUD AFFH Data and Mapping Tool Map 7 - Demographics and School Proficiency, Variation: School Proficiency and Family Status Description: School Proficiency Index for City of Tampa and Region with race/ethnicity, national origin, family status, and R/ECAPs Note: Darker shaded areas indicate better access to high proficiency schools and lighter shading indicates access to lower performing schools 102

Hillsborough County Figure 23 shows race/ethnicity living patterns and school proficiency by neighborhood in the County. In general, Whites and Asians/Pacific Islanders live in areas with high school proficiency index values, particularly in the County’s north and northwest suburbs, as well as in the County’s communities to the east, including Lithia. Asians/Pacific Islanders are often found in the County’s north and northwest communities. Blacks/African-Americans and Hispanics, on the other hand, are primarily found along the I-4 corridor and census tracts bordering the City. These communities generally suffer from low school proficiency index values, particularly those census tracts to the east of Tampa.

There are also disparities in school quality based on national origin as shown in Figure 24. The more rural parts of the County, to the east and south of the City, have high concentrations of Mexicans and Colombians in areas with poor performing schools. In particular, along the I-4 corridor heading east in the County, one can see high concentrations of Mexican immigrants living near low-quality schools.

Figure 25 provides data on the location of families with children relative to neighborhoods with good quality schools. After reviewing the data, it is difficult to determine any broad trends or conclusions specific to familial status and access to quality schools.

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Figure 23: Hillsborough County – School Proficiency and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 7 - Demographics and School Proficiency Variation: School Proficiency and Race/Ethnicity Description: School Proficiency Index for Hillsborough County and Region with race/ethnicity and R/ECAPs Note: Darker shaded areas indicate better access to high proficiency schools and lighter shading indicates access to lower performing schools 104

Figure 24: Hillsborough County – School Proficiency and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 7 - Demographics and School Proficiency Variation: School Proficiency and National Origin Description: School Proficiency Index for Hillsborough County and Region with national origin and R/ECAPs Note: Darker shaded areas indicate better access to high proficiency schools and lighter shading indicates access to lower performing schools

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Figure 25: Hillsborough County – School Proficiency and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 7 - Demographics and School Proficiency Variation: School Proficiency and Family Status Description: School Proficiency Index for Jurisdiction and Region with race/ethnicity, national origin, family status, and R/ECAPs Note: Darker shaded areas indicate better access to high proficiency schools and lighter shading indicates access to lower performing schools

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iii. Informed by community participation, any consultation with other relevant government agencies, and the participant’s own local data and local knowledge, discuss programs, policies, or funding mechanisms that affect disparities in access to proficient schools.

There are several school choice options available to students in Hillsborough County Public Schools (HCPS) including, attendance area, magnet programs, school choice, and charter schools. Attendance area is the traditional method of school assignment based on a student’s home address. School choice allows families to choose schools throughout the district where space is available. School choice options include magnet schools and programs which are available at the elementary, middle, and high school levels and offer theme-based curriculum in smaller learning environments like Science, Technology, Engineering, Arts, and Math (S.T.E.A.M) and International Baccalaureate (IB). Charter schools are independent public schools operated by a non-profit organization. All students in the school district can apply to any charter school of their choice.

Even with these school options that impact access to proficient schools, local data and knowledge support the findings of the analysis of the HUD-provided data. Table 33, provides an examination of the poorest performing schools in Hillsborough County, according to the Florida Department of Education’s grades in its School Accountability Report. The data show that all nine schools with a 2016 ‘F’ grade have an 80% or more minority student population and have extremely high percentages of economically disadvantaged students.

Table 33: Florida Department of Education Lowest Performing Schools Florida Department of Education 2016 Schools with an ‘F’ grade in Tampa and Hillsborough County School Name 2016 Percent Percent Economically Jurisdiction Grade Minority Disadvantaged Students Dunbar Elementary F 91 88 Tampa School Forest Hills Elementary F 84 96 Tampa School Edison Elementary School F 95 97 Tampa

Potter Elementary School F 98 100 Tampa

Shaw Elementary School F 94 98 Hillsborough

Village of Excellence F 99 100 Tampa Academy Miles Elementary School F 87 98 Tampa Washington Elementary F 97 99 Tampa School Kings Kids Academy of F 100 98 Tampa Health Sciences Source: Florida Department of Education school grades, available at: http://schoolgrades.fldoe.org/.

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Challenges for minority students extend across the County. An analysis of Hillsborough County elementary students reveals significant differences in math achievement by race/ethnicity. According to data from the Florida Department of Education PK-20 Education Data Warehouse, of the major race/ethnicity categories, Black/African-Americans and Hispanic students had the lowest mathematics achievements in the County in grades 3 to 8 for 2015, with 35.7% and 47.3%, respectively. In the same year, White and Asian students have the highest rates of math achievement at 70.3% and 86.9%, respectively.

HCPS is aware of challenges with concentrated poverty and poor student performance in certain schools. HCPS has engaged in several school boundary change and realignments to better position its students, and their families, for success in school. This is a particularly important initiative in those neighborhoods that struggle the most with school quality, including Sulphur Springs. Starting in August of 2015, for instance, the Sulphur Springs Elementary school was renamed and converted into the Sulphur Springs K- 8 Community School. The goal of this change was to facilitate better attendance rates and continuity of attendance for students who would have previously attended a different school starting in the sixth grade.

It should be noted that there have been some efforts to address disparities in access to opportunity for protected classes, and for public housing residents in Tampa. For instance, Blake High School, located in the West Tampa area and adjacent to North Boulevard Homes, received over $50 million in renovations, and now offers a superior facility for one of the City’s most impoverished communities.

The topic of school quality, particularly the quality of schools near R/ECAPs and accessible to protected classes, was a part of the discussion during community meetings for this AI. Residents who attended community meetings across the region described poor physical school conditions, safety concerns for students within school walls and in surrounding neighborhoods, and challenges with busing and transportation options for students.

HCPS has adopted policies aimed at integrating school districts by race/ethnicity and income status. Following a lift on court-ordered busing in 2001, HCPS could no longer assign students to schools based on race. Because the school system respected the need for integration and believed in the benefits of integration for its students and student families, HCPS designed the choice system, where families could opt to send their children to suburban schools or send their child to a magnet program. The plan ultimately ran into significant challenges when fewer families than expected elected to send their children to suburban schools, and magnet programs within Tampa attracted a higher turnout than expected. The result was an insufficient number of seats within Tampa, forcing HCPS to bus students for miles to suburban schools (Marlene Sokol, “Bused and Broken: Years of district policy threw Brandon’s McLane Middle School into turmoil”, Tampa Bay Times, 4/3/15, link).

Busing challenges continue for HCPS, with a December 2016 vote by the Hillsborough County School Board voting 6 – 1 to end bus transportation for thousands of middle and high school students in the district who live within two miles of their schools (Marlene Sokol, “Courtesy busing cuts clear the Hillsborough School Board, affecting 7,500 students”, Tampa Bay Times, 12/6/16, link). The students most affected by having to walk two miles to school are those living in communities with high rates of crime, high traffic speeds, and poor pedestrian infrastructure. 108

b. Employment

i. For the protected class groups HUD has provided data, describe any disparities in access to jobs and labor markets by protected class groups in the jurisdiction and region.

Table 34 shows the jobs proximity index in the City, County, and the region. The jobs proximity index measures the physical distance between place of residence and jobs by race/ethnicity. Higher job proximity values represent better access to jobs and greater engagement in the labor market.

Table 34: Jobs Proximity Index Jobs Proximity Index Tampa-St. Hillsborough Petersburg- Tampa, FL County, FL Clearwater, FL Total Population White, Non-Hispanic 54.06 45.04 48.39 Black, Non-Hispanic 49.02 47.23 46.56 Hispanic 53.14 46.53 48.23 Asian or Pacific Islander, Non-Hispanic 50.15 45.26 49.24 Native American, Non-Hispanic 53.24 46.96 48.58 Population below federal poverty line White, Non-Hispanic 53.51 48.30 50.21 Black, Non-Hispanic 46.36 52.38 47.11 Hispanic 49.35 50.29 50.35 Asian or Pacific Islander, Non-Hispanic 37.89 46.17 45.50 Native American, Non-Hispanic 50.73 56.30 50.84

Source: Longitudinal Employer-Household Dynamics (LEHD), 2014

City of Tampa The data reveal that in Tampa, Whites have the greatest job proximity at 54.06, followed closely by Native Americans at 53.24, Hispanics at 53.14, and Asian/Pacific Islanders at 50.15. Blacks/African-Americans represent the race/ethnicity with the least job proximity at 49.02. Native Americans and Asian/Pacific Islanders represent approximately 3.5% of the City’s population. Due to the small size of these groups, the jobs proximity index may be high even if the group’s members are not as close to jobs as the larger populations.

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When further analyzing the data, income level makes a slight contribution to job proximity since the values decrease for persons living below the federal poverty line. For the population below the federal poverty line, Whites have the greatest job proximity at 53.51, followed closely by Native Americans at 50.73, Hispanics at 49.35 and Blacks/African-Americans at 46.36. There is a shift in which race/ethnicity below the poverty line has the least proximity to jobs with Asians/Pacific Islanders representing the lowest value at 37.89. Again, caution should be taken when interpreting the job proximity indices for Native Americans and Asian/Pacific Islanders.

An important trend to note is when comparing race/ethnicities above and below the poverty line Whites have nearly the same proximity values (54.06 and 53.51 respectively), while minorities have a greater disparity in values. This trend demonstrates that regardless of income, minorities have the least job proximity compared to Whites overall.

Regionally, job proximity for the total population is lower for all race/ethnicities when compared to the City. However, minorities in the region, living below the federal poverty line have closer job proximity than those in the City.

Hillsborough County In Hillsborough County, Blacks/African-Americans have the greatest job proximity at 47.23, followed closely by Native Americans at 46.96, Hispanics at 46.53, and Asian/Pacific Islanders at 45.26. Unlike Tampa, Whites represents the race/ethnicity with the lowest value for job proximity for the general population at 45.04.

This trend slightly changes for the population below the poverty line with Native Americans having the greatest job proximity at 56.30, followed closely by Blacks/African-Americans at 52.38, Hispanics at 50.29, and Whites at 48.30. For the population below the poverty line, Asian/Pacific Islanders represent the race/ethnicity with the lowest value for job proximity at 46.17.

When compared to the County, residents in the region have better access to jobs with the exception of Black/African-Americans. For the population below the federal poverty line, Whites and Hispanics in the region have closer proximity to jobs than those in the County at 50.21 and 50.35 versus 48.30 and 50.29, respectively. Conversely, Blacks/African-Americans, Asian/Pacific Islanders, and Native Americans in the region have lower job proximity values than those in the County indicating that they live further away from where the jobs are located.

Table 35 shows the labor market engagement index which provides a measure of unemployment rate, labor-force participation rate, and percent of the population ages 25 and above with at least a bachelor’s degree, by neighborhood. A higher value indicates higher level of labor engagement.

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Table 35: Labor Market Index Labor Market Index Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL Total Population White, Non-Hispanic 64.46 54.82 47.28 Black, Non-Hispanic 22.32 44.93 34.52 Hispanic 40.57 45.69 42.97 Asian or Pacific Islander, Non-Hispanic 66.08 61.27 54.96 Native American, Non- Hispanic 45.05 48.63 41.34 Population below federal poverty line White, Non-Hispanic 50.46 47.20 37.91 Black, Non-Hispanic 18.72 34.92 25.83 Hispanic 31.93 35.86 33.77 Asian or Pacific Islander, Non-Hispanic 54.09 50.80 43.56 Native American, Non- Hispanic 31.58 29.48 30.54

Source: American Community Survey (ACS), 2009-2013

City of Tampa There is a significant difference in the values for labor market engagement in the City indicating an unequal participation in the labor market amongst different race/ethnicities. Asian/Pacific Islanders represent the race/ethnicity having the greatest engagement in the labor market at 66.08 followed closely by Whites at 64.46. Compared to the race/ethnicities with the greatest engagement in the labor market, values start to decrease for Native Americans at 45.05 and Hispanics at 40.57. Blacks/African-Americans have the lowest level of labor market engagement at 22.32.

Poverty level has an even greater impact on labor market engagement with values dropping significantly for the population below the federal poverty line across all race/ethnicities. The data show the same pattern as the population above the poverty line, with Asian/Pacific Islanders having the greatest engagement in the labor market at 54.09 followed by Whites at 50.46. Hispanics and Native Americans 111

follow with marginal engagement in the labor market at 31.93 and 31.58, respectively and similar to the general population, Blacks/African-Americans (18.72) demonstrate the least engagement in the labor market for populations below the poverty line.

Regionally, the trend for the population above and below the poverty line are the same with Asian/Pacific Islanders experiencing the greatest labor market engagement, followed by Whites, Hispanics, Native Americans, and Blacks/African-Americans. This pattern also mimics the trends identified for the City’s population below the poverty line.

Hillsborough County Labor market engagement patterns in the County are consistent with that of the City as far as which race/ethnicities are shown to be more or less engaged in the labor market. However, value margins in the County are not nearly as great as the City’s margins. Table 35 shows Asian/Pacific Islanders as having the greatest participation in the labor market at 61.27, followed by Whites at 54.82, Native Americans at 48.63, and Hispanics at 45.69. Blacks/African-Americans in the County have the lowest value for labor market engagement at 44.93.

Asian/Pacific Islanders also lead in labor market engagement for the County’s population under the poverty line with a value of 50.80. Whites have the second highest level of engagement for the population below the federal poverty line at 47.20. There is a slight change in the pattern from the general population, with Hispanics having the third greatest value followed by Blacks/African- Americans at 35.86 and 34.92, respectively. Labor market engagement values for the County indicate that for the population below the poverty line, Native Americans have the lowest value at 29.48, which differs from that of the County’s general population values.

Regionally, trends for the population above the poverty line are similar to that of the County with the exception that Hispanic values for labor engagement are greater than Native Americans. For the population below the poverty line, regional trends differ from that of the County. Though Asian/Pacific Islanders and Whites are still the race/ethnicities experiencing the greatest labor market engagement regionally, Black/African-Americans in the region have the least labor market engagement while County values identify Native Americans as having the least value for labor market engagement.

ii. For the protected class groups HUD has provided data, describe how disparities in access to employment relate to residential living patterns in the jurisdiction and region.

Figures 26 through 37 show residential living patterns by race/ethnicity, national origin, and familial status compared to the location of jobs in the City and the County. Figures 26 through 31 show values for the job proximity index and figures 32 through 37 show values for the labor market engagement index with shading at the neighborhood level. Darker shaded tracts indicate a higher (better) value for the index being used. Therefore, darker shaded tracts would indicate closer proximity to jobs or a higher level of labor engagement for the households living there. Lighter shaded tracts show lower (worse) index values for these index measures.

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Job Proximity

City of Tampa Tampa has major employers in each quadrant of the City. Tampa International Airport is located in the West, MacDill Airforce in the South, and the University of South Florida in the North. Downtown Tampa is also the central business district located in East Tampa. The location of major employers is what allows the disparity in proximity to jobs to remain low. Figure 26 demonstrates that for Asians, the disparity in jobs proximity above and below the poverty line is because there are two main areas in the City where Asians live: South Tampa and New Tampa. Major employers are not located in these areas, resulting in low job proximity for Asians.

Figure 27 shows that Cubans, Mexicans and Haitians have greater job proximity to the R/ECAP area of East Tampa and surrounding areas. There is also a concentration of Cubans near the Tampa International Airport, which is also a major employer in the City.

Figure 28 also shows that a large percentage of households that have families with children have the greatest proximity to jobs in R/ECAP areas, specifically East Tampa.

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Figure 26: City of Tampa – Job Proximity and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 8 - Demographics and Job Proximity Variation: Job Proximity and Race/Ethnicity Description: Jobs Proximity Index for City of Tampa and Region with race/ethnicity and R/ECAPs Note: Darker shaded tracts indicate closer proximity to jobs 114

Figure 27: City of Tampa – Job Proximity and National Origin

Source: HUD AFFH Data and Mapping Tool Map 8 - Demographics and Job Proximity Variation: Job Proximity and National Origin Description: Jobs Proximity Index for City of Tampa and Region with national origin and R/ECAPs Note: Darker shaded tracts indicate closer proximity to jobs 115

Figure 28: City of Tampa – Job Proximity and Familial Status

Source: HUD AFFH Data and Mapping Tool Map 8 - Demographics and Job Proximity Variation: Job Proximity and Family Status Description: Jobs Proximity Index for City of Tampa and Region with family status and R/ECAPs Note: Darker shaded tracts indicate closer proximity to jobs 116

Hillsborough County According to Figure 29, Whites have proximity to jobs both to the east and west of Tampa, slightly further out from city limits which, is the hub for the region’s main labor industries, but also where housing costs are higher. This could be an indication that Whites have higher incomes and greater access to personal vehicles for transportation to and from employment. Whites below the poverty level have better access to jobs than Whites above the poverty level, indicating that they are living closer to city limits where housing is more affordable. Blacks/African-Americans residing within the County also have greater proximity to jobs closer to city limits or within Tampa, but also largely in R/ECAP areas. Again, this is where housing is more affordable and living closer to the urban core or on the outskirts of city limits allows for greater proximity to major employers. Residing closer to city limits also allows for greater access to public transportation. Hispanics have greater proximity to jobs west of Tampa and in the southern portion of the County surrounding the Bay. Asian/Pacific Islanders have greater job proximity in the northwest portions of the County.

Figure 30 shows that Cubans and Columbians have the greatest job proximity in the northwest region of the County, while persons originating from Mexico and India have greater job proximity to central and northeast Hillsborough County.

Figure 31 suggests that a large percentage of households comprised of families with children have the greatest proximity to jobs outside R/ECAP areas in the southern portion of the County and some closer to the Bay.

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Figure 29: Hillsborough County- Job Proximity and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 8 - Demographics and Job Proximity Variation: Job Proximity and Race/Ethnicity Description: Jobs Proximity Index for Hillsborough County and Region with race/ethnicity and R/ECAPs Note: Darker shaded tracts indicate closer proximity to jobs 118

Figure 30: Hillsborough County – Job Proximity and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 8 - Demographics and Job Proximity Variation: Job Proximity and National Origin Description: Jobs Proximity Index for Hillsborough County and Region with national origin and R/ECAPs Note: Darker shaded tracts indicate closer proximity to jobs 119

Figure 31: Hillsborough County – Job Proximity and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 8 - Demographics and Job Proximity Variation: Job Proximity and Family Status Description: Jobs Proximity Index for Hillsborough County and Region with family status and R/ECAPs Note: Darker shaded tracts indicate closer proximity to jobs 120

Labor Market Engagement

City of Tampa

Figure 32 demonstrates labor market engagement in relation to geographic and R/ECAP areas within the City. Analysis indicates that Whites and Hispanics have greater labor market engagement outside of R/ECAP areas while Blacks/African Americans tend to engage in the labor market within the R/ECAP areas.

Cubans, Mexicans, and Haitians show greater labor market engagement in the East Tampa R/ECAP area and its surrounding areas, particularly in the western region of the City as shown in Figure 33.

Figure 34 demonstrates that households comprised of families with children that are engaged in the labor market are dispersed relatively evenly throughout the City with a slightly greater amount of those households located close to or in R/ECAP areas.

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Figure 32: City of Tampa – Labor Market and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 9 - Demographics and Labor Market Variation: Labor Market and Race/Ethnicity Description: Labor Engagement Index with race/ethnicity and R/ECAPs Note: Darker shaded tracts indicate a higher level of labor engagement 122

Figure 33: City of Tampa – Labor Market and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 9 - Demographics and Labor Market Variation: Labor Market and National Origin Description: Labor Engagement Index with national origin and R/ECAPs Note: Darker shaded tracts indicate a higher level of labor engagement 123

Figure 34: City of Tampa – Labor Market and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 9 - Demographics and Labor Market Variation: Labor Market and Family Status Description: Labor Engagement Index with family status and R/ECAPs Note: Darker shaded tracts indicate a higher level of labor engagement 124

Hillsborough County Analysis of Figure 35 shows labor market engagement for Whites mostly occurs centrally within the County, east of Tampa and also in northwest Hillsborough County outside R/ECAP areas. Blacks/African- Americans labor market engagement remains strong within City limits and in or near R/ECAP areas while Hispanic labor market engagement is scattered throughout the County but mostly east of the Bay.

Figure 36 shows that Cubans and Columbians have greater labor market engagement in the northwest region of the County while persons of Mexican and Indian origin have greater labor engagement in the northeast region of the County.

Households comprised of families with children that engage in the labor market tend to be located in the northern and eastern portions of the County, according to Figure 37.

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Figure 35: Hillsborough County – Labor Market and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 9 - Demographics and Labor Market Variation: Labor Market and Race/Ethnicity Description: Labor Engagement Index with race/ethnicity and R/ECAPs Note: Darker shaded tracts indicate a higher level of labor engagement 126

Figure 36: Hillsborough County – Labor Market and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 9 - Demographics and Labor Market Variation: Labor Market and National Origin Description: Labor Engagement Index with national origin and R/ECAPs Note: Darker shaded tracts indicate a higher level of labor engagement 127

Figure 37: Hillsborough County- Labor Market and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 9 - Demographics and Labor Market Variation: Labor Market and Family Status Description: Labor Engagement Index with race/ethnicity, national origin, family status and R/ECAPs Note: Darker shaded tracts indicate a higher level of labor engagement 128

iii. Informed by community participation, any consultation with other relevant government agencies, and the participant’s own local data and local knowledge, discuss whether there are programs, policies, or funding mechanisms that affect disparities in access to employment.

It is not uncommon for there to be disparities between housing location and access to employment. Community participation identified transportation as an impeding factor of this relationship. Many low- income persons do not have reliable transportation which is critical to obtaining and maintaining employment. If a person’s place of residence is not adequately accessible to public transportation, the ability to obtain employment decreases significantly.

Access to transportation is not only directly related to the ability to obtain employment it also indirectly links other impeding factors that are critical to obtaining employment, such as adequate access to childcare. Childcare is often looked at as a secondary impeding factor to obtaining employment however, it is a critical part of the equation. Thus, if housing location is not accessible to transportation, access to childcare providers, as well as employment is compromised.

Housing location can also affect obtaining employment within a reasonable distance. Often time bus lines have limited routes or require riders to have connecting routes to reach their final destination. Depending on housing location, certain areas may not be conducive to obtaining employment based on travel time. Types of employment may also be limited along bus lines.

c. Transportation

i. For the protected class groups HUD has provided data, describe any disparities in access to transportation related to costs and access to public transit in the jurisdiction and region.

Table 36 shows the transit trips index in the City, County, and the region. The transit trip index measures how often low-income families in a neighborhood use public transportation. A higher value indicates better access to transportation.

Table 36: Transit Index Transit Index Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL Total Population White, Non-Hispanic 49.84 37.99 40.45 Black, Non-Hispanic 49.68 42.16 44.26 Hispanic 49.44 41.83 41.91

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Transit Index Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL Asian or Pacific Islander, Non-Hispanic 48.35 41.43 42.06 Native American, Non- Hispanic 49.47 39.13 40.58 Population below federal poverty line White, Non-Hispanic 49.61 41.67 41.98 Black, Non-Hispanic 51.19 46.92 47.46 Hispanic 51.11 43.34 43.84 Asian or Pacific Islander, Non-Hispanic 48.42 49.55 46.64 Native American, Non- Hispanic 54.87 45.11 45.51

Source: Location Affordability Index (LAI) data, 2008-2012

City of Tampa When measuring how often low-income families in Tampa use public transportation, the data are similar for all racial/ethnic groups. Whites represent the race/ethnicity with the highest usage rates at 49.84 followed very closely by Blacks/African-Americans at 49.68, Native Americans at 49.47, and Hispanics at 49.44. Asian/Pacific Islanders use public transportation the least at 48.35.

The values for the population below the poverty line are generally higher than the values for the general population, indicating that the population below the poverty line uses public transportation slightly more than persons not considered to be in poverty. Native Americans have the highest usage rate at 54.87, followed by Blacks/African-Americans at 51.19, Hispanics at 51.11, and Whites at 49.61. The race/ethnicity showing the lowest usage rate is Asian/Pacific Islanders at 48.42.

Compared to the region, families in the City have better access to public transportation regardless of income. Blacks/African-Americans in the region use public transportation more frequently than any other race/ethnic group.

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Hillsborough County There is more disparity in the transit index values in the County than in the City. Additionally, the values in the County are lower than those in the City and the region indicating that families in the County use public transportation at a lower rate. Blacks/African Americans have the highest public transportation usage rate at 42.16, followed by Hispanics at 41.83, Asian/Pacific Islanders at 41.43, and Native Americans at 39.13. Whites show the lowest usage rate within the County at 37.99.

The population below the federal poverty level have higher values that the general population however, usage patterns based on race/ethnicity vary with Asian/Pacific Islanders having the highest value at 49.55, followed by Blacks/African-Americans at 46.92, Native Americans at 45.11, and Hispanics at 43.34. White families in the general population and below the federal poverty level have the lowest value for usage of public transportation.

The region has higher transit index values than the County for all race/ethnic groups with the exception of Asian/Pacific Islanders living below the federal poverty level.

Table 37 shows the low transportation cost index which measures cost of transportation and proximity to public transportation by neighborhood. Higher values indicate lower transportation costs or greater access to public transportation.

Table 37: Low Transportation Cost Index Low Transportation Cost Index Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL Total Population White, Non-Hispanic 52.89 31.90 36.08 Black, Non-Hispanic 54.69 41.20 44.90 Hispanic 55.03 39.16 40.62 Asian or Pacific Islander, Non-Hispanic 48.26 37.33 39.78 Native American, Non- Hispanic 54.41 35.34 37.90 Population below federal poverty line White, Non-Hispanic 55.28 38.85 39.49 Black, Non-Hispanic 56.86 49.50 50.27

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Low Transportation Cost Index Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL Hispanic 57.98 41.89 44.46 Asian or Pacific Islander, Non-Hispanic 50.92 48.40 47.32 Native American, Non- Hispanic 62.75 45.70 46.32

Source: Location Affordability Index (LAI) data, 2008-2012

City of Tampa For the City, Hispanics represent the race/ethnicity having the lowest cost and greatest proximity to public transportation at 55.03 followed by Blacks/African-Americans at 54.69, Native Americans at 54.41, and Whites at 52.89. The race/ethnicity experiencing higher costs or the least proximity to public transportation is Asian/Pacific Islanders at 48.26.

When considering income, the data indicate inequality between the general population and population below the federal poverty line in access to transportation. Native Americans have the lowest transportation costs and greatest proximity to transit at 62.75, followed by Hispanics at 57.98, Blacks/African-Americans at 56.86, and Whites at 55.28. The race/ethnicity below the poverty line experiencing the highest cost or least access is Asian/Pacific Islanders at 50.92.

Regionally, for the population above the poverty line, there is a greater disparity in values in the region than for the City and the values in the region are lower for all race/ethnic groups indicating that persons residing in the region have higher transportation costs or less access to transit than those in the City. This is true for both the general population and the population below the federal poverty level because of the greater distance from their homes to transit.

Hillsborough County For the total population in the County, Blacks/African-Americans experience the lowest cost and greatest access to public transportation at 41.20, followed by Hispanics at 39.16, Asian/Pacific Islanders at 37.33, and Native Americans at 35.34. The race/ethnicity experiencing the highest cost and least access is Whites at 31.90.

For the population below the poverty line, Blacks/African Americans experience the lowest cost and greatest access at 49.50, followed by Asian/Pacific Islanders at 48.40, Native Americans at 45.70, and Hispanics at 41.89. These race/ethnicity trends are slightly different from the general population however, Whites still experience the highest cost and least access to public transportation at 38.85.

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Generally, residents in the region have slightly better access to transportation and lower transportation costs than persons residing in the County.

ii. For the protected class groups HUD has provided data, describe how disparities in access to transportation related to residential living patterns in the jurisdiction and region.

Transit Trips

City of Tampa Figure 38 analyzes demographics and transit trips and identifies public transportation patterns for low- income families in the City. Data indicate that Blacks/African-Americans transit patterns are concentrated in the East Tampa R/ECAP area and just north of that. For Whites, transit trips tend to be in South Tampa, outside of R/ECAP defined areas and Hispanic transit patterns navigate towards West/Central Tampa and outside City limits into Hillsborough County.

Figure 39 shows the transit trip patterns for Cubans and Mexicans focus just west of East Tampa and the Sulphur Springs R/ECAP areas while Haitian transit trip patterns cluster in the East Tampa R/ECAP area.

Figure 40 shows that a large portion of households comprised of families with children are scattered throughout the City and their transit patterns, like other protected groups, are concentrated in the City but also extend into the county to a lesser degree.

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Figure 38: City of Tampa – Transit Trips and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 10 - Demographics and Transit Trips Variation: Transit Trips and Race/Ethnicity Description: Transit Trips Index for City of Tampa and Region with race/ethnicity and R/ECAPs Note: Darker shaded tracts indicate better access to public transportation 134

Figure 39: City of Tampa – Transit Trips and National Origin

Source: HUD AFFH Data and Mapping Tool Map 10 - Demographics and Transit Trips Variation: Transit Trips and National Origin Description: Transit Trips Index for City of Tampa and Region with national origin and R/ECAPs Note: Darker shaded tracts indicate better access to public transportation 135

Figure 40: City of Tampa – Transit Trips and Familial Status

Source: HUD AFFH Data and Mapping Tool Map 10 - Demographics and Transit Trips Variation: Transit Trips and Family Status Description: Transit Trips Index for City of Tampa and Region with family status and R/ECAPs Note: Darker shaded tracts indicate better access to public transportation 136

Hillsborough County For the County, Figure 41 shows that transit patterns for Blacks/African-Americans are still focused within city limits and near the R/ECAP area of East Tampa and just north of that. Whites show more transit patterns within the County than Blacks/African Americans but, to the east of the Bay and still closer to city limits. For Hispanics, transit patterns are scattered throughout the County but still clustered within city limits leading out to the northwest region of the County.

Figure 42 shows that Cubans and Columbians tend to show transit trip patterns in the northwest region of the County while Mexican transit trip patterns are clustered in the northeast region of the County.

Households comprised of families with children are associated with transit patterns east of the Bay and closer to city limits as shown in Figure 43.

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Figure 41: Hillsborough County – Transit Trips and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 10 - Demographics and Transit Trips Variation: Transit Trips and Race/Ethnicity Description: Transit Trips Index for Hillsborough County and Region with race/ethnicity and R/ECAPs Note: Darker shaded tracts indicate better access to public transportation 138

Figure 42: Hillsborough County – Transit Trips and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 10 - Demographics and Transit Trips Variation: Transit Trips and National Origin Description: Transit Trips Index for Jurisdiction and Region with national origin and R/ECAPs Note: Darker shaded tracts indicate better access to public transportation 139

Figure 43: Hillsborough County – Transit Trips and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 10 - Demographics and Transit Trips Variation: Transit Trips and Family Status Description: Transit Trips Index for Hillsborough County and Region with family status and R/ECAPs Darker shaded tracts indicate better access to public transportation 140

Low Transportation Costs

City of Tampa Figure 44 indicates that Blacks/African Americans tend to experience lower transportation cost in or near the defined R/ECAP areas of Tampa, specifically in East Tampa running north to Sulphur Springs. Whites experience lower transportation cost focused around South Tampa and outside R/ECAP areas. Hispanics experience lower transportation cost just west of the R/ECAP area of Old West Tampa.

When analyzing lower transportation cost by demographics and national origin, the data in Figure 45 indicates that persons of Cuban origin experience lower transportation cost in northwest Tampa outside of R/ECAP while persons of Mexican or Haitian origin experience lower costs in the University Area and East Tampa respectively.

Figure 46 shows that households comprised of families with children experiencing lower transportation costs are fairly evenly dispersed throughout Tampa, with a slightly greater cluster in or near the East Tampa R/ECAP area.

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Figure 44: City of Tampa – Low Transportation Cost and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 11 - Demographics and Low Transportation Cost Variation: Low Transportation Cost and Race/Ethnicity Description: Low Transportation Cost Index with race/ethnicity and R/ECAPs Note: Darker shaded tracts indicate lower transportation costs or better access to public transit for the households living there. Lighter shaded tracts show higher transportation costs and less access to transit 142

Figure 45: City of Tampa – Low Transportation Cost and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 11 - Demographics and Low Transportation Cost Variation: Low Transportation Cost and National Origin Description: Low Transportation Cost with national origin and R/ECAPs Note: Darker shaded tracts indicate lower transportation costs or better access to public transit for the households living there. Lighter shaded tracts show higher transportation costs and less access to transit 143

Figure 46: City of Tampa – Low Transportation Cost and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 11 - Demographics and Low Transportation Cost Variation: Low Transportation Cost and Family Status Description: Low Transportation Cost Index with family status and R/ECAPs Note: Darker shaded tracts indicate lower transportation costs or better access to public transit for the households living there. Lighter shaded tracts show higher transportation costs and less access to transit 144

Hillsborough County Demographic patterns demonstrate that Blacks/African-Americans mainly experience lower transportation costs within City limits but, may also experience lower transportation cost northeast of the Bay in central Hillsborough County. Figure 47 also identifies a cluster of Whites experiencing lower transportation costs in central Hillsborough County. Hispanics experiencing lower transportation costs seems to be evenly dispersed throughout the County.

The data reveal that persons of Mexican origin experience lower transportation costs in northeast Hillsborough County while persons of Cuban and Columbian origin experience lower costs in the northwest region of the County as shown in Figure 48.

Figure 49 shows that a large percentage of households comprised of families with children experience lower transportation cost in central Hillsborough County and in northwest Hillsborough County.

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Figure 47: Hillsborough County – Low Transportation Cost and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 11 - Demographics and Low Transportation Cost Variation: Low Transportation Cost and Race/Ethnicity Description: Low Transportation Cost Index with race/ethnicity and R/ECAPs Note: Darker shaded tracts indicate lower transportation costs or better access to public transit for the households living there. Lighter shaded tracts show higher transportation costs and less access to transit 146

Figure 48: Hillsborough County – Low Transportation Cost and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 11 - Demographics and Low Transportation Cost Variation: Low Transportation Cost and National Origin Description: Low Transportation Cost with national origin and R/ECAPs Note: Darker shaded tracts indicate lower transportation costs or better access to public transit for the households living there. Lighter shaded tracts show higher transportation costs and less access to transit 147

Figure 49: Hillsborough County – Low Transportation Cost and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 11 - Demographics and Low Transportation Cost Variation: Low Transportation Cost and Family Status Description: Low Transportation Cost Index with family status and R/ECAPs Note: Darker shaded tracts indicate lower transportation costs or better access to public transit for the households living there. Lighter shaded tracts show higher transportation costs and less access to transit 148

iii. Informed by community participation, any consultation with other relevant government agencies, and the participant’s own local data and local knowledge, discuss whether there are programs, policies, or funding mechanisms that affect disparities in access to transportation.

The public transportation system for the City of Tampa and Hillsborough County is managed and operated by Hillsborough Area Regional Transit (HART). The agency provides fixed-route local and express bus service, door-to-door paratransit service (HARTplus), flex-route neighborhood connector service (HARTflex), a scaled down version of Bus Rapid Transit (MetroRapid) and manages the TECO Line Streetcar System. Hillsborough County also operates the Sunshine Line, providing door-to-door service for the elderly, low-income, and people with disabilities.

Service/Routes HART operates through nine different transit centers. The main hub for HART is the Marion Transit Center in Downtown Tampa, serving nearly 30 local and express routes. The center was constructed in 2001, replacing the obsolete Northern Terminal, which sat underneath the I-275 viaduct. The Marion Transit Center includes a customer service center, office space, bus driver lounge, restrooms, bus shelters, and an array of public art displays. Other transit centers include University Area, Britton Plaza, netp@rk, Northwest, Plaza, Westfield-Brandon, West Tampa, and Yukon.

In 2017, HART implemented a comprehensive system redesign, known as Mission MAX. Through Mission MAX, HART is modernizing the system to deliver more efficient service and higher frequencies on high- demand routes.

HART currently offers transportation for 28 local routes and covers an area of approximately 1000 sq. miles with a fleet of almost 200 buses. HART is currently transforming its fleet to Compressed Natural Gas (CNG), which is American-sourced, less expensive, clean and safer than diesel fueled vehicles. HART has buses that are specifically used for persons with disabilities through its HARTPlus service. These buses have the ability to kneel thus increasing accessibility.

HART also offers MetroRapid Service which connects Downtown Tampa and the University Area via Nebraska Avenue and Fletcher Avenue. Alternate trips connect the University Area to the Hidden River Regional Park-n-Ride. This service features 17.5 miles of limited stops, traffic signal priority (GPS technology that extends green lights and shortens red lights improving travel time by 15%), ticket vending machines at select station stops, enhanced passenger stations with bicycle racks, and low floor buses. HART also operates MetroRapid North-South which is a service that operates weekdays with 15-minute service between 5 AM - 8 PM.

Van services are also offered through HARTFlex and HARTPlus Paratransit. HARTFlex is a door-to-door service within defined geographic zones of the county which include Brandon, South County, Northdale, Town 'N Country, and South Tampa. HARTPlus offers transportation for people with disabilities. Persons are eligible for this service if they have physical, cognitive, emotional, visual or other disabilities that prevent them from using HART fixed route bus system, either permanently or under

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certain conditions. Bus service is fully accessible to people who use wheelchairs or motorized scooters. All buses have PA systems to announce stops and lighted stop-requested signs. HARTPlus services, available only where HART bus routes operate, are based solely on the applicant's functional ability to use HART buses, not disability alone.

Hillsborough County also offers the Sunshine Line. The Sunshine line provides door-to-door transportation and bus passes for elderly, low-income, and people with disabilities who do not have or cannot afford their own transportation. Transportation is provided primarily to medical appointments and Aging Services day care and nutrition sites, but non-medical trips are provided on a space-available basis.

Fare/Costs HART offers several different fare options from daily ticketing to long-term passes. Discounts are also available. Passengers must have a HART discount permit or paratransit permit to ride for a discount fare, with the exception of Medicare cardholders. Discount fares are available to seniors, 65 years and older; youth, 5-18 years; and people with disabilities. Students older than 18 years of age may purchase HART farecards at a 25% discount from participating educational institutions with proper student ID.

The one-day unlimited pass allows for unlimited local rides on the date the pass is activated. Transfers are not necessary, and the pass can be purchased on board the bus or from any HART sales outlet. The one- day pass is sold in local, discount and express fare categories. A local and limited express pass is $4.00, and an express pass is $6.00. Discounts allow for a local & limited express pass and an express pass to be purchased for half off. One-way fares range $2.00 and $3.00 with discounts allowing for half off. HARTflex is either $1.00 for one-way or $2.00 for all day. HARTPlus offers a one-way cash fare and also has an option for a 10-ride farecard for $40.00.

Available at select HART facilities and HART sales outlets are other fare options such as the 31-Day Unlimited HART Fare which offers local & limited express and express passes for $65.00 and $95.00 respectively. HART also offers a 10-Pack One Day Unlimited for $37.00 and $53.00 and a 3-Day Unlimited for $11.75. HART/PSTA Passport provides unlimited travel on all HART and PSTA local, express, Flex and In-Towner routes, and the TECO Line Streetcar System for an entire calendar month for $85.00. Some options include discounts allowing for half off.

HART also offers the Corporate Transit Program. Federal law entitles all U.S. employers to a completely tax-deductible business expense of up to $255 per employee per month toward the cost of using public transportation. For most employees, this will mean a $95 monthly Express Pass or a $65 monthly Local Pass. Funds can also be allocated to vanpooling. Once the program is set up within a company, bus passes will be mailed or hand-delivered to the company's appointed representative every month, then distributed to eligible employees. HART provides route schedules, informational brochures and a customer service line to answer any questions about routes and time schedules. Upon request, a HART representative will visit the company to talk to employees about the bus system and other commute alternatives.

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HART has partnered with the University of South Florida (USF) for the USF U-PASS Program. USF students showing a new valid USF ID can ride HART Local, Limited Express, MetroRapid and Flex routes FREE. USF faculty and staff pay only 50¢ with their new valid USF ID card.

HART survey results have indicated that riders believe fares are affordable. HART completes an annual fare review and it has been a few years since the fares have increased. If HART decides to implement a fare increase, the agency must follow Title VI review and approval.

Hours/Reliability Hours vary based upon ridership however, core routes will run until 12:00 AM every 15 to 20 minutes. Many bus routes start serving riders at 4:00 AM. Not all routes run these hours and during the AI community meetings, stakeholders commented that many routes, outside of core routes, do not run in the very early or very late hours, so public transportation is not available for those who work night shifts. Residents also noted that persons not living close to the bus lines have an extremely difficult time getting to work. However, according to HART’s On-Board Survey, the average length of the walk from the bus stop to home is 2.4 blocks and HART continues efforts to make transportation accessible to location of housing.

HART is at its maximum for the number of vehicles that can be put into service, but the agency is trying to extend service hours, especially on heavily traveled routes. HART’s goal is to have no routes running any less than 30-minute intervals. Frequency of service is HART’s most expensive item in transit.

HART On-Board Survey Results HART continues to conduct surveys in an effort to obtain feedback and improve the transportation system. HART’s on-board survey provides critical demographic information that assists in determining where to focus efforts. The most recent survey revealed that Blacks/African-Americans have the greatest usage rate of public transportation at 49% followed by Whites at 25%. The survey also demonstrated a marginal difference between male and female riders at 51% and 49%, respectively. Additionally, the survey showed that the majority of its riders are below the poverty level with 36% having household incomes below $10,000. This is important when considering fare changes.

Survey results also showed that more than 57% of average weekday riders are employed either full-time (> 35 hours) or part-time (< 35 hours). This trend indicates that majority of riders are using public transportation as their primary mode of transportation to and from their place of employment. Only 25% of riders are students utilizing public transportation to access their educational establishment.

Though HART offers a 31-day pass, which would be more cost effective if utilizing public transportation regularly, the survey shows that 47% of riders only purchase a 1-Day pass for $4.00. Combined with the knowledge that majority of riders have incomes falling below the poverty line, this may indicate that riders are unable to pay the 31-Day fee of $65.00 up front. HART reports that 33% of riders utilize public transportation 5 days a week. For these riders, this means their monthly cost for transportation increases by $15.00 if they are unable to afford the $65.00 pass.

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Suitable access to transportation can also be measured by the numbers of times a rider must transfer routes to reach their final destination. HART reports that 57% of its riders are not required to transfer and are able to reach their destination by utilizing one route. Only 33% have to make one transfer and 8% have to make more than one transfer. This demonstrates HART’s efforts and success in developing a system that provides riders direct access to various destinations throughout the City.

Over 50% of riders originate their trip from home with 90% of those riders walking to the first bus stop. The average length of the walk from the bus stop to home is only 2.4 blocks, demonstrating concerted efforts by HART to make transportation accessible to location of housing. As mentioned above, HART has identified access to public transportation in rural and unincorporated Hillsborough County as a challenge due to lack of funding to increase their bus fleet and also lack of coordination amongst agencies during the planning process. Many times the infrastructure in these areas cannot support an extensive public transportation system. This poses a challenge in providing adequate access to transportation to households in areas of opportunities that are rural in nature.

Respondents were also asked to specify service improvements that would make HART better for them to use. The top three service improvements indicated by riders include: more frequent service on existing routes, more service on weekdays, and later service on existing routes. As stated above, HART is at its maximum for the number of vehicles that can be put into service but the agency is trying to extend service hours on popular routes. HART’s goal is to have no routes running any less than 30-minute intervals. Frequency of service is HART’s most expensive item in transit.

Barriers/Efforts Title VI is the governing policy for public transportation and HART must comply with its requirements. HART operates an extensive transportation system in Tampa and Hillsborough County and continues to strive to meet the transportation needs for all income levels and race/ethnicities. Though the transportation system has been developed to cover over 1,000 sq. miles, access to unincorporated Hillsborough County still remains as a challenge. Growth areas often prove difficult to serve as the location may have inadequate infrastructure to support public transportation. HART does offer park and ride services to assist in alleviating this issue. There is currently no policy in place that requires developers to contact HART prior to the planning process. Developers are encouraged to contact HART in the beginning phases of the project and involve the agency in the planning process to ensure that adequate access to transportation is considered. When proper planning does not include HART, transportation becomes a challenge in new growth areas.

HART is launching hyperlink application hailed services to increase service to low density transit areas and unincorporated Hillsborough County. HART unveiled the nation's first transit-operated rideshare service: HART HyperLINK. Breaking down the first mile/last mile barrier, HART HyperLINK uses rideshare technology to connect riders to and from our expansive transit system. The innovative transit solution will extend the footprint of the network direct to resident’s doorsteps, delivering rides to and from designated local bus stops for passengers in the University and Carrollwood areas with later expansion to Brandon. This is a state-subsidized pilot program, meaning passengers only pay a low fare for each trip. 152

Lack of funding is also a barrier to providing increased access to transportation. Federal grants can only be used for capital, meaning the grant will buy the bus but will not pay for drivers or fuel costs. HART’s bulk of resources for their annual operating budget come from rider fares, Ad Valorem tax revenue, and federal and state grants. The 2016 total operating revenue was approximately $61 million with the same amount of total operating expenses. Funds largely go to covering the overhead of employee costs at $42 million.

Lack of funding can affect transportation services in many ways including low budget for servicing vehicles, no budget to purchase new vehicles which would increase services, and most importantly there is little budget to expand services to growth areas. In August of 2017, HART restructured routes cutting approximately 20% of service in areas outside of Tampa, e.g. Sun City Center, FishHawk, and Temple Terrace, while growing routes with higher ridership. d. Access to Low Poverty Neighborhoods

i. For the protected class groups HUD has provided data, describe any disparities in access to low poverty neighborhoods in the jurisdiction and region.

