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DEPARTMENT OF COMMUNITY DEVELOPMENT
FY 2020 ANALYSIS OF IMPEDIMENTS
TO FAIR HOUSING CHOICE
MAY 2020
Mr. Allen Davis, Director of Community Development
Ms. Darlene Brandt, Grants Coordinator
City of Oshkosh Department of Community Development
215 Church Avenue, Oshkosh, WI 54903-1130
City of Oshkosh, WI
Table of Contents
ExecutiveSummary........................................................................................................ 2
I. Introduction.............................................................................................................8
II. Background Data.................................................................................................. 10
A. Population, Race, Ethnicity, and Religion: .................................................... 10
B. Households: .................................................................................................. 23
C. Income and Poverty: ..................................................................................... 30
D. Employment: ................................................................................................. 36
E. Housing Profile: ................................................. ........................................39
F. Housing Costs: ............................................ .........................................43
G. Household Housing Problems: .............. ...............................................49
H. Racial and Ethnic Housing Problems ..................................................... 53
I. Racial and Ethnic Housing Cost Burd................................................... 56
J. Disabled Households :...........: .......................................................57
III. Review/Update to Original Plan ....... ... .................................................... 59
A. Summary of Impediment ..................................................................... 59
IV. Impediments to Fair HG&ng .................................................................. 66
A. Fair Housing pi .............................................................................. 66
B. Public Sec :........ ............................................................................... 72
C. Private S r:.......................................................................................... 104
V. Actions and Recommendations........................................................................... 150
VI. Certification......................................................................................................... 153
VII. Maps................................................................................................................... 154
VII I. Appendix............................................................................................................. 155
Analysis of Impediments to Fair Housing Choice 1 of 159
City of Oshkosh, WI
Executive Summary
The City of Oshkosh is an entitlement community under the U.S. Department of
Housing and Urban Development's (HUD) Community Development Block Grant
Program (CDBG). In accordance with the Housing and Community Development Act of
1974, as amended, each entitlement community must "affirmatively further fair housing."
In order to demonstrate that the entitlement community is "affirmatively furthering fair
housing," each community must conduct a Fair Housing Analysis which identifies any
impediments to fair housing choice and what steps it will take to address those
impediments. HUD advises communities that the Analysis of Impediments to Fair
Housing Choice should address the Fair Housing Act, Title VI of the Civil Rights Act of
1964, Section 504 of the Rehabilitation Act of 1973, Section 109 of Title I of the Housing
and Community Development Act of 1974, Title II of the Americans with Disabilities Act
of 1990, Architectural Barriers Act of 1968, Age Discrimination Act of 1975, Title IX of
the Education Amendments Act of 1972, Executive Order 11063, Executive Order
11246, Executive Order 12892, Executive Order 12898, Executive Order 13166, and
Executive Order 13217.
The HUD Fair Housing and Equal Opportunity (FHEO) Office advises Federal
entitlement communities to update their Analysis of Impediments (AI) to Fair Housing
Choice to coincide with their Five Year Consolidated Plan, and then every five (5) years
thereafter. In addition, each year the entitlement communities, as part of its Annual
Action Plan, must sign certifications tha he rictions will affirmatively further fair
housing. This means that the entitleme ommisdunities will conduct an Analysis of
Impediments to Fair Housing oic take propriate actions to overcome the effects
of any impediments identifi thr a I, and maintain records reflecting what
analysis and corrective action a
The City of Oshkosh evRWly
prepared an Analysis of Impe ents to
Fair Housing Choice in March 13. On
July 16, 2015, the U.S. Dep ment of
Housing and Urban Development
(HUD) published its final rule on
Affirmatively Furthering Fair Housing.
This rule attempted to establish a
standardized process for fair housing
planning. On May 18, 2018, due to
deficiencies in the requirements,
information available, and public
participation HUD announced the
withdrawal of the AFFH Rule,
eliminating the AFH Tool, and requiring
communities to revert back to the
preparation of an Analysis of
Impediments to Fair Housing Choice.
n
1
Google. (n.d.). City of Oshkosh, WI. Retrieved from
https://www.google.com/maps/place/Oshkosh
Analysis of Impediments to Fair Housing Choice 2 of 159
City of Oshkosh, WI
The Fair Housing Act was originally passed in 1968 to protect buyers and renters from
discrimination from sellers and landlords by making it unlawful to refuse the sale or
rental of a property to persons included under the category of a protected class. The
Fair Housing Act prohibits discrimination against persons based on their race, color,
religion, sex, national origin, disability, or familial status in the sale, rental, and
financing of housing.
