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Affirmatively Furthering Fair Housing (AFFH) INTRODUCTION and OVERVIEW of AB 686

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Affirmatively Furthering Fair Housing (AFFH) INTRODUCTION and OVERVIEW of AB 686 Appendix C: Affirmatively Furthering Fair Housing (AFFH) INTRODUCTION AND OVERVIEW OF AB 686 In January 2017, Assembly Bill 686 (AB 686) introduced an obligation to AFFH into California state law. AB 686 defined “affirmatively further fair housing” to mean “taking meaningful actions, in addition to combat discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity” for persons of color, persons with disabilities, and other protected classes. The Bill added an assessment of fair housing to the Housing Element which includes the following components: a summary of fair housing issues and assessment of the City’s fair housing enforcement and outreach capacity; an analysis of segregation patterns and disparities in access to opportunities, an assessment of contributing factors, and an identification of fair housing goals and actions. COMMUNITY OUTREACH As part of the Housing Element Update, the City implemented a community engagement program, soliciting input from the general public, housing stakeholders, and City decision makers. Results and feedback obtained during the community engagement program have been incorporated into the Housing Element, including this section on affirmatively furthering fair housing practices. Please see Chapter 1 for more details on the City’s outreach efforts. SUMMARY OF FAIR HOUSING ISSUES COUNTY OF RIVERSIDE TRENDS As part of the Community Development Block Grant (CDBG) program certification process, participating jurisdictions must prepare an analysis of impediments to fair housing choice every five years. The Riverside Regional Analysis of Impediments to Fair Housing Choice (County of Riverside AI), is an assessment of the Riverside County regional laws, ordinances, statutes, and administrative policies, as well as local conditions that affect the location, availability, and accessibility of housing. It also analyzes the conditions in the private market and public sector that may limit the range of housing choices or impede a person’s access to housing, and provides solutions and measures that will be pursued to mitigate or remove identified impediments. To focus efforts in the City of Corona, the City conducted its own analysis of impediments to fair housing choice certified by the Corona City Council (Corona AI). The Corona AI covers the City of Corona and provides a comparative demographic profile of the City and Riverside County; assesses the extent of housing needs among specific income groups; and evaluates the availability of a range of housing choices for residents. Regionally, the County of Riverside AI identifies the following impediments to fair housing: ▪ Hispanic and Black residents continue to be underrepresented in the homebuyer market and have experienced large disparities in loan approval rates ▪ Concentrations of housing choice voucher use have occurred due to the geographic disparity of rental prices 1 ▪ Housing choices for special needs groups, especially persons with disabilities, are limited ▪ Fair housing enforcement activities are limited – despite laws prohibiting discrimination, residents can experience housing bias on the basis of physical disability, race, and ethnicity ▪ Nearly 63 percent of all fair housing complaints in Riverside County over the last five years were on the basis of disability ▪ Today, people obtain information on housing options and availability through many media forms, not limited to traditional newspaper noticing or other print forms CITY OF CORONA TRENDS The Corona AI identified jurisdiction-specific impediments. Contributing factors identified as impediments to fair housing in Corona are discussed in detail below, as well as descriptions of how each impediment is addressed in this Housing Element. Concentrations of Lower- and Moderate-Income Populations The U.S. Department of Housing and Urban Development (HUD) defines a Lower- and Moderate-Income (LMI) area as a Census tract or block group where over 51 percent of the population is LMI. Corona has extensive areas where a majority of residents are LMI populations throughout its downtown areas starting in the northwest and spanning across toward the southeast. This impediment is addressed in the Housing Element Update through Housing Policies HE-1.1 through HE-1.5, which direct the City to maintain an ongoing inventory of sites that may be suitable for residential development affordable for LMI residents, support the production of LMI housing development, and seek additional funding sources to expand housing resources in the City. Language barriers Language barriers can be an impediment to accessing housing. Those with limited English may face discrimination in obtaining housing, communication challenges while trying to obtain housing, and barriers to accessing housing services and information. According to the Corona AI, 19.1 percent of the City’s population speaks English less than “very well.” This impediment is addressed in the Housing Element Update through Policies H-4.1 and H-4.2 and Programs 20 and 27 which direct the City to provide counseling for property owners and tenants on fair housing related issues, facilitate housing opportunities, and provide materials on housing related materials in multiple languages. Lending by Race/Ethnicity The Fair Housing Act prohibits discrimination when obtaining a mortgage. However, in some communities the lending pool is not representative of the demographics of a community and lending practices can be an impediment to fair housing. The Corona AI notes that this is the case in Corona, where African American and Hispanic households have limited access to conventional home purchase loans due to disproportionate denial rates compared to households of other racial groups. This impediment is addressed in the fair housing and enforcement policy section in Chapter 6 of the Housing Element, specifically Programs 20 and 21, which direct the City to remove impediments to fair housing, provide and expand counseling residents on fair housing related issues, explore grant opportunities for fair housing support, conduct fair housing testing, and participate in regional efforts to reduce discriminatory housing practices. 2 Overcrowded Conditions Large households are those defined with five or more individuals and can sometimes include multiple families living together. Due to the high cost of housing in Corona, large households are often forced to obtain housing that is not of sufficient size, leading to overcrowding issues. According to the 2014-2018 ACS, overcrowding affected 5.9 percent of households in Corona. Overcrowding decreased from 2010, when approximately 8.2 percent of households were overcrowded. This impediment is addressed in Housing Element programs that direct the City to monitor and support affordable housing development with a mix of housing opportunities, particularly for special needs populations. Housing for Farmworkers Due to the high cost of housing and low wages, migrant farm workers may have difficulty finding affordable, safe, and sanitary housing. According to the State Employment Development Department, the average farm worker earned a mean annual income of $32,000 in 2020. This limited income is exacerbated by a tenuous and/or seasonal employment status. Determining the true size of the agricultural labor force is difficult. For instance, the government agencies that track farm labor do not consistently define farmworkers (e.g. field laborers versus workers in processing plants), length of employment (e.g. permanent or seasonal), or place of work (e.g. the location of the business or field). According to SCAG, it is estimated that 152 City residents were considered farmworkers (employed in farming, fishing, and forestry occupations). The City can accommodate the development of farmworker housing in any zone that permits the type of housing being built (i.e., agricultural zones) without special conditions. Since the City does not have a large farmworker population, the housing needs of this group are addressed through the City’s standard affordable housing programs for lower-income households. Limiting Local Land Use Policies The Fair Housing Act prohibits jurisdictions from making land use decisions or implementing land use policies that exclude or can otherwise be seen as discriminatory. The Housing Element directs the City to update its land use policies to be consistent with State laws and AFFH goals. For example, recent changes to the density bonus makes it more difficult to meet housing goals, and a lack of inclusionary housing requirements. These impediments are addressed in Program 14 of the Housing Element which directs the City to revisit its supportive/transitional parking requirements and emergency shelter regulations. FAIR HOUSING OUTREACH AND ENFORCEMENT Fair housing enforcement and outreach capacity relates to the ability of a local jurisdiction and fair housing entities to disseminate information related to fair housing and provide outreach and education to assure community members are informed of fair housing laws and tenants’ rights. In addition, enforcement and outreach capacity includes the ability to address compliance with fair housing laws, such as investigating complaints, obtaining remedies, and engaging in fair housing testing. Fair Housing Outreach The County of Riverside contracts with the non-profit organization Fair Housing Council of Riverside County, Inc. (FHCRC) to address fair housing complaints and engage the community
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