Families living in poverty face a range of challenges beyond those experienced by families living above the poverty line including difficulties in accessing good jobs, affording healthy foods, affordable transportation options, and access to both affordable and healthy housing. In terms of fair housing, ensuring the protected classes have access to low poverty neighborhoods is essential to overcoming long- standing patterns of segregation.

The data in Table 38, show the low poverty index values for the City, County, and the region by race/ethnicity and for populations above and below the federal poverty line. These values indicate the degree of exposure to poverty in a given neighborhood. Higher values on the index indicate a community where one can expect to be exposed to less poverty. Inversely, lower scores indicate a community with high exposure to poverty.

Table 38: Low Poverty Index Low Poverty Index Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL Total Population White, Non-Hispanic 55.46 56.54 53.59 Black, Non-Hispanic 18.97 43.32 33.30 Hispanic 32.59 42.35 42.40 Asian or Pacific Islander, Non-Hispanic 56.42 58.33 55.51

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Low Poverty Index Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL Native American, Non- Hispanic 37.19 48.48 45.80 Population below federal poverty line White, Non-Hispanic 40.98 45.27 42.26 Black, Non-Hispanic 14.23 28.88 21.70 Hispanic 23.10 28.95 29.80 Asian or Pacific Islander, Non-Hispanic 41.35 46.20 41.48 Native American, Non- Hispanic 20.89 24.03 27.64 Source: American Community Survey (ACS), 2009-2013

City of Tampa In the City, low poverty index values for Whites is 55.46. For Blacks/African-Americans, the low poverty index value is 18.97, a difference of 36.49, indicating a severe disparity in access to neighborhoods with low exposure to poverty. Disparities in access to low poverty neighborhoods are not restricted solely to Whites and Blacks/African-Americans. Hispanics and Native Americans also experience greater rates of exposure to high poverty neighborhoods at 32.59 and 37.19, respectively. The difference in values between Whites and Hispanics is 22.87, considerably less than the difference between Whites and Blacks/African-Americans, but still a concern.

When comparing the City to the region, all race/ethnicity groups have greater access to low poverty neighborhoods in the region except for Whites and Asians/Pacific Islanders. Blacks/African-Americans, Hispanics, and Native Americans have greater access to low poverty neighborhoods in the region compared to the City.

The data summarized above reveals the degree to which Blacks/African-Americans are segregated in low poverty neighborhoods within City limits. Comparing these figures for the population overall to those living under the federal poverty line, there is a worsening of the trend. After reviewing the difference between the City’s population living above the federal poverty line and below it, it can be concluded that Whites living below the federal poverty line have greater access to low poverty neighborhoods at 40.98, while Black/African-Americans are exposed to higher rates of poverty at 14.23.

Hillsborough County The County exhibits a similar pattern of disparity in access to low poverty neighborhoods between racial/ethnic groups as seen in the City. There is a 13.22 value difference between index values for Whites (56.54) and Blacks/African- Americans (43.32). This difference between Whites and Blacks/African 154

Americans is cause for concern, but not nearly as severe as seen in the City. Overall, Whites and Asians/Pacific Islanders have the greatest access to low poverty neighborhoods in the County. Hispanics (42.35) and Blacks/African Americans (43.32) have essentially equal access to low poverty neighborhoods in the County.

When examining data comparisons between the County and the region overall, Blacks (43.32 in the County versus 33.30 in the region), Hispanics (42.35 versus 42.40) and Native Americans (48.48 versus 45.80) all have greater exposure to low poverty neighborhoods compared to the region. Only Whites (56.54 versus 53.59) and Asians/Pacific Islanders (58.33 versus 55.51) have less exposure to low poverty neighborhoods in the region compared to the County. This indicates that the County offers greater access to low poverty neighborhoods for minority populations than the overall region.

In terms of differences between access to low poverty neighborhoods in the City versus the County, minorities are exposed to less poverty in the County as compared to the City.

ii. For the protected class groups HUD has provided data, describe how disparities in access to low poverty neighborhoods relate to residential living patterns of those groups in the jurisdiction and region.

Figures 50 through 55 shows residential living patterns by race/ethnicity, national origin, and familial status compared to low poverty neighborhoods in the City and the County.

City of Tampa After analyzing Figure 50, there is evidence of patterns of segregation and exposure to high poverty neighborhoods for Blacks/African-Americans and Hispanics. There is a concentration of Blacks/African- Americans in the City’s core, with a notable concentration in the R/ECAP areas. R/ECAP areas have a higher exposure to poverty. There is also a concentration of Hispanics on the west side of the City, with less degree of exposure to poverty than the City’s R/ECAP areas, but still higher than other areas of the City. Finally, there is a concentration of Whites living in lower poverty exposure neighborhoods – particularly in South Tampa.

When examining trends in access to low poverty neighborhoods by national origin, Figure 51, there is a concentration of Cubans on the west side of Tampa. It is important to note, however, that foreign born populations have a tendency to cluster in ethnic enclaves, where their neighbors speak the same language and have similar customs. Thus, the concentration of Cubans in West Tampa may be out of choice.

After reviewing Figure 52 which shows familial status data, certain areas of the City appear to have low poverty exposure with a vast majority of families with children – South Tampa, for instance. Many of the lower value areas in terms of poverty exposure have a relatively lower portion of families with children.

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Figure 50: City of Tampa – Poverty and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 12 - Demographics and Poverty Variation: Poverty and Race/Ethnicity Description: Low Poverty Index with race/ethnicity and R/ECAPs Note: Darker shaded areas indicate a lower level of poverty and lighter shaded areas indicate a higher concentration of poverty

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Figure 51: City of Tampa - Poverty and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 12 - Demographics and Poverty Variation: Poverty and National Origin Description: Low Poverty Index with national origin and R/ECAPs Note: Darker shaded areas indicate a lower level of poverty and lighter shaded areas indicate a higher concentration of poverty 157

Figure 52: City of Tampa – Poverty and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 12 - Demographics and Poverty Variation: Poverty and Family Status Description: Low Poverty Index with family status and R/ECAPs Note: Darker shaded areas indicate a lower level of poverty and lighter shaded areas indicate a higher concentration of poverty

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Hillsborough County In terms of racial/ethnic dispersion, the County is more integrated than the City. At a broad level, one can see a ring of low poverty exposure neighborhoods (i.e., wealthy) in the County's exurbs, in places like Sun City Center, Bloomingdale and Citrus Park, as shown on Figure 53. These areas have low exposure to poverty and simultaneous high concentrations of Whites and Asians.

Figure 54 shows that there is a concentration of Mexicans along the I-4 corridor to the east of the City. These areas are also characterized by high exposure to poverty, according to the low poverty index.

Access to low poverty neighborhoods is particularly important to families with children. HUD shows the location of families with children relative to neighborhoods with high and low exposure to poverty on Figure 55. After reviewing the data, it is difficult to determine any broad trends or conclusions specific to familial status and access to low poverty neighborhoods.

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Figure 53: Hillsborough County – Poverty and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 12 - Demographics and Poverty Variation: Poverty and Race/Ethnicity Description: Low Poverty Index with race/ethnicity and R/ECAPs Note: Darker shaded areas indicate a lower level of poverty and lighter shaded areas indicate a higher concentration of poverty 160

Figure 54: Hillsborough County – Poverty and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 12 - Demographics and Poverty Variation: Poverty and National Origin Description: Low Poverty Index with national origin and R/ECAPs Note: Darker shaded areas indicate a lower level of poverty and lighter shaded areas indicate a higher concentration of poverty 161

Figure 55: Hillsborough County – Poverty and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 12 - Demographics and Poverty Variation: Poverty and Family Status Description: Low Poverty Index with family status and R/ECAPs Note: Darker shaded areas indicate a lower level of poverty and lighter shaded areas indicate a higher concentration of poverty 162

iii. Informed by community participation, any consultation with other relevant government agencies, and the participant’s own local data and local knowledge, discuss whether there are programs, policies, or funding mechanisms that affect disparities in access to low poverty neighborhoods.

When considering exposure to poverty, policymakers must also consider broad trends in poverty expansion and constriction across the region. Examining trends in poverty over time facilitates a stronger understanding of challenges from a policy-making perspective. By plotting the change in poverty at the census tract level between 2000 and the period of 2011 – 2015 from ACS data, it is possible to see areas in the region experiencing significant shifts in poverty. This analysis facilitates a better understanding of the prospects of poverty exposure at the neighborhood level – as areas reduce the level of poverty, or vice versa, exposure to poverty will shift accordingly.

Figure 56 shows the estimated percent change in the number of people living in poverty (independent of race/ethnicity). This map demonstrates dramatic shifts in poverty over time. In terms of the City, it is readily apparent that South Tampa has experienced a dramatic reduction in the number of people living in poverty. As discussed previously, this same area is primarily inhabited by Whites. The areas noted as having high concentrations of Cubans in the City, such as West Tampa, saw increases in poverty over time, although this is not a uniform trend across all neighborhoods.

From the County’s perspective, many rural communities experienced dramatic increases in the number of people living in poverty. In many cases, these areas experienced poverty rate increases of 132.5% or more. In Hopewell, for instance, a small rural community along Route 60 to the east of Tampa, there were approximately 168 people in poverty in 2000 versus 601 in the years between 2010-2014.

Further analysis of this trend in the County shows a significant portion of the increase can be attributed to Hispanics living in poverty. Presumably this increase and concentration in Hispanic poverty in rural areas is due to the abundance of agricultural jobs. In the Hopewell community, for instance, there was a 484.62% increase in the estimated number of people working in the Agriculture industry subsector between 2000 and 2010-2014 (Census tract 12057013100, ACS).

According to the Shimberg Center for Housing Studies, Hillsborough County has one of the highest concentrations of farmworkers in the state of Florida, rivaling only Miami-Dade County in the number of farmworkers (http://flhousingdata.shimberg.ufl.edu/docs/Farmworkers_total.jpg). These workers are exposed to high rates of poverty in the rural communities of Hillsborough County.

In addition to trends on poverty, community meetings highlighted a trend in certain areas of the City and County: so-called reverse discrimination against non-foreign-born populations. In communities like the University area - communities with high concentrations of foreign-born families - it can be difficult to access housing if one is not from that background. Anecdotally, areas have become ethnic enclaves, where the business owners are of the same national origin, landlords are of the same national origin, and all of the residents are of the same origin. This situation makes it increasingly difficult for ‘outsider’ individuals to access housing in communities of choice. 163

Figure 56: Percentage Change in the number of people living in poverty

Source: Change in poverty level. PolicyMap Analysis Tool.

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e. Access to Environmentally Healthy Neighborhoods

i. For the protected class groups HUD has provided data, describe any disparities in access to environmentally healthy neighborhoods in the jurisdiction and region.

HUD provides environmental health index data by census tract and for racial/ethnic groups above and below the federal poverty level. The index is based upon nationally standardized Environmental Protection Agency (EPA) data on exposure to airborne carcinogenic, respiratory, and neurological toxins by neighborhood. A higher value on the index indicates lower exposure to dangerous environmental conditions, while a lower value on the index indicates greater exposure rates to harmful toxins. Table 39 presents Environmental Health Index data by race/ethnicity, for the City, County, and region, and for populations above and below the federal poverty line.

Table 39: Environmental Health Index Environmental Health Index

Tampa-St. Hillsborough Tampa, FL Petersburg- County, FL Clearwater, FL

Total Population White, Non-Hispanic 38.79 54.10 58.55 Black, Non-Hispanic 33.74 50.42 50.19 Hispanic 35.64 52.61 47.51 Asian or Pacific Islander, Non-Hispanic 42.45 54.26 55.16 Native American, Non- Hispanic 37.45 52.12 55.16 Population below federal poverty line White, Non-Hispanic 37.55 52.56 58.01 Black, Non-Hispanic 32.91 47.19 47.16 Hispanic 33.77 52.60 45.94 Asian or Pacific Islander, Non-Hispanic 48.83 52.97 55.53 Native American, Non- Hispanic 34.96 47.94 46.94 Source: National Air Toxics Assessment (NATA) data, 2011

City of Tampa Although racial and ethnic minorities are not consistently located in areas with lower air quality in the City and the County, there is a trend of greater exposure to air quality hazards among certain racial and ethnic

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groups, moderated by poverty status. However, the difference in air quality in the City is marginal regardless of race/ethnicity and income level.

Overall, air quality is lower in Tampa than in the region as a whole, particularly for Blacks/African- Americans and Hispanics. Both above and below the poverty line at both geographic level, Blacks/African- Americans live in neighborhoods with relatively low air quality. For example, Blacks/African-Americans above and below the poverty level have environmental health index values of 33.74 and 32.91, respectively, compared to 38.79 and 37.55 for the total White population and Whites living below the federal poverty level. Whites and Asians/Pacific Islanders have the best environmental conditions in the City, at 38.79 and 42.45, respectively. This trend is repeated in the region overall.

Hillsborough County Differences in environmental conditions by race/ethnicity in the County are less pronounced than differences identified in the City. Whites (54.10) and Asians/Pacific Islanders (54.26) in the County live in neighborhoods with the highest air quality, while Blacks/African-Americans (50.42) and Native Americans (52.12) have the lowest values.

When examining data in the County compared to the region overall, Whites, Asians/Pacific Islanders, and Native Americans have better environmental conditions in the region, while Blacks/African-Americans and Hispanics have better conditions in the County. The difference between the populations is negligible, however, making it difficult to draw general conclusions related to residential living patterns in the County compared to the region.

Reviewing HUD environmental index data for County races/ethnicities above and below the federal poverty line reveals a consistent trend. Living in poverty is associated with higher rates of exposure to environmental hazards compared to the population living above the poverty level. This disparity is most pronounced for the Native American population, with a difference between the above-poverty and below- poverty population of 4.18. Blacks/African-American persons living under the poverty line have the lowest environmental health index values in the County at 47.19.

ii. For the protected class groups HUD has provided data, describe how disparities in access to environmentally healthy neighborhoods relate to residential living patterns in the jurisdiction and region.

Figures 57 through 62 show residency patterns of racial/ethnic, national origin groups and families with children compared to environmentally healthy neighborhoods. Darker shading at the neighborhood (census tract) level indicates lower levels of exposure to environmental health hazards for the jurisdiction and the region.

City of Tampa Most of Tampa has low to moderate air quality, and the relationship between air quality and the geographic distribution of racial and ethnic minorities in the City is not clear-cut. Figure 57 maps racial/ethnic living patterns in the City. Many census tracts with low to moderate air quality, including 166

some in the East Tampa R/ECAP, the West Tampa R/ECAP, and the area west of the Hillsborough River, have high concentrations of racial and ethnic minority groups. However, parts of heavily White Seminole Heights and South Tampa have low to moderate air quality as well, while some neighborhoods with higher air quality (such as the Sulphur Springs R/ECAP) have high minority concentrations. Overall, air quality in the City appears to be heavily determined by the locations of major transportation corridors, intensive downtown development, and industrial uses.

Figure 58 shows the geographic distribution of Tampa’s foreign-born residents for the top 5 most common national origins, overlaid over a map of air quality by census tract. These foreign-born populations appear to be more concentrated in areas of low to moderate air quality than racial and ethnic minorities are. Several hundred Haitians and Latin Americans live in areas in or near the East Tampa R/ECAP and Seminole Heights with the lowest air quality levels. Cubans, the largest group of foreign-born residents, are mainly located west and north of the Hillsborough River in census tracts with lower-than-moderate air quality levels.

Figure 59 shows the percentage of households with children, superimposed over a map of air quality by census tract. There is no clear relationship between the prevalence of families with children and air quality levels.

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Figure 57: City of Tampa – Environmental Health and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Map 13 - Demographics and Environmental Health Variation: Environmental Health and Race/Ethnicity Description: Environmental Health Index with race/ethnicity and R/ECAPs Note: Darker shaded areas indicate lower levels of exposure to environmental health hazards and lighter shaded areas indicate greater exposure to environmental health hazards 168

Figure 58: City of Tampa – Environmental Health and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 13 - Demographics and Environmental Health Variation: Environmental Health and National Origin Description: Environmental Health Index with national origin and R/ECAPs Note: Darker shaded areas indicate lower levels of exposure to environmental health hazards and lighter shaded areas indicate greater exposure to environmental health hazards 169

Figure 59: City of Tampa – Environmental Health and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 13 - Demographics and Environmental Health Variation: Environmental Health and Family Status Description: Environmental Health Index with family status and R/ECAPs Note: Darker shaded areas indicate lower levels of exposure to environmental health hazards and lighter shaded areas indicate greater exposure to environmental health hazards 170

Hillsborough County Overall, Hillsborough County has better environmental conditions than the City. Unsurprisingly, the County’s census tracts with the highest air quality tend to be away from major highways in very rural areas, which are also heavily White as shown in Figure 60. Some census tracts with low to moderate air quality, such as those near the City’s eastern boundaries, and parts of the University Area R/ECAP, Egypt Lake-Leto, and Town ‘N’ Country have low minority concentrations. However, some census tracts with relatively high concentrations of minorities have moderate to high air quality.

Figure 61 compares the geographic distribution of foreign-born residents and air quality levels in the County. Foreign-born residents from the top 5 countries of origin in Hillsborough County are not as clearly concentrated in low air quality census tracts as they are in Tampa. In northwestern Hillsborough County, foreign-born residents—especially Mexicans and Cubans—tend to be in census tracts with low to moderate air quality. In eastern Hillsborough County, foreign-born residents live in census tracts across much of the spectrum of air quality. For example, many Mexican residents—likely agricultural workers, live in census tracts with high air quality south of Plant City.

Figure 62 shows the percentage of households with children, superimposed over a map of air quality by census tract. There is no clear relationship between the prevalence of families with children and air quality levels.

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Figure 60: Hillsborough County – Environmental Health and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 13 - Demographics and Environmental Health Variation: Environmental Health and Race/Ethnicity Description: Environmental Health Index with race/ethnicity and R/ECAPs Note: Darker shaded areas indicate lower levels of exposure to environmental health hazards and lighter shaded areas indicate greater exposure to environmental health hazards 172

Figure 61: Hillsborough County – Environmental Health and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 13 - Demographics and Environmental Health Variation: Environmental Health and National Origin Description: Environmental Health Index with race/ethnicity, national origin, family status and R/ECAPs Note: Darker shaded areas indicate lower levels of exposure to environmental health hazards and lighter shaded areas indicate greater exposure to environmental health hazards 173

Figure 62: Hillsborough County – Environmental Health and Familial Status

Source: HUD AFFH Data and Mapping Tool Name: Map 13 - Demographics and Environmental Health Variation: Environmental Health and Family Status Description: Environmental Health Index with race/ethnicity, national origin, family status and R/ECAPs Note: Darker shaded areas indicate lower levels of exposure to environmental health hazards and lighter shaded areas indicate greater exposure to environmental health hazards 174

iii. Informed by community participation, any consultation with other relevant government agencies, and the participant’s own local data and local knowledge, discuss whether there are programs, policies, or funding mechanisms that affect disparities in access to environmentally healthy neighborhoods.

The Hillsborough County Office of Neighborhood Relations provides funding to residents and neighborhood organizations to conduct clean-up projects in their communities. The Office of Neighborhood Relations also administers a Tree Grant program that provides environmental benefits such as oxygen production and air pollution control. Trees added through the program may be planted in community-maintained areas or road rights-of-way. f. Patterns in Disparities in Access to Opportunity

i. For the protected class groups HUD has provided data, identify and discuss any overarching patterns of access to opportunity and exposure to adverse community factors. Include how these patterns compare to patterns of segregation, integration, and R/ECAPs. Describe these patterns for the jurisdiction and region.

Previous sections in this report examined a broad range of topics focused on opportunities for protected classes living in the City, County, and the region. From exposure to environmentally unhealthy neighborhoods, the quality of transit access, school proficiency and labor market conditions, this analysis repeatedly identified concentrations of protected classes living in low opportunity neighborhoods, with high exposure to poverty. In particular, data analysis by race/ethnicity uncovered consistent disparities in access to opportunity. Blacks/African-Americans and Hispanics are disproportionately impacted by poor neighborhood conditions, whereas Whites and Asians have access to thriving communities, in both the County and the City.

This analysis also reviewed spatial living patterns and patterns in access to opportunity by familial status and national origin. It is difficult to draw solid conclusions related to familial status in the City and in the County, although there are some areas with higher concentrations of this household type. For national origin, the County has high concentrations of primarily Cubans in the communities just to the west of the City’s border, in areas like Egypt-Lake Leto and Town ‘N Country. These communities have relatively low opportunity index values, particularly for labor market and school proficiency.

ii. Based on the opportunity indicators assessed above, identify areas that experience: (a) high access; and (b) low access across multiple indicators.

According to data and mapping provided by HUD, areas in the jurisdiction that experience high access to opportunity across multiple data sets include South Tampa and Downtown Tampa in the City and Westchase, Cheval, Lutz, and Bloomingdale in the County.

Conversely, one sees a strong correlation between communities of low opportunity and areas identified as R/ECAPs. Areas in East Tampa, Old West Tampa, the University Area, Sulphur City and South Ybor are all communities with R/ECAP census tracts and low access to opportunity.

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2. Additional Information

a. Beyond the HUD-provided data, provide additional relevant information, if any, about disparities in access to opportunity in the jurisdiction and region affecting groups with other protected characteristics. In addition to data on race/ethnicity, color, religion, sex, familial status, national origin and disability, both Hillsborough County and Tampa include sexual orientation in their respective human rights ordinances. In terms of this analysis, it was not possible to secure data on population counts of LGBTQ individuals in the County or the City. A cursory examination of the protections afforded LGBTQ individuals in the City indicates that the City is one of the strongest advocates for this population in the nation (accessed via the following link: http://hrc-assets.s3-website-us-east-1.amazonaws.com//files/assets/resources/Tampa- Florida-2016.pdf)

The Human Rights Campaign publishes an annual Municipal Equality Index, with cities rated on a scale of 0 – 100, based on the city’s laws, policies, benefits and services offered to the LGBTQ community. The scorecard for Tampa shows the City scoring 86 out of 100 on the index, with maximum points awarded for a wide range of topics, including non-discrimination laws in employment, housing, and public accommodations, a police liaison for the LGBTQ community, an LGBTQ liaison in the Mayor’s office, and services provided by the City to LGBTQ youth. b. The program participant may also describe other information relevant to its assessment of disparities in access to opportunity, including any activities aimed at improving access to opportunities for areas that may lack such access, or in promoting access to opportunity (e.g., proficient schools, employment opportunities, and transportation).

The following section discusses opportunity characteristics outside of those discussed through the lens of HUD-provided indices and mapping. The discussion centers on broad topics such as access to healthcare, access to childcare, access to quality food, and the spatial living patterns of protected classes in relation to those topics.

Access to Healthcare Access to health insurance and healthcare providers, whether through a job or other means, is a critical source of financial and physical security for any family. It is important to examine the degree to which health insurance and healthcare providers are geographically distributed across the study area.

Figure 63 shows the estimated percentage of uninsured individuals by census tract, with dark red shaded areas showing census tracts with at least 32.1% of the total population uninsured. R/ECAP areas are also shown. The analysis demonstrates high concentrations of uninsured across the study area, with particular concentrations in rural areas of the County to the west and southeast, and the University Area R/ECAP. Areas with high rates of uninsured individuals should anticipate higher rates of chronic illness and economic dislocation.

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In addition to the percentage of the total population that is uninsured, it is also important to assess the degree to which different race/ethnicity categories access health insurance in the region. Table 40 shows the total number of individuals within each race/ethnicity category in the County, and the total number of uninsured individuals. This analysis shows, at a very broad level, the degree to which each race/ethnicity in the region has access to health insurance. Of interest is the discovery that Native Americans and Hispanics are struggling far more than the other races/ethnicities in the region. Blacks/African-Americans are finding more success accessing insurance relative to Hispanics and Native Americans.

Table 40: Uninsured Individuals in Hillsborough County Uninsured Individuals in Hillsborough County

White Black Native Asian Hispanic American Total # 910,709 210,007 6,622 45,729 327,081 # Uninsured 147,974 38,526 2,859 8,360 91,656 % Uninsured 16.25% 18.35% 43.17% 18.28% 28.02%

Source: American Community Survey (ACS), 2010-2014

Having insurance is only one means of accessing healthcare – the physical proximity of healthcare providers is also a critical component of the healthcare landscape. The Health Resources and Services Administration (HRSA) identifies communities across the country meeting certain criteria as Medically Underserved Areas (MUA). The MUA definition relies on the Index of Medical Underservice (IMU), which is composed of the following factors: • Providers per 1,000 population ratio; • % population at 100% of the Federal Poverty Level; • % population age 65 and over; and • Infant Mortality Rate.

Areas are ranked on a scale from 0 to 100 on the IMU. An area with an IMU of 62.0 or below qualifies for designation as a MUA. Figure 64 shows areas classified as a MUA in Hillsborough County. Once again, the more rural areas of Southeast Hillsborough County are classified as a MUA, and much of the central urban core of the City.

It should be noted that the MUA definition includes demographic and economic characteristics of the region, in addition to the availability of healthcare providers. Thus, it is reasonable to assume that areas scoring poorly on the IMU would also be classified as a R/ECAP. Figure 65 identifies areas that are both a MUA, as classified by HRSA, and a R/ECAP. This analysis shows that R/ECAPs in the study area not only face considerable pressures in terms of excessive racial/ethnic concentration and poverty, but also a lack of access to primary care providers.

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Figure 63: Location of Uninsured Individuals in Hillsborough County

Source: American Community Survey (ACS), 2010-2014 178

Figure 64: Medically Underserved Areas

Source: HRSA MUA 2016. PolicyMap Analysis Tool.

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Figure 65: Medically Underserved Areas and R/ECAPs

Source: HRSA MUA 2016, R/ECAP HUD, PolicyMap analysis tool.

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Access to Childcare

Access to childcare services is critical for any family with children. The degree to which childcare services are available, particularly in R/ECAPs and in areas with high concentrations of protected classes, is a critical component of a region’s access to opportunity.

A report by The Children’s Board of Hillsborough County states that almost 7% of the population in Hillsborough County is children aged from birth to four years old. (source: ).

This analysis examines two data sets on childcare: the location of childcare homes in the County and the total number of licensed childcare providers in Hillsborough County.

Figure 66 shows the total number of licensed family childcare homes by census tract in the study area. A licensed family child care home is any occupied residence in which childcare is regularly provided for children unrelated to the operator and where payment is received for those services. In general, there are higher concentrations of licensed childcare homes in the urbanized portions of the study area, with a notable concentration in Town ‘N Country and in Egypt Lake-Leto. The more rural areas of Hillsborough County have few to no licensed family childcare homes. This represents a challenge for families and the higher growth population centers in the County such as Wimauma.

For further detail, Figure 67 shows the location of licensed childcare providers across Hillsborough County, with an overlay of the total population under the age of 18. The location of childcare centers corresponds to the data provided previously. Not surprisingly, there are high concentrations of licensed child care providers near areas with large populations of youth. Further, the analysis indicates R/ECAPs in the City have acceptable access to childcare providers, aside from one R/ECAP, the University Area.

In addition to the data presented here, feedback gathered from the community meetings also provided evidence of a shortage of quality childcare providers in the region. During these meetings, residents expressed frustration with childcare costs which were rarely, if ever, included in the cost of living. Residents also expressed concern with the relative focus on housing versus providing funding and subsidy for childcare services.

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Figure 66: Location of Family Childcare Homes

Source: Hillsborough County Licensed Child Care Centers as of September 2015, accessed via Hillsborough Community Atlas. 182

Figure 67: Location of Licensed Childcare Centers

Source: American Community Survey (ACS), 2010-2014 183

Access to Quality Food In recent years, policymakers at the federal, state and local levels across the nation have turned attention to the issue of food deserts – areas defined as having a lack of access to fresh food. The nexus between access to high quality food - rather than prepared meals, snacks, candies and other unhealthy foods - has been well researched and well established. A study commissioned by the Florida Department of Agriculture and Consumer Services in 2014 found that “individuals living in places where many households reside more than a half-mile from the nearest full-service grocer and lack access to a vehicle are more likely to die prematurely from diabetes, diet-related cancers, stroke and liver disease than individuals living where grocers are closer and vehicles are more available, after controlling for other key factors.” (http://www.marigallagher.com/site_media/dynamic/project_files/Florida_Full_Technical_Addendum_. pdf).

Because good health is connected to good food, it is worth examining data on trends on access to quality food across the City and the County. Figure 68 shows areas identified by the United States Department of Agriculture (USDA) as a ‘food desert’ in 2016. A food desert is an area where there is both a high proportion of low-income families and low access to quality food, typically 1 mile to a full-service grocery store.

The USDA Food Desert model has been used regularly across the nation to identify areas with limited access to healthy food. This approach, however, fails to differentiate areas by potential demand versus areas with little hope for securing access to healthy food through the private market and siting of private grocers in those communities. This distinction is important because the natural solution to eliminating food deserts is simply to place a full-service grocery store in each community. The ability to identify areas with significant unmet demand is critical to addressing food access in low-income communities.

To address this very real concern, The Reinvestment Fund (TRF) created a grocery retail leakage rate, defined as the percentage of an area’s retail demand for groceries that is being lost to stores located in other areas. Figure 69 shows leakage rates across Hillsborough County, with darker shaded areas indicating areas with the most grocery retail leakage. Areas of particular concern are those areas identified as a R/ECAP that also have unmet grocery demand. In particular, the University Area.

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Figure 68: USDA Food Deserts in Hillsborough County

Source: USDA Food Deserts, accessed through the ‘Roadmap to Living Healthy’ geospatial analysis tool made available by the Florida Department of Agriculture and Consumer Services department: . 185

Figure 69: Grocery Store Leakage Rate

Source: 2014 TRF Food Access Leakage, made available through PolicyMap. 186

3. Contributing Factors of Disparities in Access to Opportunity

Identify factors that significantly create, contribute to, perpetuate, or increase the severity of disparities in access to opportunity.

• Access to financial services • Availability, type, frequency, and reliability of public transportation • Impediments to mobility • Lack of access to opportunity due to high housing costs • Lack of local or regional coordination • Lack of private investments in specific neighborhoods • Lack of public resources for investment in specific neighborhoods, including services and amenities • Land use and zoning laws • Lending discrimination • Location and type of affordable housing • Location of proficient schools and school assignment policies • Loss of Affordable Housing • Private Discrimination • Source of income discrimination • Educational Attainment

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iv. Disproportionate Housing Needs

1. Analysis a. Which protected class groups (by race/ethnicity and familial status) experience higher rates of housing problems (cost burden, overcrowding, or substandard housing) when compared to other groups for the jurisdiction and region? Which groups also experience higher rates of severe housing cost burdens when compared to other groups?

The AFFH defines disproportionate housing needs as a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing needs when compared to the proportion of members of any other relevant groups or the total populations experiencing that category of housing need.

There are four types of housing problems that are assessed in the evaluation of housing need: cost burden, overcrowding, lack of complete kitchen facilities, or lack of complete plumbing facilities. • Housing cost burden is the percentage of a household’s total gross income that is spent on housing costs. A household is considered cost burdened if they spend 30% or more of their income on housing costs and severely cost burdened if they spend 50% or more of their income for housing. • An overcrowded household refers to a household having more than 1.01 to 1.5 persons per room (excluding bathrooms, porches, foyers, halls, and half-rooms). Severely overcrowded means there are more than 1.51 persons per room. • Lack of complete kitchen facilities refers to a household that lacks a sink with piped water, a range or stove, or a refrigerator. • Lack of complete plumbing facilities refers to a household without hot or cold piped water, a flush toilet and a bathtub or shower.

City of Tampa Table 41 shows the number and percent of households that are experiencing any of the four housing problems. According to the data in the table, 44.08% of all households within the City are experiencing at least one of the four housing problems. Black/African-American households, Hispanic households, Native American households, and Other households all have a level of housing problems that exceed the rate of housing problems citywide. However, Black/African-American households and Hispanic households have the highest rates of housing problems and a higher level of need at 54.52% and 53.14%, respectively. White households are experiencing the lowest level of housing problems in the City at 35.81%.

Table 41 also provides data on housing problems by family size. Large family households experience a higher rate of housing problems at 58.06% than non-family households at 46.46% and small family households at 40.13%.

In regard to severe housing problems, 23.78% of households in the City are experiencing at least one severe housing problem. Black/African-Americans and Hispanic households are also the racial or ethnic groups 188

experiencing the highest rates of severe housing problems in the City at 31.47% and 30.37%, respectively. White households have less severe housing problems than all types of households in the City at 17.58%.

Table 41: City of Tampa - Demographics of Households with Disproportionate Housing Needs Disproportionate Tampa, FL Tampa-St. Petersburg-Clearwater, FL Housing Needs Households # with # % with # with # % with experiencing any of 4 problems households problems problems households problems housing problems Race/Ethnicity White, Non-Hispanic 25,635 71,585 35.81% 288,760 826,185 34.95% Black, Non-Hispanic 17,255 31,650 54.52% 60,455 114,604 52.75% Hispanic 15,460 29,095 53.14% 73,245 143,070 51.20% Asian or Pacific Islander, Non- Hispanic 1,754 4,092 42.86% 10,404 26,387 39.43% Native American, Non-Hispanic 88 166 53.01% 950 2,111 45.00% Other, Non-Hispanic 885 1,963 45.08% 6,035 13,583 44.43% Total 61,085 138,590 44.08% 439,840 1,125,960 39.06% Household Type and Size Family households, <5 people 27,090 67,505 40.13% 204,570 619,995 33.00% Family households, 5+ people 4,860 8,370 58.06% 37,080 73,204 50.65% Non-family households 29,140 62,715 46.46% 198,200 432,765 45.80% Households # with % with # with % with experiencing any of 4 # # severe severe severe severe Severe Housing households households problems problems problems problems Problems Race/Ethnicity White, Non-Hispanic 12,585 71,585 17.58% 136,865 826,185 16.57% Black, Non-Hispanic 9,960 31,650 31.47% 33,429 114,604 29.17% Hispanic 8,835 29,095 30.37% 40,225 143,070 28.12% Asian or Pacific Islander, Non- Hispanic 1,114 4,092 27.22% 5,794 26,387 21.96% Native American, Non-Hispanic 29 166 17.47% 488 2,111 23.12% Other, Non-Hispanic 430 1,963 21.91% 3,205 13,583 23.60% Total 32,950 138,590 23.78% 220,005 1,125,960 19.54% Source: Comprehensive Housing Affordability Strategy (CHAS), 2009-2013 189

When considering severe housing cost burden, the data in Table 42 indicate that Black/African-American households experience the highest incidence of severe housing cost burden at 28.66% followed by Hispanic households at 26% in the City. The same racial/ethnic groups also experience the highest rates of severe housing burden in the region.

With respect to family size, large family households in the City face the greatest level of severe housing cost burden at 24.13% while in the region, non-family households experience the highest rate of severe housing cost burden.

Table 42: City of Tampa - Demographics of Households with Severe Housing Cost Burden Households with Tampa-St. Petersburg-Clearwater, Severe Housing Tampa, FL FL Cost Burden # % % # with with with with # severe Race/Ethnicity severe severe # households severe households cost cost cost cost burden burden burden burden White, Non- Hispanic 11,685 71,585 16.32% 125,720 826,185 15.22% Black, Non- Hispanic 9,070 31,650 28.66% 30,195 114,604 26.35% Hispanic 7,565 29,095 26.00% 32,910 143,070 23.00% Asian or Pacific Islander, Non- Hispanic 834 4,092 20.38% 4,604 26,387 17.45% Native American, Non-Hispanic 30 166 18.07% 465 2,111 22.03% Other, Non- Hispanic 375 1,963 19.10% 2,885 13,583 21.24% Total 29,559 138,590 21.33% 196,779 1,125,960 17.48% Household Type and Size Family households, <5 people 12,835 67,505 19.01% 86,564 619,995 13.96% Family households, 5+ people 2,020 8,370 24.13% 11,445 73,204 15.63% Non-family households 14,705 62,715 23.45% 98,789 432,765 22.83% Source: Comprehensive Housing Affordability Strategy (CHAS), 2009-2013

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Hillsborough County Table 43 shows that a lower percentage of the total households in the County are experiencing housing problems when compared to the total households in the City – 39.30% in the County versus 44.08% in the City. The difference in the rate of housing problems for each racial/ethnic group in the County is marginal compared to the region.

Native American households in the County are experiencing the greatest rate of housing problems at 62.17%. However, due to the relatively small size of this population, the information is less reliable as a measure of housing need. Like Tampa, Black/African-American households and Hispanic households are the racial/ethnic groups experiencing higher rates of housing problems at 51.36% and 51.12%, respectively.

In regard to family size, large family households are the household type experiencing the highest rate of housing problems in the County and the region at 50.29% and 50.65%, respectively.

Almost 20% of all households in Hillsborough County have a severe housing problem. Native American, Hispanic, and Black/African-American households experience the highest rates of severe housing problems at 28.59%, 27.71%, and 26.60%, respectively.

Table 43: Hillsborough County - Demographics of Households with Disproportionate Housing Needs Disproportionate Hillsborough County, FL Tampa-St. Petersburg-Clearwater, FL Housing Needs Households # with # % with # with # % with experiencing any of problems households problems problems households problems 4 housing problems Race/Ethnicity White, Non- Hispanic 68,063 206,973 32.88% 288,760 826,185 34.95% Black, Non-Hispanic 20,665 40,237 51.36% 60,455 114,604 52.75% Hispanic 35,500 69,451 51.12% 73,245 143,070 51.20% Asian or Pacific Islander, Non- Hispanic 4,049 10,364 39.07% 10,404 26,387 39.43% Native American, Non-Hispanic 424 682 62.17% 950 2,111 45.00% Other, Non- Hispanic 2,102 5,097 41.24% 6,035 13,583 44.43% Total 130,760 332,740 39.30% 439,840 1,125,960 39.06% Household Type and Size Family households, <5 people 64,982 194,250 33.45% 204,570 619,995 33.00% Family households, 5+ people 15,414 30,648 50.29% 37,080 73,204 50.65%

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Disproportionate Hillsborough County, FL Tampa-St. Petersburg-Clearwater, FL Housing Needs Non-family households 50,338 107,813 46.69% 198,200 432,765 45.80% Households # with % with # with % with experiencing any of # # severe severe severe severe 4 Severe Housing households households problems problems problems problems Problems Race/Ethnicity White, Non- Hispanic 30,913 206,973 14.94% 136,865 826,185 16.57% Black, Non-Hispanic 10,703 40,237 26.60% 33,429 114,604 29.17% Hispanic 19,246 69,451 27.71% 40,225 143,070 28.12% Asian or Pacific Islander, Non- Hispanic 2,069 10,364 19.96% 5,794 26,387 21.96% Native American, Non-Hispanic 195 682 28.59% 488 2,111 23.12% Other, Non- Hispanic 1,001 5,097 19.64% 3,205 13,583 23.60% Total 64,120 332,740 19.27% 220,005 1,125,960 19.54% Source: Comprehensive Housing Affordability Strategy (CHAS), 2009-2013

Table 44 shows the percentage of households in the County experiencing severe housing cost burden. Native American households in Hillsborough County have the highest rate of severe cost burden at 27.27% but this figure is skewed because of the small size of that population. After Native Americans, Black/African- American and Hispanic households are also experiencing disproportionately greater severe housing cost burden in the County at 23.35% and 22.58%, respectively.

Non-family households in the County and the region experience a higher rate of severe housing cost burden than other household types.

Table 44: Hillsborough County - Demographics of Households with Severe Housing Cost Burden Households with Tampa-St. Petersburg-Clearwater, Severe Housing Hillsborough County, FL FL Cost Burden # % # % with with with with # Race/Ethnicity severe severe severe # households severe households cost cost cost cost burden burden burden burden White, Non- Hispanic 28,122 206,973 13.59% 125,720 826,185 15.22%

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Households with Tampa-St. Petersburg-Clearwater, Severe Housing Hillsborough County, FL FL Cost Burden # % # % with with with with # Race/Ethnicity severe severe severe # households severe households cost cost cost cost burden burden burden burden Black, Non- Hispanic 9,394 40,237 23.35% 30,195 114,604 26.35% Hispanic 15,681 69,451 22.58% 32,910 143,070 23.00% Asian or Pacific Islander, Non- Hispanic 1,563 10,364 15.08% 4,604 26,387 17.45% Native American, Non-Hispanic 186 682 27.27% 465 2,111 22.03% Other, Non- Hispanic 897 5,097 17.60% 2,885 13,583 21.24% Total 55,843 332,740 16.78% 196,779 1,125,960 17.48% Household Type and Size Family households, <5 people 26,230 194,250 13.50% 86,564 619,995 13.96% Family households, 5+ people 4,625 30,648 15.09% 11,445 73,204 15.63% Non-family households 24,994 107,813 23.18% 98,789 432,765 22.83% Source: Comprehensive Housing Affordability Strategy (CHAS), 2009-2013

b. Which areas in the jurisdiction and region experience the greatest housing burdens? Which of these areas align with segregated areas, integrated areas, or R/ECAPs and what are the predominant race/ethnicity or national origin groups in such areas?

There are several areas throughout the City and the County that are experiencing high levels of housing burden. Figures 70 and 71 show the residential living patterns for persons by race/ethnicity and national origin, overlaid on shading indicating the percentage of households experiencing one or more housing problems in a particular census tract. Darker shading indicates a higher prevalence of such problems.

City of Tampa The majority of the areas in the City with the greatest housing burden are located within the R/ECAPs or in the areas adjacent to the R/ECAPs. These neighborhoods include: • Tampa Heights, Ybor Heights, , East Tampa, Highlands Pines, Historic, , and Downtown Tampa which are either in the East Tampa R/ECAP or surrounding the R/ECAP.

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• East Seminole Heights, Rivergrove, , Live Oaks Square, North East Community and Temple Crest, within the portion of the Sulphur Springs R/ECAP west of Nebraska Ave. and surrounding areas. • Terrace Park (just south of the USF) and the Forest Hills Community and Plaza Terrace neighborhoods.

Since the R/ECAP areas in the City are predominantly occupied by Black/African-American households, most of the areas with the greatest housing burden are also primarily comprised of Black/African Americans. However, there are some areas with severe housing cost burden that are more integrated or have a higher Hispanic population including Terrace Park, Forest Hills, and Plaza Terrace.

South Tampa has several neighborhoods with lighter shading indicating that households in this area are experiencing a lower level of housing cost burden. These areas are occupied by predominantly White households.

Figure 71 shows that the predominant race/ethnic group in areas with the greatest housing burden are Haitians and Cubans in the East Tampa and University Area R/ECAPs. The Plaza Terrace neighborhood also has a significant concentration of households of Cuban origin that are experiencing a high rate of housing burden.

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Figure 70: City of Tampa – Housing Burden and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 6 - Housing Problems Variation: Housing Burden and Race/Ethnicity Description: Households experiencing one or more housing burdens in City of Tampa and Region with R/ECAPs and race/ethnicity dot density Note: Darker shading indicates a higher rate of housing burden 195

Figure 71: City of Tampa – Housing Burden and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 6 - Housing Problems Variation: National Origin Description: Households experiencing one or more housing burdens in City of Tampa and Region with R/ECAPs and race/ethnicity dot density Note: Darker shading indicates a higher rate of housing burden 196

Hillsborough County Within the County, the area experiencing the greatest housing burden is the University Area R/ECAP as shown in Figure 72. Other communities that are experiencing severe housing burden (but at a lower rate than the University Area R/ECAP) include: • Egypt-Lake Leto, Town ‘N’ County, Citrus Park, and Carrollwood in the western portion of the County; • Sun City Center and Wimauma in south Hillsborough County; and • Plant City, Seffner, and Brandon in eastern Hillsborough County.

Hillsborough County is more diverse than the City and most of the areas experiencing severe housing burden are comprised of White and Hispanic households. The University Area R/ECAP has a combination on White, Hispanic, and Black/African-American households experiencing severe housing burdens but the area is predominantly Black/African-American.

In regard to the national origin of households experiencing housing burden, Figure 73 shows that there is a concentration of Cubans in Egypt-Lake Leto and Town ‘N’ County. Also, there is a significant Mexican population in Wimauma and Plant City.

Regionally, the areas experiencing the greatest housing burdens include Dade City, New Port Richey and the R/ECAP areas in Clearwater and St. Petersburg.

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Figure 72: Hillsborough County – Housing Burden and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 6 - Housing Problems Variation: Housing Burden and Race/Ethnicity Description: Households experiencing one or more housing burdens in Hillsborough County and Region with R/ECAPs and race/ethnicity dot density Note: Darker shading indicates a higher rate of housing burden 198

Figure 73: Hillsborough County – Housing Burden and National Origin

Source: HUD AFFH Data and Mapping Tool Name: Map 6 - Housing Problems Variation: Housing Burden and National Origin Description: Households experiencing one or more housing burdens in Hillsborough County and Region with R/ECAPs and national origin dot density Note: Darker shading indicates a higher rate of housing burden 199

c. Compare the needs of families with children for housing units with two, and three or more bedrooms with the available existing housing stock in each category of publicly supported housing for the jurisdiction and region.

City of Tampa Table 45 shows the number of households occupying publicly supported housing and the number of children currently residing in each of the housing types (public housing, project-based Section 8, other multifamily, and HCV Program) in the City.

There are 8,180 publicly supported housing units of which 4,393 (53.7%) are units with 2 or more bedrooms. Over 38% (3,168) of households currently residing in publicly supported housing are households with children.