7 Race
The methodology i
• Research
included:
- Review of the 2013 Analysis of Impediments to Fair Housing
Choice, Zoning Ordinances, Comprehensive Plans, Five Year
Consolidated Plans, Annual Action Plans and Consolidated Annual
Performance Evaluation Reports.
- Review of the Housing Authorities' Five Year and Annual PHA
Plans.
Review of the most recent demographic data for the area from the
U.S. Census, which included general, demographic, housing,
economic, social, and disability characteristics.
Review of the U.S. Department of Housing and Urban Development
Comprehensive Housing Affordability Strategy (HUD-CHAS) data.
Analysis of Impediments to Fair Housing Choice 3 of 159
City of Oshkosh, WI
- Review of the residential segregation data from PolicyMap.
- Review of financial lending institutions through the Home Mortgage
Disclosure Act (HMDA) database.
- A review of the real estate and mortgage practices.
- Home mortgage foreclosure data.
• Interviews & Meetings
- Meetings and interviews were conducted with various City and
County Departments; Housing Authorities; community, social
service, and advocacy agencies, as well as public meetings.
- Follow up phone calls were made when an organization neither
returned a survey nor attended a meeting.
• Analysis of Data
- Low- and moderate -income areas were identified and mapped.
- Concentrations of minority populations were analyzed.
- Concentrations of wner-occupied and renter -occupied housing
units were identifie apped.
- Fair housing awaren i 'the community was evaluated.
- Distribution by locatio f public and assisted housing units were
analyzed o, d mapped.
- The loexpenditures throughout the area were
analyz
- 413G/iHV�Ee Goals and Objectives were reviewed.
• Potential IMpedirnents
- Public lector policies that may be viewed as impediments were
analyzed.
- Private sector policies that may be viewed as impediments were
analyzed.
- The status of previously identified impediments was analyzed.
Citizen Participation
- A public survey was publicized by the various participating
jurisdictions, public meetings were held, and copies of the draft Al
were placed on public display to encourage citizen input.
Analysis of Impediments to Fair Housing Choice 4 of 159
City of Oshkosh, WI
- The public survey was available at the following link
https://www.surveVmonkeV.com/r/OSHCDBG from September 1,
2019 until November 1, 2019.
• Key Findings
- Median age is younger
- Housing costs are high
- Cost of housing (rental and purchase) increase vs income increase
- Housing unit growth vs. household growth
- Older housing stock requires renovations for accessibility
- Building permits are down
- Household incomes have increased at a slower rate than home
prices.
- Gaps in new home construction
The City of Oshkosh Analysis of Impediments to Fair Housing Choice has identified the
following impediments, as well as defined specific goals and strategies to address each
impediment.
Impediment 1: Need for Fair Housing Education and Outreach
There is a need to imp rovNknowledge and understanding concerning
the rights and responsibif individuals, families, members of the
protected classes, landlorestate professionals, and public officials
under the Fair 4sing Ac
Goal: Improve t lies k rMwledge and awareness of the Fair Housing
Act, rel Icer
ations, and requirements to affirmatively further fair
housi n the u
Strategi In to meet this goal, the following activities and
strategies should be undertaken:
- 1-A: Educate residents of their rights under the Fair Housing Act
(FHA) and the Americans with Disabilities Act (ADA).
- 1-B: Educate realtors, bankers, housing providers, and other real
estate professional of their responsibilities under the Fair Housing
Act (FHA) and the Americans with Disabilities Act (ADA).
- 1-C: Educate policy makers and city staff about the Fair Housing
Act (FHA) and the Americans with Disabilities Act (ADA).
- 1-11): Support Fair Housing organizations and legal advocacy
groups to assist persons who may be victims of housing
discrimination.
Analysis of Impediments to Fair Housing Choice 5 of 159
City of Oshkosh, WI
- 1-E: Identify the language and communication needs of LEP
persons to provide the specific language assistance that is
required.
- 1-F: Continue to partner with regional jurisdictions and housing
providers to encourage fair housing choice throughout
Winnebagoland.
Impediment 2: Need for Affordable Housing
Almost half (45.6%) of all renter households are paying over 30% of their
monthly incomes on housing costs. A quarter (25.0%) of all owner
households with a mortgage are paying over 30% of their monthly income
on housing costs. The number of households that are housing cost
burdened significantly increases as household income decreases.