The breakout of the number of housing units by size in each housing type is as follows: • Public housing – 417 units with 2 or more bedrooms and 325 are currently occupied by households with children. • Project-based Section 8 – 748 units with 2 or more bedrooms and 637 are currently occupied by households with children. • Other Multifamily – 3 units with 2 bedrooms and 2 are currently occupied by households with children. • HCV Program – 3,225 units with 2 or more bedrooms and 2,204 are currently occupied by households with children.

Table 45: City of Tampa – Publicly Supported Housing by Program Category – Units by Number of Bedrooms and Number of Children Tampa, FL Households in 0-1 Households in 2 Households in 3+ Bedroom Bedroom Bedroom Households with Units Units Units Children Housing Type # % # % # % # % Public Housing 636 48.40% 239 18.19% 178 13.55% 325 24.73% Project-Based Section 8 1,813 70.38% 555 21.55% 193 7.49% 637 24.73% Other Multifamily 509 97.70% 3 0.58% 0 0.00% 2 0.38% HCV Program 829 19.99% 1,373 33.10% 1,852 44.65% 2,204 53.13% Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014

Hillsborough County Table 46 shows the number of households occupying publicly supported housing and the number of children currently residing in each of the housing types in the County.

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There are 5,045 publicly supported housing units of which 3,469 (68.8%) are units with 2 or more bedrooms. Approximately 47% (2,375) of households currently residing in publicly supported housing in the County are households with children.

The breakout of the number of housing units by size in each housing type is as follows: • Public housing – 156 units with 2 or more bedrooms and 132 are currently occupied by households with children. • Project-based Section 8 – 205 units with 2 or more bedrooms and 141 are currently occupied by households with children. • Other Multifamily – 5 units with 2 bedrooms and 3 are currently occupied by households with children. • HCV Program – 3,103 units with 2 or more bedrooms and 2,099 are currently occupied by households with children.

Table 46: Hillsborough County - Publicly Supported Housing by Program Category – Units by Number of Bedrooms and Number of Children Hillsborough County, FL Households in 0-1 Households in 2 Households in 3+ Bedroom Bedroom Bedroom Households with Units Units Units Children Housing Type # % # % # % # % Public Housing 39 19.70% 89 44.95% 67 33.84% 132 66.67% Project-Based Section 8 218 50.93% 138 32.24% 67 15.65% 141 32.94% Other Multifamily 280 92.72% 5 1.66% 0 0.00% 3 0.99% HCV Program 1,039 24.46% 1,509 35.53% 1,594 37.53% 2,099 49.42% Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014

d. Describe the differences in rates of renter and owner occupied housing by race/ethnicity in the jurisdiction and region.

City of Tampa Table 47, shows homeownership and rental rates by race/ethnicity for the City and the region. In the City, there are 138,590 occupied housing units and 70,570 (50.92%) are owner occupied while 68,020 (49.08%) are renter occupied. The region has 1,125,960 occupied housing units and 747,425 (66.38%) are owner occupied while 378,535 (33.62%) are renter occupied.

There are significant differences in the rate of homeownership between racial and ethnic groups. In both the City and the region, White households have the highest homeownership rate followed by Hispanic households and then Black/African-American households. Among renters, White households also rent at a greater rate than other racial/ethnic groups. In the City there is a larger proportion of Black/African- American renters than Hispanic renters. 201

Table 47: City of Tampa - Homeownership and Rental Rates by Race/Ethnicity Tampa, FL Tampa-St. Petersburg-Clearwater, FL Homeowners Renters Homeowners Renters Race/Ethnicity # % # % # % # % White, Non-Hispanic 42,875 60.76% 28,720 42.22% 599,625 80.23% 226,575 59.86% Black, Non-Hispanic 10,810 15.32% 20,845 30.65% 47,225 6.32% 67,370 17.80% Hispanic 13,130 18.61% 15,975 23.49% 73,845 9.88% 69,220 18.29% Asian or Pacific Islander, Non-Hispanic 2,675 3.79% 1,425 2.09% 17,910 2.40% 8,470 2.24% Native American, Non- Hispanic 100 0.14% 65 0.10% 1,310 0.18% 810 0.21% Other, Non-Hispanic 975 1.38% 995 1.46% 7,505 1.00% 6,095 1.61% Total Household Units 70,570 - 68,020 - 747,425 - 378,535 - Source: Comprehensive Housing Affordability Strategy (CHAS), 2009-2013

Hillsborough County Table 48, shows homeownership and rental rates by race/ethnicity for the County and the region. In the County, there are 332,740 occupied housing units and 212,355 (63.82%) are owner occupied while 120,385 (36.18%) are renter occupied. The homeownership and rental rates in the County align with those of the region.

Like the City and the region, White households in Hillsborough County own at a greater rate than any other racial/ethnic group followed by Hispanic households and then Black/African-American households. The majority of renters in the County are White households followed by Hispanic and then Black/African- American households. These trends are similar in the region.

Table 48: Hillsborough County - Homeownership and Rental Rates by Race/Ethnicity Hillsborough County, FL Tampa-St. Petersburg-Clearwater, FL Homeowners Renters Homeowners Renters Race/Ethnicity # % # % # % # % White, Non-Hispanic 149,515 70.41% 57,405 47.68% 599,625 80.23% 226,575 59.86% Black, Non-Hispanic 17,529 8.25% 22,685 18.84% 47,225 6.32% 67,370 17.80% Hispanic 35,749 16.83% 33,700 27.99% 73,845 9.88% 69,220 18.29% Asian or Pacific Islander, Non- Hispanic 6,467 3.05% 3,895 3.24% 17,910 2.40% 8,470 2.24% Native American, Non-Hispanic 443 0.21% 252 0.21% 1,310 0.18% 810 0.21% Other, Non-Hispanic 2,635 1.24% 2,469 2.05% 7,505 1.00% 6,095 1.61% Total Household Units 212,355 - 120,385 - 747,425 - 378,535 - Source: Comprehensive Housing Affordability Strategy (CHAS), 2009-2013 202

2. Additional Information

a. Beyond the HUD-provided data, provide additional relevant information, if any, about disproportionate housing needs in the jurisdiction and region affecting groups with other protected characteristics.

There is no additional information available about disproportionate housing needs in the City or the County. See the Disability and Access section of this AI for information on the housing needs of persons with disabilities.

b. The program participant may also describe other information relevant to its assessment of disproportionate housing needs. For PHAs, such information may include a PHA’s overriding housing needs analysis.

THA Housing Needs Analysis THA conducted a housing needs analysis of families on its Section 8 tenant-based rental assistance waiting list as part of its 2017 Annual PHA Plan. There were 4,099 families on the waiting list with the following characteristics: • 2,564 families with children (62.6%); • 1,501 elderly families (36.6%); and • 34 families with disabilities (0.8%) In regard to race/ethnicity, 67% of the families on the waiting list were Black/African-American, 32% were White families, 0.3% were Asian, 0.1% Native American, and 0.6% unknown race/ethnicity. The waiting list data shows that families with children and Black/African-American households are experiencing the greatest level of housing need and require housing assistance when compared to other household types.

Lending Practices This section contains an analysis of Home Mortgage Disclosure Act (HMDA) data for Hillsborough County (including the City) and the region. The HMDA was enacted by Congress in 1975 and is implemented by the Federal Reserve Board as Regulation C. The analysis of HMDA data can show possible discriminatory lending patterns and can also aid public officials in targeting public capital investments in order to attract additional private sector investments where it is needed.

Financial institutions are required to collect and publicly disclose data such as race/ethnicity, income, location of loans by census tract, loan type, loan purpose, property type, occupancy characteristics of the property, the credit characteristics of the loan applicants, and the number and dollar amount of each loan.

While this AI reviews HMDA data to identify disparities in lending across different racial and ethnic groups, it must be noted that further analysis of any correlation between loan denial rates is warranted before arriving at any final conclusions. Factors to consider include borrower-related factors including income, loan amount, and credit. The most recent HMDA data available for Hillsborough County and the region is from 2015. 203

Loan Applications and Originations by Race/Ethnicity 2015

Hillsborough County (including City of Tampa) Table 49 shows that in 2015, there were 41,751 loan applications (loans originated, application approved but not accepted, application denied by financial institutions, and files closed for incompleteness) to purchase one to four-family homes in Hillsborough County. Of these applications, 24,660 (59.1%) were approved and originated. The total loan volume was $7.04 billion or approximately $285,000 per loan, according to HMDA data.

Table 49 also provides data on the percentage of loan applications that were approved and originated by race/ethnicity. For all the loans in Hillsborough County, Whites had the highest approval rating at 62.3% indicating that White households are more likely to access mortgage financing than minorities. ‘Other’ households had the lowest loan approval rate at 46.8% however, the relatively small population size of persons categorized as Other and Asian makes comparisons between these groups and the larger race/ethnic groups less reliable. Hispanic applicants had a higher approval rate than Black/African- American applicants at 55.1% and 48.3%, respectively.

Table 49: Hillsborough County - Mortgage Application and Originations by Race Mortgage Applications and Originations by Race, 2015 Hillsborough County Race/Ethnicity Population Applications Originations Approval/ Origination Disparity Ratio Origination Disparity Loans/Population Rate Size White 660,565 26,785 16,695 62.3% 1.00 1.26 (53.7%) (64.2%) (67.7%) Black/African 191,260 4,093 1,976 48.3% 1.29 0.51 American (15.6%) (9.8%) (8.0%) Hispanic 306,635 7,965 4,392 55.1% 1.13 0.71 (24.9%) (19.1%) (17.8%) Asian 41,328 1,886 1,119 59.3% 1.05 1.35 (3.4%) (4.5%) (4.5%) Other 29,438 1,022 478 46.8% 1.33 0.79 (2.4%) (2.4%) (1.9%) Total 1,229,226 41,751 24,660 59.1% 1.00

Source: Demographics are derived from the 2010 U.S. Census.

Origination disparity is a measure of the likelihood of a minority application being originated compared to the likelihood of a White application being originated. In Hillsborough County, loans for Whites applicants are 1.29 times more likely to be originated than loans for Black/African-American applicants and 1.13 times more likely to be originated than loans for Hispanic applicants.

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The disparity ratio between originated loans and population size is the difference between lending to a racial/ethnic group in relation to their population size. That is, if population size and loan originations are equal, there is no disparity. As shown in Table 49, Whites comprised 53.7% of the population however they received 1.26 times the loans that their population size indicated they should whereas Black/African- Americans received approximately half of the loans that their population size indicated they should receive. Hispanics also received less than their share of loans based on that population’s size. Figure 74 depicts the disparity ratio between loan originations and population size in the County.

Figure 74: Hillsborough County - Comparison of loan originations to population by Race/Ethnicity

2015 HMDA Originations 2010 Population

Black 8.0% Black Hispanic 15.6% 17.8% White 53.7% Asian Asian 3.4% 4.5%

Hispanic 24.9% White 67.7%

Region In the region, there were a total of 96,020 loan applications for one to four-family homes in 2015. Of these applications, 56,262 (58.6%) were approved and originated. The loan volume was $14.3 billion or an average of $254,842 per loan, according to HMDA data. Approximately 50% of the loans in the region were made in Hillsborough County and the average loan amount in the County was almost 12% more than in the region.

Table 50 provides data on the percentage of loan applications that were approved and originated by race/ethnicity. The approval or origination rates in the region are similar to the County. Whites had the highest loan approval rate at 60.5% followed by Asians at 57.2%, Hispanics at 55.0%, Black/African- Americans at 48.1%, and Other Races at 48.1%.

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Table 50: Tampa-St. Petersburg-Clearwater, FL - Mortgage Application and Originations by Race Mortgage Applications and Originations by Race, 2015 Tampa – St. Petersburg – Clearwater, FL Race/Ethnicity Population Applications Originations Approval/ Origination Disparity Ratio Origination Disparity Loans/Population Rate Ratio Size White 1,879,437 71,911 43,521 60.5% 1.00 1.15 (67.5%) (74.9%) (77.4%) Black/African 310,357 6,428 3,093 48.1% 1.26 0.49 American (11.2%) (6.7%) (5.5%) Hispanic 452,208 12,279 6,755 55.0% 1.10 0.74 (16.2%) (12.8%) (12.0%) Asian 79,501 3,254 1,860 57.2% 1.06 1.13 (2.9%) (3.4%) (3.3%) Other 61,740 2,148 1,033 48.1% 1.26 0.82 (2.2%) (2.2%) (1.8%) Total 2,783,243 96,020 56,262 58.6% 1.00 Source: Demographics are derived from the 2010 U.S. Census.

The origination disparity in the region indicates that loans for Whites applicants are 1.26 times more likely to be originated than loans for Black/African-American applicants and 1.10 times more likely to be originated than loans for Hispanic applicants.

The disparity ratio between originated loans and population size shows that Whites comprised 67.5% of the population however they received 1.15 times the loans that their population size indicated they should. Black/African-Americans, Hispanics, and ‘Other’ loan applicants all had a negative disparity meaning that less loans were originated for these groups than their population size indicated. Like the County, Black/African-Americans applicants had the lowest lending activity when compared to their population size. Figure 75 depicts the disparity ratio between loan originations and population size in the region.

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Figure 75 - Tampa-St. Petersburg-Clearwater CBSA - Comparison of loan originations to population by Race/Ethnicity

2015 HMDA Originations 2010 Population Black, 5.5%

Black Hispanic, 12.0% 11.2% White Asian 67.5% Asian, 2.9% 3.3% White, Hispanic 77.4% 16.2%

Application Denial by Race/Ethnicity in 2015

Table 51 provides data on the percentage of loan applications denied by race/ethnicity in Hillsborough County and the region. The data suggests that Blacks/African-Americans are more likely to be denied home purchase loans than any other race/ethnic group.

For all loans in Hillsborough County, 33.4% of Black/African-American loans were denied, while 26.8% of Hispanic and 18.8% of White loans were denied. The data show that Blacks/African-Americans have a disproportionately greater home purchase loan denial rate. The loan denial rates in the region are similar to those of the County.

Table 51: Loan Application Denials by Race/Ethnicity Loan Application Denials by Race/Ethnicity Jurisdiction Total White Black/African Hispanic Asian Other Denial Rate American

Percentage of Loan Application Denied Hillsborough 22.1% 18.8% 33.4% 26.8% 19.6% 31.5% County Denial Rate 1.00 1.78 1.43 1.04 1.66 Disparity Ratio CBSA 22.2% 20.2% 33.8% 26.4% 21.4% 29.4% Denial Rate 1.00 1.67 1.30 1.06 1.46 Disparity Ratio Source: 2015 HMDA

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Figure 76 shows a comparison of the denial rates by race/ethnicity in the County and the region. The denial rate disparity compares the denial rates for a specific minority group to the denial rate for Whites. The ratio indicates that all minority groups in Hillsborough County and the region are more likely to be denied home purchase loans than White applicants. The denial rate of Asian applicants is almost equal to the denial rate of White applicants. Black/African-American and Hispanic applicants have the largest disparity between White applicants and the Black/African-American denial rate is the highest. Black/African-American applicants are approximately 1.7 times more likely to be denied a loan than White applicants in both the County and the region.

Figure 76 – Single-family Home Purchase Denial Rate

Single Family Home Purchase Denial Rate, 2015 40.00% 33.4%33.8% 35.00% 31.5% 29.4% 30.00% 26.8%26.4% 25.00% 21.4% 18.8%20.2% 19.6% 20.00% 15.00% Denial Rate Denial 10.00% 5.00% 0.00% White Black/African Hispanic Asian Other American Race/Ethnicity

Hillsborough County CBSA CBSA

The data in Figure 76 suggests that minorities may have received unequal treatment in the home purchase loan approval process given the large difference between the denial of White and Black/African-American loans and to a lesser extent between White and Hispanic loans. However, it is important to note that the denial rate disparity does not prove that there are unfair lending practices in Hillsborough County or the region. Instead, it suggests that further research is needed into the reason for denials. Reasons for denial for loan products other than discriminatory lending practices include debt-to-income ratio, employment history, credit history, lack of collateral, insufficient cash for downpayment and closing costs, incomplete credit applicants, and unverifiable information.

Home Purchase Loan Analysis by Income Level 2015

Hillsborough County (including City of Tampa) Table 52 provides data on mortgage applications/originations and loan denials by income level of the applicant and by census tract characteristics. Of the 41,751 total loan applications in Hillsborough County, 17,352 (41.6%) were made by low- and moderate-income applicants (LMI applicants) and 24,399 (58.4%) were made by middle- and upper-income applicants (MUI applicants).

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Table 52: Hillsborough County - Mortgage Application by Income Level Mortgage Applications by Income Level, 2015 Hillsborough County Income Population Applications Originations Approval/ Denial Rate Level Origination Rate LMI 17,352 8,487 48.9% 28.6% Applicant N/A (41.6%) (34.4%) MUI 24,399 16,173 66.3% 17.4% Applicant (58.4%) (65.6%) Applicant in 372, 810 9,107 4,396 48.3% 31.1% LMI Tract (30.3%) (21.8%) (17.8%) Applicant in 856,416 32,644 20,264 62.1% 19.6% MUI Tract (69.7%) (78.2%) (82.2%) Applicant in 478,969 16,348 8,606 52.6% 27.3% Minority (39.0%) (39.2%) (34.9%) Tract Source: 2015 HMDA; Income based on FFIEC calculations as of 2015

Table 52 shows that MUI homebuyers have higher loan approval rates than LMI homebuyers (66.3% vs 48.9%). This suggests that the income level of an applicant plays a role in the ability of the applicant to qualify for a loan. Conversely, the higher income group experiences lower denial rates (17.4%) than that of the lower income group (28.6%). Based on the HMDA data, in terms of loan volume, a little over $5 billion (71.3%) of all home purchase loans in the County are made to MUI applicants compared to approximately $2 billion (28.7%) to LMI applicants. The average value of a loan made to LMI applicants is $237,804 while the average value of a loan made to MUI applicants is $310,283.

The income characteristics of the census tracts also indicates that applicants in LMI census tracts also experience higher denial rates (31.1%) than homebuyers in MUI census tracts (19.6%). Applicants in MUI tracts are more likely to have their home purchase loans approved and originated. There are 215 MUI tracts in Hillsborough County representing 67% of the total census tracts however, these tracts account for over 82% of the total loan originations in the County. LMI tracts represent 33% of all census tracts in the County but only 17.8% of the originated loans are for applicants in LMI tracts.

The proportion of loan volume in MUI tracts (89.5%) versus LMI tracts (10.5%) represents a difference in investment of over $5.6 billion. The average value of a loan made to an applicant in a LMI tract is $168,612 while the average value of a loan made to an applicant in a MUI tract is $310,661.

Region The mortgage lending patterns in the region are similar to those in the County. There was a total of 96,020 loan applications in the region of which 41,123 (42.8%) were made by LMI applicants and 54,897 (57.2%) were made by MUI applicants.

Table 53 shows that MUI applicants were more likely to be approved for a home purchase loan than LMI applicants (65.6% vs 49.3%). Additionally, a larger volume of loans were originated for MUI applicants and 209

the loan denial rate is lower for higher income groups. Based on the HMDA data, the dollar value of the loans in the region was $14.3 billion: $10.3 billion (72.1%) was made to MUI applicants and $4 billion (27.9%) to LMI applicants. The average value of a loan made to LMI applicants in the region is $197,278 while the average value of a loan made to MUI applicants is $287,260.

Table 53: Tampa – St. Petersburg – Clearwater, FL – Mortgage Applications by Income Level Mortgage Applications by Income Level, 2015 Tampa – St. Petersburg – Clearwater, FL Income Population Applications Originations Approval/ Denial Rate Level Origination Rate LMI 41,123 20,270 49.3% 28.6% Applicant N/A (42.8%) (36.0%) MUI 54,897 35,992 65.6% 17.3% Applicant (57.2%) (64.0%) Applicant in 805,369 20,894 10,448 50.0% 29.6% LMI Tract (28.9%) (21.8%) (18.6%) Applicant in 1,977,874 75,126 45,814 61.0% 20.1% MUI Tract (71.1%) (78.2%) (81.4%) Applicant in 570,638 18,917 9,814 51.9% 27.9% Minority (20.5%) (19.7%) (17.4%) Tract Source: 2015 HMDA; Income based on FFIEC calculations as of 2015

Like the County, the income characteristics of the census tracts indicates that applicants in LMI census tracts also experience higher denial rates (29.6%) than homebuyers in MUI census tracts (20.1%). Higher income applicants and applicants purchasing homes in MUI tracts are more likely to have their home purchase loans approved and originated.

The MUI tracts in the region represent 68% of the total census tracts (746 tracts) however, these tracts account for over 81% of all single-family loan originations. LMI tracts represent 32% of all census tracts in the region but only 18.6% of the originated loans are for applicants in LMI tracts.

The share of loan volume in MUI tracts (89%) versus LMI tracts (11%) represents a difference in investment of over $11.2 billion. The average value of a loan made to an applicant in a LMI tract is $149,732 while the average value of a loan made to an applicant in a MUI tract is $278,812.

Figure 77 is a map of residential lending between 2012-2015 by census tract that shows a substantial difference in lending between the heavily minority urban core of Tampa and the R/ECAPs – less than 5 loans per 100 homes in each census tract –as compared to other areas of the City, namely South Tampa and New Tampa, as well as unincorporated Hillsborough County, which have loans ranging from 5 to more than 50 loans per 100 homes.

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Figure 77 – Residential Lending in Hillsborough County

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Bank Branch Locations In addition to analyzing disparities in lending by race/ethnicity and income levels, it is also important to evaluate the level of access to financial services especially in minority-concentrated and/or high poverty areas. The purpose of this analysis is to determine if there is equitable treatment in the provision of financial services. Failing to place bank branches in certain areas may discriminate against protected classes. Gaps in banking services reduces the chance of an individual becoming a homeowner, impacts the ability to sustain homeownership, and affects an individual’s credit. Residents in underserved areas may also be more likely to use costly payday lending services. Access to financial services is a key factor in lifting people out of poverty.

According to FDIC branch data for 2015, there are 744 bank branches in the region of which 302 (40.6%) are located in Hillsborough County. For purposes of this AI, bank branches include Full Service Brick and Mortar Office (accept deposits, make loans, open/close accounts, loan officer on site, normal hours, full- time staff; may have safe deposit facilities on site) and Full Service Retail Office (accept deposits, make loans, open/close accounts, loan officer on site, normal hours, full-time staff, located in a retail facility such as a supermarket or department store; may have safe deposit facilities on site).

Of the 302 bank branches in the County, 5.6% are located in low- and moderate-income tracts (LMIT) only, 11.9% are located in middle income tracts (MINT) only, 14.6% are located in both LMIT and MINT tracts, and the majority of bank branches, 65.6%, are located in neither LMIT or MINT tracts. The region also has the majority of its bank branches (69.4%) located in areas that are neither LMIT or MINT. A larger percentage of bank branches are located in the LMIT only in the region when compared to the County (16.4% vs 5.6%). Approximately 8% of bank branches are located in both LMIT and MINT tracts and there are no bank branches in MINT only tracts.

Figure 78 shows the location of bank branches in the County. When examining the map, the majority of banks in the County are concentrated in two areas – Brandon and Carrollwood and there are a fair share of banks in Plant City. There is however, a limited number of banks in the low- and moderate-income tracts in the County.

In the City, bank branches are concentratrated in downtown Tampa, West Tampa, and South Tampa. The banks in the West Tampa area, near the Airport, are concentrated in LMIT tracts including the neighborhoods of Carver City/Lincoln Gardens and Westshore Palms. The R/ECAPs within the City limits have little to no bank braches. The only R/ECAP where banks are located is the East Tampa R/ECAP which has a few banks in the East Ybor Historic Neighborhood.

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Figure 78 – Hillsborough County Bank Branches

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3. Contributing Factors of Disproportionate Housing Needs

Identify factors that significantly create, contribute to, perpetuate, or increase the severity of disproportionate housing needs.

• Access to financial services • Availability of affordable units in a range of sizes • Displacement of residents due to economic pressures • Lack of access to opportunity due to high housing costs • Lack of private investments in specific neighborhoods • Lack of public resources for investment in specific neighborhoods, including services and amenities • Land use and zoning laws • Lending discrimination • Loss of Affordable Housing • Source of income discrimination • Educational Attainment

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C. Publicly Supported Housing Analysis

1. Analysis a. Publicly Supported Housing Demographics i. Are certain racial/ethnic groups more likely to be residing in one program category of publicly supported housing than other program categories (public housing, project-based Section 8, Other Multifamily Assisted developments, and Housing Choice Voucher (HCV)) in the jurisdiction?

The HUD data on publicly supported housing is grouped into four program categories: public housing; project-based Section 8; Section 8 tenant-based Housing Choice Vouchers (HCV); Other Multifamily housing (including Section 202 Supportive Housing for the Elderly, Section 811 Supportive Housing for Persons with Disabilities, and Low-Income Housing Tax Credit (LIHTC) housing). Tables 54 through 56 presents data by race/ethnicity for persons occupying each category of publicly supported housing in the City, County, and the region.

City of Tampa Based on the data in Table 54, Black/African-American households are more likely to live in public housing and in HCV program units while Hispanic households are more likely to live in project-based Section 8 and Other multifamily housing. White households and Asian/Pacific Islander households represent a relatively small proportion of families residing in publicly supported housing.

Blacks/African-Americans represent a majority of residents living in public housing in the City with 57.81% of all residents in public housing. The second largest share of residents in public housing is Hispanic residents at 35.14%, followed by Whites at 6.67%. Asians/Pacific Islanders are essentially absent from the public housing program with a total of 4 residents or 0.38%. With Blacks/African- Americans making up 22.84% of total households in the City of Tampa, this demonstrates that Blacks/African-Americans are proportionally overrepresented in the public housing program. Blacks/African-Americans also represent a large majority of HCV program residents at 73.21%. The second largest share of HCV program residents is held by Hispanics at 18.38%. The Black/African American share of residents in the HCV program (73.21%) is the largest share of any racial/ethnic group in any publicly supported housing program type.

Hispanics represent a majority of residents in the project-based section 8 program at 50.45% of all residents. The second largest share of residents is Blacks/African-Americans at 34.37%, followed by Whites at 14.58%. Hispanic households represent only 20.99% of all households in the City, demonstrating that a disproportionate share of Hispanics live in project-based Section 8 units. Hispanic households also represent a majority of program residents in the Other Multifamily category making up 66.26% of all residents in project-based Section 8 units. The second largest share is held by Whites at 21.62%, followed by Blacks/African-Americans at 10.30%.

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Table 54: Publicly Supported Housing Residents by Race/Ethnicity Race/Ethnicity Asian or Pacific Tampa, FL White Black Hispanic Islander Housing Type # % # % # % # % Public Housing 70 6.67% 607 57.81% 369 35.14% 4 0.38% Project-Based Section 8 369 14.58% 870 34.37% 1,277 50.45% 14 0.55% Other Multifamily 107 21.62% 51 10.30% 328 66.26% 9 1.82% HCV Program 322 7.99% 2,952 73.21% 741 18.38% 16 0.40% Total Households 71,585 51.65% 31,650 22.84% 29,095 20.99% 4,092 2.95% 0-30% of AMI 5,935 29.21% 7,990 39.32% 5,755 28.32% 494 2.43% 0-50% of AMI 10,120 27.82% 13,385 36.80% 10,170 27.96% 794 2.18% 0-80% of AMI 18,485 32.22% 19,635 34.23% 15,620 27.23% 1,329 2.32%

Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014

Hillsborough County Overall, the racial and ethnic composition of publicly supported housing developments in Hillsborough County suggests that Black/African-Americans and Hispanics often live in publicly supported housing more so than Whites, and to a lesser extent, Asian/Pacific Islanders as shown in Table 55. Black/African-American households dominate the public housing and HCV programs, but have limited representation in Other Multifamily and project-based Section 8 units.

Like the City, the majority of public housing in Hillsborough County is occupied by Blacks/African- Americans representing 76.53% of all residents in the program. The remaining population in public housing is 12.76% Whites and 10.71% Hispanics. This disproportionate share of public housing residents in the County is compounded by the fact that Black/African-American households comprise only 12.09% of all households in the County. Blacks/African-Americans also represent a majority of program participants in the County’s HCV Program, 58.02% of all program participants. The second largest share in the HCV program is Hispanics at 29.17%, followed by Whites at 12.57%.

The County’s project-based Section 8 program is relatively diverse, with Hispanics having the greatest share of all residents in the program at 42.35%, followed closely by Whites at 38.82%. Blacks/African- Americans are a distant third at 18.35%. The County’s Other Multifamily programs are composed of 216

two principle groups, Hispanics representing 50.54% of all residents and Whites making up 44.09% of the population. Blacks/African-Americans represent only 4.30% of residents in Other Multifamily units.

Table 55: Hillsborough County - Publicly Supported Housing Residents by Race/Ethnicity Hillsborough Asian or Pacific County, FL White Black Hispanic Islander Housing Type # % # % # % # % Public Housing 25 12.76% 150 76.53% 21 10.71% 0 0.00% Project-Based Section 8 165 38.82% 78 18.35% 180 42.35% 1 0.24% Other Multifamily 123 44.09% 12 4.30% 141 50.54% 2 0.72% HCV Program 514 12.57% 2,373 58.02% 1,193 29.17% 5 0.12% Total Households 206,973 62.20% 40,237 12.09% 69,451 20.87% 10,364 3.11% 0-30% of AMI 13,226 43.23% 5,987 19.57% 9,661 31.58% 953 3.12% 0-50% of AMI 22,903 37.21% 10,437 16.95% 18,889 30.68% 1,747 2.84% 0-80% of AMI 51,254 45.81% 17,519 15.66% 31,941 28.55% 2,768 2.47%

Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014 ii. Compare the racial/ethnic demographics of each program category of publicly supported housing for the jurisdiction to the demographics of the same program category in the region.

City of Tampa Compared to data for the region in Table 56, there is a smaller proportion of White households in City’s public housing (6.67% of total in the City versus 18.79% in the region), while the Black/African-American population remains essentially even (57.81% in the City versus 57.09% in the region. The percentage of Hispanic households living in public housing is significantly higher in the City compared to the region (35.14% in the City versus 23.39% in the region). These same trends are repeated across program types, with the exception of the HCV program, where 24.45% of households are White in the region compared to 7.99% in the City.

Hillsborough County Comparing Tables 55 and 56 shows that the White population represents a larger share of project- based Section 8 housing in the County compared to the region (38.82% versus 36.37% in the region). Whites comprise a smaller share of all other housing types compared to the region. The Black/African American population represents a larger share of public housing residents (76.53% 217

in the County versus 57.09% in the region). Blacks/African-Americans compose a smaller percentage of project-based Section 8, Other multifamily, and the HCV program in the County compared to the region. The Hispanic population represents a larger share of project-based Section 8, Other multifamily, and the HCV program in the County compared to the region. The only housing type where Hispanics represent a smaller share compared to the region is in public housing (10.71% in the County versus 23.39% in the region).

Table 56: Tampa-St. Petersburg-Clearwater Region - Publicly Supported Housing Residents by Race/Ethnicity Tampa-St. Petersburg- Clearwater, Asian or Pacific FL White Black Hispanic Islander Housing Type # % # % # % # % Public Housing 461 18.79% 1,401 57.09% 574 23.39% 15 0.61% Project- Based Section 8 1,946 36.37% 1,521 28.43% 1,841 34.41% 31 0.58% Other Multifamily 777 49.74% 168 10.76% 594 38.03% 21 1.34% HCV Program 4,350 24.45% 10,342 58.14% 3,018 16.97% 59 0.33% Total Households 826,185 73.38% 114,604 10.18% 143,070 12.71% 26,387 2.34% 0-30% of AMI 68,160 59.13% 21,854 18.96% 20,545 17.82% 2,493 2.16% 0-50% of AMI 117,170 49.75% 38,224 16.23% 40,120 17.03% 4,503 1.91% 0-80% of AMI 245,615 58.64% 59,814 14.28% 67,610 16.14% 7,908 1.89% Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014 iii. Compare the demographics, in terms of protected class, of residents of each program category of publicly supported housing (public housing, project-based Section 8, Other Multifamily Assisted developments, and HCV) to the population in general, and persons who meet the income eligibility requirements for the relevant program category of publicly supported housing in the jurisdiction and region. Include in the comparison, a description of whether there is a higher or lower proportion of groups based on protected class.

Table 54 provides data on the racial and ethnic breakdown of households occupying publicly supported housing as well as racial and ethnic data for lower income households and all households

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in the City. Table 55 offers the same data for Hillsborough County. The publicly supported housing types reviewed in these tables are targeted to households with low- and moderate-incomes (0-80% AMI), particularly those with very low incomes (≤50% AMI).

City of Tampa

Public Housing In the City, Whites represent a majority of total households (51.65%) and hold a small share of public housing residents (6.67%). Blacks/African-Americans represent 22.84% of total households in the City, compared to a disproportionate share of public housing program residents (57.81%). Hispanics represent 20.99% of total households compared to a disproportionate share of public housing program residents (35.14%). There are only 4,092 Asian/Pacific Islander households (2.95%), with only a 0.38% share in the public housing program.

Considering income, it appears that again Whites are underrepresented in the public housing program. Whites represent 32.22% of low-income households (0-80% AMI), while holding only a 6.67% share of public housing residents. Blacks/African-Americans hold a similar share of total low- income households (34.23%) yet represent 57.81% of public housing program participants. Hispanic households are also overrepresented in public housing (27.23% of total household share between 0- 80%AMI), and represent 35.14% of all public housing program residents.

Whites also represent the majority of households in the region (73.38%) and like the City, are underrepresented in public housing overall as well as by income. Black/African-American and Hispanic households occupy a disproportionate share of public housing in the region, like in the City.

Project-Based Section 8 Whites are underrepresented in project-based Section 8 housing (14.58%), compared to the group’s total share of households (51.65%). Blacks/African-Americans are overrepresented in the program (34.37%) compared to the group’s total share of households (22.84%). Hispanics are the most overrepresented in the program (50.45%) compared to the group’s total share of households (20.99%).

Considering income, Whites are underrepresented in project-based Section 8 compared to the total low-income households (32.22%). Blacks/African-Americans are barely overrepresented in the program relative to the total low-income households (34.37% share in the program, compared to 34.23% of low-income households). Hispanics, on the other hand, are heavily overrepresented in the program compared to the group’s low-income household share (27.23% of total households).

Other Multifamily Whites are underrepresented in the Other Multifamily program (21.62%) compared to group’s total share of households in the City (51.65%). Blacks/African-Americans are also underrepresented in the Other Multifamily program category (10.30% program participation compared to 22.84% total 219

households). For Hispanics, the share of Other Multifamily is overrepresented (66.26%) relative to the Hispanic share of total households (20.99%). The number of Asians/Pacific Islanders is negligible.

Considering income, Whites are underrepresented in the program category compared to the total share of White low-income households (29.21%). Blacks/African-Americans are underrepresented in the Other Multifamily category relative to the total population of low-income households (34.23%). Hispanics are heavily overrepresented in the Other Multifamily category, compared to the group’s share of low-income households (27.23%).

HCV Program Whites are underrepresented in the HCV Program (7.99%) compared to the White share of total households in the City (51.65%). Blacks/African-Americans are heavily overrepresented in the HCV Program (73.21%) relative to the group’s share of total households (22.84%). Hispanics are underrepresented in the City’s HCV Program (18.38%) compared to the group’s total share of households (20.99%).

Considering income, Whites are underrepresented in the program category compared to the total share of White low-income households (29.21%). Blacks/African-Americans are heavily overrepresented in the HCV Program, compared to its low-income share of total households (34.23%). Hispanics are underrepresented in the HCV Program relative to the total share of low-income Hispanic households overall (27.23%).

Hillsborough County

Public Housing In Hillsborough County, Whites represent a majority of total households (62.20%), and hold a small share of public housing residents (12.76%). Blacks/African-Americans represent 12.09% of total households in the County, compared to a disproportionate share of public housing program residents (76.53%). Hispanics represent 20.87% of total households compared to a smaller share of public housing program residents (10.71%). There is a total of 10,364 Asian/Pacific Islander households (3.11%), with zero public housing program households.

Considering income, Whites are underrepresented in the public housing program. Whites represent 45.81% of low-income households (0-80% AMI), while holding only a 12.76% share of public housing residents. Blacks/African-Americans hold a 15.66% share of total low-income households, and represent 76.53% of public housing program participants. Hispanic households are also overrepresented in public housing with 28.55% total households between 0-80%AMI, and 10.71% of all public housing program residents.

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Project-Based Section 8 Whites are underrepresented in project-based Section 8 (38.82%), compared to the group’s total share of households (62.20%). Blacks/African-Americans are overrepresented in the program (18.35%) compared to the group’s total share of households (12.09%). Hispanics are the most overrepresented in the program (42.35%) compared to the group’s total share of households (20.87%).

Considering income, Whites are underrepresented in project-based Section 8 compared to the total low-income households (45.81%). Blacks/African-Americans are barely overrepresented in the program relative to the total low-income households (18.35% share in the program, compared to 15.66% of low-income households). Hispanics, on the other hand, are heavily overrepresented in the program compared to the group’s low-income total household share (42.35% program share compared to 28.55% low-income household share).

Other Multifamily Whites are underrepresented in the Other Multifamily program (44.09%) compared to group’s total share of households in the City (62.20%). Blacks/African-Americans are also underrepresented in the Other Multifamily program category (4.30% program participation compared to 12.09% total households). For Hispanics, the share of Other Multifamily is overrepresented (50.54%) relative to the Hispanic share of total households (20.87%).

Considering income, Whites are barely underrepresented in the program category compared to the total share of White low-income households (45.81%). Blacks/African-Americans are underrepresented in the Other Multifamily category relative to the total population of low-income households (15.66%). Hispanics are heavily overrepresented in the Other Multifamily category, compared to the group’s share of low-income households (28.55%).

HCV Program Whites are underrepresented in the HCV Program (12.57%) compared to the White share of total households in the County (62.20%). Blacks/African-Americans are heavily overrepresented in the HCV Program (58.02%) relative to the group’s share of total households (12.09%). Hispanics are overrepresented in the City’s HCV Program (29.17%) compared to the group’s total share of households (20.87%).

Considering income, Whites are underrepresented in the program category compared to the total share of White low-income households (45.81%). Blacks/African-Americans are heavily overrepresented in the HCV Program, compared to its low-income share of total households (15.66%). Hispanics are overrepresented in the HCV Program relative to the total share of low-income Hispanic households overall (28.55%).

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b. Publicly Supported Housing Location and Occupancy i. Describe patterns in the geographic location of publicly supported housing by program category (public housing, project-based Section 8, Other Multifamily Assisted developments, HCV, and LIHTC) in relation to previously discussed segregated areas and R/ECAPs in the jurisdiction and region.

City of Tampa Figure 79 shows the location of publicly supported housing and HCV usage in the City along with the R/ECAP boundaries and race/ethnicity data. Based on the analysis of this map, most of the City’s publicly supported housing is concentrated in East Tampa, Downtown, and the area across the Hillsborough River from Downtown.

Project-based Section 8 developments are particularly concentrated in the downtown, Ybor City, and West Tampa areas. These neighborhoods, as well as areas of Sulphur Springs and , account for most of the City’s public housing. Most LIHTC developments are in East Tampa or northern Tampa south of Fowler Avenue, while other HUD multifamily developments are the most widely distributed type of publicly supported housing development.

Many of the City’s publicly supported housing developments are located in or near R/ECAPs or other areas with high concentrations of Black/African-American and/or Hispanic residents. LIHTC developments are particularly concentrated in or near R/ECAPs in primarily Black/African-American neighborhoods. The areas with the lowest concentration of publicly supported housing developments – other than the airport area and southeast Tampa where population is low—are South Tampa and Seminole Heights near the Hillsborough River, where the population is primarily White.

Census tracts with the largest percentages of housing units subsidized by vouchers are in East Tampa and northern Tampa south of Fowler Avenue, in or near primarily Black/African-American R/ECAPs. It is not surprising that some census tracts in the City’s R/ECAPs have a relatively low share of voucher- subsidized units, since the HCV program is intended to allow participants to find decent housing in neighborhoods of their choice. However, the fact that vouchers are most heavily utilized in largely Black/African-American census tracts, often near R/ECAPs, suggests that voucher holders face barriers to finding units in other neighborhoods. Some census tracts with moderate levels of voucher utilization, particularly in northern Tampa south of Fowler Avenue, are fairly diverse. However, voucher utilization is notably low in the largely White areas such as South Tampa and in Seminole Heights area near the Hillsborough River, and in the heavily Hispanic areas west of the Hillsborough River.

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Figure 79: City of Tampa – Publicly Supported Housing and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 5 - Publicly Supported Housing and Race/Ethnicity Description: Public Housing, Project-Based Section 8, Other Multifamily, and LIHTC locations mapped with race/ethnicity dot density map with R/ECAPs, distinguishing categories of publicly supported housing by color Note: Darker shading represents a heavier concentration of vouchers 223

Hillsborough County Hillsborough County’s publicly supported housing developments are most densely concentrated in the University Area R/ECAP, in Brandon, and in Plant City as shown in Figure 80. The developments in the University Area R/ECAP are primarily Black/African-American and Hispanic and mostly White in the areas of Brandon and Plant City. Clusters of developments are also found in the Town ‘N’ Country, Egypt Lake-Leto, and Citrus Park areas, which are primarily Hispanic and White, but are absent from the more heavily White suburbs in northwestern Hillsborough County. Another cluster is found in the area of Progress Village, Riverview, and western Brandon. While this overall area is diverse, it is notable that the publicly supported housing is west of the more heavily White parts of Brandon. Two other small clusters are found in largely Hispanic neighborhoods in southern Hillsborough County – Ruskin and Wimauma.

LIHTC and other HUD multifamily developments are the most widely distributed type of publicly supported housing development in Hillsborough County, whereas project-based Section 8 is most heavily concentrated in the University Area R/ECAP. The only public housing in Hillsborough County outside of Tampa is a development in Plant City owned by the Plant City Housing Authority, and a development in Del Rio near Tampa’s eastern City limit.

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Figure 80: Hillsborough County -Publicly Supported Housing and Race/Ethnicity

Source: HUD AFFH Data and Mapping Tool Name: Map 5 - Publicly Supported Housing and Race/Ethnicity Description: Public Housing, Project-Based Section 8, Other Multifamily, and LIHTC locations mapped with race/ethnicity dot density map with R/ECAPs, distinguishing categories of publicly supported housing by color Note: Darker shading represents a heavier concentration of vouchers 225

ii. Describe patterns in the geographic location for publicly supported housing that primarily serves families with children, elderly persons, or persons with disabilities in relation to previously discussed segregated areas or R/ECAPs in the jurisdiction and region.

The HUD-provided maps do not distinguish between developments that serve families, elderly, or persons with disabilities. Therefore, Google Maps was used to plot publicly supported housing developments in the Affordable Housing Inventory maintained by the Shimberg Center for Housing Studies at the University of Florida as shown in Figure 81 for the City and Figure 82 for the County.

The Affordable Housing Inventory identifies the target population(s) that each development serves. However, the “family” category indicates that the development is designed for general occupancy by income qualified households; the Shimberg Center does not provide data on the share of families with children at each development. The map excludes four developments in Hillsborough County that are targeted to both “families” and farmworkers, since it was assumed that these developments would serve a lower proportion of families with children than strictly “family” developments.

City of Tampa

Persons with Disabilities Tampa has four publicly supported housing developments that explicitly serve persons with disabilities. Three are in the primarily Hispanic and White areas west of the Hillsborough River, and one is located near the Gandy Boulevard Bridge in a largely White neighborhood in South Tampa.

Elderly Developments serving elderly-headed households are fairly widespread throughout Tampa, but are notably concentrated in the downtown area, near West Tampa, and Ybor City/East Tampa areas. They are also common in western and near northern Tampa, extending from the Raymond James Stadium area to the University Square area. Note that many of the developments serving elderly households in these areas also serve families, although such developments in western and northern Tampa tend to be close to the Hillsborough River. South Tampa has several developments that primarily serve elderly households, but they are mainly clustered between the Fairoaks Manhattan Manor neighborhood and the shoreline. The South Tampa development for people with disabilities, and a development serving both elderly and family households, are located in this same cluster. Overall, developments serving elderly households tend to be in areas where Whites are not heavily concentrated.

Families Developments serving families in the City, with no units set aside for elderly or disabled households, are primarily located in East Tampa (which is primarily Black/African-American), in or near Ybor City, and across the Hillsborough River from the downtown and Tampa Heights area. A few additional developments are located in South Tampa, the Plaza Terrace neighborhood, North Tampa, and the New Tampa/Pebble Creek area. As noted above, several additional developments in downtown 226

Tampa, Ybor City and East Tampa, and just west of the Hillsborough River serve both families and elderly households. Like publicly supported housing developments for elderly households, those serving families are not exclusively located in R/ECAPs or high-minority areas. However, family developments—to a somewhat greater extent than elderly developments—are primarily located in areas with lower concentrations of Whites.

Figure 81: Distribution of Publicly Supported Housing Developments in Tampa by Population Served

Green = targeted to people with disabilities

Yellow-green = targeted to families and people with disabilities

Red = targeted to elderly

Orange = targeted to families and elderly

Blue = targeted to families

Source: Shimberg Center Assisted Housing Inventory, 2016

Hillsborough County

Persons with Disabilities In Hillsborough County, outside of Tampa, publicly supported housing developments serving people with disabilities are dispersed throughout the community, with development clusters in the primarily Black/African-American and Hispanic/Latino University Area R/ECAP and in Brandon. Notably, the developments for people with disabilities in Brandon are located further east, in a moderately Whiter neighborhood, than many of the other publicly supported housing in the Brandon area. Additionally, there are two developments for people with disabilities in the suburbs northwest of Tampa (between

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the Carrollwood and Egypt Lake-Leto areas), one south of Thonotosassa, and one in southwestern Plant City—all relatively diverse areas.

Elderly Publicly supported housing developments serving elderly-headed households are scattered throughout Hillsborough County, but the majority are in eastern Hillsborough County. The biggest concentration is in Plant City with 5 of the 11 located in the city. One development serving both elderly and family households is in a largely Black/African-American part of Plant City, but the other three, which primarily serve elderly households, are in more diverse neighborhoods north of Highway 92. The other five elderly developments east of Tampa are located between New Tampa and Progress Village. The elderly developments south of , near Mango, and in Brandon are in fairly diverse neighborhoods, while the developments serving both elderly and family households (south of the Selmon Expressway and in Progress Village) are in neighborhoods with relatively low concentrations of Whites.

The remaining two developments serving elderly-headed households also serve families and are in northwestern Hillsborough County. One is just north of the primarily Black/African-American and Hispanic/Latino University Area R/ECAP, in a largely White neighborhood north of Bearss Avenue. The other is in a primarily White neighborhood south of Citrus Park.

Families Developments serving families in Hillsborough County, with no units set aside for elderly or disabled households, are primarily located in the suburbs east of Tampa, in the University Area R/ECAP, and in the Egypt Lake-Leto, Citrus Park, and Carrollwood areas. The neighborhoods where these developments are located tend to be fairly diverse, except for the primarily Black/African-American and Hispanic/Latino University Area R/ECAP, which has the densest concentration of family developments in the County. Other family developments are located in a diverse area of Plant City, and largely Hispanic/Latino Ruskin and Wimauma. Overall, while publicly supported housing developments serving families in Hillsborough County are not restricted to areas with high minority concentrations, they are not often located in predominantly White areas.

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Figure 82: Distribution of Publicly Supported Housing Developments in Hillsborough County by Population Served Green = targeted to people with disabilities

Yellow-green = targeted to families and people with disabilities

Red = targeted to elderly

Orange = targeted to families and elderly

Blue = targeted to families

Source: Shimberg Center Assisted Housing Inventory, 2016)

iii. How does the demographic composition of occupants of publicly supported housing in R/ECAPS compare to the demographic composition of occupants of publicly supported housing outside of R/ECAPs in the jurisdiction and region?

City of Tampa Table 57 shows the percentage of occupants in four publicly supported housing program categories (public housing, project-based Section 8, Other Multifamily, and HCV) in units located either within R/ECAPs or outside of R/ECAPs. The table also breaks out this information by race/ethnicity, elderly and disability status.

In the City, Black/African-American households are more prevalent in developments within R/ECAPs than in developments outside R/ECAPs, whereas White households are more prevalent in developments outside R/ECAPs than within R/ECAPs. For example, in Other HUD multifamily developments, White households account for 22.22% and 21.51% of households in developments within and outside R/ECAPs, respectively, whereas Black/African-American households account for 31.94% and 6.62% of households, respectively.

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Hispanic households are more prevalent in all publicly supported housing types outside R/ECAPs than within R/ECAPs in the City. They account for 36.59% and 21.52% of public housing and HCV households, respectively, outside R/ECAPs, compared to 12.34% and 11.77%, respectively, within R/ECAPs. Hispanics account for 70.45% of Tampa’s other HUD multifamily households outside R/ECAPs, while representing 41.67% of households within R/ECAP tracts. Asians/Pacific Islanders comprise a very small percentage of publicly supported housing residents both within and outside R/ECAPs.

Families with children living in project-based Section 8 housing are heavily overrepresented in R/ECAP tracts compared to non-R/ECAP tracts (34.69% of families with children in a R/ECAP tract compared to 15.94% in non-R/ECAP tracts). A similar pattern is reflected in data on the HCV program, where 56.92% of families with children reside in R/ECAP tracts compared to 51.38% of families with children living outside of R/ECAP tracts.

Elderly households are typically concentrated outside of R/ECAP tracts in public housing and HCV units (17.24% vs. 28.44% and 15.27 vs. 23.62%, respectively) and are moderately less prevalent in other HUD multifamily developments outside R/ECAPs (94%) than in those within R/ECAPs (100%).

Households with a member living with a disability residing in public housing have a larger share living in a R/ECAP tract than outside a R/ECAP (15.00% in R/ECAP tracts versus 12.57% in a non- R/ECAP tract. Households with disabled members are more prevalent in Other HUD multifamily developments outside R/ECAPs (10.29%) than within R/ECAPs (0%).

Table 57: City of Tampa - R/ECAP and Non-R/ECAP Demographics by Publicly Supported Housing Program Category % % Total # % Tampa, % % % Asian or Families % units with a FL White Black Hispanic Pacific with Elderly (occupied) disability Islander children Public Housing

R/ECAP tracts 381 0.52% 87.14% 12.34% 0.00% 34.31% 17.24% 15.00% Non R/ECAP tracts 365 4.71% 58.33% 36.59% 0.36% 37.72% 28.44% 12.57% Project-based Section 8 R/ECAP tracts 1,170 12.76% 43.49% 43.07% 0.67% 34.69% 49.17% 10.18% Non R/ECAP tracts 1,352 16.19% 26.27% 57.01% 0.45% 15.94% 71.13% 12.94% 230

% % Total # % Tampa, % % % Asian or Families % units with a FL White Black Hispanic Pacific with Elderly (occupied) disability Islander children Other Multifamily R/ECAP tracts 76 22.22% 31.94% 41.67% 4.17% 0.00% 100.00% 0.00% Non R/ECAP tracts 431 21.51% 6.62% 70.45% 1.42% 0.45% 90.83% 10.29% HCV Program R/ECAP tracts 1,298 4.31% 83.69% 11.77% 0.23% 56.92% 15.27% 21.77% Non R/ECAP tracts 2,730 9.74% 68.23% 21.52% 0.48% 51.38% 23.62% 22.95% Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014

Hillsborough County In Hillsborough County, no public housing or other multifamily developments are located in R/ECAPs as shown in Table 58.

Black/African-American households are more prevalent in project-based Section 8 and HCV units within R/ECAPs (22.14% and 60.56%, respectively) than in such units outside R/ECAPs (16.67% and 57.49%, respectively), while Hispanic households are more prevalent in project-based Section 8 and HCV units outside R/ECAPs (55.78% and 31.24%, respectively) than in R/ECAPs (12.21% and 19.52%%, respectively).

White households are more prevalent in project-based Section 8 developments inside R/ECAPs (64.12%) than outside R/ECAPs (27.55%) but are less prevalent in HCV units outside R/ECAPs (10.99%) than in them (19.65%).

As in the City, Asians/Pacific Islanders comprise a very small share of households in publicly supported housing both within and outside R/ECAPs.

Elderly households are more prevalent in project-based Section 8 developments outside R/ECAPs (39.06%) than inside R/ECAPs (14.50%) and are about equally prevalent in HCV units within and outside R/ECAPs (19.74% and 16.46%, respectively).

Households with disabled members are more prevalent in project-based Section 8 within R/ECAPs than outside (93.13% within R/ECAPs versus 9.76% outside R/ECAPS). For HCV units, households with disabled members are more concentrated inside R/ECAPs (36.08%) than outside of R/ECAPs (22.42%).

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Families with children, meanwhile, are much more prevalent in project-based Section 8 and HCV units outside R/ECAPs (22% and 59%, respectively) than in such units within R/ECAPs (4% and 29%, respectively).

Table 58: Hillsborough County - R/ECAP and Non-R/ECAP Demographics by Publicly Supported Housing Program Category % % Total # % Hillsborough % % % Asian or Families % units with a County, FL White Black Hispanic Pacific with Elderly (occupied) disability Islander children Public Housing R/ECAP tracts N/a N/a 0.00% N/a N/a N/a N/a N/a Non R/ECAP tracts 198 12.76% 76.53% 10.71% 0.00% 66.67% 20.71% 16.67% Project-based Section 8 R/ECAP tracts 126 64.12% 22.14% 12.21% 0.76% 0.00% 14.50% 93.13% Non R/ECAP tracts 286 27.55% 16.67% 55.78% 0.00% 47.47% 39.06% 9.76% Other Multifamily R/ECAP tracts 0 N/a N/a N/a N/a N/a N/a N/a Non R/ECAP tracts 216 58.29% 5.69% 34.60% 0.95% 1.33% 76.00% 24.89% HCV Program R/ECAP tracts 752 19.65% 60.56% 19.52% 0.00% 24.58% 19.74% 36.08% Non R/ECAP tracts 3,306 10.99% 57.49% 31.24% 0.15% 55.02% 16.46% 22.42% Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014

iv. (A) Do any developments of public housing, properties converted under the RAD, and LIHTC developments have a significantly different demographic composition, in terms of protected class, than other developments of the same category for the jurisdiction? Describe how these developments differ.

City of Tampa The analysis of disparities in the demographic composition of publicly supported housing is limited by the availability of data. However, based on the data shown in Table 59, in a typical public housing development in the City, more than half of the households are Black/African-American, most of the remaining households are Hispanic, and fewer than 10% of households are White. Most of the City’s public housing developments have no Asian/ Pacific Islander households, and no development has more than 3% Asian or Pacific Islander households.

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The developments below are notable in that their households are more than 10% White and/or less than 50% Black/African-American: • The Ella at Encore – 13% White, 32% Black, 52% Hispanic • The Reed at Encore – 14% White, 43% Black, 43% Hispanic • Oaks at Riverview – 7% White, 48% Black, 45% Hispanic

The City’s project-based Section 8 developments have greater diversity than its public housing (median 10% White, 20% Black/African-American, 53% Hispanic/Latino, and 2% Asian) and more than half of the City’s project-based Section 8 developments have no households with children, while the remaining developments have a sizable share of households with children (35% to 82%). Five developments have percentages of White households which are above average and none of these developments has households with children. • Freedom Village II – 40 units, 66% White, 17% Black/African-American, 17% Hispanic/Latino • Presbyterian Villas of Tampa – 56 units, 61% White, 4% Black/African-American, 84% Hispanic/Latino, 1% Asian/Pacific Islander • Acorn Trace Apartments – 100 units, 60% White, 14% Black/African-American, 21% Hispanic/Latino, 5% Asian/Pacific Islander • Manhattan Place – 74 units, 42% White, 3% Black/African-American, 51% Hispanic/Latino, 3% Asian/Pacific Islander

In other HUD multifamily developments in the City, as in project-based Section 8 developments, the racial and ethnic composition varies widely. However, the prevalence of Black/African-American households is distinctly lower in these developments than in public housing and project-based Section 8, while the prevalence of White and Hispanic households is higher (median 23% White, 12% Black/African-American, 59% Hispanic, 5% Asian/Pacific Islander). Households with children are entirely or nearly absent from each development of this type, with the exception of Matthew’s Corner, with 11% households with children.

Table 59: City of Tampa - Demographics of Publicly Supported Housing Development, by Program Category Tampa, FL Public Housing

Households # Development Name PHA Name White Black Hispanic Asian with Units Children

Tampa Housing Scruggs, Jl Young Annex Authority 136 N/a N/a N/a N/a N/a Tampa Housing The Trio at Encore Authority 32 0% 69% 31% N/a 44% Tampa Housing Shimberg, C Blythe Authority 135 N/a N/a N/a N/a N/a Tampa Housing Gardens at South Bay Authority 25 5% 37% 58% N/a 48% 233

North Boulevard/Mary Tampa Housing Bethune Homes Authority 295 N/a N/a N/a N/a N/a Tampa Housing North Blvd Homes Authority 524 N/a N/a N/a N/a N/a Tampa Housing Seminole, Squire Villa Authority 130 1% 90% 9% N/a 68% Tampa Housing Robles Park Village Authority 433 N/a N/a N/a N/a N/a Tampa Housing Belmont Phase II Authority 102 1% 87% 12% N/a 73% Tampa Housing Belmont Phase I Authority 193 1% 86% 14% N/a 40% Belmont Heights Estates, Tampa Housing Phase III Authority 96 1% 89% 10% N/a 54% Tampa Housing The Ella at Encore Authority 32 13% 32% 52% 3% N/a Tampa Housing The Reed at Encore Authority 14 14% 43% 43% N/a N/a Tampa Housing Oaks at Riverview Authority 205 7% 48% 45% 1% 49% Project-Based Section 8 Households # Development Name PHA Name White Black Hispanic Asian with Units Children Tampa Heights Apartments Phase II N/a 36 6% 48% 45% N/a 35% Oakhurst Square Apts II N/a 39 0% 94% 6% N/a 78% Acorn Trace Apartments N/a 100 60% 14% 21% 5% N/a Silver Oaks Apartments N/a 199 1% 91% 7% N/a 80% Oakhurst Square Apts N/a 45 0% 98% 2% N/a 71% Jackson Heights N/a 111 6% 84% 10% N/a 63% Manhattan Place N/a 74 42% 3% 51% 3% N/a Mary Walker Apartments N/a 85 24% 20% 55% N/a N/a Columbus Court Apts N/a 160 1% 87% 12% N/a 82% Freedom Village II N/a 40 66% 17% 17% N/a N/a Casa De Palma N/a 24 4% N/a 96% N/a N/a Village at University Square Apartm N/a 122 3% 26% 69% 2% 62% Hacienda Villas N/a 98 16% 14% 69% 1% N/a Haciendas De Ybor N/a 97 7% 6% 86% N/a N/a Aqua Apartments N/a 185 11% 4% 84% 1% N/a Presbyterian Villas of Tampa N/a 56 61% 4% 32% 4% N/a Tampa Park Apartments II N/a 34 10% 90% 0% N/a 41% Tampa Napfe Towers N/a 84 21% 17% 61% N/a N/a 234

Central Court Apartments N/a 68 9% 87% 4% N/a 79% Vista 400 Aka Methodist Place N/a 1 N/a N/a N/a N/a N/a Palm Avenue Baptist Towers N/a 168 18% 4% 78% N/a N/a Mar Plaza Apartments N/a 82 19% 20% 61% N/a N/a Vista 400 Aka Methodist Place N/a 167 20% 24% 55% 1% N/a Tampa Park Apartments I N/a 172 4% 81% 15% N/a 58% King'S Arms N/a 84 1% 2% 97% N/a N/a Jewish Center Towers N/a 186 19% 1% 80% N/a N/a King'S Manor Apartments N/a 99 2% N/a 98% N/a N/a Other Multifamily Assisted Housing

Households # Development Name PHA Name White Black Hispanic Asian with Units Children

Hunter Oaks N/a 24 37% 29% 29% N/a N/a San Lorenzo Terrace N/a 80 4% N/a 96% N/a N/a Epiphany Arms N/a 76 22% 32% 41% 5% N/a Myrtle Oaks N/a 99 37% 12% 51% N/a N/a Patrician Arms II N/a 68 22% 4% 69% 4% N/a Patrician Arms N/a 82 24% 3% 66% 6% N/a Hillsborough Voa Lc II N/a 8 N/a N/a N/a N/a N/a San Lorenzo II N/a 68 7% 1% 91% N/a N/a Matthew's Corner N/a 18 37% 32% 32% N/a 11% Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016

Hillsborough County Table 60 shows that Hillsborough County has only one public housing development for which demographic data is available, which is owned by the Plant City Housing Authority and is nearly three- quarters Black/African-American.

Hillsborough County's project-based Section 8 developments are notably more diverse overall than those in the City (median 46% White, 21% Black/African-American, 38% Hispanic, 1% Asian/Pacific Islander). Similar to the City, though, the racial and ethnic composition of the County’s project-based Section 8 developments vary widely. The demographic composition of Country Oaks Apartments is significantly different than the other project-based Section 8 developments in that 80% of the households are Hispanic.

In regard to Other HUD multifamily developments in Hillsborough County, these properties are similar to the City in that the percentage of Black/African-American residents is generally low (median 6%), but

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White households are more prevalent (median 64%) and Hispanic households are less prevalent (median 29%). Brewer’s Bridgeway is the only other HUD multifamily development in Hillsborough County that has families with children, but they account for only 17% of families in the development. Brewer’s Bridgeway is in a fairly diverse neighborhood in southwestern Plant City.

Table 60: Hillsborough County - Demographics of Publicly Supported Housing Development, by Program Category Hillsborough County, FL Public Housing Households # Development Name PHA Name White Black Hispanic Asian with Units Children Plant City Housing 200 13% 76% 11% N/a 67% Maryland/Madison Authority Project-Based Section 8 Country Oaks 146 3% 17% 80% N/a 64% Apartments N/a Northside Properties I N/a 78 65% 26% 8% 1% N/a Plant City Towers N/a 74 85% 4% 11% N/a N/a New Horizons 24 62% 8% 31% N/a N/a Apartments N/a Summit Ridge 40 30% 25% 45% N/a 61% Apartments N/a Newmauma Homes 42 6% 35% 59% N/a 68% Phase I N/a Other Multifamily Assisted Housing Hillsborough Voa Living 10 N/a N/a N/a N/a N/a Center N/a San Clemente Villas N/a 68 51% 4% 44% N/a N/a Plant City Living Center N/a 42 80% 8% 13% N/a N/a Hillsborough Voa Lc III N/a 7 N/a N/a N/a N/a N/a Brewer'S Bridgeway N/a 18 72% 6% 17% N/a 17% Apostle's Village N/a 55 55% 4% 40% 2% N/a Grace Manor N/a 19 21% 21% 58% N/a N/a Jontilly Place N/a 18 72% 6% 17% 6% N/a Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016

(B) Provide additional relevant information, if any, about occupancy, by protected class, in other types of publicly supported housing for the jurisdiction and region.

No additional information is available about occupancy of other types of publicly supported housing.

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v. Compare the demographics of occupants of developments in the jurisdiction, for each category of publicly supported housing (public housing, project-based Section 8, Other Multifamily Assisted developments, properties converted under RAD, and LIHTC) to the demographic composition of the areas in which they are located. For the jurisdiction, describe whether developments that are primarily occupied by one race/ethnicity are located in areas occupied largely by the same race/ethnicity. Describe any differences for housing that primarily serves families with children, elderly persons, or persons with disabilities.

City of Tampa Using a HUD Query tool, the data available in Table 59, and Figure 79, a comparison of the demographic occupancy data of developments in the jurisdiction to the areas in which they are located was made.

Public Housing Public housing developments in the City are primarily occupied by Black/African-American households – the median percentage of Black/African-American households in these developments is 69%. It is worth noting that the census tracts where these developments are located have a similar median percentage of Black/African-American households (66%). This data demonstrates that public housing residents are majority Black/African-American, and these residents are living in majority Black/African- American neighborhoods, suggesting these residents are segregated in majority-minority neighborhoods.

There are no public housing developments where the resident White population is greater than the neighboring census tract, primarily because there is a small overall share of White residents in public housing developments in the City.

For Hispanics, many public housing developments are home to a greater share of Hispanic residents than the neighboring census tract. There are some exceptions, most notably: Seminole, Squire Villa (9% Hispanic resident share compared to 51% Hispanic share in the census tract), Belmont Phase I (14% Hispanic resident share compared to 22% in census tract), and Belmont Phase II (12% resident share compared to 28% in census tract).

The two public housing developments where Black/African-American households are most overrepresented compared to the surrounding census tracts are: Seminole, Squire Villa: 90% Black/African-American vs. 11% in census tract and Scruggs, JL Young Annex: 60% Black/African- American vs. 8% in census tract.

The share of Black/African-American households in each public housing development is overrepresented relative to the surrounding census tract in all but three developments. Gardens at South Bay (37% Black/African-American population compared to 62% in census tract) is in an integrated South Tampa neighborhood just north of the MacDill Air Force Base. The Ella at Encore (32% Black/African-American resident population compared to 66% Black/African-American population in

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the census tract), and The Reed at Encore (43% Black/African- American resident population compared to 66% Black/African-American population in the census tract), are both located in the same area in downtown Tampa. The Encore redevelopment is a multi-site redevelopment of old public housing into a mixed use, mixed-income development. Hispanic households are more likely to be underrepresented than overrepresented in public housing developments relative to the census tracts where the developments are located.

It is important to note that there is missing demographic data for five public housing developments: North Blvd Homes, North Boulevard/Mary Bethune, Robles Park, Scruggs JL Young Annex, and Shimberg C Blythe. This is likely due to these projects being slated for redevelopment, or conversion to the RAD program according to the Tampa Housing Authority’s strategic plan.

There are seven public housing developments in the City of Tampa with families with children, ranging from 40% of all households in the development to 73%. Of these seven, the following represent the top three developments with the largest shares of households with children: 1) Belmont Phase II – 73% households with children, 87% Black/African- American 2) Seminole, Squire Villa – 68% households with children, 90% Black/African-American 3) Belmont Heights Estates, Phase III – 54% households with children, 89% Black/African- American This data indicates that those public housing developments with the largest shares of households with families are also those with large shares of Black/African-American households. This pattern does not repeat for other racial/ethnic categories.

Project-Based Section 8 In the City’s project-based Section 8 developments, the median percentages of White, Black/African- American, Hispanic, and Asian/Pacific Islander households are 10%, 20%, 53%, and 2%, respectively. By comparison, in the census tracts where these developments are located, the median percentages of White, Black/African-American, Hispanic, and Asian/Pacific Islander residents are 27%, 43%, 20%, and 1%, respectively, with a median poverty rate of 27%. Thus, overall, Hispanic households are overrepresented in Tampa’s project-based Section 8 developments, while White and Black/African-American households are underrepresented. However, the racial and ethnic compositions of individual developments vary widely compared to the census tracts in which they are located, as well as compared to each other.

There are ten project-based section 8 developments in the City of Tampa with families with children, ranging from 35% of all households in the development to 82%. Of these ten, the following represent the top three developments with the largest shares of households with children: 1) Columbus Court Apartments – 82% households with children, 87% Black/African American 2) Silver Oaks Apartments – 80% households with children, 91% Black/African American 3) Central Court Apartments – 79% households with children, 87% Black/African American

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This data indicates that those project-based section 8 developments with the largest shares of households with families are also those with large shares of Blacks/African-American households. This pattern does not repeat for other racial/ethnic categories.

Other HUD Multifamily Developments In other HUD multifamily developments in the City, the median percentages of White, Black/African- American, Hispanic, and Asian/Pacific Islander households are 23%, 12%, 59%, and 5%, respectively. By comparison, in the census tracts where these developments are located, the median percentages of White, Black/African-American, Hispanic, and Asian/Pacific Islander residents are 24%, 12%, 24%, and 3%, respectively, with a 27% poverty rate. As in the City’s project-based Section 8 developments, Hispanic households are overrepresented while White and Black/African-American households are underrepresented. However, Other HUD multifamily developments vary widely in how they compare to their census tracts.

There is only one Other HUD Multifamily development in the City with families with children (Matthew’s Corner, 11% households with children with essentially equal representation between Whites, Blacks/African-Americans, and Hispanics).

Hillsborough County

Using a HUD Query tool, the data available in Table 60, and Figure 80, a comparison of the demographic occupancy data of developments in the jurisdiction to the areas in which they are located was made.

Public Housing The households in Maryland/Madison, the one public housing development in the County for which demographic data is available, are 13% White, 76% Black/African-American, 11% Hispanic, and 0% Asian or Pacific Islander. Black/African-American households are overrepresented in Maryland/Madison compared to the percentage of Black/African-American residents in the census tract where it is located (56%), though not to the same degree as in Tampa’s public housing developments. Hispanics are underrepresented (11% vs. 26%), while the percentage of White households in Maryland/Madison (13%) is just below the percentage of White residents in the census tract (16%).

The Maryland/Madison public housing development is composed of 67% households with children, with 76% of households Black/African-American. This mirrors previous data discussed for the City, which showed that public housing developments with large shares of families are typically composed of a majority of Black/African-American households.

Project-Based Section 8 Hillsborough County’s project-based Section 8 developments are more demographically similar to the census tracts where they are located than in the City’s project-based Section 8 developments. The median percentages of White, Black/African-American, Hispanic, and Asian/Pacific Islander households in the County’s project-based Section 8 developments are 46%, 21%, 38%, and 1%, respectively. By comparison, 239

in the census tracts where these developments are located, the median percentages of White, Black/African-American, Hispanic, and Asian/Pacific Islander residents are 25%, 15%, 31%, and 1%, respectively.

There are three project-based section 8 developments in Hillsborough County with families with children, ranging from 61% of all households in the development to 68%.

1) Newmauma Homes Phase I – 68% households with children, 59% Hispanic, 35% Black/African American 2) Country Oaks Apartments – 64% households with children, 80% Hispanic, 17% Black/African American 3) Summit Ridge Apartments – 61% households with children, 45% Hispanic, 30% White, 25% Black/African American

This data indicates that those project-based section 8 developments with households with families are relatively diverse in their racial/ethnic composition, with Hispanics holding the largest share of households in these developments.

Other HUD Multifamily Developments In Other HUD multifamily developments in Hillsborough County, as in the County’s project-based Section 8 developments, the demographic mix of tenant households is similar to the demographics of the census tracts where the developments are located. The median percentages of White, Black/African-American, Hispanic, and Asian/Pacific Islander households in the County’s other HUD multifamily developments are 64%, 6%, 29%, and 4%. By comparison, in the census tracts where these developments are located, the median percentages of White, Black/African-American, Hispanic, and Asian/Pacific Islander residents are 50%, 11%, 34%, and 2%, respectively.

There is only one development in Hillsborough County with families with children (Brewer’s Bridgeway) with 17% households with children. This single development is composed of 72% White households, 17% Hispanic, and 6% Black/African American. c. Disparities in Access to Opportunity

i. Describe any disparities in access to opportunity for residents of publicly supported housing in the jurisdiction and region, including within different program categories (public housing, project-based Section 8, Other Multifamily Assisted Developments, HCV, and LIHTC) and between types (housing primarily serving families with children, elderly persons, and persons with disabilities) of publicly supported housing.

City of Tampa This analysis refers to the maps in the Disparities in Access to Opportunity section of this AI.

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School Proficiency To a large extent, school proficiency is higher in areas with a lower density of publicly supported housing. The largely White Seminole Heights area is an exception in the sense that school proficiency and the density of publicly supported housing developments are low, although voucher utilization is low as well in this area. Another exception is the North Tampa area south of Fowler Avenue, where school proficiency is moderate to high, voucher utilization is fairly high, and several subsidized developments are present.

Public housing, project-based Section 8 developments, and other LIHTC developments are generally located in areas of low to moderate school proficiency. Even the developments of these types in South Tampa are mostly located in parts of the peninsula with lower school proficiency. Since Other HUD multifamily developments are more broadly distributed in general, these developments are slightly more likely to be in areas of moderate to high school proficiency. However, as the previous discussion showed, virtually none of the households in these developments have children. Additionally, comparing the geographic variation in school proficiency, it appears that developments serving families are largely located in areas with low to moderate school proficiency. On the whole, there is a mismatch between the location of subsidized developments with large percentages of families with children and areas with higher school proficiency.

Job Proximity There is no clear relationship between job proximity and the locations of different types of publicly supported housing. For instance, multiple types of publicly supported housing developments, in terms of subsidy type and population served, are clustered in the East Tampa R/ECAP, where proximity to jobs varies widely. By contrast, in Seminole Heights where publicly supported housing developments and HCV households are largely absent, many areas have only low to moderate proximity to jobs.

Labor Market In general, publicly supported housing is located in areas with a low to moderate labor market index. One notable exception is the presence of subsidized developments in areas of South Tampa with moderate to high labor market index values. In the University of South Florida/Busch Gardens area, where the labor market index is low (possibly due to the presence of students), subsidized developments are notably absent but voucher utilization is fairly high. LIHTC developments and developments serving families with children are slightly more likely than other development types to be in areas with low labor market index values, despite being more likely to be inhabited by working-age heads of household.

Transit Trips and Transportation Costs The level of transit use by low-income households is moderate throughout most of the City. The western part of the East Tampa R/ECAP has a moderately high level of transit use and a concentration of several subsidized development types, but otherwise there is no clear trend between the location of publicly supported housing and geographic variations in transit usage among low-income households. Many, though not all, publicly supported housing developments are located in areas with low to moderate transportation costs, such as downtown and in R/ECAPs. For housing choice vouchers, there is even less

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of a clear relationship between the prevalence of subsidized units and transportation costs. Since Other HUD multifamily developments are the most widely distributed, they are exposed to a slightly wider range of transportation costs. This may be problematic, since these developments largely serve elderly-headed households and people with disabilities, who are often on fixed incomes and dependent on public transit, paratransit, and private taxis.

Access to Low-Poverty Neighborhoods Publicly supported housing is mainly located in higher-poverty areas of the City and is largely absent from areas of low to moderate poverty. LIHTC developments and family developments are most heavily concentrated in higher-poverty areas.

Access to Environmentally Healthy Neighborhoods Exposure to environmental health hazards including respiratory and neurological toxins is moderate to high throughout most of the City. Publicly supported housing tends to be located in areas with moderate to high hazard levels, such as East Tampa. However, developments are absent and HCV units are sparse in some areas with high hazard levels, such as part of Seminole Heights, while the Sulphur Springs R/ECAP and the portion of the University Area R/ECAP in Tampa have several developments and relatively low hazard levels.

Hillsborough County

School Proficiency Based on a comparison of the maps showing data on school proficiency index and the location of publicly supported housing, the geographic relationship between the location of publicly supported housing and school proficiency is more varied in Hillsborough County than in the City. Publicly supported housing is heavily clustered in the University Area R/ECAP where school proficiency is low (Figure 20) and publicly supported housing in the suburbs extending from Egypt Lake-Leto to Carrollwood is generally in areas with lower school proficiency than the rest of northwestern Hillsborough County. Publicly supported housing is also abundant in the suburbs east of East Tampa and parts of the west Brandon/Progress Village area where school proficiency is low to moderate. However, some publicly supported housing is also located in areas of Brandon and Plant City with moderate to high school proficiency.

Maryland/Madison, the public housing development in Plant City, most of the County’s project-based Section 8 developments, and census tracts with the highest HCV concentrations are in areas with low school proficiency. LIHTC developments are more likely to be located in areas of moderate to high school proficiency, but generally are not located in the parts of the County with the most proficient schools. Other multifamily developments (Section 202 and Section 811) are the development type most likely to be in areas of moderate to high school proficiency. Subsidized developments serving different population types (families with children, elderly-headed households, people with disabilities) do not vary widely in terms of their likelihood to be located in areas with higher school proficiency.

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Job Proximity There is not a clear relationship between job proximity and the locations of different types of publicly supported housing. Subsidized developments and areas of high voucher utilization are spread throughout areas of low, moderate, and high job proximity. Even the rural areas, from which publicly supported housing is largely absent, have pockets of both low and high job proximity.

Labor Market The relationship between the location of publicly supported housing and labor market index is unclear as well. Census tracts with a moderate to high percentage of voucher-subsidized units also tend to have lower labor market index values. Additionally, the labor market index in the University Area R/ECAP, where several subsidized developments are located, is relatively low compared to high value areas in the County, and the subsidized developments in the suburbs northwest of Tampa are located in areas with lower labor market index values than other parts of Northwestern Hillsborough County. However, subsidized developments in the suburbs east of East Tampa are found in areas with both low and high labor market values, and labor market values are moderate to high in the Brandon/Progress Village area where many developments are located. Labor market index values also vary in Plant City and southern Hillsborough County, where several other publicly supported housing developments are located. As a result of this variation, there is no clear relationship between the location of different types of publicly supported housing and labor market index values.

Transit Trips and Transportation Costs Publicly supported housing tends to be located in areas with higher transit usage and lower transportation costs, which coincide with the more urban areas of the County. The relationship is not absolute, though, and is less clear-cut for voucher-subsidized units than for other types of publicly supported housing. For example, voucher utilization rates are high in Progress Village, where transit usage is relatively low and transportation costs are relatively high, while the opposite is true for the Census tracts across Highway 301 in western Brandon. Subsidized developments serving different populations (families with children, elderly-headed households, people with disabilities) do not differ systematically in terms of transit usage and transportation costs where they are located.

Access to Low-Poverty Neighborhoods To some extent, Hillsborough County’s publicly supported housing is located in areas with moderate to high poverty rates. This is most apparent in the University R/ECAP, and poverty rates also tend to be higher in the suburban parts of northwestern Hillsborough County with several developments than in the exurban parts with no developments. The suburbs east of East Tampa, Plant City, and southern Hillsborough County also tend to have moderate to high poverty rates in areas where publicly supported housing is located. However, the western Brandon/Progress Village area where several subsidized developments are located has moderate to low poverty rates. Publicly supported housing developments serving different populations do not differ substantially in terms of poverty rates where they are located.

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Access to Environmentally Healthy Neighborhoods This analysis is based on the environmental health index provided by HUD. The County’s publicly supported housing is generally located in areas of moderate to high exposure to environmental hazards, which coincide with the more urban and built-up areas. The publicly supported housing in northwestern Hillsborough County, including the University Area R/ECAP, is generally the most exposed to environmental hazards, while such housing in the Plant City area is the least exposed. It should be noted that while the Plant City area does perform well on the environmental health index provided by HUD, local knowledge provided by stakeholder input suggests this area may suffer from fertilizer plant-related health hazards. Publicly supported housing developments serving different populations do not differ substantially in terms of exposure to environmental hazards.

2. Additional Information a. Beyond the HUD-provided data, provide additional relevant information, if any, about publicly supported housing in the jurisdiction and region, particularly information about groups with other protected characteristics and about housing not captured in the HUD-provided data.

No additional information is available. b. The program participant may also describe other information relevant to its assessment of publicly supported housing. Information may include relevant programs, actions, or activities, such as tenant self-sufficiency, place-based investments, or geographic mobility programs.

See the discussion under the Segregation/Integration analysis (Section B) regarding place-based investments and resident services in areas of Tampa and Hillsborough County where publicly supported housing is prevalent, as well as the Tampa Housing Authority’s services and opportunities for its program participants.

3. Contributing Factors of Publicly Supported Housing Location and Occupancy

Identify factors that significantly create, contribute to, perpetuate, or increase the severity of fair housing issues related to publicly supported housing, including Segregation, R/ECAPs, Disparities in Access to Opportunity, and Disproportionate Housing Needs.

• Admissions and occupancy policies and procedures, including preferences in publicly supported housing • Community opposition • Displacement of residents due to economic pressures • Impediments to mobility • Lack of access to opportunity due to high housing costs • Lack of private investment in specific neighborhoods

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• Lack of public resources for investment in specific neighborhoods, including services and amenities • Land use and zoning laws • Loss of affordable housing • Siting selection policies, practices and decisions for publicly supported housing, including discretionary aspects of Qualified Allocation Plans and other programs • Source of income discrimination • Educational Attainment

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D. Disability and Access Analysis

1. Population Profile a. How are persons with disabilities geographically dispersed or concentrated in the jurisdiction and region, including R/ECAPs and other segregated areas identified in previous sections?

City of Tampa Table 61 shows that of the total population in the City, 2.96% has a hearing difficulty, 2.95% has a vision difficulty, 5.10% has a cognitive difficulty, 6.96% has ambulatory difficulties, 2.75% has self-care difficulties, and 4.47% has independent living difficulties. Overall, the City’s population of persons with disabilities is much less than that of the region, however the percentage of persons with vision difficulties in the City is greater than that of the region as a whole. Figures 83 and 84 shows the distribution of persons with disabilities by disability type. Persons with disabilities are geographically dispersed in various areas of the City. While there are no particular areas of significant concentration, HUD data does present slight clusters of persons with disabilities near or in R/ECAP areas including University Area, Sulphur Springs, and East Tampa.

Table 61: City of Tampa – Disability by Type Tampa-St. Tampa, FL Petersburg- Clearwater, FL Disability Type # % # % Hearing difficulty 9,409 2.96% 108,486 4.12% Vision difficulty 9,377 2.95% 66,629 2.53% Cognitive difficulty 16,202 5.10% 138,004 5.25% Ambulatory difficulty 22,104 6.96% 214,326 8.15% Self-care difficulty 8,742 2.75% 78,434 2.98% Independent living difficulty 14,192 4.47% 138,974 5.28% Source: American Community Survey (ACS), 2009-2013 (For variables on disability, percentages are calculated based on the total population age 5 years and older).

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Figure 83: City of Tampa – Disability and Type

Source: HUD AFFH Data and Mapping Tool Name: Map 14 - Disability by Type Variation: Hearing, Vision and Cognitive Disability Description: Dot density map of the population of persons with disabilities by persons with vision, hearing, cognitive, ambulatory, self-care, and independent living difficulties with R/ECAPs for City of Tampa and Region 247

Figure 84: City of Tampa – Disability by Type

Source: HUD AFFH Data and Mapping Tool Name: Map 14 - Disability by Type Variation: Ambulatory, Self-Care and Independent Living Disability Description: Dot density map of the population of persons with disabilities by persons with vision, hearing, cognitive, ambulatory, self-care, and independent living difficulties with R/ECAPs for City of Tampa and Region

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Hillsborough County Table 62 shows of the total population in Hillsborough County, 3.14% has a hearing difficulty, 2.23% has a vision difficulty, 4.67% has a cognitive difficulty, 6.69% has ambulatory difficulties, 2.72% has self-care difficulties, and 4.42% has independent living difficulties. Overall, the County’s population of persons with disabilities is much less than that of the region and the percentages of persons experiencing a disability in the County is less than persons experiencing a disability in the region as a whole. As with the City, there are no areas in the County that are significantly concentrated by persons with disabilities as shown in Figures 85 and 86. There is an indication of a slight cluster of persons with disabilities in the northern portion of the University Area R/ECAP, which is right outside City limits and located in County boundaries.

Table 62: Disability by Type Tampa-St. Hillsborough Petersburg- County, FL Clearwater, FL Disability Type # % # % Hearing difficulty 26,551 3.14% 108,486 4.12% Vision difficulty 18,863 2.23% 66,629 2.53% Cognitive difficulty 39,497 4.67% 138,004 5.25% Ambulatory difficulty 56,633 6.69% 214,326 8.15% Self-care difficulty 22,987 2.72% 78,434 2.98% Independent living difficulty 37,373 4.42% 138,974 5.28% Source: American Community Survey (ACS), 2009-2013 (For variables on disability, percentages are calculated based on the total population age 5 years and older).

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Figure 85: Hillsborough County – Disability and Type

Source: HUD AFFH Data and Mapping Tool Name: Map 14 – Disability by Type Variation: Hearing, Vision and Cognitive Disability Description: Dot density map of the population of persons with vision, hearing, cognitive, ambulatory, self-care and independent living difficulties with R/ECAPS for Hillsborough County and Region

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Figure 86: Hillsborough County – Disability and Type

Source: HUD AFFH Data and Mapping Tool Name: Map 14 – Disability by Type Variation: Ambulatory, Self-Care and Independent Living Disability Description: Dot density map of the population of persons with vision, hearing, cognitive, ambulatory, self-care and independent living difficulties with R/ECAPS for Hillsborough County and Region 251

b. Describe whether these geographic patterns vary for persons with each type of disability or for persons with disabilities in different age ranges for the jurisdiction and region.

City of Tampa Table 63 provides data on the percentage of the population with disabilities by age for the City and the region. For the total population over the age of 5 in the City, 1.15% of persons with disabilities are between the ages of 5-17, 7.56% are in the 18-64 age range, and 4.54% are age 65 or over.

Figures 83 and 84 demonstrate that the overall geographic distribution of persons with disabilities in the City does not show significant areas of concentration by type of disability, but there are slight clusters near or in R/ECAP areas. Looking at geographical location by type of disability, there are clusters of persons with hearing difficulty centered in between the University Area and Sulphur Springs R/ECAPs and clusters of persons with vision difficulties in the same area as well as also in the East Tampa R/ECAP. Persons with ambulatory, independent living, and self-care difficulties also show clusters in the East Tampa R/ECAP, and additionally for self-care there are clusters in the University Area R/ECAP. Persons with cognitive difficulties show a sight cluster in the Old West Tampa R/ECAP area.

Geographic patterns do differ for persons with disabilities of different age ranges, as shown in Figure 87. Persons with disabilities in the 5-17 age range shows a cluster in or near the Sulphur Springs R/ECAP while persons with disabilities ages 18-64 have clusters in the University Area, Sulphur Springs, and the East Tampa R/ECAPs. Persons with disabilities that are over the age of 64 cluster in the southern part of the City.

Table 63: City of Tampa- Age of People with Disabilities Tampa-St. Tampa, FL Petersburg- Clearwater, FL Age of People with Disabilities # % # % Age 5-17 with Disabilities 3,661 1.15% 23,517 0.89% Age 18-64 with Disabilities 24,008 7.56% 187,138 7.11% Age 65+ with Disabilities 14,420 4.54% 170,080 6.47% Source: American Community Survey (ACS), 2009-2013 (For variables on disability, percentages are calculated based on the total population age 5 years and older).

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Figure 87: City of Tampa – Disability by Age Group

Source: HUD AFFH Data and Mapping Tool Name: Map 15 - Disability by Age Group Description: All persons with disabilities by age range (5-17) (18-64)(65+) with R/ECAPs 253

Hillsborough County For the total population over the age of 5 in the County, 0.94% of persons with disabilities are in the 5- 17 age range, 6.53% are between ages 18-64, and 4.72% are age 65 or over as shown in Table 64.

The geographic distribution of persons with disabilities in the County does not show significant areas of concentration, however when looking at geographic trends by type of disability, Figures 85 and 86 shows a pattern in the County of slight clusters, for all disability types, in the northern portion of the University Area R/ECAP, which is in County boundaries.

The geographic patterns are more diverse when looking at clusters of persons with disabilities in the County by age range, as shown in Figure 88. Persons with disabilities in the age range of 5-17 are evenly dispersed throughout the City. For persons with disabilities ages 18-64, clusters are identified in the northwest area of the County and in the northern portion of the University Area R/ECAP located within County boundaries. Persons with disabilities that are over the age of 64 are clustered in the southern portion of the County near Sun City Center.

Table 64: Hillsborough County – Age of People with Disabilities Tampa-St. Hillsborough Petersburg- County, FL Clearwater, FL Age of People with Disabilities # % # % Age 5-17 with Disabilities 7,989 0.94% 23,517 0.89% Age 18-64 with Disabilities 55,292 6.53% 187,138 7.11% Age 65+ with Disabilities 39,916 4.72% 170,080 6.47% Source: American Community Survey (ACS), 2009-2013 (For variables on disability, percentages are calculated based on the total population age 5 years and older).

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Figure 88: Hillsborough County – Disability by Age Group

Source: HUD AFFH Data and Mapping Tool Name: Map 15 – Disability by Age Group Description: All persons with disabilities by age range (5-17)(18-64)(65+) with R/ECAPS 255

2. Housing Accessibility a. Describe whether the jurisdiction and region have sufficient affordable, accessible housing in a range of unit sizes.

Availability of affordable housing is a challenge in the City, County, and the region, and the availability of affordable, accessible housing is an even greater challenge. Facilities accommodating persons with disabilities are primarily operated by larger non-profit organizations or smaller private facilities certified as group homes. Though accessible housing is available, it often requires persons with disabilities to be in group home setting or private facility, which can be costly. In some cases, subsidies from federal or state programs, or insurance coverage, still leave partial responsibility for housing costs to the individual with a disability or their family. Often times these costs are not affordable, especially for very-low or low-income persons or families.

The Agency for Persons with Disabilities (APD) is the lead agency in the State of Florida providing persons with disabilities with housing and supportive service resources. The APD provides information for multiple non-profits organizations that manage accessible housing for the disabled in the Tampa and Hillsborough County region. These organizations include: Florida Mentor Network; Goodwill; Angels Unaware; Quest; Pensacola Care Inc.; The Human Development Center; and McClain Incorporated.

• The Florida Mentor Network offers Host Homes, in which adults with disabilities live in private family homes with dedicated caregivers; Waiver Group Homes; and Intermediate Care Facilities.

• Goodwill has Freedom Village II, located on the Tampa side of the , which offers 40-units of accessible housing. The apartment building is architecturally barrier-free for people with limited incomes who have disabilities or are at least 62 years old. Freedom Village II offers one- and two-bedroom apartments.

• Angels Unaware is another non-profit dedicated to providing quality professional residential care facilities and services for the severe and profound Developmentally Disabled of Tampa. Angels Unaware currently operates eight group homes which serves 50 residents with disabilities.

• The non-profit, Quest, provides residential options for the disabled through Intermediate Care Facilities; group homes; Behavioral Group Homes; Transitional Living; and Supported Living.

• Pensacola Care Inc. is licensed by the Agency for Healthcare Administration (AHCA) as Intermediate Care Facilities for the Developmentally Disabled. Pensacola Care Inc. operates the Hillsborough County Developmental Center (HCDC), which provides residential services to individuals with developmental challenges.

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• The Human Development Center (HDC) provides community based residential Group Home services in a variety of settings, including three group homes in Seffner, three in Tampa, and various supported living homes throughout Hillsborough County. The Group Homes include Bessie Dix, Flora House, Stark House, Cass House, Thatcher House, and Terrace Place House.

• McClain Incorporated also provides comprehensive housing services provided in three small Group Home settings. Each home is located in a residential area of Tampa. Two of the homes are for women and one is for men. The three Group Homes include the Emerald House, Stall House, and the Woodlawn House,

THA also makes efforts to provide accessible, affordable housing. Units are available to persons with disabilities and applicants are considered through the same process as all other residents. Local preference for persons with disabilities is given when selecting persons from the waiting list for affordable housing. Currently, THA public housing units are occupied by 555 families with disabilities and 1,515 vouchers are being utilized by families with disabilities.

Additionally, there are multiple private providers serving the City and the County that have been certified by ADP and designated as small group homes and there are numerous private home care companies available in the region.