Goal: Increase the supply of decent, safe and sanitary housing that is
affordable and accessible through the new construction and rehabilitation
of various types of housing, esp Ily h sing that is affordable to lower
income households.
Strategies: In order to m oal, following activities and
strategies should be undert en.
- 2-A: Support and a rage private developers and non-profit
housing provide`rto create, through construction or rehabilitation,
affordatand i- came housing.
- 2-113• ON and encourage the rehabilitation of existing renter-
pYhousinag
wner-occupied housing units in the City for
ouse80% AMI.
- • Supebuyer education, training programs, and closing
cosnt assistance to increase the number of owner-
occupunits.
- 2-11): Provide federal, state and local funding in response to HMDA
data discrimination patterns to support higher loan to value ratios
for minority homebuyers.
- 2-E: Create a database of decent, safe, and sanitary housing that is
affordable and accessible for households below 80% AMI.
Impediment 3: Need for Accessible Housing
There is a lack of accessible housing units in the City of Oshkosh as the
supply of accessible housing has not kept pace with the demand of
individuals desiring to live independently.
Analysis of Impediments to Fair Housing Choice 6 of 159
City of Oshkosh, WI
Goal: Increase the supply of accessible housing through new construction
and rehabilitation for persons with disabilities.
Strategies: In order to meet this goal, the following activities and
strategies should be undertaken:
- 3-A: Promote the need for accessible and visitable housing by
supporting and encouraging private developers and non -profits to
develop, construct, or rehabilitate housing that is accessible to
persons with disabilities.
- 3-13: Provide financial assistance for accessibility improvements to
renter -occupied and owner -occupied housing units to enable
seniors and persons with disabilities to remain in their homes.
- 3-C: Promote and enforce the ADAAnd Fair Housing requirements
for landlords to make "reason ablefRommodations" to their rental
properties so are accessible to nants.
• Impediment 4: Public Policy
The City Zoning Ordinan d nal definitions and provisions
concerning Fair Housing.
Goal: Revise the City Zoning Ordinance to promote the development of
various types of affordable housing throughout the City.
Strategies: In order to meet this goal, the following activities and
strategies should be undertaken:
- 4-A: Revise the City Zoning Ordinance to include additional
definitions, statements, and revisions.
- 4-13: Adopt a written Reasonable Accommodation Policy for
housing developers and the Planning/Zoning Commission to follow
when reasonable accommodation requests are made concerning
zoning and land use as it applies to protected classes under the
Fair Housing Act.
- 4-C: Develop financial incentives to encourage developers and
housing providers to offer more affordable housing options in the
City.
- 4-11): Encourage LMI, minority, and protected class resident
participation in the various City Boards and Commissions.
Analysis of Impediments to Fair Housing Choice 7 of 159
City of Oshkosh, WI
I. Introduction
HUD defines "fair housing choice" as:
"The ability of persons, regardless of race, color, religion, sex,
national origin, familial status, or handicap, of similar income levels
to have available to them the same housing choices"
a
it Housing Analysis consists of the following six (6) conditions:
• The sale or rental of dwellings (public or private);
• The provision of housing brokerage services;
• The provision of financial assistance for dw ings;
• Public policies and actions affecting roval of sites and other
building requirements used in the approval pro for the construction of
publicly assisted housing; OF
• The administrative policies cold
housing activities, which affect o
select housing inside or o rf
r community development and
nities of minority households to
Minority concentration; and
• Where there is a determin n ul segregation or other housing
discrimination by a court or ing of noncompliance by HUD regarding
assisted housing in a recipie 's jurisdiction, an analysis of the actions
which could be taken by th recipient to remedy the discriminatory
condition, including actions involving the expenditure of funds made
available under 24 CFR Part 570.
HUD-FHEO suggests that communities conducting a fair housing analysis
consider the policies surrounding "visitability," the Section 504 Rehabilitation Act,
the Americans with Disabilities Act, and the Fair Housing Act. Housing that is
"visitable" has the most basic level of accessibility that enables persons with
disabilities to visit the home of a friend, family member, or neighbor. "Visitable"
housing has at least one accessible means of ingress/egress, and all interior and
bathroom doorways have as a minimum a 32-inch clear opening. Section 504 of
the Rehabilitation Act (24 CFR Part 8), known as "Section 504" prohibits
discrimination against persons with disabilities in any program receiving Federal
funds. The Americans with Disabilities Act (42 U.S.C. 12131; 47 U.S.C. 155, 201,
218, and 225) (ADA) prohibits discrimination against persons with disabilities in
all programs and activities sponsored by state and local governments. The Fair
Housing Act requires property owners to make reasonable modifications to units
and/or public areas in order to allow a disabled tenant to make full use of the unit.