There is a lack of accessible units in a range of sizes primarily due to the structure of group homes and Intermediate Care Facilities. Accessible housing and facilities are designed to provide housing and social services to the greatest number of beneficiaries possible. Accessible housing is often built to accommodate the provision of 24/7 care that many persons with disabilities need. Because of this, most group home or Intermediate Care Facilities are only one or two-bedroom units. Private group homes may be 3 or more-bedroom units, but ultimately, they are designed as communal living, therefore they would be considered more like 1 bedroom units. b. Describe the areas where affordable accessible housing units are located in the jurisdiction and region. Do they align with R/ECAPs or other areas that are segregated?

Much of the disabled population in the City and County reside in group homes or private care facilities that are scattered throughout the region. Goodwill’s Freedom Village II, is located on the Tampa side of the Gandy Bridge, an area not located in or near R/ECAPs or identified as a segregated area.

Pensacola Care’s residential treatment facility is located on Bruce B Downs Boulevard in the northern portion of the County near Temple Terrace and is significantly north of R/ECAP areas.

Angels Unaware has several group homes with only one located near the University Area R/ECAP. Other group homes managed by Angels Unaware are located in the County, one just west of the University Area R/ECAP and three in the northwest portion of the County.

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The Human Development Center has the Cass Home located southwest of the Old West Tampa R/ECAP, the Thatcher Home located far west of any R/ECAP areas in the City, and the Flora Home and Bessie Dix Home which are located the County boundaries of Seffner, also further out from R/ECAP or segregated areas.

McClain Incorporated also has scattered site group homes including the Emerald Home located in Emerald Avenue within City limits. However, this home is located outside of R/ECAP areas northwest of the East Tampa and Old West Tampa R/ECAPs.

Additionally, publicly supported housing is available to persons with disabilities and offers affordable, accessible housing. Much of the regions publicly supported housing is located in R/ECAP areas, therefore disabled occupants of publicly supported housing are likely to be residing in segregated areas. c. To what extent are persons with different disabilities able to access and live in the different categories of publicly supported housing in the jurisdiction and region?

The ability to access and live in different categories of publicly supported housing largely depends on availability. Currently there are 1,704 publicly supported housing units occupied by persons with disabilities in the City and 1,298 in the County. The demand for affordable, accessible housing outweighs the supply. Many multi-family housing developments that offer accessible units are at maximum occupancy. Further, THA’s waiting list is extensive and may not be open for another 5-7 years.

An individual’s disability type may also impact the extent in which persons with disability are able to access and live in different categories of public housing. Persons with disabilities that are more self- sufficient have the ability to live more independently in affordable units provided through publicly supported housing. Persons with disabilities requiring 24/7 care are more limited in housing choice and often cannot reside in publicly supported housing as they need greater access to supportive services.

City of Tampa Table 65 provides data on the number and percentage of persons with disabilities residing in four categories of publicly supported housing in both the City and the region. For the City, 32.12% of persons with disabilities live in public housing, 11.65% live in project-based Section 8 units, and 8.83% reside in Other Multifamily units. For the HCV program 22.57% of persons with disabilities utilize vouchers. With the exception of public housing developments, there is a larger percentage of persons with disabilities residing in publicly supported housing in the region.

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Table 65: City of Tampa -Disability by Publicly Supported Housing Program Category People with a Tampa, FL Disability # % Public Housing 422 32.12% Project-Based Section 8 300 11.65% Other Multifamily 46 8.83% HCV Program 936 22.57% Tampa-St. Petersburg- Clearwater, FL Public Housing 780 28.48% Project-Based Section 8 960 17.53% Other Multifamily 332 18.89% HCV Program 4,467 24.29% Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014

Hillsborough County According to the data in Table 66, in Hillsborough County, 16.67% of persons with disabilities live in public housing, 35.28% live in project-based Section 8 units, and 18.54% reside in other multi-family units. For the HCV program 24.91% of persons with disabilities utilize vouchers.

Table 66: Hillsborough County -Disability by Publicly Supported Housing Program Category People with a Hillsborough County, FL Disability # % Public Housing 33 16.67% Project-Based Section 8 151 35.28% Other Multifamily 56 18.54% HCV Program 1,058 24.91% Tampa-St. Petersburg- Clearwater, FL Public Housing 780 28.48% Project-Based Section 8 960 17.53% Other Multifamily 332 18.89% HCV Program 4,467 24.29% Source: Inventory Management System (IMS)/ PIH Information Center (PIC), 2016; Tenant Rental Assistance Certification System (TRACS), 2016; Low Income Housing Tax Credit (LIHTC) database, 2014

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3. Integration of Persons with Disabilities Living in Institutions and Other Segregated Settings

a. To what extent do persons with disabilities in or from the jurisdiction or region reside in segregated or integrated settings?

Integrated settings are those that enable individuals with disabilities to live and interact with individuals without disabilities to the greatest extent possible and receive the healthcare and supportive services from the provider of their choice. Much of the disabled population live in group homes or Intermediate Care Facilities serving Tampa and Hillsborough County. Persons with disabilities living in Intermediate Care Facilities tend to be more segregated due to it being a larger development and the need for 24-hour care. However, group homes are often single-family homes in residential areas of the community, allowing for a more integrated setting.

The overall goal is to provide services to both institutionalized and non-institutionalized persons with disabilities so that they can become more independent and live in more integrated settings. In support of this goal, the Florida Center for Inclusive Communities (FCIC) is committed to developing a range of supports and services in the areas of Community Supports, Early Childhood, Education, Employment, Health, and Interdisciplinary Training. The efforts of the FCIC focus on individuals with developmental disabilities achieving full integration and inclusion in society. The FCIC offers programs and activities for the general population to assert awareness regarding the needs of this population. Programs and activities include Emergency Preparedness, Disability Awareness for Law Enforcement, and The Social Inclusion Project, which provides a framework to support the vision of including students with developmental disabilities.

b. Describe the range of options for persons with disabilities to access affordable housing and supportive services in the jurisdiction and region.

Access to Affordable Housing Housing options for persons with disabilities can be limited due to availability of affordable housing and the individual’s type of disability. The most viable options for this population are group homes and Intermediate Care Facilities. These facilities may or may not be affordable depending on subsidies provided. Depending on the type of disability, many individuals may be able to stay in their home if they are independent enough to access services or have an in-home caregiver. The ability to remain in their home is not always affordable, as maintenance on the home is required and can be costly. Many persons with disabilities do not have the option to stay in their home as they require a deeper level of care and access to 24/7 supportive services. This limits their housing options.

The affordable housing options for persons with disabilities in the City and the County include group homes, Intermediate Care Facilities, and publicly supported housing. Group homes include: The Florida Mentor Network’s Host Homes, Waiver Group Homes, and Intermediate Care Facilities; Goodwill’s Freedom Village II; Angels Unaware eight group homes; Quest’s Intermediate Care Facilities, Group Homes, Behavioral Group Homes, Transitional Living, and Supported Living; Pensacola Care’s

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Intermediate Care Facilities; HDC’s six community based residential Group Homes; and McClain Incorporated’s three small group homes.

THA provides affordable housing options and currently serves 555 disabled families in public housing and 1,515 disabled families through the voucher program. Publicly supported housing would be a viable option for persons with disabilities to access affordable housing but the demand is much higher than the supply. Waiting lists impede availability of publicly supported housing for the disabled, even though THA gives a local preference for persons with disabilities during selection. There are simply not enough units and not enough turn-around of occupants to serve the high demand for accessible units.

Additional options for accessible affordable housing include private providers serving Tampa and Hillsborough County that have been certified by APD and designated as small group homes.

Access to Supportive Services There are numerous organizations, serving Tampa and Hillsborough County collectively, where persons with disabilities can access supportive services. All of the group homes identified in the Housing Accessibility section above provide supportive services intended to increase integration. There are primary organizations, and numerous other organizations, in the region offering supportive services aimed at increasing opportunity for persons with disabilities and encouraging inclusion in community living.

The ARC Tampa Bay offers adult day training programs which provide life skills and social skills development consisting of day time supervision and individual training programs for adults age 22 and older and supported employment programs which focus on helping individuals acquire and sustain paid employment in a community-based setting.

Self Reliance Inc., the Center for Independent Living serving Hillsborough County, offers programs in accordance with the five core services of the independent living philosophy including advocacy, information and referral, independent living skills, peer support, and transition. In addition to its core services, Self Reliance also offers repair and maintenance of power chairs and scooters, youth transition program, and training and education programs for consumers and the community at large.

Abilities Foundation supports the ServiceSource Florida Regional Office which provides career counseling, vocational evaluation, job development, workplace accommodations, and follow-up service to help persons with disabilities obtain and maintain gainful employment. In addition, Abilities Foundation offers vocational rehabilitation counselor services, benefits planning, a Veterans Employment Program, the Warrior Bridge Program, case management home and community services, and youth transition services.

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Suncoast New Options offers adult day training, supported behavioral services, companion services, in-home support services, personal care assistance, residential habilitation, respite care, supported living services, supported employment services, and transportation assistance.

MacDonald Training Center (MTC) offers services in the areas of educational, vocational and residential supports for persons with disabilities. The MTC day services includes vocational skills training and life enrichment activities from computer lab and fine arts instruction to recreational outreaches for people with developmental disabilities. Additionally, MTC provides supported employment counseling and placement services for people with a wide variety of disabilities.

The Tampa Lighthouse for the Blind provides services and training designed to help each person maximize his or her independence, including, enhancing prospects for gainful employment. All services are provided at no charge to the individual.

United Cerebral Palsy (UCP) of Tampa Bay utilizes a comprehensive approach to services and offers pediatric speech, occupational, and physical therapy services for children birth through 21 years of age. Services include screenings, comprehensive evaluations, and individualized treatment sessions. In addition, UTP has early childhood education programs encompassing inclusionary preschool for children 6 weeks through 5 years of age. UPC also provides in-home respite services for children and adults with disabilities and a supported employment program, which provides community-based services for adults with disabilities.

4. Disparities in Access to Opportunity a. To what extent are persons with disabilities able to access the following in the jurisdiction and region? Identify major barriers faced concerning:

i. Government services and facilities Persons with disabilities are able to access government services and facilities through partnerships between providers and government entities. Many of the primary organizations and advocates for this population have formed alliances with local, state, or federal funding agencies so that persons with disabilities have greater access to government services and facilities.

The Arc Tampa Bay has been a key affiliate member of The Arc of Florida, which is state funded. Through this partnership the Arc of Tampa Bay is able to provide a variety of services to persons with disabilities.

Self Reliance works with local and state government entities and planning committees to ensure availability and accessibility of public transportation, affordable housing, emergency operations and construction or reconstruction of roadways, parks and public buildings.

Abilities Foundation, through ServiceSource, partners with the State of Florida Division of Vocational Rehabilitation to provide core vocational rehabilitation services in numerous workforce regions. The 262

goal of this program is to expand and improve the delivery of vocational rehabilitation services and employment outcomes through a private-provider system. Also, through ServiceSource's government and commercial contracts, individuals with disabilities provide quality services to Ability Foundation’s customers in supportive, community-based work environments. The Successful Transitions is another government funded program that persons with disabilities have access to through the Abilities Foundation. The program is funded by the Department of Education and Division of Vocational Rehabilitation.

Suncoast New Options provides services through the State of Florida, Agency for Persons with Disabilities, Home and Community Based Waiver (Big Waiver) and the Florida and Supported Living Waiver (Little Waiver). The partnership with APD has allowed Suncoast New Options to successfully provide services to individuals with dual diagnosis of developmental disability and mental health disability, to individuals with severe physical disabilities, and to individuals offering behavioral challenges.

The City of Tampa’s Department of ADA Compliance and Accessible Tampa is fully committed to providing equitable access to the City’s programs and services. The ADA Coordinator facilitates the City’s efforts to ensure compliance under Title II of the Americans with Disabilities Act (ADA), ADA Amendments (ADAA) and Section 504 of the Rehabilitation Act. The mission is to ensure the City’s services and programs are accessible to persons with disabilities. The City offers an informational portal for persons with disabilities to access government resources.

Hillsborough County has an ADA Office which represents the County on disability issues and applicable disability rights laws, and responds to citizen grievances and coordinates resolutions concerning Hillsborough County programs, services, or facilities under federal, state, or local disability rights laws. In addition, the ADA Officer provides information and training on disability related resources, disability etiquette, and disability rights laws. The ADA Officer also receives requests for accommodations for persons with disabilities which would enable such persons to access County facilities, programs, services and activities.

Though these organizations strive to provide the greatest access to government services and facilities for persons with disabilities, often times the application process is very lengthy and impedes access to such services. Lack of funding, for persons with disabilities and non-profit organizations alike, can also be a barrier in obtaining government services. ii. Public infrastructure (e.g., sidewalks, pedestrian crossings, pedestrian signals) The City of Tampa’s Department of Transportation and Stormwater Services is primarily responsible for maintaining and building the City of Tampa’s stormwater and transportation infrastructure, which includes and/or involves: Traffic Signal Management; Maintenance of Traffic; Project Development, Design, Management and Construction; Sidewalk Program; Stormwater Systems; Street Resurfacing; Street Lighting; Traffic Calming; Traffic Engineering; and Traffic Signage.

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The City’s Sidewalk Construction & Restoration Program consists of capital improvement sidewalk projects as well as the maintenance and restoration of the existing network. All new sidewalk construction projects are scored and selected for inclusion in the long-term work program based, with ADA Safety being the top scoring criteria. The City of Tampa Parking Division makes every effort to comply with guidelines of the Americans with Disabilities Act. The City’s on-street disabled parking inventory consists of thirty-three (33) designated spaces located throughout the downtown core area. Florida State Statute Chapter 553.5041(4b) states that there must be one (1) accessible parking space for each 150 metered on- street parking spaces provided by state agencies and political subdivisions. The City of Tampa meets and exceeds this total by providing one (1) accessible space per every 43 on-street spaces within the downtown core.

The Hillsborough County Public Works Department is the division at the County providing safe and efficient transportation for the community, including persons with disabilities, by maintaining roads, bridges, traffic signals, and street signs. The department also manages stormwater systems, mosquito control, and trash service.

Additionally, the City and County may utilize its federal resources such as the CDBG when possible to revitalize its public infrastructure including street improvements, street lighting, and ADA accessible pedestrian crossings and signals.

Lack of funding can act as a barrier in addressing all infrastructure issues. Government entities have a strict budget that must be allocated to multiple departments, limiting funds for large scale revitalization projects that address accessibility barriers. Infrastructure repair is often the most costly of the budget items. Leveraging federal funds can help alleviate costs and allow for additional revitalization and repair. iii. Transportation

The public transportation system for the City of Tampa and Hillsborough County is managed and operated by HART. Van services are offered through HARTFlex and HARTPlus Paratransit. HARTFlex is a door-to-door service within defined geographic zones of the county which include Brandon, South County, Northdale, Town 'N Country, and South Tampa.

HARTPlus also offers transportation for persons with disabilities. Persons with disabilities are eligible for this service if they have physical, cognitive, emotional, visual or other disabilities that prevent them from using HART fixed route bus system, either permanently or under certain conditions. Bus service is fully accessible to people who use wheelchairs or motorized scooters. All buses have PA systems to announce stops and lighted stop-requested signs.

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HARTPlus services, available only where HART bus routes operate, are based solely on the applicant's functional ability to use HART buses, not disability alone. HART has buses that are specifically used for persons with disabilities through its HARTPlus service. These buses have low flooring thus increasing accessibility. HARTPlus Paratransit fares are $4 one-way cash fare and $40 for a 10-ride fare card. Discounted fares are offered for persons with disabilities.

Hillsborough County also offers the Sunshine Line. The Sunshine Line provides door-to-door transportation and bus passes for elderly, low-income, and people with disabilities who do not have or cannot afford their own transportation. Transportation is provided primarily to medical appointments and Aging Services day care and nutrition sites, but non-medical trips are provided on a space-available basis.

Service providers also try to supplement transportation services to assist in meeting the needs of persons with disabilities. ARC provides a range of trips for purposes that include: medical, nutrition, shopping, social service, educational, employment, social and recreational. ARC uses a variety of vehicles to provide passenger services including vans, modified vans, cars, trucks and freightliners. Eleven of the vehicles are equipped for wheelchair service and ARC has 35 vehicles for passenger transport.

Suncoast New Options provides accessible transportation services to assist individuals in attending adult day programs and community functions and activities.

MacDonald Training Center provides transportation services to their GateWay Day Services locations in Tampa and Plant City. Routes in Tampa currently cover North, West and Central Hillsborough County. Plant City operates routes as far East as Lakeland and South of Brandon. Their fleet of modern vans includes fully accessible vehicles. Some are equipped with adaptive features and lifts to accommodate those with ambulatory challenges.

Persons with disabilities also have access to the Transportation Disadvantaged Program which effectively coordinates funds and activities to provide older adults, persons with disabilities, and persons with low income access to employment, health care, education and other life sustaining activities. Transportation services are available in all 67 Florida counties for persons who are eligible and have no access to transportation. Services are provided through a statewide network of Community Transportation Coordinators.

Though there are options for accessible transportation, community participation revealed that disabled residents who do not live close to HART bus routes have an extremely difficult time getting to employment or healthcare appointments. Additional options, such as Medicaid supported taxi services, have been found to be unreliable, with untrained drivers and are often not available. These issues cause transportation barriers for the disabled population.

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iv. Proficient schools and educational programs

Public Schools The Exceptional Student Education (ESE) Department is comprised of administration, teachers and other district level staff who are assigned to provide support and services to students with disabilities (SWD) in need of special education services. HCPS serves over 29,000 students with disabilities, ages birth through 21, in over 250 schools. The continuum of services for most of these students can be provided in their neighborhood school. Each of the eight Area Offices has an ESE Team which offers support and assistance to school staff and parents.

The ESE Department supports the District in processes related to identification, evaluation, eligibility determination, educational placement and the provision of a free appropriate public education to SWD.

The ESE Department supports the parents of SWD in addressing any issues or concerns they may have. The ESE Department ensures that parents have the opportunity to be a partner in the educational decisions made regarding their child, and that they are afforded the procedural safeguards to which they are entitled.

Private Schools and Social Service Providers Often times educational programs specific to persons with disabilities is obtained through private schools or service providers. Private schools and service providers in the area offer various educational programs, with service providers primarily teaching independent living skills.

Tampa Day School is an accredited, specialized school for students in grades 2-8 with mild to moderate learning disabilities, dyslexia, anxiety, and ADHD. The Tampa Day School teaches the same material as traditional schools, but with small class sizes, a personalized approach, and specialized programs.

The Broach School is a private K-12, non-profit special education school for children with specific learning disabilities (SLD) and autism. School features include hands-on active learning approach that includes field trips, speakers, and special projects. Students are taught personally in small groups to ensure every student can proceed at their own pace and assignments are generally completed at school. The Broach School also offers summer school and private tutoring.

The Learning For Life Academy is a special education school in Tampa that provides children with Autism Spectrum Disorders & other developmental delays, such as Down syndrome, intellectual disabilities, & language disorders comprehensive individualized education. Learning For Life Academy provides an intensive educational program based upon the principles of Applied Behavior Analysis (ABA) and Applied Verbal Behavior.

Self Reliance provides life skills training to individuals with disabilities that can range from budgeting and management of personal finances, to rights as a voter, how to look for and keep employment,

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how to write a resume, accessing transportation or developing self-advocacy skills. These skill trainings are performed either on a one-to-one basis or in a group setting.

The Abilities Foundation offers Youth Transition Services. The Successful Transitions is a program funded by the Department of Education and Division of Vocational Rehabilitation to assist with self- sufficiency and placement of youth with disabilities ages 14-22 in Hillsborough, Pinellas and Pasco Counties. The High School/High Tech program is a community-based partnership that provides high school students with all types of disabilities, ages 14-22, the opportunity to explore jobs and post- secondary education leading to technology-related careers.

Suncoast New Options Supported Living provides coaching services designed to teach skills, help individuals obtain their goals, and further their independence. Training and assistance can be in the individuals’ own home or apartment.

The MacDonald Training Center offers EXCEL, MTC’s new IT training cohort, developed in partnership with local universities and employers. This program is uniquely aligned to the skills and affinities of youth on the autism spectrum. Curriculum includes A+ TIA track, instruction in data entry, programming, network basics and Microsoft Office fundamentals.

Though the Hillsborough County Public School System does serve persons with disabilities, sometimes public schools do not have the staff capacity or specialized tools necessary to accommodate special needs populations. This can become a barrier for persons with disabilities in accessing proficient schools. If a disabled student requires a deeper level of attention or special accommodations due to their disability, many times the only option is private schools, which can be costly and unaffordable to low-income families. v. Jobs Service providers have programs highly focused on teaching independent living skills and providing employment opportunities for persons with disabilities. The ARC Tampa Bay’s Habilitation Centers are designed to promote work opportunities, using vocational endeavors as the primary therapeutic activity. ARC has business agreements with several local businesses to provide contract work, such as packaging, shrink wrapping, collating, sorting and product assembly. Products are brought to the Habilitation Centers where they are packaged or assembled and then shipped back to the supplier. Some of these contract jobs include pool toys, clothing, pens, screws and boxes. Individuals are taught skills that will help them once they advance to employment opportunities outside of the Habilitation Centers.

ARC also offers employment assistance for those who are seeking community-based employment. A supported employment coach assists the individuals in the program to obtain identification cards, arrange transportation, apply for jobs and learn specific skills for the job. Individuals who remain in the workforce can request long-term supports for as long as they need.

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The Abilities Foundation offers job placement and vocational evaluation which provides career counseling, vocational evaluation, job development, workplace accommodations, and follow-up service to help persons with disabilities obtain and maintain gainful employment.

The Abilities Foundation offers several programs for employment opportunities including vocational rehabilitation counselor services and a Veterans Employment Program. ServiceSource partners with the State of Florida Division of Vocational Rehabilitation to provide core vocational rehabilitation services in numerous workforce regions. The goal of this program is to expand and improve the delivery of vocational rehabilitation services and employment outcomes through a private-provider system. The Veterans Employment Program provides job placement services to injured and wounded military veterans.

Suncoast New Options Supported Employment provides coaching services for persons with disabilities to obtain, learn and maintain paid employment at or above minimum wage. Training and assistance to both the individual served and consultation to the employer to enhance natural supports in the workplace can also be acquired.

The MacDonald Training Center provides employment services giving individuals with disabilities the necessary one-on-one employability skills training, such as: resume preparation and interview etiquette; job development and utilizing an individual's community support network; web-enhanced job search; mock interview sessions; transportation and travel training; community based job observation; job fair attendance; competitive job placement services; on-the-job training and skills acquisition; self-advocacy; job maintenance services and utilization of natural supports; interpreting services in American Sign Language; ADA assistance and employer/co-worker sensitivity training; and career advancement support and financial benefits planning.

The Tampa Lighthouse for the Blind offers a variety of employment programs and services including computer training, direct job placement, job development, rehabilitation engineering, and supported employment.

Reasonable accommodations often become a barrier in accessing employment for persons with disabilities. Employers may not be knowledgeable about the Disability Act resulting in an unwillingness to provide accommodations for a disabled employee. Service providers offering employment training and partnering with local businesses helps to alleviate the misconception around reasonable accommodations and provides more opportunities for the disabled to obtain employment. b. Describe the processes that exist in the jurisdiction and region for persons with disabilities to request and obtain reasonable accommodations and accessibility modifications to address the barriers discussed above.

There are several options for persons with disabilities to request and obtain reasonable accommodations and accessibility modifications in the region. 268

City of Tampa The City’s Department of ADA Compliance and Accessible Tampa, in accordance with the requirements of Title II of the Americans with Disabilities Act of 1990 (ADA), has adopted a policy that the City will not discriminate against individuals with disabilities in providing services, programs or activities. Reasonable accommodations will be made to policies and programs to ensure that persons with disabilities have an equal opportunity to enjoy all of its programs, services and activities. Persons requesting reasonable accommodation or needing to file a grievance can contact the City’s ADA Coordinator at ADA Coordinator, Office of the Chief of Staff, 306 E. Jackson, 4N, Tampa, FL 33602. The telephone number is 813-274-3964 and email is [email protected].

The Tampa Office of Human Rights (TOHR) provides the public with the opportunity to file discrimination complaints in the areas of employment, housing and public accommodations through the enforcement of the City of Tampa Human Rights Ordinance as well as state and federal laws. Persons wishing to inquire about reasonable accommodations may contact TOHR.

Hillsborough County The County has an ADA Officer that represents Hillsborough County on disability issues and applicable disability rights laws and responds to citizen grievances and coordinates resolutions concerning Hillsborough County programs, services, or facilities under federal, state, or local disability rights laws. In addition, the ADA Officer provides information and training on disability related resources, disability etiquette, and disability rights laws. The ADA Officer receives requests for accommodations for persons with disabilities which would enable such persons to access County facilities, programs, services and activities. The ADA Officer can be contacted at County Center, 21st floor, 601 E. Kennedy Blvd., Tampa, FL 33602. The telephone number is 813-276-8401.

Hillsborough County also has its Equal Opportunity Office which provides assistance to County residents who believe they have been discriminated against because of race, color, gender, age, national origin, religion, disability, marital or familial status, sexual orientation, or gender identity or expression. The Office investigates employment, housing, credit extension, contracting, and other practices, and provides training to residents, businesses, and organizations. Persons can also call the Equal Opportunity Office to request accommodation and the EEO will refer the appropriate contact information.

In addition to City and County departments, persons with disabilities can contact local providers serving the disabled such as ARC, Self-Reliance, Abilities Foundation, Suncoast New Options, or the MacDonald Training Center. These providers can assist with providing information, referring clients to a proper contact, or with the actual modifications depending on the case. c. Describe any difficulties in achieving homeownership experienced by persons with disabilities and by persons with different types of disabilities in the jurisdiction and region.

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Homeownership opportunities can be directly linked to the ability to obtain employment and earn a viable income to qualify for financing or homeownership assistance. Though there are multiple organizations in the region that provide independent living skills programs and employment training, obtaining employment is still a challenge for persons with disabilities. This limits homeownership opportunities for this population.

For persons with disabilities that are able to obtain employment, often times their incomes are still not sufficient enough for homeownership to be affordable. The Florida Housing Data Clearinghouse (Shimberg Center) profile for Hillsborough County/Tampa states that in 2016 the median sales price of a single-family home was $199,800. ACS data shows that in 2016, median earnings of the non- institutionalized population having a disability, was $23,452. An annual income of $23,452 makes it very difficult to qualify for a market rate home, unless deep housing subsidies are involved. In addition, a portion of a disabled person’s earnings are allocated towards covering health expenses, leaving a minimal margin to afford housing costs. The City and the County offer purchase assistance programs, available to persons with disabilities, to help alleviate mortgage costs and increase opportunities for homeownership.

Opportunities for homeownership also depend on the individual’s type of disability. As discussed previously, many persons with disabilities who require 24/7 care only have the option of living in group homes or other care facilities. Persons with disabilities who are more self-sufficient may still require accessible accommodations for their home. The majority of homes for sale on the local market are not set-up with accessible features. For a person with a disability to purchase a home, often times modifications are necessary, and the purchaser would be responsible for retrofitting. Modifications can be very expensive, increasing the total cost of buying the home and essentially making homeownership unaffordable.

5. Disproportionate Housing Needs a. Describe any disproportionate housing needs experienced by persons with disabilities and by persons with certain types of disabilities in the jurisdiction and region. Persons with disabilities experience greater challenges with access to affordable housing, creating disproportionate housing needs for this population in comparison to the general population. A lack of affordable housing combined with lack of employment opportunities for persons with disabilities, limits housing opportunities even more. With access to employment being a barrier, persons with disabilities are likely to be low income, limiting housing opportunities such as homeownership. In addition, the need for accessibility further limits the type of housing persons with disabilities have access to and often restricts access to affordable housing in a range of unit sizes. Further, because certain types of disabilities require 24/7 care, many times the only option is group homes or other care facilities, often increasing segregation for this population.

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6. Additional Information

a. Beyond the HUD-provided data, provide additional relevant information, if any, about disability and access issues in the jurisdiction and region including those affecting persons with disabilities with other protected characteristics.

There is no additional local data or knowledge available relevant to disability and access issues in the jurisdiction or region

b. The program participant may also describe other information relevant to its assessment of disability and access issues.

No additional information is available.

7. Disability and Access Issues Contributing Factors

Identify factors that significantly create, contribute to, perpetuate, or increase the severity of disability and access issues and the fair housing issues, which are Segregation, R/ECAPs, Disparities in Access to Opportunity, and Disproportionate Housing Needs.

• Access to publicly supported housing for persons with disabilities • Access to transportation for persons with disabilities • Lack of access to opportunity due to high housing costs • Lack of affordable in-home or community-based supportive services • Lack of affordable, accessible housing in range of unit sizes • Lack of affordable, integrated housing for individuals who need supportive services • Lack of assistance for housing accessibility modifications • Lack of assistance for transitioning from institutional settings to integrated housing • Loss of Affordable Housing • Source of income discrimination • Private discrimination

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E. Fair Housing Enforcement, Outreach Capacity, and Resources Analysis

1. List and summarize any of the following that have not been resolved: • A charge or letter of finding from HUD concerning a violation of a civil rights-related law; • A cause determination from a substantially equivalent state or local fair housing agency concerning a violation of a state or local fair housing law; • Any voluntary compliance agreements, conciliation agreements, or settlement agreements entered into with HUD or the Department of Justice; • A letter of findings issued by or lawsuit filed or joined by the Department of Justice alleging a pattern or practice or systemic violation of a fair housing or civil rights law; • A claim under the False Claims Act related to fair housing, nondiscrimination, or civil rights generally, including an alleged failure to affirmatively further fair housing; or • A pending administrative complaints or lawsuits against the locality alleging fair housing violations or discrimination. There are several fair housing organizations that are engaged in the enforcement of Federal, state, and local fair housing laws in Tampa and Hillsborough County. These include HUD, the Florida Commission on Human Relations (FCHR), the City of Tampa’s Office of Human Rights (TOHR), Hillsborough County Equal Opportunity Administrator’s Office (EOA), and Bay Area Legal Services, Inc. (BALS).

As of October 2016, FCHR had three cases pending closure. One of the cases was in the process of being adjudicated by the Florida Division of Administrative Hearings (DOAH). BALS had nine cases open.

Table 67 provides information on unresolved housing discrimination cases including the processing office, filing date, parties, claims, and the current status of each case.

Table 67: Unresolved Housing Discrimination Cases Unresolved Housing Discrimination Cases

Processing Filing Date Basis Status Petitioner Respondent Office FCHR 4/27/16 Disability, DOAH Oliver Fox Wood at Trinity physical Community, Assoc., Inc. Color National Origin, Hispanic Multi-racial Disability, mental FCHR 8/15/2016 Familial Status, Pending Sevigny Stonebrier/ Homeowners Children under Closure Association, Inc. 18

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Unresolved Housing Discrimination Cases

FCHR 9/19/2016 Sex, Female Pending Acosta Royal Hills Homeowners National Origin, Closure Association, Inc. Hispanic BALS 9/28/2016 Familial Status Open Harman Captive Club, LLC BALS 9/29/2016 Race Open Stephens Greenwood Associates BALS 9/26/2016 Familial Status Open Harris Tampa Bay Communities, LLC BALS 9/30/2016 Disability Open Rodgers Preserve at , Robbins Property Associates BALS 12/17/2015 Race Open Newsome T. Morning, Realtor BALS 12/14/2015 Race Open Newsome T. Morning, Realtor BALS 10/10/2016 Disability Open Rivers Mark Meysembourge BALS 7/6/2016 Race Open Newsome T. Morning, Realtor BALS 10/20/2015 Disability Open Morales Vista Grande at Tampa Palms n/k/a/ The Preserve at Tampa Palms

2. Describe any state or local fair housing laws. What characteristics are protected under each law?

Florida Fair Housing Act Title XLIV, Chapter 760 of the Florida Statutes, Civil Rights, covers discrimination in the treatment of persons and minority representation. Part II, the Florida Fair Housing Act, (ss. 760.20 – 760.37), prohibits discrimination in the sale, rental, advertising, financing, or provision of brokerage services for housing. The Florida Fair Housing Act is substantially equivalent to the federal Fair Housing Act (FHA) and protects persons from housing discrimination on the bases of race, color, religion, national origin, sex, pregnancy, disability, and familial status. FCHR is responsible for enforcing the Florida Fair Housing Act.

City of Tampa Human Rights Ordinance The Tampa Human Rights Ordinance (Ord. No. 92-147) was adopted on September 10, 1992. The City is a participant in HUD’s Fair Housing Assistance Program (FHAP). HUD has determined that the City’s Human Rights Ordinance is substantially equivalent to the federal FHA. The Tampa Human Rights Ordinance includes protection for persons covered by the federal FHA as well as additional protections for individuals based on sexual orientation, gender identity or expression, age, and marital status. Discrimination complaints are investigated in the areas of employment, housing, and public accommodations. The Tampa Human Rights Board is responsible for enforcing the Human Rights Ordinance by receiving and investigating complaints.

Hillsborough County Human Rights Ordinance The Hillsborough County Board of County Commissioners adopted the Hillsborough County Human Rights Ordinance in 2000 (Ord. No. 00-37). The County’s Human Rights Ordinance prohibits discrimination on 273

the basis of race, color, sex, age, national origin, religion, disability, or marital status in connection with employment, public accommodations, real estate transactions, or County contracting and procurement, and discrimination on the basis of familial status in connection with real estate transactions. The County’s Human Rights Ordinance was amended in October 2014 (Ord. No. 14-30) to add sexual orientation and gender identity or expression as protected classes. The Equal Opportunity Administrator’s Office through the Human Relations Board receives and investigates complaints from residents of Hillsborough County not including discrimination that occurred within the limits of the City of Tampa.

3. Identify any local and regional agencies and organizations that provide fair housing information, outreach, and enforcement, including their capacity and the resources available to them.

There are four fair housing enforcement agencies that enforce the Federal, state, and local fair housing laws and conduct education and outreach activities in the region. These agencies often collaborate in order to ensure a comprehensive fair housing enforcement program. The fair housing organizations are: • The Tampa Office of Human Rights (FHAP); • Hillsborough County Equal Opportunity Administrator’s Office; • Bay Area Legal Services (FHIP); and • Gulfcoast Legal Services

Tampa Office of Human Rights The TOHR is a FHAP and is contracted with HUD to carry out certain eligible activities including complaint investigation, training, and education and outreach. In addition to the TOHR staff, the functions performed by the Office are also supplemented by other City divisions including Legal Affairs (preparation of contracts, subpoenas, and resolutions), City of Tampa Television (public service announcements and video production), and Graphic Design and Publication (development of outreach materials included flyers, brochures, and posters). Other funding sources for TOHR include General Fund, U.S. Equal Employment Opportunity Commission, and funding from the Mayor’s Hispanic Advisory Council and the Mayor’s Alliance for Persons with Disabilities.

TOHR is a section within the Housing and Community Development Division. The structure of the fair housing enforcement program conforms to the HUD requirements and ensures a fair and unbiased process for investigating and resolving fair housing complaints.

Residents of the City can initiate a housing discrimination complaint by completing a questionnaire at the TOHR office, online, mail, or by fax. The questionnaire gathers information on the complainant, the respondent that may have discriminated against the individual, the action that the complainant found discriminatory, and the bases for the discriminatory action. Based on the information from the questionnaire and follow-up with the complainant, TOHR makes a determination whether the alleged action violated the fair housing laws.

Once a complaint is filed, both the Complainant and the Respondent are notified of the charge and may move on to mediation if both parties agree. TOHR dual files complaints with HUD Office of Fair Housing 274

and Equal Opportunity (FHEO). If an agreement is not reached during mediation, the charge is fully investigated and TOHR attempts conciliation between both parties. If the parties sign a conciliation agreement, the investigation ends, and the case is closed.

Between FY 2011-2016, TOHR processed 40 housing discrimination cases and negotiated settlement agreements in 12 of those cases.

Hillsborough County Equal Opportunity Administrator’s Office The EOA investigates complaints in employment, public accommodation, housing, county contracting and procurement activities, and credit extension practices. The County jurisdiction includes unincorporated Hillsborough County and Plant City. EOA provides referrals to TOHR for cases that are non-jurisdictional.

In regard to housing complaints, residents within the jurisdictional boundaries can file a complaint by filling out an intake questionnaire that collects basic information on the complainant and respondent, the basis for the discrimination, and relief sought. The EOA investigates complaints and issues cease and desist orders. Between January 2011 and December 2015, EOA investigated 45 housing discrimination cases.

Bay Area Legal Services BALS receives funding through HUD’s Fair Housing Initiatives Program (FHIP) to carry out investigations and other enforcement activities to eliminate unlawful practices throughout Hillsborough County.

BALS is a multi-year awardee and received $300,000 in grant funds through FHIP in 2016. BALS performs all the comprehensive activities that are required of a FHIP including education, investigation, testing, and enforcement.

Gulfcoast Legal Services Gulfcoast Legal Services (GLS) is a non-profit organization providing free legal assistance to residents of the Tampa Bay area including Pinellas, Manatee, and Sarasota Counties. GLS through an agreement with Pinellas County provides legal representation for complainants in fair housing actions and carries out the enforcement provisions of the Pinellas County Human Rights Ordinance. The City of Tampa is in the process of changing the structure of its fair housing enforcement program by contracting with GLS.

Information and Outreach There are also other non-profit agencies that also provide fair housing information and outreach to protected class members. These agencies include: • National Association for the Advancement of Colored People (local branch) • Greater Tampa Association of Realtors • Bay Area Apartment Association • Mayor’s Alliance for Persons with Disabilities • Corporation to Develop Communities of Tampa • Tampa Lighthouse for the Blind • League of United Latin American Citizens 275

• Mayor’s African American Advisory Council • Mayor’s Hispanic Advisory Council

TOHR collaborates with all of the aforementioned groups on fair housing training and outreach and education events including the Tampa Bay Fair Housing Symposium. These organizations also refer residents to the TOHR to file discrimination complaints.

4. Additional Information

a. Provide additional relevant information, if any, about fair housing enforcement, outreach capacity, and resources in the jurisdiction and region.

Complaint Data A review of the housing discrimination cases filed with the TOHR, EOA, BALS, FCHR, and HUD over the last five fiscal years provides insight into the nature and extent of fair housing complaints and identifies trends in fair housing discrimination in the County.

Table 68 shows that between January 2011 and June 2016, 135 fair housing cases were closed between the five organizations. The table below breaks out the fair housing cases received and closed by type of complaint. In 31 of the cases, complaints were filed on more than one basis. Approximately 42% of the cases were based on disability (physical and mental), 23% of the cases had multiple bases, and 17% were based on race.

Table 68: Housing Discrimination Closure Log (2011-2016) Housing Discrimination Closure Log (2011-2016)

Race National Religion Sex Familial Disability Sexual Retaliation Multiple Total Origin Status Orientation Bases TOHR 5 1 1 - 1 25 - - 7 40

EOA 9 7 - 1 3 15 1 - 9 45

BALS 2 - - - - 2 - - - 4

FCHR 6 - 1 - 3 13 - 2 12 37

HUD 1 1 - 1 1 2 - - 3 9

Total 23 9 2 2 8 57 1 2 31 135

* The cases reported by BALS were filed between 2015 and 2016.

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The review of trends in closure of cases by year shows that with the exception of 2013 and 2016, fair housing investigations were relatively steady averaging 29 cases per year (116 cases in 2011, 2012, 2014, 2015) as shown in Table 69. The number of cases closed in 2013 is skewed because TOHR did not investigate any cases and EOA experienced a decline in housing complaints when they discontinued their participation in HUD’s FHAP. Discrimination based on disability and race were consistently the most prevalent housing discrimination complaints.

Table 69: Fair Housing Cases Closed by Year Fair Housing Cases Closed by Year

Basis 2011 2012 2013* 2014 2015 2016** Race 5 5 2 4 2 4 National Origin 3 5 - - - 1 Religion - - - - 2 - Sex - 1 - 1 - - Familial Status 4 1 - 2 - 1 Disability 12 11 4 13 15 3 Sexual Orientation - 1 - - - -

Retaliation - - - 1 - 1 Multiple Bases 7 6 3 6 9 - Total 31 30 9 27 28 10 * The total cases closed in 2013 is skewed because Hillsborough County EOA relinquished its participation in HUD’s FHAP in April 2013 and as a result, the number of housing complaints received by the County decreased. Additionally, TOHR did not investigate any cases in FY 2012-2013.

**The closed cases reported for 2016 are for a portion of the fiscal year.

The review of fair housing complaint data is not enough to determine the fair housing issues in the region since complaints are based on allegations of unlawful discrimination. Fair housing issues may be determined by reviewing the disposition of the cases. Often times, complainants may voluntarily withdraw their complaints, fail to cooperate, or resolve the issue in some other manner.

Table 70 shows how the 29 fair housing cases that were determined to have cause were resolved. A review of the cases found to have cause shows that 21 cases (72%) were based on disability (including 2 cases combined with national origin and retaliation), 4 cases (14%) were based on race, 2 cases (7%) were based on familial status, 1 case (3%) was based on sex, and 1 case (3%) was on multiple bases – color, national origin, and familial status. Respondents included multifamily apartment complexes, real estate professionals, homeowner associations, property management companies, and individual landlords.

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Table 70: Fair Housing Case Resolutions Fair Housing Case Resolutions Date Agency Case Basis Closure Code Respondent Filed number TOHR Cases 6-30-11 11-0009 Disability NSA Tampa Park Apartments 6-28-10 10-0035 National NSA American Home Mortgage Servicing, Inc. Origin

Disability 10-12-11 12-0002 Disability Withdrawal Dockside Condo Assoc. with benefits 1-18-12 12-0003 Familial NSA Daejan Oak Manor Status 9-6-12 13-0003 Disability NSA Armenia Village Condo 10-26-12 13-0007 Disability NSA Mobile Property Mgt. 11-05-12 13-0008 Disability NSA Shore Colony Condo 4-25-12 13-0010 Disability NSA Jewish Center Tower 7-07-14 15-0002 Disability NSA Maureen and William Whitaker, et al 2-10-15 15-0003 Disability NSA Park Avenue Apartments 8-26-14 15-0002 Disability NSA Good Samaritan Inn 1-26-16 16-0006 Disability NSA (in Fairfield Arbor Walk, LLC, et al progress) 5-03-16 16-0020 Disability NSA Tampa Park Apartments EOA Cases

332-H-11 Disability Conciliated Sligh Ave Apts./Richman Group

334-H-11 Familial Conciliated SP St. James, LP Status 335-H-11 Race Conciliated Enrique Cardenas

340-H-11 Disability Conciliated Clayre DeSilva, Mgr.

341-H-11 Disability Conciliated Spivey

345-H-11 Race Conciliated Calusa Trace; Andrew Dougill; Hoffam Realty; T. Gaffney 359-H-12 Disability Resolved Rocky Creek Retirement Properties

364-H-12 Disability Conciliated Claymore Housing and Richmond Properties 398-H-14 Sex Conciliated Meir Barack BALS Cases 10-30-15 - Disability Resolved Lue Betts, Voucher Manager Tennessee Valley Regional Housing Authority 5-2-16 - Race Resolved Livingston Family Communities, LLC 278

Fair Housing Case Resolutions FCHR Cases 7-1-14 2015H0003 Disability Withdrawal Paradise Lakes Condo Assoc. with benefits Retaliation 8-6-14 2015H0025 Disability Withdrawal Collier Commons Apts., LLC. with benefits 3-17-15 2015H0193 Race Withdrawal James & Patty Lathrop (owners) with benefits 9-4-15 2016H0086 Disability Withdrawal Jissett Martinez with benefits HUD Cases 02-19-13 04-13-0423-8 Color, Conciliated National Origin, Familial Status

2015-2016 Testing Results

Fair housing organizations use testing to determine where discrimination is occurring. Fair housing testing is a simulation of housing transactions by individuals posing as renters or homebuyers. BALS testing results for 2015 and 2016 further show that race and disability are the primary bases for housing discrimination in Hillsborough County. BALS conducted 224 tests to examine unlawful housing discrimination practices including rental, sales, and lending tests. Approximately 25% (57) of the tests resulted in a cause finding. Of the 57 tests that resulted in a cause finding, 30 were rental tests, 19 were lending tests, 6 were sales tests, and 2 were homeowners’ insurance tests. Table 71 summarizes the testing results.

Table 71: Housing Discrimination Testing Results Housing Discrimination Testing Results Year Number of Disability Race Sex National % of cause Tests Origin findings

2015 102 8.8% 9.8% 1.0% 1.0% 20.0% 2016 122 7.4% 15.6% 6.6% 0.8% 30.4% Total 224 8.0% 12.9% 4.0% 1.8% 25.4%

b. The program participant may also include information relevant to programs, actions, or activities to promote fair housing outcomes and capacity.

The City, THA, and the County have all taken actions to increase knowledge of the fair housing laws and eliminate housing discrimination. BALS also conducted 39 presentations and 10 community outreach events with a combined total of over 2,400 participants between 2015 and 2016. 279

Hillsborough County identified insufficient knowledge of fair housing laws and lack of awareness of the County’s Human Rights Ordinance as impediments in its 2011 AI. During the five years since the AI’s adoption, the County has implemented the following actions: • Established a Fair Housing Awareness Program that includes a dedicated fair housing webpage that provides information on how to file a complaint as well as provides links to housing resources, the County’s ADA Liaison webpage, HUD FHEO webpage, information on the Fair Housing Act, and the phone number for HUD and EOA. • Developed public service announcements, social media posts, and posts fair housing materials in County libraries. The cities of Plant City and Temple Terrace have also posted links to fair housing information on the County’s website. • The EOA processes complaints online through links on EOA webpage and the Affordable Housing Services (AHS) webpage. • Participates in the Tampa Bay Area Fair Housing Partnership event that is held in April of each year as well as an annual disability awareness event held in July of each year. • Posted the Human Rights Ordinance on both the EOA and AHS webpages. • AHS and EOA work together on all issues involving fair housing and links to the EOA webpage is on the AHS webpage and vice-versa.

In 2015 and 2016, the City, through TOHR, has undertaken or collaborated on several trainings, outreach, and education events to provide information to the general public and stakeholders on fair housing laws. Some of the events targeted specific protected classes including persons with disabilities, minorities (Blacks/African-Americans and persons of Hispanic ethnicity), and the LGBTQ community. Below is a sample of the City’s efforts: • Attended the League of United Latin American Citizens (ULAC) monthly meeting and provided flyers and information about the service provided by TOHR. • Made presentations at Solita’s House to a homebuyer’s education class on TOHR services, housing discrimination, and how to file a complaint. • Attended the Mayor’s Alliance for Persons with Disabilities Luncheon and distributed flyers and provided information on housing discrimination. • Participated in Operation Reveille by distributing flyers and providing information on how to file a housing complaint to over 100 veterans. • Distributed fair housing literature at the 2016 Apprenticeship Event which was attended by LMI residents from East Tampa. Other participants included Mayor’s African American Advisory Council, the Hillsborough County School District, and Leary Technical Center. • Attended the Creating a Plan for the Future workshop which focused on Post-Secondary planning for students with disabilities. Provided referral information and addressed fair housing inquiries and questions. • Produced a public service announcement and negotiated free airtime with Bright House Network.

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• Participated in a homebuyer education class held by the City’s Housing and Community Development Division and presented an overview of the FHA and how to report fair housing complaints. • Participated in the Tampa Bay Consortium 13th Annual Fair Housing Symposium, which is a full day of workshops, vendors, and networking. The Consortium is comprised of agencies from the City of Tampa, Hillsborough County, City of St. Petersburg, Pinellas County, City of Largo, Bay Area Legal Services, Gulfcoast Legal Services, Greater Tampa Association of Realtors, and Pinellas Realtor Organization. • TOHR conducted a 2-hr Fair Housing 101 class for the Mayor’s African American Advisory Council. The class included an overview of the federal FHA and the City’s Human Rights Ordinance, reporting, and elements of a fair housing case. The training also included discussion on HUD’s new guidance on the use of criminal background records.

THA has adopted a Fair Housing Policy which is a part of the agency’s Management Plan. The policy and procedures outline actions to comply with the Fair Housing Act, state and local fair housing laws, and other civil rights regulations. The Fair Housing Policy addresses nondiscrimination, affirmative marketing, operations, reasonable accommodations, and participation of persons with limited English proficiency (LEP).

5. Fair Housing Enforcement, Outreach Capacity, and Resources Contributing Factors

Identify factors that significantly create, contribute to, perpetuate, or increase the lack of fair housing enforcement, outreach capacity, and resources and the severity of fair housing issues, which are Segregation, R/ECAPs, Disparities in Access to Opportunity, and Disproportionate Housing Needs. For each significant contributing factor, note which fair housing issue(s) the selected contributing factor impacts.

• Lack of resources for fair housing agencies and organizations • Lack of state or local fair housing laws • Other – Lack of awareness of fair housing laws and enforcement programs

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V. Fair Housing Goals and Priorities

1. For each fair housing issue as analyzed in the Fair Housing Analysis section, prioritize the identified contributing factors. Justify the prioritization of the contributing factors that will be addressed by the goals set below in Question 2. Give the highest priority to those factors that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance.

Table 72 identifies the contributing factors for each fair housing issue analyzed. The highest priority is given to the factors that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance. The City, County, and THA have chosen to prioritize contributing factors as either priority or non-priority items. A non-priority contributing factor does not indicate that the factor is not significant but rather that there are other factors that have greater effects on fair housing choice and access to opportunity and that priority factors will likely need to be addressed first.

Table 72: Contributing Factors Prioritization and Justification # Contributing Factor Identified Fair Housing Issue Priority Justification 1 Access to financial services Disparities in Access to Priority An analysis of bank branch locations showed that the Opportunity majority of bank branches are located outside of low- and middle-income census tracts. Not having access to financial Disproportionate Housing services like financing for home repair loans, mortgages, or Needs refinancing of mortgages can have an impact on the housing problems experienced by Black/African-American families that predominantly reside in R/ECAPs and other low – and moderate-income census tracts.

Community meetings and interviews with key stakeholders revealed a lack of access to traditional financial services, particularly in the University Area. This lack of access to traditional financial services extends to other R/ECAP areas as well, and impacts protected classes living in those communities. Community residents reported predatory

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# Contributing Factor Identified Fair Housing Issue Priority Justification lenders, payday lenders, and other nontraditional financial institutions in communities across Tampa. 2 Access to publicly supported Disability and Access Priority There is a lack of sufficient number of accessible units in housing for persons with Tampa and Hillsborough County and persons with disabilities disabilities who have extremely low incomes, such as those who rely on Supplemental Security Income (SSI) for their sole income, do not have adequate access to publicly supported housing due to extensive waiting lists. The demand for additional affordable housing units for persons who require supportive services is illustrated by the waiting lists for THA developments. A second factor is that those on waiting lists for support cannot reside outside of the family home or in supervised group settings. 3 Access to transportation for Disability and Access Non- The inability of persons with disabilities to access persons with disabilities Priority transportation may limit housing choice and access to opportunity. While the HARTflex and HARTplus systems provide thousands of rides per year, program limitations result in limited public bus service routes. Persons with disabilities who reside outside of HART route zones do not have access to reliable and affordable transportation.

This contributing factor is selected as a non-priority item because there are currently numerous public and private accessible transportation options available in the City and the County and the majority of the transportation options are physically accessible. The availability, type, frequency, and reliability of public transportation has been selected as a priority item and as deficiencies in the transit system are addressed improvements in access in terms of proximity

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# Contributing Factor Identified Fair Housing Issue Priority Justification and reliability will simultaneously occur for persons with disabilities. 4 Admissions and occupancy Publicly Supported Housing Priority Based on input from residents and stakeholders, there are policies and procedures, including certain policies and procedures that are disproportionately preferences in publicly supported limiting the access of Blacks/African-Americans and other housing minority groups to publicly supported housing. The main policies that are impacting residents in Tampa and Hillsborough County are criminal record and tenant screening procedures.

In April 2016, HUD issued guidance on the use of criminal records in excluding applicants and tenants from housing. When considering criminal history during screening, landlords and housing providers must consider the severity of the crime and when it occurred. HUD also recommended that housing providers apply their policy on an individual basis and consider factors such as the age of the individual at the time the criminal act occurred and tenant history before and after the crime and/or conviction occurred.

It was repeatedly stated during community and stakeholder meetings that criminal background checks are a recurring and insistent challenge for minorities and that it is impossible to get into housing if an applicant has a criminal history. Broadly speaking, many privately owned, publicly subsidized developments use tenant screening criteria comparable to those of market-rate developments.

Admissions and occupancy policies and procedures is

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# Contributing Factor Identified Fair Housing Issue Priority Justification selected as a priority item because although HUD has recently issued guidance to curtail some of this practice, some property managers/landlords have either not changed their policy on criminal background checks or they do not apply the policy on an individual basis. 5 Availability of affordable units in a Disproportionate Housing Priority The lack of affordable housing in Tampa, Hillsborough range of sizes Needs County, and the region is a significant factor that limits fair housing choice. Cost burden is the most common housing problem experienced by residents in the three geographic areas. The analysis revealed that the areas experiencing the greatest housing burden overlap with the R/ECAPs and areas adjacent to the R/ECAPs. These areas are predominantly occupied by minorities, specifically Black/African-American households. The analysis also revealed that large family households (families with five or more related members) are also more likely to experience housing problems than small related households and non- family households.

The shortage of affordable housing is a severe barrier that was mentioned by many residents and several housing and service professionals in the public, private, and nonprofit sectors. There is a lack of both public and private subsidized housing and the population growth in the area coupled with high rent costs increases the need for additional affordable housing units.

The gap between the supply of affordable housing units and the need for these units indicates that the availability of affordable units in a range of sizes is a major factor in

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# Contributing Factor Identified Fair Housing Issue Priority Justification housing choice especially for minorities and large families with children. This factor is selected as a priority item because the shortage of affordable housing impacts low- and moderate-income persons who are disproportionately protected class members. 6 Availability, type, frequency, and Disparities in Access to Priority Community meetings and the fair housing survey indicated reliability of public transportation Opportunity that residents feel the hours and reliability of public transit are insufficient to meet their transportation needs. Residents commented that many bus routes do not run late at night or early morning to accommodate employees working second shift hours. Residents also commented that bus routes do not provide access to their employers.

Input from residents indicated that affordable housing options in the County are often located in remote areas with little or no public transit, such as Wimauma. Mapping conducted of transportation patterns in the City of Tampa and Hillsborough County, and consultation with HART, revealed that despite the extensive public transportation system, residents in unincorporated Hillsborough County have limited access to public transit.

This contributing factor is selected as a priority item because lack of access to transit impacts the ability to access opportunities like good quality jobs. 7 Community Opposition Segregation/Integration Priority Community meeting feedback indicated that Not in My Back Yard (NIMBY) resistance is a common problem faced R/ECAPs by Low Income Housing Tax Credit (LIHTC) developers seeking to have land rezoned for multifamily development, Disparities in Opportunity particularly in affluent areas where affordable housing is

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# Contributing Factor Identified Fair Housing Issue Priority Justification most needed. Survey respondents and community meeting Disproportionate Housing participants did not explicitly state that they did not want Needs affordable housing in high opportunity neighborhoods, however, many strongly associated the presence of Publicly Supported Housing affordable housing with neighborhoods that have high crime, poor schools, and other undesirable characteristics. Community opposition is selected as a priority item because NIMBY is a ubiquitous issue faced by affordable housing development and must be addressed if affordable housing opportunities are to be expanded in high- opportunity neighborhoods. 8 Deteriorated and abandoned R/ECAPs Priority Substandard housing was mentioned as a feature of properties undesirable neighborhoods by several survey respondents and community meeting participants. Deteriorated and abandoned properties is a priority item because substandard properties threaten public health and safety and perpetuates the negative image of a neighborhood which discourages private investment thus limiting access to opportunity. 9 Displacement of residents due to Segregation/Integration Priority In Tampa and Hillsborough County displacement impacts economic pressures renters more than homeowners. According to 2010 and R/ECAPs 2015 ACS 5-year estimates, the median value of housing units with a mortgage declined by approximately 20% and Disproportionate Housing property taxes related to housing prices have also been on Needs the decline. For the same time period (2010-2015), median gross rent has increased by almost 10% in the City and Publicly Supported Housing about 6% in Hillsborough County and the region.

In addition to affordable housing supply challenges, tenants are also being displaced because of rent inflation

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# Contributing Factor Identified Fair Housing Issue Priority Justification at the time of lease renewal. Some community members stated that there are incidences where rents have increased by between $200-$300 per month when a tenant is up for lease renewal. This forces lower income families to move because they can no longer afford their current housing. In the current market of high demand and limited supply of affordable housing, landlords and property owners have a greater incentive to increase rents.

Displacement of residents due to economic pressures is selected as a priority item because it exacerbates residential segregation and impacts access to opportunity because as residents move to more affordable areas or experience challenges if they attempt to return to where they previously lived, their access to opportunities such as good quality schools often declines. 10 Educational Attainment Segregation/Integration Priority HUD data revealed that Blacks/African-Americans have the least engagement in the labor market overall for the City R/ECAPs and the County.

Disparities in Access to There are several factors that can be related to low labor Opportunity market engagement, with educational attainment being the leading impediment. Census data shows that for the Disproportionate Housing City and County, 28% and 27% respectively, of the Needs population age 18 and older have less than a high school degree. Census data also shows that for populations with Publicly Supported Housing less than a high school degree for both the City and the County, 34% and 28% live under the poverty level. Regionally, for Blacks/African-Americans, the race/ethnicity with the least labor market engagement,

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# Contributing Factor Identified Fair Housing Issue Priority Justification 32% have less than a high school degree.

This is an indication that educational attainment may be a significant contributing factor to labor market engagement, and may demonstrate a direct correlation to disparities, particularly for Blacks/African-Americans. There are many background variables that directly impact educational attainment such as family income, family type, family size, and parent’s education. These can all be determinants of the amount and quality of education received.

Residents also mentioned in community meetings, lack of access to employment training. While this is not measured in the analysis, employment training can be an essential service needed to obtain suitable employment, specifically for low-income persons. Even for those who do graduate high school, employment training can be crucial to developing the proper professional knowledge and skills necessary to obtain employment providing a higher income. 11 Impediments to mobility Disparities in Access to Priority Discrimination against Section 8 recipients and other Opportunity voucher holders was mentioned in the resident surveys and community meetings. Also, a few residents expressed Publicly Supported Housing frustration with the Section 8 waitlist being closed and poorly managed. Another barrier households face when attempting to move to a neighborhood of their choice is low vacancy rates.

Impediments to mobility is selected as a priority item

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# Contributing Factor Identified Fair Housing Issue Priority Justification because source of income discrimination is a barrier to families trying to move to areas of opportunity and disproportionately affects minority households. 12 Lack of access to opportunity due Disparities in Access to Priority This analysis shows a lack of access to high opportunity to high housing costs Opportunity neighborhoods due to high housing costs for the protected classes, particularly race/ethnicity. LMI persons and Disability and Access protected class members that live in publicly supported housing are primarily living in neighborhoods with limited Publicly Supported Housing access to opportunities.

Persons with disabilities have overall lower incomes than persons without disabilities. Persons who rely on SSI income, of which there are over 19,000 in Hillsborough County, are completely priced out of the housing market and must rely on subsidized housing. Serving persons with extremely low-income along with special needs populations requires deeper subsidies and advanced support systems to maintain safe, decent and affordable housing. Two residents mentioned the shortage of affordable housing for the elderly and persons with disabilities.

Lack of access to opportunity due to high housing costs is a severe barrier mentioned by many residents and several housing and service professionals in the public, private, and nonprofit sectors. This factor is selected as a priority item because it has a profound effect on low- and moderate-income people, including minorities, seniors, and persons with disabilities.

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# Contributing Factor Identified Fair Housing Issue Priority Justification 13 Lack of affordable in-home or Disability and Access Priority Due to lack of Florida Medicaid funding and extensive community based supportive waiting list for Medicaid Waiver enrollment, persons with services disabilities may be prevented from independent community-based living. There are 138,974 persons with independent living difficulty in the region. There are just under 2,000 individuals who receive community-based support that provides a wide array of self-determination and independent living supports for consumers of Florida Agency for Persons with Disabilities (APD). The statewide waiting list of over 20,000 for APD consumer support services is an indication of the need for these services. The gap in funding is at the discretion of the Florida Legislature which determines the amount of funding Florida will match to federal Medicaid funding. While this is an external contributing factor the results are thousands of persons with disabilities who do not have the support needed to reside in a residential setting that is the least restrictive possible. 14 Lack of affordable, accessible Disability and Access Priority Persons with disabilities who have extremely low incomes housing in a range of unit sizes such as those who rely on SSI for their sole income, do not have access to affordable housing in the private market or subsidized housing due to high demand and insufficient supply. In addition, accessibility modification support is limited to homeowners in jurisdiction’s housing programs. This contributing factor is selected as a priority item because it limits fair housing choice for persons with disabilities who are either forced to make costly modifications on their own or live in housing that is not accessible or where their landlords are not willing to make reasonable modifications at their expense.

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# Contributing Factor Identified Fair Housing Issue Priority Justification 15 Lack of affordable, integrated Disability and Access Priority This contributing factor is selected as a priority item housing for individuals who need because demand exceeds supply for accessible, integrated supportive services housing units. This is reinforced by the need for accessible publicly supported housing. There are just over 3,000 persons with disabilities residing in publicly supported housing and there are another estimated 4,000 residing in disability specific housing. The demand for additional affordable housing units for persons who require supportive services is illustrated by the waiting lists for public housing units with over 27,000 for public housing and 4,100 for Housing Choice Vouchers. 16 Lack of assistance for housing Disability and Access Priority This contributing factor is selected as a priority item accessibility modifications because persons with disabilities who require housing accessibility modifications are limited in housing choice. Program restrictions and insufficient funding prevent persons with disabilities from obtaining the accessibility modifications they need. City and County housing programs offer rehabilitation and barrier removal or accessibility modification funding to homeowners only. Homeowners must have owned the home for a minimum of two years and their mortgage must be current. Residents of manufactured housing are not eligible for assistance unless they reside in USDA designated rural areas of the County and they may apply for loans or grants to USDA. 17 Lack of assistance for Disability and Access Priority The lack of assistance for persons transitioning from transitioning from institutional institutional settings to integrated housing is a priority item settings to integrated housing because persons with disabilities who reside in family homes or group homes who wish to live in the least restrictive setting possible do not have access to adequate

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# Contributing Factor Identified Fair Housing Issue Priority Justification independent supported living services as evidenced by the extensive wait lists for Medicaid support services and public housing. Persons transitioning to integrated settings also have financial difficulties with affording rent or they encounter private discrimination particularly if their source of income is SSI or vouchers. This is evidenced by community input as well as fair housing complaint data that show that the majority of discrimination cases are based on disability. 18 Lack of awareness about fair Fair Housing Enforcement, Priority According to the resident survey responses, Black/African- housing laws and enforcement Outreach Capacity, and American residents were less likely than White residents to programs Resources feel that they understand their fair housing rights and residents with a disabled household member were less likely to understand their rights than residents without. However, several other respondents identified lack of fair housing knowledge among residents as a moderate to severe fair housing barrier. Housing and service professionals who took the survey also have varying opinions on whether certain practices constitute fair housing barriers, and uncertainty about whether certain practices constitute barriers is widespread. Additionally, some service providers are unsure of where to refer clients who have faced housing discrimination, or would refer them to incorrect agencies.

Stakeholder comments at a community meeting and direct interviews with stakeholders indicated that tenants and applicants including public housing applicants and residents do not know where to file discrimination cases locally and are told to contact HUD. Public housing

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# Contributing Factor Identified Fair Housing Issue Priority Justification residents need to be well informed of their fair housing rights because the majority of THA residents are protected class members. Additionally, HCV holders are experiencing source of income discrimination in the region, which is not currently protected.

This contributing factor is selected as a priority item because residents are being denied housing based on protected characteristics. 19 Lack of local or regional Disparities in Access to Priority The lack of local or regional coordination is selected as a coordination Opportunity priority item because fair housing issues in the City and the County transcend jurisdictional boundaries and the housing departments responsible for administering the HUD programs and implementing the goals of this AI will need to collaborate with other government agencies such as the HCPS and HART in order to successfully address issues with accessing transportation and in accessing a quality education. 20 Lack of private investments in Segregation/Integration Priority Repeatedly, in community meetings, in surveys, and specific neighborhoods through examination of data on concentrations of poverty R/ECAPs in the City and in Hillsborough County, this analysis identified a lack of private investments in specific Disparities in Access to neighborhoods as a particular concern. Most notably from Opportunity a policymaking perspective, R/ECAPs suffer from chronic private sector disinvestment. This disinvestment from the Disproportionate Housing private sector imposes significant burdens on residents Needs living in the R/ECAP areas, especially public housing residents, whose lack of access to personal transportation Publicly Supported Housing places a greater emphasis on amenities within close proximity.

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# Contributing Factor Identified Fair Housing Issue Priority Justification

One of the indicators of a lack of private investment in R/ECAPs is the location of banks in R/ECAPs and LMI tracts. The bank branch location analysis for Hillsborough County found that only two R/ECAPs had banks located within their boundaries - University Area and East Tampa, and even then, there were only a few. Overall, 66% of bank branches are located outside of LMI and middle-income tracts and only 6% of the bank branches are in LMI tracts only.

In order to significantly address patterns of segregation, there must be a combination of resources from public and private sources. The City, Hillsborough County, and THA currently invest public funds in R/ECAPs and there is also participation from non-profits and other non- governmental entities however there is a need for a community redevelopment strategy that includes financial institutions, foundations, corporations, and other private entities in order to have a coordinated system to address the needs in these neighborhoods.

This factor was selected as a priority item because without sufficient private investment to leverage public funding, residents are left to live in distressed neighborhoods with substandard housing, high crime, limited access to amenities, public facilities, banks, jobs, and other opportunities. 21 Lack of public resources for Segregation/Integration Priority This contributing factor is complicated by the regional investment in specific nature of this AI. Based on community input, there are two

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# Contributing Factor Identified Fair Housing Issue Priority Justification neighborhoods, including services distinctions worth noting under public investment across and amenities R/ECAPs the region. The first is a notable and commendable investment of public funds in certain R/ECAP communities Disparities in Opportunity in the City, especially those involving redevelopment of THA properties. The second distinction is around the public Disproportionate Housing investment in rural communities in Hillsborough County, Needs particularly around infrastructure like sewer, transportation and other public needs. Although the Publicly Supported Housing County has invested millions in rural communities, inequalities still exist because of the limited resources compared to the need.

Several survey respondents and community meeting participants expressed a desire for more public services, such as educational and workforce development programs. Affordable housing developers noted that a lack of water and sewer infrastructure drives up the cost of housing development. Additionally, both community feedback and consultation with HART revealed a deficiency of bus service in rural and newly growing areas of the County.

Although the lack of public investment was not the most prominent issue raised by survey respondents and the City and County already have programs in place to invest in housing and community development and public services and amenities, a high priority is assigned because there are disparities in the provision of infrastructure (especially with the rural areas of Hillsborough County) that have a direct impact on the development and availability of affordable housing that is dispersed throughout the

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# Contributing Factor Identified Fair Housing Issue Priority Justification County. Additionally, issues with accessing public transportation and services also results in disparities in accessing jobs, businesses, and schools. 22 Lack of resources for fair housing Fair Housing Enforcement, Non- TOHR, EOA, BALS, and Gulfcoast Legal Services are the agencies and organizations Outreach Capacity, and priority local and regional fair housing organizations that enforce Resources the fair housing laws in Tampa and Hillsborough County. Funding for these organizations come from both public and private sources. TOHR is a FHAP but most of the funding for the division is from City’s general fund. TOHR is in the process of contracting with Gulfcoast Legal Services because the City does not have the financial or human resources to manage all of the fair housing complaints it receives.

This contributing factor is selected as a non-priority item because the City, County and region have comprehensive fair housing outreach and enforcement programs in place that even with limited resources they can still test, enforce, and build awareness of fair housing laws and rights. 23 Lack of state or local fair housing Fair Housing Enforcement, Priority Both the City of Tampa and Hillsborough County have laws Outreach Capacity, and adopted local fair housing laws that provide additional Resources protection beyond the Federal FHA. However, source of income discrimination has been identified as a contributing factor with a high priority. Although THA, residents, and other stakeholders have expressed that source of income discrimination is occurring it is not currently covered in the local fair housing laws.

This is selected as a priority item because source of income discrimination limits fair housing choice for HCV recipients

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# Contributing Factor Identified Fair Housing Issue Priority Justification and other voucher-assisted tenants, who are disproportionately Black/African-American. 24 Land use and zoning laws Segregation/Integration Priority Land use and zoning laws in effect among the jurisdictions can have negative impacts on affordability and accessibility R/ECAPs of housing for protected classes. These disparate impacts are identified in several areas of regulations including Disparities in Opportunity zoning, land development regulations, funding policies, and affordable housing incentives. Special areas of Disproportionate Housing concern include site standards, approvals and incentives. Needs The following are examples that were identified among the codes and regulations for Hillsborough County, Tampa, Publicly Supported Housing Plant City and Temple Terrace. Affordable housing incentives are offered by Hillsborough County and the City of Tampa, but they are not tracked as to frequency or effectiveness. There is a suitable array of incentives providing relief or benefits in the areas of site standards, density, impact fees, accessory dwellings, and expedited permitting, among others. But to be effective, they must be implemented and made available to developers in a relevant manner.

In several community meetings, some of the challenges with zoning and land use regulations that were mentioned include restrictions on accessory dwelling units (ADUs), minimum lot size requirements in Hillsborough County, and the lack of inclusionary zoning practices.

Land use and zoning laws is selected as a priority item because zoning policies and practices affect the housing

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# Contributing Factor Identified Fair Housing Issue Priority Justification choices of protected classes by impacting the cost, location, type, and accessibility of housing. 25 Lending Discrimination Segregation/Integration Priority Lending discrimination is selected as a priority item because an analysis of 2015 HMDA data indicated that there are R/ECAPs disparities in lending between White applicants and minority households applying for home purchase loans. In Disparities in Access to Hillsborough County, Black/African-American applicants Opportunity had a loan denial rate of 33.4% while White applicants had a loan denial rate of 18.8%. Other minority groups also had Disproportionate Housing denial rates higher than that of White applicants. Although Needs there are discrepancies in the denial rates by race/ethnicity further analysis is needed to conclude that it is based on discriminatory lending practices. Borrower-related factors such as income and credit may also be playing a role in loan denials. 26 Location and type of affordable Segregation/Integration Priority A central challenge across the region is the availability of housing affordable housing in high opportunity communities. The R/ECAPs publicly supported housing analysis shows that much of the City and County’s publicly supported housing is located Disparities in Access to in or near R/ECAPs, or in other areas with high Opportunity concentrations of Black/African-American and/or Hispanic residents. Additionally, publicly supported housing in the City and (to a lesser extent) the County is often located in neighborhoods with lower school proficiency, lower labor market engagement, higher poverty, and higher exposure to air toxins. In Tampa, moreover, developments serving mainly Black/African-American households and families with children tend to be in neighborhoods with high poverty rates and minority concentrations, while developments serving elderly households or people with

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# Contributing Factor Identified Fair Housing Issue Priority Justification disabilities have fewer Black/African-American households and are located in neighborhoods with lower minority concentrations and poverty rates.

Additionally, there is strong evidence from surveys and community meetings that the location and type of affordable housing contributes to disparities in access to opportunity. Many residents mentioned affordable housing being concentrated in undesirable neighborhoods. In addition, other types of survey respondents largely identified concentration of affordable housing as a problem.

The location and type of affordable housing is selected as a priority item because it has a profound effect on low- and moderate-income people, among whom minorities, seniors, and people with disabilities are overrepresented. 27 Location of proficient schools and Disparities in Access to Non- This is a significant factor based on resident feedback school assignment policies Opportunity Priority about affordable housing often being near poor schools, and neighborhoods with poor schools being undesirable. There is no easy solution to the challenge of low-quality schools in low opportunity communities, and low-quality schools located in neighborhoods with housing affordable to low-income individuals.

Although access to proficient schools has a profound impact on children’s well-being and is important for fair housing choice, the HCPS offers programs that enable students to attend a school of their choice regardless of place of residence.

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# Contributing Factor Identified Fair Housing Issue Priority Justification 28 Loss of affordable housing Segregation/Integration Priority Naturally Occurring Affordable Housing (NOAH) is disappearing due to low vacancy rates and the growing R/ECAPs demand for rental housing. Without no net replacement program, such as inclusionary housing, this put individuals Disparities in Access to and families at risk for displacement. Opportunity Data available from the Shimberg Center show that over Disproportionate Housing 1,700 units have been lost from the affordable housing Needs inventory since 2012 and another 700 units are at risk of being lost by 2022 due to subsidy expiration. Publicly Supported Housing

Disability and Access 29 Private discrimination Segregation/Integration Priority According to input by housing professionals, service providers, and other stakeholders, tenants with criminal R/ECAPs backgrounds, eviction histories, and bad credit have difficulty getting into apartments in more desirable areas. Disparities in Access to Opportunity Landlords are using strict criteria including high credit scores, requiring significant security deposits and other Disproportionate Housing fees, and subscribing to tenant screening programs that Needs provide unverified information on an individual’s rental history. These policies predominantly impact minorities Disability and Access especially Black/African-American women with children.

Housing complaint data for Tampa and Hillsborough County also shows that private discrimination is affecting fair housing choice especially for persons with disabilities.

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# Contributing Factor Identified Fair Housing Issue Priority Justification Private discrimination is selected as a priority item because it is a direct violation of fair housing law, and particularly affects low- and moderate-income renters whose housing choices are already limited. Private discrimination has a significant impact on people who are disproportionately minority and limit where they can live and their access to opportunity. Although there are federal laws that should safeguard against some of these practices, because of low rental vacancy rates, landlords continue to institute these policies and procedures and persons that are impacted by these decisions often do not report fair housing violations to the fair housing organizations that serve the region. 30 Siting selection policies, practices Publicly Supported Housing Non- Several community meeting participants mentioned that it and decisions for publicly priority is difficult for Low Income Housing Tax Credit (LIHTC) supported housing, including developers to make a development financially feasible if it discretionary aspects of Qualified is not in a high-poverty area that receives a basis boost. Allocation Plans and other Additionally, community meeting feedback indicated that programs NIMBY resistance is a common problem faced by LIHTC developers seeking to have land rezoned for multifamily development, and many survey respondents strongly associated the presence of affordable housing with neighborhoods that have high crime, poor schools, and other undesirable characteristics. Some respondents strongly indicated a desire to keep affordable housing out of one’s own neighborhood even if it was not said outright. This contributing factor is a non-priority because financial incentives are vital for developing affordable housing in high-opportunity areas, and HUD and the Florida Housing Finance Corporation are already implementing site

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# Contributing Factor Identified Fair Housing Issue Priority Justification selection policies to expand LIHTC development outside of minority or low-income areas. 31 Source of income discrimination Segregation/Integration Priority THA residents noted consistent and frustrating barriers to finding private landlords willing to accept their Section 8 R/ECAPs vouchers. Often, the only apartments that accept Section 8 vouchers are those located in high poverty, low Disparities in Access to opportunity areas in the City. Interviews with THA staff Opportunity revealed a pattern of discrimination based on source of income. Interviews with private landlords in the Disproportionate Housing community revealed frustrations with bureaucracy, red Needs tape, and financial burdens vouchers impose on day-to-day operations as well as stigma associated with voucher Publicly Supported Housing holders.

Disability and Access Realtors that participated in the stakeholder forums also indicated that potential homebuyers utilizing homebuyer vouchers through the FSS program are also experiencing discrimination from lenders that are unwilling to participate in the program.

Interviews with housing providers also identified an unwillingness of landlords to accept VASH vouchers. Landlords are refusing to rent to applicants because of concerns around PTSD and other disabling conditions. One veteran advocate found that landlords/property managers of approximately 30% of all available rental units refused to accept VASH vouchers.

Source of income discrimination is selected as a priority item because it limits fair housing choice for HCV recipients

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# Contributing Factor Identified Fair Housing Issue Priority Justification and other voucher-assisted tenants, who are disproportionately Black/African-American. 32 State or local laws, policies, or Disability and Access Priority There are local restrictions that discourage individuals with practices that discourage disabilities from living in apartments, family homes, individuals with disabilities from supportive housing or shared housing and other integrated being placed in or living in settings of their choice: apartments, family homes, and a) Housing Rehabilitation Policy Section b.3 requires that other integrated settings an eligible applicant have a minimum period of ownership of two years. This puts a barrier on homeowners who have purchased their home within the past two years. The purpose of requiring some degree of equity in the home has valid underwriting purposes but the rule can prevent persons with disabilities who are otherwise eligible from getting the accessibility modifications they require.

b) The SHIP Local Housing Assistance Plans for both the City and County do not include manufactured housing as eligible for rehabilitation or other assistance. While Statute 420 permits SHIP expenditures on manufactured housing built after 1994 and no more than 20% of the annual allocation, neither the City nor County has exercised this option. Stakeholders reported a high need for accessibility modifications for persons who reside in mobile homes.

c) Neither City or County housing subsidy programs offer funding for tenants who need accessibility modification funding. Tenants must pay for modifications themselves and rely on the landlord agreeing to reasonable accommodations.

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2. For each fair housing issue with significant contributing factors identified in Question 1, set one or more goals. Using the table below, explain how each goal is designed to overcome the identified contributing factor and related fair housing issue(s). For goals designed to overcome more than one fair housing issue, explain how the goal will overcome each issue and the related contributing factors. For each goal, identify metrics and milestones for determining what fair housing results will be achieved, and indicate the timeframe for achievement.

Table 73: Fair Housing Goals # Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

1 Increase the production and Community Opposition Segregation/Integration City of Tampa preservation of affordable housing units in a range of sizes within high Land use and zoning laws R/ECAPs Hillsborough opportunity areas and R/ECAPs County Location and type of affordable housing Disparities in Opportunity Tampa Housing Displacement due to economic pressures Disproportionate Housing Authority Needs Lack of access to opportunity due to high housing costs Publicly Supported Housing

Loss of affordable housing

Availability of affordable units in a range of sizes

Deteriorated and abandoned properties

Lack of affordable, accessible housing in a range of unit sizes

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Lack of private investments in specific neighborhoods, including services or amenities

Lack of public resources for investment in specific neighborhoods, including services or amenities Metrics, Milestones, and Timeframe for Achievement: • Within 5 years, utilize land use ordinances in the City and the County that strongly encourage workforce housing be built concurrently by the private sector under certain circumstances when land use permits for new construction or redevelopment are approved.

• Within 5 years, identify additional opportunities to amend existing City and County land use and zoning codes to encourage a variety of housing types including lower-income housing.

• Within 5 years, amend the City and County zoning codes to allow ADUs ‘as-of-right’ in all single-family residential districts for the purpose of creating additional affordable rental units.

• Within 2 years, provide support to a community land trust that operates throughout Hillsborough County.

• Within 5 years, ensure the development of new affordable rental housing in high opportunity areas (near public transit, good schools, and job centers) through strategies such as continued partnership with THA to create mixed-income developments, inclusionary zoning, local housing trust fund, and leveraging federal, state, and local public funding with private sector funding.

• Within 5 years, develop a mapping system that identifies sites in high opportunity areas in the City and County that are suitable for affordable housing development. If publicly owned, make these sites available through a surplus land program.

• Within 5 years, preserve existing affordable housing by encouraging owners of subsidized developments to preserve units likely to be lost from the affordable housing inventory.

• Over the next 5 years, continue to rehabilitate housing units throughout the City and County, including LMI areas and R/ECAPs.

• Over the next 5 years, hold workshop(s) to educate elected officials, local government staff, and for-profit/non-profit developers on avoiding or overcoming NIMBY opposition to affordable housing development in high opportunity neighborhoods.

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Discussion: The housing market in the City and County has tightened, with sharp increases in home and rental prices. Lower income households are facing a wide financial gap between the supply of affordable housing and the quantity demanded. Although affordable housing is not the same as fair housing, it relates closely to and overlaps with fair housing because persons that benefit from low-cost housing are disproportionately protected class members including minority households and persons with disabilities. Equal and free access to residential housing (housing choice) is fundamental to meeting essential needs and pursuing personal, educational, employment, or other goals.

The City and County will undertake a balanced approach to addressing the lack of affordable housing, one that improves overall living conditions in R/ECAPs while expanding affordable housing options in higher opportunity areas. Both the City and County should study the feasibility of inclusionary zoning as a strategy to increase the supply of mixed-income communities. There is a strong development market with substantial amounts of new construction and low vacancy rates. Inclusionary zoning will encourage developers to create below market rental or homeownership units in connection with proposed market-rate development projects.

Inclusionary zoning is just one strategy that the City and County can use to expand affordable housing options in higher opportunity areas. The City and County will need to continue to provide developer incentives to ensure the feasibility of projects affected by the inclusionary zoning policy, including density bonuses, impact fee relief, and reduced parking requirements. The City and County should also identify other strategies that will also result in the production of affordable housing units. While exploring these options, the City and County should continue to undertake the review of proposed policies, procedures, ordinances, and regulations to identify any financial impact on affordable housing and to identify policies that limit the feasibility of providing low-cost housing, such as minimum lot sizes requirements in the County.

Accessory dwelling units (ADUs) are another strategy that the City and County can utilize to help meet the need for affordable housing. Both the City and County permit ADUs in residential zoning districts as a conditional use which requires a special use permit and public hearing. This process can deter homeowners from building ADUs due to costs as well as the unpredictability of the development review process. Another potential barrier to ADU development in the City and County is requiring that the primary dwelling be owner-occupied. This requirement should be flexible to at least allow the owner to occupy the ADU and lease the primary dwelling. Allowing flexibility in living arrangements could increase the interest in ADUs.

Community land trusts (CLT) are another mechanism to not only increase affordable housing development but also to ensure the units are not lost after subsidy expiration. A CLT ensures permanent affordability by restricting the resale price of a home through a 99-year ground lease. A CLT also provides homeownership opportunities for minorities and low- and moderate-income households that would otherwise be unable to qualify to purchase a home on the conventional market. The City and County could partner with an existing CLT in the surrounding geographic area or establish a new CLT. Either way, in order for the CLT to be successful, the City and County will need to support the organization by providing funding, donating land, and through developer incentives.

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Regarding the preservation of affordable housing, the City and County will continue to allocate state and federal funding for housing rehabilitation programs to improve the quality of the existing affordable housing stock. Investing in R/ECAPs through rehabilitation, reconstruction of replacement housing, or demolition of vacant, dilapidated homes, will help to transform these areas and attract commercial and employment opportunities. The City and County will also explore ways to encourage owners of multifamily rental developments that have expiring subsidies to keep the units affordable. This includes providing funds to rehabilitate the units and extending the affordability period.

NIMBYism is an obstacle to producing affordable housing. To overcome community opposition to the placement of certain types of housing in certain neighborhoods, the City and County should use strategies such as reviewing zoning codes to ensure they include adequate land development regulations that eliminate unnecessary public hearings for affordable housing projects. Also, the City and County should encourage developers to meet with neighbors ahead of any public hearings to address questions and concerns about proposed developments. The City’s Office of Human Rights and the County’s Equal Opportunity Administrator Office will continue to offer technical assistance, workshops, and PSAs to educate the public on fair housing law.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

2 Increase the supply of affordable, Lack of affordable, accessible housing in a Disability and Access City of Tampa accessible housing in integrated settings range of unit sizes for persons with disabilities including Disproportionate Housing Hillsborough individuals who need supportive Lack of access to opportunity due to high Needs County services housing costs Publicly Supported Housing Tampa Housing Loss of affordable housing Authority

Lack of assistance for housing accessibility modifications

Lack of affordable, integrated housing for individuals who need supportive services

Lack of affordable in-home or community based supportive services

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Access to publicly supported housing for persons with disabilities

Lack of assistance for transitioning from institutional settings to integrated housing

Private discrimination Metrics, Milestones, and Timeframe for Achievement: • Within 5 years, revise programmatic policies that limit eligibility of applicants for accessibility modification assistance in owner-occupied and rental housing.

• Within 5 years, direct the taskforce on accessible housing and supported living a to develop an action plan for meeting the unmet housing needs of persons with disabilities by reviewing the current support system, identifying needs for supported living services, reviewing current segregated populations, and resolving funding constraints.

• Within 5 years, develop and implement a public relations campaign with the purpose of removing barriers to accessible housing and making homes accessible for all residents with disabilities. Discussion: Persons with disabilities represent 12.5% of the population in the City and 11.7% percent in the County. Persons with disabilities are often segregated or prevented from living in their community of choice because a great deal of housing is inaccessible, supportive services are not available, or because they experience a high rate of discrimination.

Goal #1, above, addressed the need to increase the supply of affordable housing throughout the City and the County in general. However, there is also a need to increase the number of units in those developments that are accessible. Publicly supported housing developments are already required to be physically accessible and programmatically accessible – subscribe to policies and procedures that increase housing options for persons with disabilities and their families such as special population preferences, waitlist procedures, and reasonable accommodation procedures. The City, County, and THA will continue to fund and develop housing projects that include accessible units and features, including permanent supportive housing.

To increase the number of accessible units for individuals with disabilities who require housing accessibility modifications to use and enjoy their dwelling, both the City and the County fund rehabilitation/barrier removal programs. These programs are limited to homeowners, and homeowners must have owned the homes for a minimum of two years to receive assistance. The City and County will explore revising the

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policies for these programs to address barriers that prevent otherwise eligible applicants from participating. Potential actions include reducing or eliminating the minimum time the applicant must own the home to receive assistance and making funds available for modifications to privately-owned rental housing. Landlords are required to permit reasonable modifications to a housing unit at the recipient’s expense, but where the cost of the modifications is prohibitive to the tenant, the City and County may provide assistance to make those units accessible to persons with disabilities and their families.

In addition to increasing the supply of affordable, accessible housing units, there needs to be increase in the provision of supportive services for persons with disabilities who are able to, and choose to live independently. There are several agencies that provide supportive services in the City and County. However, the lead agency in Florida providing persons with disabilities with housing and supportive services, Florida Agency for Persons with Disabilities (ADP), has a statewide waiting list of over 20,000 individuals which affects persons with independent living difficulties in the City and the County. Medicaid is the main source of funding available to provide one-on-one care for persons outside of institutional settings and the deficient funding of Medicaid services has resulted in thousands of persons with disabilities who do not have the support needed to live in residential settings that is the least restrictive. To address this issue, the City and the County should assign a taskforce or committee to assess the need for supportive services. The taskforce should assess existing supportive housing programs, the cost of these services, and funding constraints. The City and County should develop a plan to assist individuals with disabilities with receiving community- based services, improve coordination between housing and disability service agencies, remove any programmatic barriers that prevent individuals with disabilities from accessing mainstream housing, and fund programs that help special needs populations meet their housing needs, such as tenant-based rental assistance programs and supportive housing.

Another barrier to persons with disabilities accessing affordable housing is discrimination. Housing discrimination cases based on disability accounted for a significant portion of the complaints investigated by the fair housing enforcement agencies in the City and the County. Even with training and guidance for the public, developers, and landlords, there is still overt discrimination against persons with disabilities or refusal to make reasonable accommodations or modifications. To address this, the City’s ADA Coordinator and Office of Human Rights, and the County’s Equal Opportunity Administrator’s Office will continue to educate the public on ADA and reasonable accommodation law.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

3 Increase access to opportunity for Lack of local or regional cooperation Segregation/Integration City of Tampa persons residing in R/ECAPs or low opportunity areas Availability, type, frequency, reliability of R/ECAPs Hillsborough public transportation County

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Disparities in Access to Educational Attainment Opportunity Tampa Housing Authority Lack of private investments in specific Disproportionate Housing neighborhoods Needs

Lack of public resources for investment in Publicly Supported Housing specific neighborhoods, including services or amenities Metrics, Milestones, and Timeframe for Achievement: • Within 5 years, enhance coordination between local government agencies, Hillsborough County Public Schools (HCPS), Hillsborough Area Regional Transit Authority (HART), THA, and housing developers to ensure proper planning of growth areas to improve access to affordable housing, public transportation, and quality education.

• Within 5 years, increase access to transportation in rural and unincorporated Hillsborough County through enhanced coordination with HART in planning processes.

• Within 5 years, support education and employment training programs that are available to residents of low opportunity neighborhoods and provide employment, job readiness skills, job placement, and job counseling.

• Within 5 years, provide or support rental counseling programs that improve overall financial health of residents by improving financial literacy, credit standing, knowledge of tenant rights and affordable housing options, and money management skills to prevent delinquency or eviction. Discussion: The City is heavily segregated by race and ethnicity and members of the protected classes have lower incomes, higher unemployment rates, and higher poverty rates. County residents face similar challenges but to a lesser extent than the residents of the City in some cases. Improving fair housing choice and reversing segregation are essential to creating access to opportunity for everyone because where a person lives determines one’s access to a range of opportunities and impacts life outcomes around education, employment, health, and wealth.

The involvement (input and cooperation) of governmental agencies, community and business organizations, and other non-governmental entities, can greatly assist in the elimination of fair housing impediments in areas such as sales and rental of housing, lending, employment, education, social services, and transportation.

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Interdepartmental cooperation, communication, and coordination in planning and executing housing, transportation, education, and community services is key to transforming R/ECAPs and low-income areas into neighborhoods of opportunity with access to good schools, healthy foods, affordable and reliable transportation, and good jobs. The City and the County will work towards improving coordination of policies and procedures through existing boards and committees to remove barriers to accessing opportunity for members of the protected classes.

Transportation services are essential where employment opportunities are not located near lower-income housing and this AI shows the need to link job centers with lower income housing locations in the County. While HART has determined that it is fiscally unsound to provide service to rural parts of the County, the provision of public transportation services can improve access to jobs, training opportunities, and housing and community services for minorities, families with children, and persons with disabilities. As HART and other transportation agencies in the County consider options to make public transit more accessible to the broader area, the City and County housing departments should be involved in future transportation development and planning and prioritize linking job centers with lower income neighborhoods and with affordable housing developments. This includes, reaching out to education and transportation stakeholders during the development of Consolidated Plans and fair housing planning documents.

Given the educational attainment gap and relationship between racially concentrated areas of poverty and employment, minorities in the City and County experience higher unemployment rates than Whites. To address this, the City and the County will continue to fund public service and economic development activities and THA will continue to assist residents with identifying employment and training opportunities within the community. Potential public service activities that the City and County may fund include employment training to increase self-sufficiency, literacy, independent living skills, and job training; housing counseling for renters, homeowners, and/or potential homebuyers; assistance to microenterprises and for-profit businesses for job creation/retention; and capacity building for the non-profit organizations that will provide these services.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

4 Increase homeownership opportunities Lending discrimination Segregation/Integration City of Tampa and improve equal access to credit and financial services for minorities and low- Access to financial services R/ECAPs Hillsborough and moderate-income persons County Lack of private investments in specific Disparities in Access to neighborhoods Opportunity

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Tampa Housing Impediments to mobility Disproportionate Housing Authority Needs

Metrics, Milestones, and Timeframe for Achievement: • Within 1 year, establish a community reinvestment review committee, made up of appropriate City and County government departments and community-based organizations in the community and economic development field, to conduct an assessment of lenders’ performance, analyze the degree to which lenders are meeting community needs, and monitor reinvestment needs and CRA performance.