Additionally, property owners are required to make reasonable accommodations
to rules or procedures to afford a disabled tenant full use of the unit. In regard to
local zoning ordinances, the Fair Housing Act prohibits local government from
Analysis of Impediments to Fair Housing Choice 8 of 159
City of Oshkosh, WI
making zoning or land use decisions, or implementing land use policies that
exclude or discriminate against persons of a protected class.
The participating entitlement previously prepared an Analysis of Impediments to
Fair Housing Choice in 2013. This Analysis of Impediments to Fair Housing
Choice will outline progress that has been made since the previous Analysis of
Impediments, explore the continuation of these impediments where necessary,
and identify any new impediments to fair housing choice. Furthermore, this
Analysis of Impediments will bring the participating entitlement communities into
sequence with their FY 2020-2024 Five Year Consolidated Plans. The document
is designed to act as a planning tool, providing the participating entitlement
communities with the necessary framework to strategically reduce any identified
impediments to fair housing choice over the next five (5) years, and continue to
make modifications based on events and activities ' the community during this
time period.
In order to affirmatively further fair housing in the City of Oshkosh, residents
recognized that they must coordinate fair housing with other entities. Fair housing
choice is the goal of the Al and the opportunity should be made available to low-
income residents and the members of the protected classes to live anywhere in
the City of Oshkosh.
tk
Analysis of Impediments to Fair Housing Choice 9 of 159
City of Oshkosh, WI
II. Background Data
The City of Oshkosh is a city in Winnebago County, in eastern Wisconsin. It is
situated west of Lake Michigan, between Lake Butte des Morts, and Lake
Winnebago, and is bifurcated by the Fox River. Oshkosh is the sixth most
populous city in the state of Wisconsin with a population of 66,083 residents as of
the 2010 U.S. Census which increased to 66,649 residents in 2019 according to
the latest U.S. Census Estimate. The surrounding region has a population of
about 95,000. Oshkosh is approximately 53 miles south from Green Bay,
Wisconsin via Interstate 41, and approximately 88 miles north from Milwaukee
via Interstate 41.
In the 2000s and 2010s, Oshkosh's economy has been based in the
manufacturing industries with some service industries. There also has been
growth in health care and education.
Demographic, housing, economic, and social data was analyzed, including data
from the 2000 and 2010 U.S. Census, 2011-2015 American Community Survey
(ACS) Five -Year Estimates, 2011-2015 Comprehensive Housing Affordability
Strategy (CHAS), Association of Religious Data, U.S. Department of Housing
and Urban Development (HU HUD CPD Maps, RealtyTrac, and the
participating stakeholders. All dat ed in the analysis are documented in
the section the data is presente T was used to evaluate the area's
community and housing characteris as a basis for determining and identifying
any existing impediments to fair hous choice.
The City of Oshkosh was founded in 1853, and named after Chief Oshkosh of
the Menominee, though the Ho -Chunk Indians lived on the site for centuries. Two
towns, Athens north of the Fox River, and Brooklyn to the south, officially merged
to create Oshkosh. The Chicago Fire, devastating though it was, offered an
opportunity for Oshkosh's lumber industry to grow. The City boasted two dozen
saw mills by 1873 and the moniker "Sawdust City". In the last century, Oshkosh's
economy centered on manufacturing, including diverse offerings such as the
popular adult and children's clothing brand Oshkosh B'Gosh and Oshkosh
Corporation's emergency, utility, and military vehicles.
A. Population, Race, Ethnicity, and Religion:
The City of Oshkosh's population increased from 62,916 people in 2000 to
66,083 people in 2010 (an increase of 5.03%), and increased from 66,083
in 2010 to 66,582 in 2015 (an increase of 0.76%).
Analysis of Impediments to Fair Housing Choice 10 of 159
City of Oshkosh, WI
Winnebago County's population increased from 156,763 people in 2000 to
166,994 in 2010 (an increase of 6.52%) and increased from 166,994 in
2010 to 169,004 people in 2015 (an increase of 1.20%).