• Over the next 5 years, conduct an annual assessment of lenders’ performance in the County/region.

• Over the next 5 years, hold an annual public forum, with community-based organizations and leading banks in the region, to discuss bank performance in the City and County.

• Over the next 5 years, continue to utilize federal and state resources for homebuyer education and downpayment assistance programs.

• Within 5 years, increase the number of THA residents purchasing homes in high opportunity neighborhoods by encouraging participation in the FSS Homeownership Program.

Discussion: A review of HMDA data revealed that Black/African-American and Hispanic households in the County were denied home mortgage loans at a rate of 33.4% and 26.8% respectively, compared to a denial rate of 18.8% for Whites. Additionally, an analysis of bank branch locations coupled with input from the community, showed gaps in banking and financial services in minority areas. Racial and ethnic disparities in access to credit perpetuate racial segregation and limit access to opportunity and homeownership.

The goal is to improve conventional lending and banking service in neighborhoods that are underserved, especially for Blacks/African-Americans and Hispanics, by strengthening agreements with banks and other lending institutions subject to CRA. By taking the proposed actions, the City and County will ensure that private investments are expanded in low-and moderate-income areas. Equal access to credit will also stimulate economic growth.

The City and County will conduct meetings with the leading banks, financial regulators, community-based organizations, and other relevant stakeholders to present findings of lenders’ performance and encourage them to establish policies and guidelines to ensure fair lending practices. Specifically, the committee will review mortgage and small business lending, community development lending and investments, services such as branch locations and staffing, and philanthropic commitments. This can be accomplished at the annual regional Fair Housing 313

Symposium held during Fair Housing month (April) which the City and County are partners in planning. This convening may also involve discussions about the intersection of community development with other topics such as health, transportation, aging in community, and workforce development.

In addition to engaging financial institutions to increase home purchase loans to LMI households, the City and the County will continue to provide homebuyer education, fair housing workshops, and downpayment assistance programs. THA can collaborate with the City and County using existing purchase assistance programs to increase the homeownership rate of THA residents.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

5 Increase awareness of Federal, state, Lack of awareness about fair housing laws Fair Housing Enforcement, City of Tampa and local fair housing laws and practices and enforcement programs Outreach Capacity, and Resources Hillsborough Admissions and occupancy policies and County procedures, including preferences in Publicly Supported Housing publicly supported housing Tampa Housing Authority

Metrics, Milestones, and Timeframe for Achievement: • Within 1 year, review existing fair housing outreach and education efforts and ensure materials include new HUD guidance and rules on criminal background checks, victims of domestic violence and sexual assault, gender identity, and NIMBY concerns related to fair housing.

• Over the next 5 years, conduct an annual forum to educate landlords and lenders on various sources of income and programs for affordable housing to ease landlord and lender concerns related to source of income.

• Over the next 5 years, continue to implement fair housing awareness programs on an on-going basis in both the City and the County and participate in regular education and outreach efforts by providing training /workshops on fair housing-related topics.

• Within 1 year, THA will post information and include information in all relevant documents on how residents can file housing discrimination cases locally.

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Discussion: There is a lack of understanding by the public about the role housing discrimination plays in the inequalities that are evident in the City and County as well as a lack of awareness of how to overcome discriminatory practices.

Private fair housing organizations and government agencies and programs make up the framework that tackle housing discrimination and the City and County. Both the City and County will continue to provide public education regarding the protection under local and federal fair housing laws. This will involve the development of new material for outreach and education, and information programs and activities in collaboration with other fair housing organizations in the region on new protections and changes/clarification in HUD policy.

THA staff and housing counselors will continue to attend periodic fair housing training to stay informed of current policies. Additionally, THA will assess and disclose any fair housing complaints involving the housing authority and assess the effectiveness of new or revised procedures on how public housing residents can make fair housing complaints to the City, County, or local fair housing organizations.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

6 Increase potential for minorities, Lack of state or local fair housing laws Segregation/Integration City of Tampa persons with disabilities, and other protected groups to move to areas of Private discrimination R/ECAPs Hillsborough high opportunity County Source of income discrimination Disparities in Access to Opportunity Tampa Housing Impediments to mobility Authority Disproportionate Housing Needs

Publicly Supported Housing

Fair Housing Enforcement, Outreach Capacity, and Resources

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Metrics, Milestones, and Timeframe for Achievement: • Within 1 year, propose a local fair housing ordinance to prohibit discrimination based on source of income to improve access to opportunity for voucher holders.

• Within 5 years, THA will enhance its mobility counseling program, to include support for Section 8 voucher holders as well as participants in the FSS Homeownership Program. Discussion: The disproportionate representation of protected classes in public housing and the Section 8 HCV program indicate a lack of affordable housing options for these households in the private sector as well as private discrimination. There is a reluctance by landlords to rent to persons utilizing housing vouchers in the City and County. This discrimination keeps minority households within R/ECAPs thereby intensifying racial segregation and limiting access to opportunity.

Currently, source of income is not protected under federal or local fair housing law. Local fair housing agencies have only been able to pursue these discrimination cases based on race/ethnicity because of the demographic composition of participants in the HCV program. However, by amending the local fair housing ordinances to prohibit housing discrimination based on source of income, it will be unlawful to refuse to rent based on a household’s source of income including housing choice vouchers, disability payments, and other public subsidies. Once adopted, the City, County, and THA should educate voucher holders about source of income protections and provide them with accurate information about what to do it they experience it.

THA will continue to follow its deconcentrating policy and work towards removing other impediments to mobility. THA’s mobility counseling program seeks to increase the housing choice of Section 8 voucher holders by assisting voucher holders to find suitable rental units throughout the City and County and extending the lease up period allowed to voucher holders that have encountered difficulty finding an available unit, due to low vacancy rates or discrimination, to prevent voucher holders from losing their vouchers. THA will also enhance the mobility counseling program to provide assistance to public housing residents and voucher holders who experience discrimination when attempting to purchase a home. THA will collaborate with the City, County, and member banks to support the FSS program.

# Goal Contributing Factors Fair Housing Issues Responsible Program Participant(s)

7 Increase public investment and Lack of private investments in specific Segregation/Integration City of Tampa encourage private investment to neighborhoods address disparities in housing, proficient R/ECAPs 316

schools, employment opportunities, and Lack of public resources for investment in Hillsborough services specific neighborhoods, including services Disparities in Access to County and amenities Opportunity Tampa Housing Disproportionate Housing Authority Needs

Publicly Supported Housing

Metrics, Milestones, and Timeframe for Achievement: • Over the next 5 years, develop/review community redevelopment plans for neighborhoods in R/ECAPs to coordinate investments in the area and attract private investment, strengthen educational attainment, emphasize economic development, and financial institution engagement.

• Over the next 5 years, continue to allocate CDBG funding for public facilities and infrastructure improvements, economic development, and public services in R/ECAPs and low-income areas. Discussion: In order to revitalize neighborhoods and attract private invest, the City and County must develop a comprehensive redevelopment strategy that promotes coordination and cooperation among the public and private sectors in carrying out housing and community development activities. This includes Consolidated Planning, Comprehensive Planning, neighborhood planning documents, and plans for other types of place-based investment strategies or programs. Without sufficient public and private investment in declining and deteriorated neighborhoods, residential areas decline rapidly and small, neighborhood businesses also suffer. The lack of investment means the absence of jobs, inadequate schools and services, and limited opportunity.

Federal and state programs, including CDBG, can be used for a broad range of community development programs and HOME funds towards to the provision of affordable housing. However, one of the most important factors in addressing distressed communities is the presence of residential and commercial investment by banks and other financial institutions in low-income and minority neighborhoods. The City and County can also offer incentives for housing developers, businesses, investors, and other interested entities to assist in the revitalization effort.

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VI. Appendices

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APPENDIX A – List of Acronyms

Acronym Meaning ABE Adult Basic Education ACS American Community Survey ADA Americans with Disabilities Act ADU Accessory Dwelling Unit AFFH Affirmatively Furthering Fair Housing AFFHT Affirmatively Furthering Fair Housing Tool AFH Assessment of Fair Housing AHAB Affordable Housing Advisory Board AHAC Affordable Housing Advisory Committee AHS Hillsborough County Affordable Housing Services AI Analysis of Impediments to Fair Housing Choice AMI Area Median Income BALS Bay Area Legal Services, Inc. CAPER Consolidated Annual Performance and Evaluation Report CBSA Core Based Statistical Area CDBG Community Development Block Grant CDC Community Development Corporation CHAS Comprehensive Housing Affordability Strategy CHDO Community Housing Development Organization CNG Compressed Natural Gas CPD HUD Office of Community Planning and Development CRA Community Redevelopment Agency CRA Community Redevelopment Area Community Reinvestment Act (for information purposes only - the acronym CRA is not CRA used to refer to the Community Reinvestment Act in this document) DOAH Florida Division of Administrative Hearings DPN Disability Program Navigator ELI Extremely Low-Income 319

EOA Hillsborough County Equal Opportunity Administrator's Office EPA U.S. Environmental Protection Agency ESG Emergency Solutions Grant FAAST Florida Alliance for Assistive Services and Technology FCHR Florida Commission on Human Relations FDIC Federal Deposit Insurance Corporation FHA Fair Housing Act Federal Housing Administration (for information purposes only - the acronym FHA is FHA not used to refer to the Federal Housing Administration in this document) FHAP HUD Fair Housing Assistance Program FHEO HUD Office of Fair Housing and Equal Opportunity FHIP HUD Fair Housing Initiatives Program FSS Family Self-Sufficiency Program GED General Equivalency Diploma GLS Gulfcoast Legal Services GPS Global Positioning System HART Hillsborough Area Regional Transit Authority HCBS Medicaid Home & Community-Based Services Waiver HCD City of Tampa Housing and Community Development Division HCPS Hillsborough County Public Schools HCV Housing Choice Voucher (also known as Section 8 voucher) HEA Housing and Education Alliance HMDA Home Mortgage Disclosure Act HOME HOME Investment Partnerships Program (usually referred to as "HOME") Refers to a HUD program that provided funds for demolition and redevelopment of HOPE VI severely distressed public housing sites HOPWA Housing Opportunities for Persons With AIDS Health Resources and Services Administration (an agency of the U.S. Department of HRSA Health and Human Services) HUD U.S. Department of Housing and Urban Development iCDC iConsumer Directed Care

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IMU Index of Medical Underservice LEP Limited English Proficiency LGBTQ Lesbian, Gay, Bisexual, Transgender, Queer LHAP Local Housing Assistance Plan LI Low-Income LIHTC Low Income Housing Tax Credit LMI Low- and Moderate-Income LMIT Low- and Moderate-Income [Census] Tracts MAP Mortgage Assistance Program MINT Middle-Income [Census] Tracts MSA Metropolitan Statistical Area MUA Medically Underserved Area MUI Middle- and Upper-Income NAACP National Association for the Advancement of Colored People NCRC National Community Reinvestment Coalition NIMBY “Not In My Back Yard” NSA Negotiated Settlement Agreement NSP Neighborhood Stabilization Program PHA Public Housing Authority PSTA Pinellas Suncoast Transit Authority R/ECAP Racially/Ethnically Concentrated Area of Poverty RAB Resident Advisory Board RAD Rental Assistance Demonstration ROSS Resident Opportunity for Self-Sufficiency SAIL State Apartment Incentive Loan SHIP State Housing Initiatives Partnership SSDI Social Security Disability Insurance SSI Supplemental Security Income SSNOP Sulphur Springs Neighborhood of Promise

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TDD Telecommunications Device for the Deaf TECO Tampa Electric THA Tampa Housing Authority THHI Tampa Hillsborough Homeless Initiative TOHR Tampa Office of Human Rights TRF The Reinvestment Fund ULAC League of United Latin American Citizens USDA U.S. Department of Agriculture U.S. Department of Veterans Affairs (acronym is also used to refer to VA medical VA centers and other VA offices) VLI Very Low-Income

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APPENDIX B – Glossary of Terms

Accessible A dwelling unit or facility is located on an accessible route and when designed, constructed, altered or adapted can be approached, entered, and used by individuals with physical disabilities.

Accessory Dwelling A residential unit that is secondary to the primary residence of the Unit (ADU) homeowner. It can be an apartment within the primary residence or it can be an attached or freestanding home on the same lot as the primary residence. Affirmatively The federal Fair Housing Act requires federal agencies and federal grantees, Furthering Fair including recipients of HUD Community Planning & Development (CPD) Housing (AFFH) funds, to affirmatively further fair housing. According to HUD's AFFH rule, this means "taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics."

Affordable Housing Generally speaking, housing is considered affordable if it costs no more than 30% of a household's gross income. Costs such as utilities, mortgage insurance, and homeowners or condominium association fees are included when determining if housing costs are affordable. The term "affordable housing" is also commonly used to refer to housing that receives public subsidy to reduce the cost for low- and moderate-income households, whether the housing itself is publicly or privately owned.

Analysis of A document that analyzes impediments to fair housing choice in a Impediments to Fair community and proposes goals to address these impediments, in Housing Choice (AI) accordance with input from community residents and stakeholders. Recipients of HUD Community Planning & Development (CPD) funds have been required to prepare AIs since the 1990s. Area Median Income Median annual household income (pre-tax) for a metropolitan area, (AMI) subarea of a metropolitan area, or non-metropolitan county.

Assessment of Fair A document that analyzes barriers to fair housing choice in a community Housing (AFH) and proposes goals to address these barriers, in accordance with input from community residents and stakeholders. Recipients of HUD Community Planning & Development (CPD) funds and Public Housing Authorities (PHAs) were required under HUD's new AFFH Rule, issued in 2015, to prepare an AFH at least every five years.

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Community Housing A community-based nonprofit organization that is involved in providing Development affordable housing and meets HOME program requirements for Board of Organization (CHDO) Directors composition, experience, and organizational capacity. Jurisdictions that receive HOME funds from HUD ("Participating Jurisdictions" or PJs) must set aside at least 15% of their HOME allocation certain activities to be conducted by organizations that qualify as CHDOs, as determined by the PJ.

Community A local public entity created by a County or municipality government, with Redevelopment board members appointed by that government body. A CRA has certain Agency (CRA) powers related to redevelopment, including designating slum or blighted areas as Community Redevelopment Areas, developing community redevelopment plans for these areas, using Tax Increment Financing to fund redevelopment, and exercising eminent domain in Community Redevelopment Areas.

Core Based Statistical A CBSA consists of the county or counties associated with at least one core Area (CBSA) (urbanized area or urban cluster) with a population of at least 10,000, plus adjacent counties having a high degree of social and economic integration with the core as measured through commuting ties with the counties associated with the core.

Disabled Household A household composed of one or more persons, at least one of whom is an adult (a person of at least 18 years of age) who has a disability. A person shall be considered to have a disability if that person is determined to have a physical, mental, or emotional impairment that: • Is expected to be of long-continued and indefinite duration • Substantially impeded his or her ability to live independently • Is of such a nature that the ability could be improved by more suitable housing conditions. Elderly Household A one or two-person household in which the head of household or spouse is at least 62 years of age.

Extremely Low- Household is at or below 30% of the Area Median Income (AMI) for Income (ELI) households of the same size.

Fair Housing Act The federal Fair Housing Act was initially passed in 1968, and prohibited housing discrimination on the basis of race, color, religion, or national origin ("protected classes"). Subsequent amendments to the Fair Housing Act have added sex, familial status, and disability to the list of protected classes. The Fair Housing Act prohibits activities such as refusing to rent or sell housing on the basis of a protected class, as well as steering renters and homebuyers to certain neighborhoods or offering them higher prices or less favorable terms than other clients.

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Fair Housing A HUD program that provides noncompetitive funding annually on a Assistance Program noncompetitive basis to state and local agencies that enforce fair housing (FHAP) laws that HUD has determined to be substantially equivalent to the federal Fair Housing Act. These agencies investigate and enforce complaints of housing discrimination that arise within their jurisdiction.

Fair Housing Choice Fair housing choice means that individuals and families have the information, opportunity, and options to live where they choose without unlawful discrimination and other barriers related to race, color, religion, sex, familial status, national origin, or disability. Fair housing choice encompasses: 1. Actual choice, which means the existence of realistic housing options; 2. Protected choice, which means housing that can be accessed without discrimination; and 3. Enabled choice, which means realistic access to sufficient information regarding options so that any choice is informed. For persons with disabilities, fair housing choice and access to opportunity include access to accessible housing and housing in the most integrated setting appropriate to an individual’s needs as required under Federal civil rights law, including disability-related services that an individual needs to live in such housing.

Fair Housing A HUD program that provides funding on a competitive basis to fair housing Initiatives Program organizations and other nonprofits to help connect people who have (FHIP) experienced housing discrimination with government agencies that handle complaints of housing discrimination. FHIP grantee organizations also conduct preliminary investigation of claims. Familial Status Familial status refers to whether a household has children under 18 or anticipated (unborn) children. Familial status is a protected class under fair housing law, meaning that housing providers cannot discriminate against renters and homebuyers based on the presence or anticipated presence of children in their household.

HOME Investment The HOME Investment Partnership Program, which is authorized by Title II Partnership Program of the National Affordable Housing Act. (HOME) Limited English A person's ability to speak English, as reported to the U.S. Census Bureau, is Proficiency (LEP) less than "very well."

Low- and Moderate- In the context of Home Mortgage Disclosure Act (HMDA) data, LMI refers to Income (LMI) a mortgage applicant whose household income is <50% of Area Median Income (AMI) (low-income) or between 50% and <80% AMI (moderate- income). Note that the definitions of "low- and moderate-income" for LMI mortgage applicants are different from the definitions used in other contexts in this report.

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Low- and Moderate- In Home Mortgage Disclosure Act (HMDA) data, LMIT refers to Census tracts Income Census Tracts where the Median Family Income is <50% of Area Median Income (AMI) (LMITs) (low-income) or between 50% and <80% AMI (moderate-income). Note that the definitions of "low- and moderate-income" for LMITs are different from the definitions used in other contexts in this report.

Low-Income (LI) Households whose incomes do not exceed 80 percent of the median family income for the area, as determined by HUD with adjustments for family size. HUD income limits are updated annually.

Medically An area designated by the U.S. Health Resources and Services Underserved Area Administration (HRSA) as having too few primary care providers, high infant (MUA) mortality, high poverty or a high elderly population.

Metropolitan A Core-Based Statistical Area (CBSA) associated with at least one urbanized Statistical Area (MSA) area that has a population of at least 50,000. The metropolitan statistical area comprises the central county or counties containing the core, plus adjacent outlying counties having a high degree of social and economic integration with the central county or counties as measured through commuting.

Middle- and Upper- In the context of Home Mortgage Disclosure Act (HMDA) data, MUI refers Income (MUI) to a mortgage applicant whose household income is between 80% and <120% of Area Median Income (AMI) (middle-income) or 120% AMI or higher (middle-income). Note that the income range defined as "middle- income" for MUI mortgage applicants is referred to as "moderate-income" in other contexts in this report.

Middle-Income In Home Mortgage Disclosure Act (HMDA) data, MINT refers to Census Census Tracts tracts where the Median Family Income is between 80% and <120% AMI (MINTs) (middle-income). Note that this income range is defined as moderate- income in other contexts in this report. Moderate-Income In this report and in most Florida housing programs, a low-income household is one whose income is greater than 80% of the Area Median Income (AMI) but no higher than 120% AMI for households of the same size.

Not In My Back Yard A phenomenon where residents of a neighborhood resist the development (NIMBY) of new land uses in their neighborhood that are considered undesirable. Proposed affordable housing developments often face NIMBY resistance based on stereotypes about affordable housing and its inhabitants.

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Protected Class A protected class (or protected group) is a demographic designation on which basis it is illegal to discriminate in the housing market. Protected classes under federal and Florida law include race, color, religion, national origin, sex, familial status, and disability. The City of Tampa and Hillsborough County have fair housing ordinances that include sexual orientation and gender identity or expression as protected classes, and the City of Tampa's fair housing ordinance also includes marital status and age as protected classes. (Note that, from a legal standpoint, a person with a disability is considered a member of a protected class, but a person without a disability is not. As a result, it is legal to set aside housing units for people with disabilities in certain developments.)

Racially/Ethnically The HUD AFFH Rule defines a R/ECAP as “a geographic area with significant Concentrated Area of concentrations of poverty and minority concentrations.” An area is defined Poverty (R/ECAP) by HUD as a R/ECAP if its population is at least 50% non-White and it has a poverty rate that exceeds 40% or is three or more times the average tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

Section 8 Housing The federal government’s major program for assisting very low-income Choice Voucher families, the elderly and the disabled to afford decent, safe, and sanitary Program housing in the private market. Participants receive a voucher to find their own housing, including single-family homes, townhouses and apartments. Housing choice vouchers are administered locally by public housing agencies (PHAs). The PHAs receive federal funds from the U.S. Department of Housing and Urban Development (HUD) to administer the voucher program. Very Low-Income In this report and in most federal and Florida housing programs, a very low- (VLI) income household is one whose income is at or below 50% of the Area Median Income (AMI) for households of the same size.

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APPENDIX C – Contributing Factors Descriptions

Access to financial services (Disparities in Access to Opportunity) The term “financial services” refers here to economic services provided by a range of quality organizations that manage money, including credit unions, banks, credit card companies, and insurance companies. These services would also include access to credit financing for mortgages, home equity, and home repair loans. Access to these services includes physical access - often dictated by the location of banks or other physical infrastructure - as well as the ability to obtain credit, insurance or other key financial services. Access may also include equitable treatment in receiving financial services, including equal provision of information and equal access to mortgage modifications. For purposes of this contributing factor, financial services do not include predatory lending including predatory foreclosure practices, storefront check cashing, payday loan services, and similar services. Gaps in banking services can make residents vulnerable to these types of predatory lending practices, and lack of access to quality banking and financial services may jeopardize an individual’s credit and the overall sustainability of homeownership and wealth accumulation.

Access to publicly supported housing for persons with disabilities (Disability and Access) The lack of a sufficient number of accessible units or lack of access to key programs and services poses barriers to individuals with disabilities seeking to live in publicly supported housing. For purposes of this assessment, publicly supported housing refers to housing units that are subsidized by federal, state, or local entities. “Accessible housing” refers to housing that accords individuals with disabilities equal opportunity to use and enjoy a dwelling. The concept of “access” here includes physical access for individuals with different types of disabilities (for example, ramps and other accessibility features for individuals with physical mobility impairments, visual alarms and signals for individuals who are deaf or hard of hearing, and audio signals, accessible signage, and other accessibility features for individuals who are blind or have low vision), as well as the provision of auxiliary aids and services to provide effective communication for individuals who are deaf or hard of hearing, are blind or have low vision, or individuals who have speech impairments. The concept of “access” here also includes programmatic access, which implicates such policies as application procedures, waitlist procedures, transfer procedures and reasonable accommodation procedures.

Access to transportation for persons with disabilities (Disability and Access) Individuals with disabilities may face unique barriers to accessing transportation, including both public and private transportation, such as buses, rail services, taxis, and para-transit. The term “access” in this context includes physical accessibility, policies, physical proximity, cost, safety, reliability, etc. It includes the lack of accessible bus stops, the failure to make audio announcements for persons who are blind or have low vision, and the denial of access to persons with service animals. The absence of or clustering of

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accessible transportation and other transportation barriers may limit the housing choice of individuals with disabilities.

Admissions and occupancy policies and procedures, including preferences in publicly supported housing (Publicly Supported Housing) The term “admissions and occupancy policies and procedures” refers here to the policies and procedures used by publicly supported housing providers that affect who lives in the housing, including policies and procedures related to marketing, advertising vacancies, applications, tenant selection, assignment, and maintained or terminated occupancy. Procedures that may relate to fair housing include, but are not limited to:

• Admissions preferences (e.g. residency preference, preferences for local workforce, etc.) • Application, admissions, and waitlist policies (e.g. in-person application requirements, rules regarding applicant acceptance or rejection of units, waitlist time limitations, first come first serve, waitlist maintenance, etc.). • Income thresholds for new admissions or for continued eligibility. • Designations of housing developments (or portions of developments) for the elderly and/or persons with disabilities. • Occupancy limits. • Housing providers’ policies for processing reasonable accommodations and modifications requests. • Credit policies. • Policies related to criminal records including arrests and convictions • Eviction policies and procedures.

Availability of affordable units in a range of sizes (Disproportionate Housing Needs) The provision of affordable housing is often important to individuals with certain protected characteristics because groups are disproportionately represented among those who would benefit from low-cost housing. What is “affordable” varies by circumstance, but an often used rule of thumb is that a low- or moderate-income family can afford to rent or buy a decent-quality dwelling without spending more than 30 percent of its income. This contributing factor refers to the availability of units that a low- or moderate- income family could rent or buy, including one-bedroom units and multi-bedroom units for larger families. When considering availability, consider transportation costs, school quality, and other important factors in housing choice. Whether affordable units are available with a greater number of bedrooms and in a range of different geographic locations may be a particular barrier facing families with children.

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Availability, type, frequency, and reliability of public transportation (Disparities in Access to Opportunity) Public transportation is shared passenger transport service available for use by the general public, including buses, light rail, and rapid transit. Public transportation includes paratransit services for persons with disabilities. The availability, type, frequency, and reliability of public transportation affect which households are connected to community assets and economic opportunities. Transportation policies that are premised upon the use of a personal vehicle may impact public transportation. “Availability” as used here includes geographic proximity, cost, safety and accessibility, as well as whether the transportation connects individuals to places they need to go such as jobs, schools, retail establishments, and healthcare. “Type” refers to method of transportation such as bus or rail. “Frequency” refers to the interval at which the transportation runs. “Reliability” includes such factors as an assessment of how often trips are late or delayed, the frequency of outages, and whether the transportation functions in inclement weather.

Community opposition (Segregation/Integration, R/ECAPs, Publicly Supported Housing) The opposition of community members to proposed or existing developments—including housing developments, affordable housing, publicly supported housing (including use of housing choice vouchers), multifamily housing, or housing for persons with disabilities—is often referred to as “Not in my Backyard,” or NIMBY-ism. This opposition is often expressed in protests, challenges to land-use requests or zoning waivers or variances, lobbying of decision-making bodies, or even harassment and intimidation. Community opposition can be based on factual concerns (concerns are concrete and not speculative, based on rational, demonstrable evidence, focused on measurable impact on a neighborhood) or can be based on biases (concerns are focused on stereotypes, prejudice, and anxiety about the new residents or the units in which they will live). Community opposition, when successful at blocking housing options, may limit or deny housing choice for individuals with certain protected characteristics.

Deteriorated and abandoned properties (R/ECAPS) The term “deteriorated and abandoned properties” refers here to residential and commercial properties unoccupied by an owner or a tenant, which are in disrepair, unsafe, or in arrears on real property taxes. Deteriorated and abandoned properties may be signs of a community’s distress and disinvestment and are often associated with crime, increased risk to health and welfare, plunging decreasing property values, and municipal costs. The presence of multiple unused or abandoned properties in a particular neighborhood may have resulted from mortgage or property tax foreclosures. The presence of such properties can raise serious health and safety concerns and may also affect the ability of homeowners with protected characteristics to access opportunity through the accumulation of home equity. Demolition without strategic revitalization and investment can result in further deterioration of already damaged neighborhoods.

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Displacement of residents due to economic pressures (Segregation/Integration, R/ECAPs, Disproportionate Housing Needs, Publicly Supported Housing)

The term “displacement” refers here to a resident’s undesired departure from a place where an individual has been living. “Economic pressures” may include, but are not limited to, rising rents, rising property taxes related to home prices, rehabilitation of existing structures, demolition of subsidized housing, loss of affordability restrictions, and public and private investments in neighborhoods. Such pressures can lead to loss of existing affordable housing in areas experiencing rapid economic growth and a resulting loss of access to opportunity assets for lower income families that previously lived there. Where displacement disproportionately affects persons with certain protected characteristic, the displacement of residents due to economic pressures may exacerbate patterns of residential segregation.

Impediments to mobility (Disparities in Access to Opportunity, Publicly Supported Housing) The term “impediments to mobility” refers here to barriers faced by individuals and families when attempting to move to a neighborhood or area of their choice, especially integrated areas and areas of opportunity. This refers to both Housing Choice Vouchers and other public and private housing options. Many factors may impede mobility, including, but not limited to:

• Lack of quality mobility counseling. Mobility counseling is designed to assist families in moving from high-poverty to low-poverty neighborhoods that have greater access to opportunity assets appropriate for each family (e.g. proficient schools for families with children or effective public transportation.). Mobility counseling can include a range of options including, assistance for families for “second moves” after they have accessed stable housing, and ongoing post-move support for families. • Lack of appropriate payment standards, including exception payment standards to the standard fair market rent (FMR). Because FMRs are generally set at the 40th percentile of the metropolitan- wide rent distribution, some of the most desirable neighborhoods do not have a significant number of units available in the FMR range. Exception payment standards are separate payment standard amounts within the basic range for a designated part of an FMR area. Small areas FMRs, which vary by zip code, may be used in the determination of potential exception payment standard levels to support a greater range of payment standards. • Jurisdictional fragmentation among multiple providers of publicly supported housing that serve single metropolitan areas and lack of regional cooperation mechanisms, including PHA jurisdictional limitations. • HCV portability issues that prevent a household from using a housing assistance voucher issued in one jurisdiction when moving to another jurisdiction where the program is administered by a different local PHA. • Lack of a consolidated waitlist for all assisted housing available in the metropolitan area. • Discrimination based on source of income, including SSDI, Housing Choice Vouchers, or other tenant-based rental assistance.

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• Lack of source of income protection or discrimination based on source of income, including SSDI, Housing Choice Vouchers, or other tenant-based rental assistance.

Lack of access to opportunity due to high housing costs (Disparities in Access to Opportunity, Disproportionate Housing Needs, Publicly Supported Housing, Disability and Access) Housing that affords access to opportunities, such as proficient schools, public transportation, employment centers, low poverty, and environmentally healthy neighborhoods may be cost prohibitive for low income persons, including those receiving assistance through the Housing Choice Voucher program. High costs can have a greater effect on families with children who need multiple bedrooms and individuals with disabilities who need accessible housing or housing located close to accessible transportation. Lack of strategies to overcome barriers imposed by housing costs can deny access to opportunity. Such strategies may include Small Area fair market rents (FMRs), exception payment standards, siting of Project-Based Vouchers, buying down affordability of existing rental housing using HOME or LIHTC, inclusionary zoning (including when combined with ongoing affordability at voucher payment standards or acceptance of vouchers), and use of LIHTC for new construction of affordable housing opportunities.

Lack of affordable, accessible housing in a range of unit sizes (Disability and Access) What is “affordable” varies by circumstance, but an often used rule of thumb is that a low- or moderate- income family can afford to rent or buy a decent-quality dwelling without spending more than 30 percent of its income. For purposes of this assessment, “accessible housing” refers to housing that accords individuals with disabilities equal opportunity to use and enjoy a dwelling. Characteristics that affect accessibility may include physical accessibility of units and public and common use areas of housing, as well as application procedures, such as first come first serve waitlists, inaccessible websites or other technology, denial of access to individuals with assistance animals, or lack of information about affordable accessible housing. The clustering of affordable, accessible housing with a range of unit sizes may also limit fair housing choice for individuals with disabilities.

Lack of affordable in-home or community-based supportive services (Disability and Access) The term “in-home or community-based supportive services” refers here to medical and other supportive services available for targeted populations, such as individuals with mental illnesses, cognitive or developmental disabilities, and/or physical disabilities in their own home or community (as opposed to in institutional settings). Such services include personal care, assistance with housekeeping, transportation, in-home meal service, integrated adult day services and other services (including, but not limited to, medical, social, education, transportation, housing, nutritional, therapeutic, behavioral, psychiatric, nursing, personal care, and respite). They also include assistance with activities of daily living such as bathing, dressing, eating, and using the toilet, shopping, managing money or medications, and various household management activities, such as doing laundry. Public entities must provide services to

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individuals with disabilities in community settings rather than institutions when: 1) such services are appropriate to the needs of the individual; 2) the affected persons do not oppose community-based treatment; and 3) community-based services can be reasonably accommodated, taking into account the resources available to the public entity and the needs of others who are receiving disability-related services from the entity. Assessing the cost and availability of these services is also an important consideration, including the role of state Medicaid agencies. The outreach of government entities around the availability of community supports to persons with disabilities in institutions may impact these individuals’ knowledge of such supports and their ability to transition to community-based settings.

Lack of affordable, integrated housing for individuals who need supportive services (Disability and Access) What is “affordable” varies by the circumstances affecting the individual, and includes the cost of housing and services taken together. Integrated housing is housing where individuals with disabilities can live and interact with persons without disabilities to the fullest extent possible. In its 1991 rulemaking implementing Title II of the ADA, the U.S. Department of Justice defined “the most integrated setting appropriate to the needs of qualified individuals with disabilities” as “a setting that enables individuals with disabilities to interact with nondisabled persons to the fullest extent possible.” By contrast, segregated settings are occupied exclusively or primarily by individuals with disabilities. Segregated settings sometimes have qualities of an institutional nature, including, but not limited to, regimentation in daily activities, lack of privacy or autonomy, policies limiting visitors, limits on individuals’ ability to engage freely in community activities and manage their own activities of daily living, or daytime activities primarily with other individuals with disabilities. For purposes of this tool “supportive services” means medical and other voluntary supportive services available for targeted populations groups, such as individuals with mental illnesses, intellectual or developmental disabilities, and/or physical disabilities, in their own home or community (as opposed to institutional settings). Such services may include personal care, assistance with housekeeping, transportation, in-home meal service, integrated adult day services and other services. They also include assistance with activities of daily living such as bathing, dressing, and using the toilet, shopping, managing money or medications, and various household management activities, such as doing laundry.

Lack of assistance for housing accessibility modifications (Disability and Access) The term “housing accessibility modification” refers here to structural changes made to existing premises, occupied or to be occupied by a person with a disability, in order to afford such person full enjoyment and use of the premises. Housing accessibility modifications can include structural changes to interiors and exteriors of dwellings and to common and public use areas. Under the Fair Housing Act, landlords are required by fair housing laws to permit certain reasonable modifications to a housing unit, but are not required to pay for the modification unless the housing provider is a recipient of Federal financial assistance and therefore subject to Section 504 of the Rehabilitation Act or is covered by the Americans with Disabilities Act (in such cases the recipient must pay for the structural modification as a reasonable accommodation for an individual with disabilities). However, the cost of these modifications can be 333

prohibitively expensive. Jurisdictions may consider establishing a modification fund to assist individuals with disabilities in paying for modifications or providing assistance to individuals applying for grants to pay for modifications.

Lack of assistance for transitioning from institutional settings to integrated housing (Disability and Access) The integration mandate of the ADA and Olmstead v. L.C., 527 U.S. 581 (1999) (Olmstead) compels states to offer community-based health care services and long-term services and supports for individuals with disabilities who can live successfully in housing with access to those services and supports. In practical terms, this means that states must find housing that enables them to assist individuals with disabilities to transition out of institutions and other segregated settings and into the most integrated setting appropriate to the needs of each individual with a disability. A critical consideration in each state is the range of housing options available in the community for individuals with disabilities and whether those options are largely limited to living with other individuals with disabilities, or whether those options include substantial opportunities for individuals with disabilities to live and interact with individuals without disabilities. For further information on the obligation to provide integrated housing opportunities, please refer to HUD’s Statement on the Role of Housing in Accomplishing the Goals of Olmstead, the U.S. Department of Justice’s Statement on Olmstead Enforcement, as well as the U.S. Department of Health and Human Services’ Centers for Medicare and Medicaid Services final rule and regulations regarding Home and Community-Based Setting requirements. Policies that perpetuate segregation may include: inadequate community-based services; reimbursement and other policies that make needed services unavailable to support individuals with disabilities in mainstream housing; conditioning access to housing on willingness to receive supportive services; incentivizing the development or rehabilitation of segregated settings. Policies or practices that promote community integration may include: the administration of long-term State or locally-funded tenant-based rental assistance programs; applying for funds under the Section 811 Project Rental Assistance Demonstration; implementing special population preferences in the HCV and other programs; incentivizing the development of integrated supportive housing through the LIHTC program; ordinances banning housing discrimination of the basis of source of income; coordination between housing and disability services agencies; increasing the availability of accessible public transportation.

Lack of local or regional cooperation (Segregation, R/ECAPs, Disparities in Opportunity, Publicly Supported Housing, Disability and Access) The term “local or regional cooperation” refers here to formal networks or coalitions of organizations, people, and entities working together to plan for local or regional development. Cooperation in local or regional planning can be a useful approach to coordinate responses to identified fair housing issues and contributing factors because fair housing issues and contributing factors not only cross multiple sectors— including housing, education, transportation, and commercial and economic development—but these issues are often not constrained by political-geographic boundaries. When there are local or regional patterns in segregation or R/ECAP, access to opportunity, disproportionate housing needs, or the

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concentration of affordable housing there may be a lack of local or regional cooperation and fair housing choice may be restricted.

Lack of private investment in specific neighborhoods (Segregation, R/ECAPs, Disparities in Opportunity, Disproportionate Housing Needs, Publicly Supported Housing) The term “private investment” refers here to investment by non-governmental entities, such as corporations, financial institutions, individuals, philanthropies, and non-profits, in housing and community development infrastructure. Private investment can be used as a tool to advance fair housing, through innovative strategies such as mixed-use developments, targeted investment, and public-private partnerships. Private investments may include, but are not limited to: housing construction or rehabilitation; investment in businesses; the creation of community amenities, such as recreational facilities and providing social services; and economic development of the neighborhoods that creates jobs and increase access to amenities such as grocery stores, pharmacies, and banks. It should be noted that investment solely in housing construction or rehabilitation in areas that lack other types of investment may perpetuate fair housing issues. While “private investment” may include many types of investment, to achieve fair housing outcomes such investments should be strategic and part of a comprehensive community development strategy.

Lack of public investment in specific neighborhoods, including services or amenities (Segregation, R/ECAPs, Disparities in Opportunity, Disproportionate Housing Needs, Publicly Supported Housing)

The term “public investment” refers here to the money government spends on housing and community development, including public facilities, infrastructure, and services. Services and amenities refer to services and amenities provided by local or state governments. These services often include sanitation, water, streets, schools, emergency services, social services, parks and transportation. Lack of or disparities in the provision of municipal and state services and amenities have an impact on housing choice and the quality of communities. Inequalities can include, but are not limited to disparity in physical infrastructure (such as whether or not roads are paved or sidewalks are provided and kept up); differences in access to water or sewer lines, trash pickup, or snow plowing. Amenities can include, but are not limited to recreational facilities, libraries, and parks. Variance in the comparative quality and array of municipal and state services across neighborhoods impacts fair housing choice.

Lack of resources for fair housing agencies and organizations (Fair Housing Enforcement, Outreach Capacity, and Resources Analysis) A lack of resources refers to insufficient resources for public or private organizations to conduct fair housing activities including testing, enforcement, coordination, advocacy, and awareness-raising. Fair housing testing has been particularly effective in advancing fair housing, but is rarely used today because of costs. Testing refers to the use of individuals who, without any bona fide intent to rent or purchase a home, apartment, or other dwelling, pose as prospective buyers or renters of real estate for the purpose of gathering information, which may indicate whether a housing provider is complying with fair housing

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laws. “Resources” as used in this factor can be either public or private funding or other resources. Consider also coordination mechanisms between different enforcement actors.

Lack of state or local fair housing laws (Fair Housing Enforcement, Outreach Capacity, and Resources Analysis) State and local fair housing laws are important to fair housing outcomes. Consider laws that are comparable or “substantially equivalent” to the Fair Housing Act or other relevant federal laws affecting fair housing laws, as well as those that include additional protections. Examples of state and local laws affecting fair housing include legislation banning source of income discrimination, protections for individuals based on sexual orientation, age, survivors of domestic violence, or other characteristics, mandates to construct affordable housing, and site selection policies. Though some states and local jurisdiction may have housing laws that are designed to protect survivors of domestic violence, many do not, which impedes their ability to access and maintain their current housing as well as quickly find safe alternative housing. Also consider changes to existing State or local fair housing laws, including the proposed repeal or dilution of such legislation.

Land use and zoning laws (Segregation, R/ECAPs, Disparities in Opportunity, Disproportionate Housing Needs, Publicly Supported Housing, Disability and Access) The term “land use and zoning laws” generally refers to regulation by State or local government of the use of land and buildings, including regulation of the types of activities that may be conducted, the density at which those activities may be performed, and the size, shape and location of buildings and other structures or amenities. Zoning and land use laws affect housing choice by determining where housing is built, what type of housing is built, who can live in that housing, and the cost and accessibility of the housing. Participants should consider the following examples of such laws and policies, and any other public policies that limit or promote the production of affordable housing:

• Limits on multi-unit developments, which may include outright bans on multi-unit developments or indirect limits such as height limits, limits on project scale and density, and minimum parking requirements. • Local nuisance ordinances designed to address the number of emergency services calls resulting from, for example, assault, harassment, stalking, disorderly conduct, and many other kinds of behavior, situations, or conditions that result in the need for emergency services, that result in loss of housing or limit fair housing choice for victims of crime or persons with disabilities. • Minimum lot sizes, which require residences to be located on a certain minimum sized area of land. • Occupancy restrictions, which regulate how many persons may occupy a property and, sometimes, the relationship between those persons (refer also to occupancy codes and restrictions for further information). • Lack of inclusionary zoning practices that mandate or incentivize the creation of affordable units.

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• Lack of support for development and preservation of affordable housing (may include efforts for neighborhood stabilization, green building, transit oriented development, and smart growth development) • Requirements for special use permits for all multifamily properties or multifamily properties serving individuals with disabilities, including group and nursing homes. • Growth management ordinances. • Provision of local financial resources, assistance with site selection, fee reductions or waivers for affordable housing, reduction of administrative delays. • Restrictions on manufactured housing. • Restriction or allowance of provision of services to persons experiencing homelessness, such as limiting transitional shelters, day shelters, soup kitchens, the provision of other services, or limitations on homeless persons’ access areas that are open to the public (e.g., anti-loitering or nuisance ordinances). • Restrictions on halfway houses, transitional housing, or other housing or programs for people leaving jails and prisons and reentering society. • Restrictions on group homes and foster care homes.

Lending Discrimination

(Segregation, R/ECAPs, Disparities in Opportunity, Disproportionate Housing Needs, Disability and Access) The term “lending discrimination” refers here to unequal treatment based on protected class in the receipt of financial services and in residential real estate related transactions. These services and transactions encompass a broad range of transactions, including but not limited to: the making or purchasing of loans or other financial assistance for purchasing, constructing, improving, repairing, or maintaining a dwelling, as well as the selling, brokering, or appraising or residential real estate property. Discrimination in these transaction includes, but is not limited to: refusal to make a mortgage loan or refinance a mortgage loan; refusal to provide information regarding loans or providing unequal information; imposing different terms or conditions on a loan, such as different interest rates, points, or fees; discriminating in appraising property; refusal to purchase a loan or set different terms or conditions for purchasing a loan; discrimination in providing other financial assistance for purchasing, constructing, improving, repairing, or maintaining a dwelling or other financial assistance secured by residential real estate; and discrimination in foreclosures and the maintenance of real estate owned properties.

Location of proficient schools and school assignment policies (Disparities in Opportunity) The geographic relationship of proficient schools to housing, and the policies that govern attendance, are important components of fair housing choice. The quality of schools is often a major factor in deciding where to live and school quality is also a key component of economic mobility. Relevant factors to consider include whether proficient schools are clustered in a portion of the jurisdiction or region, the range of housing opportunities close to proficient schools, and whether the jurisdiction has policies that enable students to attend a school of choice regardless of place of residence. Policies to consider include, 337

but are not limited to: inter-district transfer programs, limits on how many students from other areas a particular school will accept, and enrollment lotteries that do not provide access for the majority of children.

Location and type of affordable housing (Segregation/Integration, R/ECAPS, Disparities in Opportunity) Affordable housing includes, but is not limited to publicly supported housing; however, each category of publicly supported housing often serves different income-eligible populations at different levels of affordability. What is “affordable” varies by circumstance, but an often used rule of thumb is that a low- or moderate-income family can afford to rent or buy a decent-quality dwelling without spending more than 30 percent of its income. The location of housing encompasses the current location as well as past siting decisions. The location of affordable housing can limit fair housing choice, especially if the housing is located in segregated areas, R/ECAPs, or areas that lack access to opportunity. The type of housing (whether the housing primarily serves families with children, elderly persons, or persons with disabilities) can also limit housing choice, especially if certain types of affordable housing are located in segregated areas, R/ECAPs, or areas that lack access to opportunity, while other types of affordable housing are not. The provision of affordable housing is often important to individuals with protected characteristics because they are disproportionately represented among those that would benefit from low-cost housing.