The State of Wisconsin's population increased from 5,363,675 people in
2000 to 5,686,986 in 2010 (an increase of 6.03%) and increased from
5,686,986 in 2010 to 5,742,117 people in 2015 (an increase of 0.97%).
Population Change for the City of Oshkosh
and Winnebago County
180,000
160,000
140,000
120,000
100,000
80,000
60,000
40,000
20,000
0
1-2015 ACS
Analysis of Impediments to Fair Housing Choice 11 of 159
City of Oshkosh, WI
Race
The following table highlights the racial composition of the City of Oshkosh
as shown in the 2010 U.S. Census and in 2015.
Race and Hispanic or Latino Population in the City of Oshkosh
Race and
2010 U.S. Census
2011-2015 ACS
Hispanic or
Latino
#
%
#
%
Total
66,083
-
66,582
-
One race
64,991
98.3%
65,593
98.5%
White alone
59,812
90.5%
61,030
91.7%
Black or African
2,051
3.1 %
2,304
3.5%
American alone
American Indian
and Alaska Native
510
0.8°0
309
0.5%
alone
Asian alone
Iff
3.2%
1,800
2.7%
Native Hawaiian
and Other Pacific
30
0.0%
11
0.0%
Islander alone
Some othere
475
0.7%
139
0.2%
alone Se
Two or more
1,092
1.7%
989
1.5%
races
Hispanic or Latino
1,565
2.7%
2,030
3.0%
Source: 2010 U.S. Census and 2011-2015 ACS
The most common race identified in the City of Oshkosh in 2010 was
White Alone with 59,812 residents comprising 90.5% of the population.
The second most common race identified in the City of Oshkosh in 2010
was Asian Alone with 2,113 residents comprising 3.2% of the population.
The most common race identified in the City of Oshkosh in 2015 was
White Alone with 61,030 residents comprising 91.7% of the population.
The second most common race identified in the City of Oshkosh in 2015
Analysis of Impediments to Fair Housing Choice 12 of 159
City of Oshkosh, WI
was Black or African American with 2,304 residents comprising 3.5% of
the population.
The following map is a racial dot map representing one dot for every
person counted during the 2010 Census. Each dot is color -coded by the
individual's race and ethnicity. Whites are coded as blue; African -
Americans, green; Asians, red; Hispanics, orange; and all other racial
categories are coded as brown. The map was created by the University of
Virginia Weldon Cooper Center for Public Service Demographics
Research Group. The map provides a picture of any areas that may have
a grouping of non-White residents. There are small areas throughout the
city with clusters of Asians and two areas in northern Oshkosh with higher
concentrations of African -Americans.
Racial Dot Map
t
2010 Census Block Data
1 Dot =1 Person
• White 0,
• Black
• Asian
• Hispanic
ome.saainaree
• 1-king
.rxiN�
What am I looking at
T
Image Copyright, 2013, Weldon Cooper Center for Public Service, Rector and Visitors of the
University of Virginia (Dustin A. Cable, creator)
Source: https://demographics.coopercenter.org/racial-dot-map
The following map calculates the diversity index per Census Tract in
Oshkosh. "The diversity index is an index ranging from 0 to 87.5 that
represents the probability that two individuals, chosen at random in the
given geography, would be of different races or ethnicities between 2013-
2017. Lower index values between 0 and 20 suggest more homogeneity
and higher index values above 50 suggest more heterogeneity. Racial and
ethnic diversity can be indicative of economic and behavioral patterns. For
Analysis of Impediments to Fair Housing Choice 13 of 159
City of Oshkosh, WI
example, racially and ethnically homogenous areas are sometimes
representative of concentrated poverty or concentrated wealth. They could
also be indicative of discriminatory housing policies or other related
barriers. Data were obtained from the Census' American Community
Survey 2013-2017 estimates and calculated by PolicyMap." (Source:
PolicyMap.com) The majority of Oshkosh has a diversity index under 30
and represents a higher level of homogeneity. The most diverse part of
Oshkosh is the northern section of the city.
Year 20132DJ7
— --
Variahle� Index.
Shaded 6y �yus Tract 20,0
20001 551 a9o0P00o2
EAR.
0—
� �evrr�me„r aele
G03 or less
_ 14.84-Y9.94
_ 2e.9s-4s31
_ 653P-5].51
auas
_ 57. 52 or more
55139W20003
4S13r391.K4ll3'4
Source'
Diversity Index
551390019043
18.04
I ✓
10�
The folMW marprovides the Theil Index calculations per Census Tract
in Oshkosh. "The Theil Index is an index ranging from 0 to 1 that displays
information about racial segregation. Lower index values below .20
suggest less segregation and higher index values above .40 suggest more
segregation. The Theil Index is a measure of how evenly members of
racial and ethnic groups are distributed within a region, calculated by
comparing the diversity of all sub -regions (Census blocks) to the region as
a whole. Patterns of racial segregation can emerge as a result of systemic
barriers and opportunities or localized individual preferences. For
example, highly segregated areas may be indicative of discriminatory
housing practices or other related barriers. Data used in the calculation of
this index were derived from the U.S. Census Bureau's 2010 Decennial
Census." (Source: PolicyMap.com) The Theil Index for all areas of the city
suggests a lack of segregation with all areas below .45.
Analysis of Impediments to Fair Housing Choice 14 of 159
City of Oshkosh, WI
Theil Index
_ MLLM
F5d ]90022013
-
k ThelI Index
Year 2✓110
:... ^,.55t 3b991;i091 t7
V—ble.- Index ..
Shaded by. census Tra, 2a7o
All
29
55139a92o0nR
-.- 15.199n91gnc3
. 78A4
EDIT- I�LJP6- RP115E5-
Insuff im[Oa�a
0.11 w less
D12 T]
_
9.19-®23
551390018M)3
_ 0.23-6.32
_ oaaw more
d9902999
Source:
Ethnicity
The followi tab ighlights the ethnicities of Oshkosh residents as of
2010 a
icity and Ancestry in the City of Oshkosh
Ancestry
2006-2010 ACS
2011-2015 ACS
Total Population
65,507
-
66,582
Afghan
0
0.0%
0
0.0%
Albanian
0
0.0%
0
0.0%
Alsatian
0
0.0%
0
0.0%
American
1,694
2.6%
2,384
3.6%
Analysis of Impediments to Fair Housing Choice 15 of 159
City of Oshkosh, WI
Arab
55
0.0%
120
0.2%
Armenian
0
0.0%
0
0.0%
Assyrian/Chaldean/Syriac
0
0.0%
41
0.0%
Australian
0
0.0%
15
0.0%
Austrian
205
0.3%
268
0.4%
Basque
0
0.0%
0
0.0%
Belgian
136
0.20%
301
0.5%
Brazilian
0
%
28
0.0%
British
69
0
203
0.3%
Bulgarian
0
0.
7
0.0%
Cajun
0.0%
0
0.0%
Canadian
0.0%
34
0.0%
Carpatho Rusyn
0.0%
0
0.0%
Celtic
7
0.0%
10
0.0%
Croatian
76
0.1 %
79
0.0%
Cypriot
0
0.0%
0
0.0%
Czech
321
0.5%
471
0.7%
Czechoslovakian
53
0.0%
91
0.0%
Danish
308
0.5%
482
0.7%
Dutch
513
0.8%
1,225
1.8%
Analysis of Impediments to Fair Housing Choice 16 of 159
City of Oshkosh, WI
Eastern European
11
0.0%
0
0.0%
English
2,222
3.4%
3,509
5.3%
Estonian
0
0.0%
0
0.0%
European
285
0.4%
670
1.0%
Finnish
330
0.5%
232
0.3%
French (except Basque)
1,146
1.7%
2,355
3.5%
French Canadian
370
0.6°l
359
0.5%
German
30,701
'A.9%
3,811
50.8%
German Russian
0
0
20
0.0%
Greek
94V*414A
0.
116
0.2%
Guyanese
0.0%
0
0.0%
Hungarian
0.2%
214
0.3%
Icelander
0.0%
8
0.0%
Iranian
33
0.0%
25
0.0%
Irish
3,711
5.7%
6,418
9.6%
Israeli
0
0.0%
0
0.0%
Italian
1,217
1.9%
2,323
3.5%
Latvian
0
0.0%
65
0.0%
Lithuanian
21
0.0%
168
0.3%
Luxemburger
21
0.0%
61
0.0%
Analysis of Impediments to Fair Housing Choice 17 of 159
City of Oshkosh, WI
Macedonian 0
0.0%
0
0.0%
Maltese 0
0.0%
0
0.0%
New Zealander 0
0.0%
0
0.0%
Northern European 138
0.2%
25
0.0%
Norwegian 1,848
2.8%
2,478
3.7%
Pennsylvania German 19
0.0%
28
0.0%
Polish 2,785
4.30
4,544
6.8%
Portuguese 0
%
0
0.0%
Romanian 6
0
120
0.2%
Russian 259
0.