Loss of Affordable Housing

(Segregation/Integration, R/ECAPs, Disparities in Access to Opportunity, Disproportionate Housing Needs, Publicly Supported Housing Location and Occupancy, Disability and Access) The loss of existing affordable housing can limit the housing choices and exacerbate fair housing issues affecting protected class groups. Affordable housing may be lost from the long-term stock due to deterioration, abandonment, or conversion to more expensive housing types, especially in sub-markets experiencing economic improvement. Buildings can leave the affordable inventory through owner opt outs from project-based Section 8 contracts, maturing long-term mortgages and expiration of use agreements (e.g. LIHTC at 15 or 30 years). Loss of this housing can affect multiple fair housing issues. For example, loss of affordable housing can lead to reduced access to areas with access to opportunity; displacement of protected class residents which may result in increased levels of segregation; a decrease in availability of affordable units resulting in disproportionate housing needs; or to disinvestment in segregated neighborhoods or R/ECAP communities. Potential efforts to prevent loss of existing affordable housing can include funding and indirect subsidies for rehabilitation and recapitalization to maintain physical structures, refinancing, renewal and extension of affordable use agreements, conversion to alternative subsidy types (e.g. Rental Assistance Demonstration), transfer of assistance to newer buildings or in alternative locations (e.g. PBRA Transfer Authority), and incentives for owners to maintain affordability (e.g. property tax abatement). Similarly, such efforts can also include addressing backlogs of repairs and maintaining the infrastructure of existing affordable housing, including publicly supported housing, such as through modernization or other improvements, when such efforts are part of concerted housing preservation and community revitalization efforts designed to affirmatively further fair housing.

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Efforts to prevent the loss of affordable housing can be part of a balanced approach to affirmatively further fair housing consistent with the Rule and HUD Guidance.

Private Discrimination (Segregation, R/ECAPs, Disparities in Opportunity) The term “private discrimination” refers here to discrimination in the private housing market that is illegal under the Fair Housing Act or related civil rights statutes. This may include, but is not limited to, discrimination by landlords, property managers, home sellers, real estate agents, lenders, homeowners’ associations, and condominium boards. Some examples of private discrimination may include: Refusal of housing providers to rent to individuals because of a protected characteristic.

• Refusal of housing providers to rent to individuals because of a protected characteristic. • The provision of disparate terms, conditions, or information related to the sale or rental of a dwelling to individuals with protected characteristics. • Steering of individuals with protected characteristics by a real estate agent to a particular neighborhood or area at the exclusion of other areas. • Failure to grant a reasonable accommodation or modification to persons with disabilities. • Prohibitions, restrictions, or limitations on the presence or activities of children within or around a dwelling. • Refusal to rent or termination of leases based on the application of a policy relating to criminal records (including arrest and conviction) or credit policies that limit access to housing or fair housing choice for members of protected class groups in a manner inconsistent with fair housing or civil rights laws. • Harassment in the form of quid pro quo harassment or hostile environment by a landlord, an owner, a property manager, other tenants, among others resulting in the loss of housing, limited access to housing or fair housing choice for members of protected class groups.

Useful references for the extent of private discrimination may be number and nature of complaints filed against housing providers in the jurisdiction, testing evidence, and unresolved violations of fair housing and civil rights laws.

Siting selection policies, practices and decisions for publicly supported housing, including discretionary aspects of Qualified Allocation Plans and other programs (Publicly Supported Housing) The term “siting selection” refers here to the placement of new publicly supported housing developments. Placement of new housing refers to new construction or acquisition with rehabilitation of previously unsubsidized housing. State and local policies, practices, and decisions can significantly affect the location of new publicly supported housing. Local policies, practices, and decisions that may influence where developments are sited include, but are not limited to, local funding approval processes, zoning and land use laws, local approval of LIHTC applications, and donations of land and other municipal contributions. For example, for LIHTC developments, the priorities and requirements set out in the governing Qualified

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Allocation Plan (QAP) influence where developments are located through significant provisions in QAPs such as local veto or support requirements and criteria and points awarded for project location.

Source of income discrimination (Segregation/Integration, R/ECAPs, Disparities in Opportunity, Disproportionate Housing Needs, Publicly Supported Housing, Disability and Access) The term “source of income discrimination” refers here to the refusal by a housing provider to accept tenants based on type of income. This type of discrimination often occurs against individuals receiving assistance payments such as Supplemental Security Income (SSI) or other disability income (such as SSDI), social security or other retirement income, or tenant-based rental assistance, including Housing Choice Vouchers. Source of income discrimination may significantly limit fair housing choice for individuals with certain protected characteristics. The elimination of source of income discrimination and the acceptance of payment for housing, regardless of source or type of income, or housing subsidy, increases fair housing choice and access to opportunity. Additionally, some jurisdictions have laws that protect against source of income discrimination and the acceptance of payment for housing regardless of the source or type of income. Having such legislation and enforcement of such legislation may increase fair housing choice and access to opportunity. Other efforts to increase fair housing choice could include outreach and actions to increase participation in the Housing Choice Voucher program. Examples of these outreach and actions may include, demonstrating effective business or administrative processes, such as expediting inspections or the use of innovative practices such as repair funds or security deposit assistance.

Some service areas require additional inspections, licenses, permits, paperwork, etc. for landlords hoping to rent to voucher holders. Some service areas also maintain stricter regulations on Section 8 landlords than market rate landlords or place restrictions on the number of vouchers that can be used in a given area.

State or local laws, policies, or practices that discourage individuals with disabilities from living in apartments, family homes, supportive housing and other integrated settings (Disability and Access) State and local laws, policies, or practices may discourage or prohibit individuals with disabilities from living in apartments, family homes, supportive housing and other integrated settings. Such laws, policies, or practices may include medical assistance or social service programs that require individuals to reside in institutional or other segregated settings in order to receive services, a lack of supportive services or affordable, accessible housing, or a lack of access to transportation, education, or jobs that would enable persons with disabilities to live in integrated, community-based settings.

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APPENDIX D – Summary of Fair Housing Survey Results

The City of Tampa, Hillsborough County, and Tampa Housing Authority hosted an online survey, which opened on September 19, 2016, and closed on January 27, 2017. There were separate questions for five types of respondents:

• Residents • Landlords and property managers (excluding public and nonprofit housing providers) • Real estate professionals • Lenders • Housing providers, social service providers, fair housing organizations, and civil servants A link to the survey was sent to over 2,000 persons. Additionally, the link to the survey was advertised on the City, County, and THA websites, and on flyers and posters in public places. Paper copies of the survey were also distributed by personnel from the Tampa Office of Human Rights and the County's Equal Opportunity Administrator's Office at events they attended, and by City, County, THA, and consultant staff responsible for seeking public input to the AI. The resident portion of the survey was offered in Spanish as well as English. Overall, the English and Spanish surveys received 811 and 14 responses, respectively. The figure below summarizes the number of English survey respondents in each category. Most respondents (647) were residents of Tampa or other parts of Hillsborough County, while social service providers, fair housing professionals, and civil servants were the next most common category (78). Of the Spanish survey respondents, 9 live in Tampa and 5 live in other communities in Hillsborough County. The responses to each question are summarized over the next few pages. Note that in some cases, questions are not discussed in the exact order that they appeared in the survey.

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Resident Responses

The survey had 414 respondents who identified themselves as residents of Tampa, and 233 who identified as residents of Hillsborough County. Demographics of Resident Respondents

The respondents are not perfectly representative of the City and County’s overall population, but they come from a fairly broad range of demographic and socioeconomic groups. Nearly three-quarters are racial or ethnic minorities and most are female and between the ages of 25 and 74. The respondents are widely distributed among different income brackets, and roughly equal proportions of respondents are married and single. About 2 in 5 respondents have children in their household, and 28% have a household member with a disability. Of the 129 respondents who speak a language other than English at home, Spanish is by far the most common language spoken.

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Gender Male 27.85% Female 72.15% Children under 18 years in household Yes 43.70% No 56.30% Household member with disability Yes 28.27% No 71.73% Languages other than English spoken at home Spanish 94.02% Creole 4.27% Chinese 1.71% All Spanish survey respondents are Hispanic. This group of respondents is fairly comparable to the English survey’s resident respondents in terms of age, gender, and marital status breakdown, as well as the presence of children in their households. Spanish survey respondents are skewed more toward low- and moderate- income brackets, and are less likely to have a household member with disabilities.

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Fair Housing Knowledge & Housing Discrimination Experiences and Responses

One set of questions for resident respondents addressed their knowledge of fair housing rights and their experiences, if any, with housing discrimination. Most English respondents (84%) believe they understand their fair housing rights, while only 57% of Spanish survey respondents feel they understand these rights. Most English respondents reported that they have not experienced discrimination in Tampa or Hillsborough County (77%), while those who felt they had experienced discrimination responded that they were most commonly discriminated against by a landlord or property manager (75%). Race and ethnicity was the most common basis for experiencing discrimination (17%), followed by color (7%), familial status (6%), and disability (5%). Question English Spanish Do you understand your fair housing rights? Yes 84% 57% No 7% 14% Not Sure 9% 29% Have you experienced housing discrimination in Tampa/ Hillsborough County? Yes 15% 0% No 77% 85% Not Sure 8% 15% If yes, did you file a report? Yes 2% 0% No 30% 22% N/A 68% 78%

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Residents were also asked to specify other reasons they may have experienced discrimination. One Black/African-American resident responded, “Stereotyping me because I receive Section 8,” another Black/African-American resident responded “Public assistance,” and one Native American resident responded that a homeowners’ association had discriminated against a group home for people with developmental disabilities. Most respondents who experienced discrimination did not file a report. The most common reason for not filing a report was that the respondent did not think it would help (64%), followed by uncertainty about where to file (27%). Some respondents also did not report because they did not know it was a violation of the law (16%) or were afraid of retaliation (18%). Notably, no Spanish survey respondents and only two 346

English survey respondents failed to report discrimination because the process was not in their native language. Despite the rarity of perceived instances of discrimination being reported by respondents, a majority of respondents (66%) indicated that they would report housing discrimination if they experienced it – including several respondents who had not reported perceived discrimination because they did not think it would help. The next largest group of respondents (17%) said they would not know what to do.

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When the data is broken down by certain groups, some variations emerge. Black/African-American respondents are slightly less likely than White respondents to feel that they understand their fair housing rights (83% vs. 87%), and respondents with a household member who has a disability are least likely to understand their fair housing rights (71%). On the other hand, Black/African-American respondents and those with disabled household members are among the most likely to have experienced discrimination (19% and 21%, respectively). Notably, of the 16 Hispanic respondents to the English survey question about why they did not report perceived discrimination, 44% indicated that they feared retaliation, a higher proportion than for other racial/ethnic groups. However, it is difficult to draw conclusions from such a small sample size. Another notable finding is that White respondents were equally likely to report experiencing discrimination on the basis or disability or race (10%). One White respondent who reported experiencing discrimination based on race noted that her significant other is African-American. However, for other White respondents who reported experiencing race-based discrimination, it is unclear whether their perceived experiences of discrimination based on race are accurate, or were based on some other characteristic and mistakenly perceived as racial discrimination. Household Selected Black/African- Hispanic/ Households All White Member has Questions American Latino with Children a Disability Do you feel you understand your fair housing rights? Yes 84% 83% 87% 87% 87% 71% No 7% 6% 8% 8% 7% 11% Not Sure 9% 12% 5% 5% 6% 18% Have you experienced discrimination? Yes 15% 19% 11% 10% 18% 21% No 77% 73% 85% 78% 75% 71% Not Sure 8% 8% 5% 12% 7% 8% Did you file a report? Yes 2% 3% 1% 2% 2% 5% No 30% 36% 27% 20% 32% 34% N/A 68% 61% 72% 77% 66% 61% Are your housing choices limited? Yes 31% 29% 29% 35% 35% 34% No 69% 71% 71% 65% 65% 66% Is affordable housing spread out/concentrated? Spread out 42% 43% 38% 45% 43% 37% Concentrated 58% 57% 62% 55% 57% 63% Are certain areas undesirable? Yes 68% 65% 78% 64% 71% 69% No 11% 14% 6% 14% 12% 8%

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Household Selected Black/African- Hispanic/ Households All White Member has Questions American Latino with Children a Disability Don't know 20% 21% 16% 23% 17% 23% What is your annual household income? <$10,000 to 24% 40% 18% 13% 17% 40% $14,999 $15,000 to 45% 35% 35% 65% 47% 38% $49,999 $50,000 to 31% 25% 48% 21% 36% 23% $100,000+ When asked what information sources they had encountered about fair housing in the City and County, nearly half of respondents selected “None.” However, substantial proportions had encountered the HUD Fair Housing and Equal Opportunity website (30%) and fair housing flyers or pamphlets (22%). Black/African- American respondents were more likely than White and Hispanic respondents to have encountered fair housing information (“None” responses of 37% and 53% and 57%, respectively).

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Perceptions of Housing Choice and Neighborhood Quality

About 3 in 10 respondents feel that their housing choices are restricted to certain neighborhoods, and Hispanic respondents and those with children in their household are most likely to view their choices as limited (35% each). When asked to specify the areas to which their housing choices are restricted, multiple respondents specified neighborhoods that have low to moderate White populations and/or moderate to high poverty rates, including Sulphur Springs, Temple Terrace, North Tampa, Brandon, East Tampa, West Tampa, Ybor City, and Carrollwood. Other respondents described the neighborhoods to which they were restricted in more broad terms, such as “low income,” “high crime,” “bad areas,” “inner city,” or areas they could afford. Some Black/African- American respondents explicitly stated that their race limits their housing choices. Notably, a few respondents (most of whom were not Black/African-American) indicated that they were restricted to better neighborhoods, presumably by their own needs and preferences.

• “Some areas are not safe enough, I look for a low crime area.” (White) • “Affordable, safe areas with high rated schools. Unfortunately, limited options are available without a lengthy commute.” (White)

• “Based on good schools.” (White) • “[Due] to the school assigned to the neighborhood/area.” (Hispanic) • “New Tampa, , South Tampa” (Asian/Pacific Islander) A majority of respondents (58%) also indicated that affordable housing options in Tampa and Hillsborough County are concentrated in certain neighborhoods rather than spread through the region. Many of the neighborhoods where respondents believe affordable housing is concentrated are the same neighborhoods to which some respondents said they were restricted. East Tampa and Sulphur Springs were the most commonly cited neighborhoods, and West Tampa, Riverview, Ruskin or South County, and Suitcase City (University of South Florida area) were among the other neighborhoods mentioned. White respondents were the only group to mention Seminole Heights, Apollo Beach, and Tampa Heights, and were more likely than Black/African-American respondents to mention Brandon or Riverview even though the latter respondent group was larger. Additionally, two White respondents stated that affordable homes are concentrated near bad schools. Several respondents across all racial/ethnic groups indicated that affordable housing is concentrated in low- income neighborhoods and “bad” or high-crime neighborhoods. Two respondents, one White and one Hispanic, specifically stated that affordable housing is concentrated in Black/African-American neighborhoods, while another Hispanic respondent answered “race.” Additionally, a few respondents stated that affordable housing options are located in remote areas, necessitating a long commute. One respondent specifically mentioned “South County (not accessible by public transportation).” A majority of respondents (68%) indicated that certain neighborhoods in the City or County are undesirable places in which to live. White respondents, respondents with children, and respondents with a disabled household member were more likely to view some neighborhoods as undesirable (78%, 71%, and 69%, 350

respectively) than were Black/African-American or Hispanic respondents (65% and 64%, respectively). Notably, White respondents and respondents with children are skewed toward higher income brackets ($50,000+), and therefore may be less likely to know from firsthand experience which neighborhoods are undesirable to live in. By contrast, Black/African-American respondents and those with a disabled household member are skewed toward low income brackets (<$15,000), and Hispanic respondents are primarily in low to moderate income brackets ($15,000 to $49,999). Similar to the previous two questions discussed, many of the neighborhoods mentioned as undesirable have higher poverty rates and percentages of racial and ethnic minorities. The specific neighborhoods that were mentioned most frequently, by residents of various races and ethnicities, include Sulphur Springs, East Tampa, the University Area, parts of Ybor City, and West Tampa. Several public housing developments were mentioned by name, including Robles Park, Belmont Heights, Jackson Heights, and North Boulevard Homes. Many respondents said that areas with high crime are undesirable, and several respondents indicated that low-income areas or areas with bad schools or substandard housing are undesirable. A few respondents indicated that neighborhoods without infrastructure and amenities such as sidewalks, lighting, and streetscaping are undesirable. Similar to the feedback about where affordable housing is concentrated, White respondents identified several undesirable areas that were not mentioned by Black/African-American respondents or (for the most part) Hispanic respondents. These areas include parts of Seminole Heights, Town ‘n’ Country, , parts of South Tampa, and Riverview.

Suggested Actions to Address Barriers to Fair Housing Choice

Residents were asked to identify actions that the City of Tampa and Hillsborough County should take to increase fair housing choice. Many responses identified a need for more affordable housing, particularly in high-opportunity neighborhoods. Several notable responses are excerpted below:

• “Build up some of the rough areas with affordable housing not condos/and [sic] overly priced areas.” (Black/African-American)

• “Congress needs to create incentives for private developers and banks to create affordable options for low income workers.” (Black/African-American)

• “Enforce more affordable rents in areas such as Citrus Park, Northdale and Carrollwood. The average rent in these areas is $1600-1800 per month for a 3 bedroom and $800/month or less in areas where crime and poor schools are located. We are forced to pay higher rent in order to live in a safe area with excellent schools (worth the sacrifice, but not financially savvy).” (Black/African-American)

• “Move low income homes deeper into the unincorporated areas of the county to spur development and provide us new opportunities. We are priced out of downtown/urban areas and are stifling development [sic].” (Black/African-American)

• “From what I have seen, it is not easy for city employees to live in the more desirable areas of the city due to financial constraints. If a policeman must live outside the city to live comfortably, we are

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continuing to require more funding for roads while less money is spent on reinvesting in and making neighborhoods desirable.” (White)

• “Zoning changes allowing boarding houses, bunk houses, and other affordable housing to be created from current structures.” (White)

• “Choice is often limited by rent prices. Encourage lower rents or set asides in ALL MF rental communities.” (White)

• “I live in a community that is being gentrified, and I worry that new development will eliminate affordable housing and push people like me out.” (Hispanic)

• “City of Tampa should always afford affordable housing because there are a lot of residents that get pay minimum salary [sic].” (Hispanic)

• “Clean, safe houses for all. Tampa was hit by housing crash and apts should make allowances for that especially downtown. If you have a good job but some housing setback you are stuck renting a house in Tampa heights with rodents.” (Other race) Other themes that arose repeatedly were a need for more fair housing enforcement and outreach, improved code enforcement and crackdowns on slumlords, and more housing opportunities for people with criminal records and other impediments in their backgrounds (such as past evictions). Additionally, several respondents expressed concerns about homeownership opportunities for low-income households and first- time homebuyers, affordable housing needs specifically for seniors and people with disabilities, and a need for more public transportation and housing options closer to places of employment. Several respondents, many of whom are Hispanic, brought up needs for improvement in Tampa Housing Authority’s (THA’s) practices:

• “Use the Post office address verification system to make sure each applicant has a fair chance to receive important life changing information from Tampa Housing Authority or any agency before any wait list purge takes place. Due to the fact that data can be entered wrong when multiple wait list[s] are combine[d] to one. This is the #1 issue in Tampa and is the leading cause of homelessness in Tampa.” (Hispanic)

• “Tampa Housing Authority, needs to hire qualified, train, their officers, employees their own Grievances procedures/protocols, and Fair Housing Rights, Civil Rights and Executive Orders [sic].” (Hispanic)

• “Properties run by the housing authority should be run and maintained in a better fashion. There are residents and guests of residents running [amok] around complexes making them unsafe. Shootings, drugs being dealt day and night, even while management office is open. Trash everywhere, it is unfair for maintenance to have to clean after grown adults who leave trash, liquor bottles and beer cans everywhere. There are some people who actually care about where they live. What is the housing authority doing to better the environment in which we are living[?]” (Hispanic)

• “Make FSS more affordable for everyone who is trying so hard to become a first-time homeowner

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make it more easier [sic] or affordable.” (Black/African-American)

• “Easier access to low income housing, Section 8. Less waiting period [sic].” (White) A few respondents made suggestions that would not be in alignment with HUD grantees’ requirements to affirmatively further fair housing:

• “Stop forcing integration.” (White) • “Build housing projects, and confine the crime to those locations.” (Mixed-race)

Concluding Thoughts on Resident Responses

Few resident respondents, particularly Black/African-American respondents and those with children or persons with disabilities in their households, have experienced discrimination. Additionally, many respondents of different demographic groups raised concerns about issues that can have a disparate impact on certain protected classes, including a shortage of affordable housing and barriers to obtaining housing for people with criminal or eviction records.

While concerns about neighborhoods with crime, substandard housing, and poor schools are widespread among respondents of different races, they are most pronounced among White respondents, who are disproportionately high-income. White respondents, as a group, also have a broader list of neighborhoods that they think have affordable housing concentrations or are undesirable. Another notable result of the survey is that most Black/African respondents, who are mostly from low- and moderate-income brackets, do not express a sense of ability to access housing in desirable neighborhoods near good schools. Many Black/African-American respondents said that their housing choices are restricted by low income or discrimination, whereas several respondents of other races indicated that their choices are “restricted” to more desirable neighborhoods. One problematic finding of the resident survey is that many respondents seem to equate “low-income” or “affordable housing” with substandard housing for extremely poor residents in undesirable neighborhoods. This perception often fuels NIMBY (Not In My Back Yard) resistance to building affordable housing in high- opportunity neighborhoods, as well as resistance among landlords to accepting Housing Choice Vouchers. Additionally, some respondents appear to believe that a community’s affirmatively furthering fair housing efforts are only targeted to low-income residents.

• “[Undesirable areas are] in and around housing projects.” (White) • “[Undesirable areas include Sulphur] Springs, any area that has high crime, low income and Section 8 housing.” (Mixed-race)

• “There are more areas housing for family with income base [sic] not for the middle class we also need help, we need more help for single income.” (Race not specified)

• “Educate the public of options of programs and the law. Not only to low income groups.” (Hispanic)

• “Don’t quite understand how it is fair housing when a 1bdrm can cost over $1000.00. Because a person 353

is not on public assistance doesn’t mean they can afford that kind of rent. So you have to live in more undesirable locations within the city.” (Hispanic)

Mortgage Lender/Broker Responses

The survey respondents included only 18 mortgage lenders and brokers, so the ability to extrapolate these findings to all lenders and brokers in Tampa and Hillsborough County is limited.

Fair Housing Knowledge and Training

Most lenders (76%) consider themselves “Somewhat Knowledgeable” of fair housing laws, while the remaining 24% consider themselves “Very Knowledgeable.” Similarly, most lenders (76%) responded that they or their colleagues have received fair housing training. 56% and 31% of lenders reported that they or their colleagues received fair housing training 1 to 5 years ago and within the last year, respectively. Most lenders (77%) feel that adequate information and training on fair housing laws is available in Tampa and Hillsborough County, although one respondent expressed a desire for more public service announcements and suggested, “Use … examples to make the topic more prevalent [sic].” When asked the best way to communicate about fair housing issues with professionals in their field, the most commonly preferred methods were websites (57%) and in-person training sessions and conferences (50% each).

Business Practices that Promote Fair Housing

All lenders reported that their firms have written policies addressing fair housing laws. Additionally, most lenders reported that their firms hire bilingual staff to assist clients with poor English Skills (71%), provide mortgages for home purchases in low-income or high-minority neighborhoods (94%), have full-service branches in minority or low- to moderate-income neighborhoods (77%), market loan availability in minority neighborhoods and encourage minorities to apply in non-minority neighborhoods (71%), provide loans to first-time homebuyers participating in government or Government-Sponsored Enterprise (GSE) loan programs (88%), and are approved lenders for low- and moderate-income purchase assistance programs offered by the City of Tampa or Hillsborough County (81%). Moreover, no lenders reported having a client file a complaint against their firm. On the other hand, most lenders (71%) reported that their firms do not partner with any organization to provide homebuyer education to their clients. Additionally, a majority of lenders (62%) do not have marketing and outreach efforts that are targeted to minorities and low-income individuals. Most lenders whose firms provide mortgages in low-income or high-minority neighborhoods are unsure of what percentages of total loans are originated in these neighborhoods, but the estimates provided range from 5% to 20%. Among lenders whose firms provide loans to participants in low- and moderate-income first-time homebuyer programs, the most commonly cited programs are the State Housing Initiatives Partnership (SHIP) and Federal Housing Administration (FHA) loans. One lender noted that their firm has

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been an approved lender for the City of Tampa and Hillsborough County “off and on over the years but end of [sic] not using them because of their difficult process.”

Barriers to Homeownership and Fair Housing Choice

When mortgage lenders and brokers were asked why their firms deny mortgage applications, the most commonly cited reasons were inadequate credit and excessive debt-to-income ratio (94% each). The next most common reasons were insufficient down payment (47%) and insufficient income (41%). Lenders were also asked about the degree to which various factors constituted a barrier to fair housing choice, and their answers varied widely. The factors that lenders were most likely to view as serious barriers to fair housing choice include poor credit histories of some prospective homebuyers (44%), concentrations of affordable housing in certain areas (31%), and lack of knowledge among residents regarding fair housing (31%). An additional 31%, 25%, and 25% of lenders considered these respective factors to be moderate barriers, and 69% of lenders considered income levels of some prospective homebuyers to be a moderate barrier. Lack of knowledge among real estate agents regarding fair housing was considered a moderate barrier by 44% of lenders.

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The factors that lenders were most likely to rank as “Not a barrier” generally related to practices in the mortgage lending industry, such as “Lenders not disclosing the determination made by the private mortgage insurer” (67%) and “Lenders targeting subprime, high risk borrowers” (63%). However, 38% of lenders consider lack of knowledge among bankers and lenders regarding fair housing to be a moderate barrier. Lenders were most likely to respond “I do not know” to questions about land use issues, restrictive covenants, steering, discrimination from insurance agencies and home sellers, and rent-to-own programs. Relatively low percentages of lenders responded “I do not know” to questions about barriers related to their own industry and to borrowers. In response to additional questions about fair housing barriers, no lenders believed that Tampa or Hillsborough County has a problem with predatory lending. Two respondents commented on the need for affordable housing in the area, several others indicated a need for more public outreach and education.

Real Estate Professional Responses

Eight survey respondents identified themselves as real estate professionals, and only 7 proceeded with the survey after the first question. As a result, the responses to this portion of the survey are far from representative.

Fair Housing Knowledge and Training

Most real estate professionals (71%) consider themselves “Very Knowledgeable” of fair housing laws, while the remaining 29% consider themselves “Somewhat Knowledgeable.” Similarly, most real estate professionals (71%) responded that they or their colleagues have received fair housing training. 57% and 14% of real estate professionals reported that they or their colleagues received fair housing training within the last year and 1 to 5 years ago, respectively. A majority of real estate professionals (60%) feel that adequate information and training on fair housing laws is available in Tampa and Hillsborough County, although one respondent stated, “It would be helpful to mandate training for all realtors and practitioners in the industry.” When asked the best way to communicate about fair housing issues with professionals in their field, the most commonly preferred methods were in-person trainings (80%), conferences (60%), government publications and City and County public meetings (40% each).

Business Practices that Promote or Hinder Fair Housing

Most real estate professionals (86%) reported that their firms have written policies addressing fair housing laws. Additionally, most lenders reported that their firms have materials displayed to promote fair housing (86%), accept listings perceived to be affordable to lower income and minority families (80%), serve clients participating in homebuyer subsidy programs (71%), provide information to clients about purchase assistance programs (86%), and do not restrict the listings they accept to a niche market (71%). Additionally, a majority (67%) reported that their firms accept listings regardless of home value.

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On the other hand, most real estate professionals (71%) reported that their firms do not have targeted marketing and outreach efforts for minority and low-income clients, and a majority (57%) reported that their firms do not intentionally hire bilingual staff to assist clients with poor English skills. Real estate professionals had the option to comment on some of the questions described above. Of the two who responded that they only accept listings in niche markets, one indicated that their niche market includes minority and/or low- and moderate-income neighborhoods, while the other indicated that their niche market does not include such neighborhoods. One respondent whose firm hires bilingual individuals stated that their knowledge of other languages (including Spanish and Creole) was a plus but not a prerequisite for the position. Additionally, one respondent whose firm conducts marketing and outreach efforts to traditionally disadvantaged buyers indicated that the outreach efforts are based on income rather than ethnicity. The purchase assistance programs about which some respondents’ firms provide information to clients include the First Time Home Buyer program (presumably from the Florida Housing Finance Corporation, but not specified by any respondents), City and County down payment assistance programs, sweat equity and Section 8 homeownership programs, and several others provided by local and regional nonprofits. A majority of respondents (60%) have not had a client raise a housing discrimination complaint. One respondent who has received a complaint believes that it resulted from a miscommunication about available units with no discriminatory intent.

Barriers to Homeownership and Fair Housing Choice Real estate professionals were asked about the degree to which various factors constituted a barrier to fair housing choice. Due to a low response rate, the feedback from real estate professionals on these questions is limited. The few responses indicated that low income levels and poor credit histories of some prospective buyers, as well as concentrations of affordable housing in certain areas, are moderate to serious barriers. Lack of knowledge among real estate agents regarding fair housing was identified as a moderate barrier, and a shortage of land zoned for duplexes, townhomes, and multifamily housing was considered a minor barrier. Additionally, one respondent considered several practices by lenders and their partners to be a serious barrier, including offering prime rates to subprime customers, repeatedly inducing borrowers to refinance loans and charging high transaction fees, and using “neighborhood stability” or similar factors as proxies for a neighborhood’s racial/ethnic makeup in appraisals. Most real estate professionals who responded to the survey (80%) do not believe that predatory lending is a problem. The one respondent who believes it is a serious barrier commented, “Don’t know exactly but hear that all the time.” When asked what actions should be taken to address fair housing barrier, one respondent suggested financing and building more affordable housing, and another recommended both providing more fair housing education to the real estate industry and home sellers using the For Sale By Owner (FSBO) approach, and funding lobbyists to promote fair housing.

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Landlord/Property Manager Responses

The survey respondents included 27 landlords and property managers.

Properties Owned or Managed

Half of the landlord/property manager respondents own or manage 10 or fewer units, while another 33% own or manage over 75 units. The remaining 17% own or manage between 11 and 50 units. A majority of respondents (56%) reported that 76% or more of their 2-bedroom units rent for over $800 per month, while another 38% reported that no more than 10% of their 2-bedroom units have rents over $800. Most respondents (76%) reported that no more than 10% of their units are handicap accessible, and a further 18% reported that between 11% and 50% are handicap accessible. Among landlords or property managers with 10 or fewer units (“small landlords”), half of respondents reported that 10% or fewer of their units rent for $800, while the other half reported that 76% or more of their units rent for $800. Among landlords or property managers with over 75 units (“large landlords”), most (80%) reported that 76% or more of their units rent for more than $800.

Fair Housing Knowledge and Training A slight majority (53%) of respondents consider themselves “Very Knowledgeable” of fair housing laws, while 29% consider themselves “Somewhat Knowledgeable” and the remaining 18% consider themselves “Not Knowledgeable.” Similarly, 53% reported that they or their colleagues have received fair housing training. 31% reported that they or their colleagues have received such training within the past year, and 25% reported that they and their colleagues have received training between 1 and 5 years ago. Furthermore, most respondents (76%) are familiar with reasonable accommodation and modification requirements that apply when screening prospective tenants who have disabilities. Among small landlords, the breakdown of self-reported knowledge is similar to that of all landlord and property manager respondents, with a plurality (44%) of small landlords considering themselves “Very Knowledgeable.” By contrast, most large landlords (80%) consider themselves “Very Knowledgeable,” while the remaining 20% consider themselves “Somewhat Knowledgeable.” Fewer than half of the small landlords reported that they or their colleagues have received fair housing training, while all of the large landlords reported that they or their colleagues have received such training. Among small landlords who reported that they or their colleagues have received fair housing training, the training occurred between 1 and 5 years ago in most cases. Among large landlords who reported that they or their colleagues have received training, it usually occurred within the past year. A majority of all landlord and property manager respondents (65%) feel that adequate fair housing information and training is available. However, among small landlords, the percentage who feel that adequate fair housing resources are available was smaller (56%), while it was larger for large landlords (80%). When respondents were asked the preferred methods for communicating with landlords and property managers about fair housing issues, the most popular option was websites (53%), followed by in-person trainings and webinars (35% each).

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Business Practices that Promote or Hinder Fair Housing

A majority of respondents (67%) reported that their company has written policies addressing fair housing laws. The majority is smaller among small landlords (57%), while all large landlords report that their companies have written fair housing policies. Only 25% of all landlord and property manager respondents reported that their companies have marketing and outreach efforts targeted to minorities or low- and moderate-income persons. The share of respondents whose companies market to these groups is somewhat larger among small landlords than among large ones (33% vs. 20%). Among all landlord and property manager respondents, comparable percentages reported that they hire bilingual staff to help clients with poor English skills (35%), do not intentionally hire bilingual staff (29%), or that this is not applicable to them since they are a small landlord with no employees (35%). Large landlords are more likely than small ones to intentionally hire bilingual individuals (80% vs. 22%). When respondents were asked about the most common reasons for denying a prospective tenant’s application, the most common were insufficient income (63%) and past eviction (56%), although fairly high proportions deny on the basis of criminal record (50%) or poor credit history (44%). Compared to all respondents, small landlords are less likely to deny applicants based on criminal record (38%), while large landlords are less likely to deny based on poor credit history (20%). A majority of respondents (59%) accept Section 8 vouchers. Among those who refuse Section 8 vouchers, reasons include having the ability to fill vacancies using “conventional methods,” being unaware of Section 8, and a policy established by the respondent’s company. The first two reasons were given by small landlords, while the third reason was given by a large landlord. A majority of respondents (64%) reported that they or their firm provide information to clients who wish to file a housing discrimination complaint. Three respondents specified options given to clients who wish to file a complaint, which include referral to Hillsborough County or the HUD website, and provision of a grievance form for the tenant to complete and return to the landlord.

Barriers to Fair Housing Choice

Landlords and property managers were asked about the degree to which various factors constituted a barrier to fair housing choice. Due to a low response rate, the feedback from landlords and property managers on these questions is limited. The factor that respondents were most likely to consider a serious barrier was poor credit of some prospective tenants (63%). Additional barriers considered to be moderate to severe by several respondents include:

• Lack of fair housing knowledge among residents (83%) • Limitations on the number of occupants or of unrelated people living together (67%) • Housing providers placing certain tenants in the least desirable units in a development (50%) • Real estate agents directing renters to housing only in certain neighborhoods (50%) • Income levels of some prospective tenants (63%)

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Summary of Lender/Broker, Real Estate Professional, and Landlord/Property Manager Responses

Most of the respondents in these professions consider themselves “Very Knowledgeable” or “Somewhat Knowledgeable” of fair housing laws, and report that they or their colleagues have received fair housing training at some point in the last 5 years. Additionally, many of these respondents and their firms have several practices in place to promote fair housing, including having written fair housing policies, displaying written fair housing materials for clients, hiring bilingual staff, and providing services to minority and low- and moderate-income clients. As a group, real estate professionals are most confident of their fair housing knowledge, while mortgage lenders and brokers have the most practices in place to promote fair housing, including marketing loan availability in minority neighborhoods. Among landlords and property managers, there is a notable divide between those with 10 or fewer units (“small landlords”) and those with 76 or more units (“large landlords”). As a group, small landlords tend to have less fair housing knowledge and training, are less likely to have written fair housing policies, are somewhat less likely to agree that sufficient fair housing information and training is available in Tampa and Hillsborough County, and are less likely to employ bilingual staff—in part because many of them are small landlords with no employees. On the other hand, small landlords offer vital housing opportunities to low- and moderate-income residents. Compared to large landlords, they are more likely to offer lower-cost 2- bedroom units, market to minorities and low- and moderate-income persons, and rent to prospective tenants with criminal records. Additionally, small landlords may have more flexibility in accepting Section 8 vouchers than large landlords or property management firms. The most complete data on perceived barriers to fair housing choice comes from the mortgage lender and broker respondents. Notably, these respondents tended to rank income, credit, and other homebuyer characteristics as the most serious barriers to fair housing, while potentially problematic practices within their own industry were generally ranked as “Not a barrier.” Lender and broker respondents were generally less likely to know whether practices outside their industry constituted fair housing barriers. Similar to mortgage lenders and brokers, real estate professionals, landlords and property managers were also most likely to view client-level characteristics such as income and credit as serious fair housing barriers. Among all three respondent types, there was a fair amount of variation in responses about potential fair housing barriers, with “I don’t know” responses being fairly common. In the future, focus groups with these professionals might be more useful than surveys for evaluating potential fair housing barriers. Overall, the mortgage lenders and brokers, real estate professionals, and landlords and property managers in Tampa and Hillsborough County appear to make good-faith efforts to offer fair housing choice to their clients. Moreover, these respondents express an eagerness for fair housing information and training, and several raised the issue of the area’s affordable housing shortage. Nonetheless, they reported several practices that do not have discriminatory intent but may affect certain protected classes disproportionately, including screening out prospective clients for credit problems and, in the case of prospective tenants, criminal history. These practices are designed to protect the firms’ investments and public safety, and abide by standard underwriting criteria. However, there is debate among housing and civil rights professionals about the degree to which these restrictions are necessary to protect public safety and private investment. For 360

example, the 2016 State of Housing in Black America report from the National Association of Real Estate Brokers (NAREB) argues that credit scoring models are outdated and overly stringent in ways that disproportionately penalize Black/African-American borrowers. Additionally, in 2016, HUD issued guidance directing landlords and property managers to avoid overly stringent criminal background screening criteria that have a disparate fair housing impact on racial minorities.

Housing Providers, Social Services Providers, Fair Housing Organizations, and Civil Servants

Among the survey respondents, 11% were social service providers, fair housing organization employees, or civil servants, and 2.4% were housing providers.

Organizations Represented

Among social service providers, fair housing professionals, and civil servants, a wide range of prominent organizations in Tampa and Hillsborough County were represented. These included nonprofit organizations such as Boley Centers, ACTS, Catholic Charities, Tampa General Hospital, and Gracepoint, as well as public agencies such as the Hillsborough County Sheriff’s Office and Homeless Services Department, and the City of Tampa’s Housing & Community Development Department. Among those respondents who identified themselves as housing providers, the only organizations specified were Solita’s House, the Tampa Housing Authority, the East Tampa Business and Civic Association, and Florida Home Partnership, Inc.

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When asked about the primary populations that their organizations serve, each of the categories except “Other” was selected by 27% or more respondents. The most common categories were low-income individuals and families (77%), homeless individuals and families (61%), and persons with mental illness and veterans (53% each). The most commonly provided services are homeless assistance (82%), affordable housing (43%), and housing for persons with disabilities (32%).

Fair Housing Knowledge and Training

The majority of respondents (68%) consider themselves “Somewhat knowledgeable” of fair housing laws, while the next largest group (21%) consider themselves “Very knowledgeable.” However, 54% respondents who identified as housing providers are “Very knowledgeable,” while 75% of the other respondents (social service providers, etc.) are “Somewhat knowledgeable.” A modest majority of respondents (58%) reported that they or their colleagues have received fair housing training. However, among self-identified housing providers, the percentage is higher (83%). Among all respondents, 30% reported that they or their colleagues have received training in the past year, and another 25% reported that they or their colleagues received training between 1 and 5 years ago. However, self- identified social service providers, fair housing professionals, and civil servants were actually more likely to have received fair housing training within the last year (30%) than 1 to 5 years ago (21%). When respondents were asked about the entities to which they would refer clients who had experienced housing discrimination, the most common answer was the City of Tampa, with many respondents specifying that they would refer clients to the Office of Human Rights or the Housing and Community Development Department. Other common options included the HUD website or Office of Fair Housing, Bay Area Legal Services, the Tampa Housing Authority, Hillsborough County, and “I don’t know.” Three respondents indicated that they would refer clients to the “EEOC” (Equal Employment Opportunity Commission).

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The percentage of respondents overall who feel that adequate fair housing information and training is available is slightly lower than the percentage who feel that fair housing resources are inadequate in the area (48% vs. 52%). However, self-identified housing providers were more likely to view available fair housing resources as adequate (67%). Among respondents overall, in-person trainings are the most preferred method for communicating with professionals in their field about fair housing issues (80%), followed by conferences and webinars (70% each). Some respondents who feel that fair housing resources are inadequate expressed a desire for more trainings for service providers – as well as for real estate professionals, property managers, and landlords – and more information disseminated to the public (especially minority communities) through methods such as news segments, commercials, and advertisements in public places such as billboards and benches.

Clients’ Experiences with Fair Housing Impediments

A slight majority of respondents (53%) reported that it is “Somewhat likely” for their clients to experience housing discrimination, and another 27% believe it is “Very likely.” However, a plurality of respondents (44%) indicated that no more than 10% of their clients have mentioned experiencing housing discrimination in Tampa or Hillsborough County on the basis of a protected class. Another 32% reported that between 11% and 50% of their clients have mentioned experiencing discrimination. The most common bases on which their clients experience housing discrimination are race (39%), disability (36%), and familial status (28%).

A slight majority of respondents overall (53%) indicated that their clients are not likely to report housing discrimination, while another 23% reported that clients are “Somewhat likely” to report it. Among self- identified housing providers, however, a majority (54%) reported that their clients are “Somewhat likely” to report discrimination. When respondents overall were asked the reasons they think clients have for not reporting discrimination, the most common reason was “They did not think it would help” (73%), followed

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by “They did not know where to file a complaint” (57%) and “They did not realize it was a violation of the law” (50%).

When respondents overall were asked to identify the best ways to inform the public about fair housing rights and responsibilities, each of the options (except “Other”) provided was selected by over half of respondents. The most favored method is presentations at community organization meetings (69%), followed by making fair housing information available in public facilities such as City Hall and libraries (66%) and providing it on community cable television (64%).

Barriers to Fair Housing Choice

When respondents were asked about potential barriers to fair housing choice, the factors most likely to be ranked as “Serious barriers” were income levels (80%) and credit histories (74%) of some prospective renters or homebuyers, concentrations of affordable housing in certain areas (66%), and lack of fair housing knowledge among residents (47%) and large landlords and property managers (38%). Several other factors were ranked as a “Moderate” to “Serious” barrier by at least half of respondents:

• Lack of fair housing knowledge among small or “mom-and-pop” landlords (71%) • Lack of fair housing among real estate agents (50%)

• Housing providers placing certain tenants in the least desirable units in a development (50%) Additionally, two factors are considered by over half of respondents to be a “Minor” to “Moderate” barrier:

• Lack of diversity in the real estate profession (61%) • Limits on the number of occupants or unrelated persons in a home (59%)

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For most questions, however, respondents varied widely in how substantial of a barrier they consider different practices to be. “I don’t know” responses were common, particularly regarding questions about lender practices.

When asked to identify additional barriers to fair housing choice, several respondents mentioned housing for sex offenders, and others mentioned general criminal history and past evictions. One respondent indicated that their clients usually encounter these barriers, and barriers related to substance abuse, mental illness, and domestic violence, when applying for HUD-funded housing.

Concluding Thoughts on Responses from Housing Providers, Social Service Providers, Fair Housing Professionals, and Civil Servants

This portion of the survey had a reasonably high response rate from a diverse group of housing and service professionals. As a group, they tend to consider themselves less knowledgeable about fair housing than many of the private housing professionals discussed above – particularly real estate professionals, landlords, and property managers – although self-identified housing providers in this portion of the survey are more likely to consider themselves very knowledgeable than are service providers. Similarly, a substantial share of respondents feel that insufficient fair housing information and training is available, although self- identified housing providers are more likely to consider it sufficient. Many respondents, if faced with a client who had experienced housing discrimination, would refer the client to an appropriate agency, such as the City of Tampa Office of Fair Housing, HUD, or Bay Area Legal Services. However, several respondents are uncertain of where to refer clients for fair housing help, and a few would refer them to the EEOC, possibly conflating it with HUD’s Office of Fair Housing and Equal Opportunity (FHEO). Since there are several pathways for a victim of housing discrimination to file a complaint, and state and local protected classes that are not included in federal fair housing law, it is easy for service providers to become confused. Most respondents believe that housing discrimination is prevalent among their clients (though not ubiquitous), and a sizeable share of respondents reported that over 10% of their clients have mentioned experiencing housing discrimination. The respondents’ second-hand knowledge about their clients’ experiences with housing discrimination is broadly similar to the feedback on the resident portion of this survey, in terms of the most common bases for discrimination, the low likelihood that the victim will report the incident, and their reasons for not reporting. The respondents to this portion of the survey are broadly in agreement with many private-sector housing professional respondents that limited income and poor credit among renters and homebuyers, as well as geographic concentration of affordable housing, are major barriers to fair housing choice. Similar to the private-sector respondents, the public-sector and nonprofit housing and service providers had widely varying opinions on whether various practices constitute fair housing barriers, and many were unsure about whether certain practices constitute barriers.

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However, the respondents to this section of the survey were somewhat more likely than private-sector housing professionals to identify factors other than client-level characteristics as moderate or severe fair housing barriers. It is unclear if these public-sector and nonprofit respondents are overestimating fair housing barriers in private housing industry practices, if private housing professionals are underestimating these barriers, or if these two groups simply have varying experiences because they work with different clients in different segments of the housing market. As with the private-sector respondents, focus groups with the public-sector and nonprofit housing and service providers might provide more information on these potential barriers. Overall, the responses to this portion of the survey highlight a need for more training opportunities for public sector and nonprofit service providers who are not strictly housing professionals. Training for these providers will help them to recognize when their clients experience discrimination, and to provide these clients with effective guidance on filing complaints.

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APPENDIX E - Proof of Publication

To file a fair housing complaint, contact:

City of Tampa Office of Human Rights 306 E. Jackson Street, 3N Tampa, FL 33602 TEL: (813) 274-5835 www.tampagov.net/housing-and-community-development/human-rights

Hillsborough County Equal Opportunity Administrator’s Office 700 E. Twiggs St. Suite 830 Tampa, FL 33602 TEL: (813) 272-6554 www.hillsboroughcounty.org/en/government/departments/equal-opportunity