406
0.6%
Scandinavian
0.2%
300
0.5%
Scotch -Irish 2410%111�
0.4%
131
0.2%
Scottish 7
0.6%
596
0.9%
Serbian 0
0.0%
35
0.0%
Slavic 24
0.0%
5
0.0%
Slovak 33
0.0%
26
0.0
Slovene 0
0.0%
29
0.0%
Soviet Union 0
0.0%
0
0.0%
Subsaharan African 188
0.3%
239
0.4%
Swedish 475
0.7%
854
1.3%
Analysis of Impediments to Fair Housing Choice 18 of 159
City of Oshkosh, WI
Swiss
303
0.5%
308
0.5%
Turkish
0
0.0%
0
0.0%
Ukrainian
28
0.0%
52
0.0%
Welsh
318
0.5%
373
0.6%
West Indian (except
Hispanic groups)
17
0.0%
2
0.0%
Yugoslavian
48
0.0%
78
0.0%
Other groups
8,140
12.4"
9,784
14.7%
Unclassified or not
reported
6,346
%JJA -
9,236
13.9%
rce6-2010 ACS and 2011-2015 ACS
The most common ancestral group identified in the City of Oshkosh in
2010 was "German" with 30,701 residents comprising 46.9% of the
population. The second most common specific ancestral group identified
in the City of Oshkosh in 2010 was "Irish" with 3,711 residents comprising
5.7% percent of the population.
The most common specific ancestral group identified in the City of
Oshkosh in 201 was also "German" with 33,811 residents comprising
50.8% of the p lation. The second most common specific ancestral
group i tified i the City of Oshkosh in 2015 was "Irish" with 6,418
residents pr' g 9.6% of the population.
Nearly a quarter of respondents identified as, "Other Groups" and
"Unclassified or Not Reported." These classifications accounted for 22.1 %
of the population in 2010 and 28.6% in 2015. The only notable change in
proportional representation of the ancestral groups in the City of Oshkosh
from 2010 to 2015 was the 3.9% increase in the proportion of residents
who identify as German (30,701 persons, or 46.9% in 2010 to 33,811
persons, or 50.8% in 2015) and Irish (3,711 persons, or 5.7% in 2010 to
6,418 persons, or 9.6% in 2015).
Analysis of Impediments to Fair Housing Choice 19 of 159
City of Oshkosh, WI
Age— Oshkosh
The following chart illustrates age distribution in the City of Oshkosh at the
time of the 2010 U.S. Census and 2011-2015 ACS. The Census shows
that currently, children under 20 years of age represent 30.2% of the
population; 38.2% of the population is between 20 and 45 years of age;
20.5% of the population is 45 to 65; and 11.2% of the population is 65
years of age and older.
Age Distribution Change for the City of Oshkosh
85 years and over
75 to 84 years
65 to 74 years
60 to 64 years
55 to 59 years
45 to 54 years
35 to 44 yea
25 to 34 yea
20 to 24 yea
15 to 19 yea
10 to 14 yea
5to9yea
Under 5 yea
,000 10,000
■ 2010 2011-2015 ACS
Source: 2010 U.S. Census and 2011-2015 ACS
Analysis of Impediments to Fair Housing Choice 20 of 159
City of Oshkosh, WI
Religion — Oshkosh, WI
The U.S. Census does not collect data on the religious affiliations of the
population in the United States. In an effort to better understand the
religious affiliations of the residents of the City of Oshkosh, the City used
the data made available by The Association of Religion Data Archives
(ARDA). ARDA surveys the congregation members, their children, and
other people who regularly attend religious services across the country.
Although this data appears to be the most comprehensive data that is
available, it is unfortunately not entirely complete as it does not accurately
include traditional African American denominations, as well as a listing of
non-Christian religions. The total number of regular attendees was
adjusted in 2010 (the most recent year for which data is available) to
represent the population including historic African American
denominations. However, the total value cannot be disaggregated to
determine the distribution across denominational groups.
The table below shows the distribu ' of residents of Winnebago County
across various denominational ps, a percentage of the population
which reported affiliation with a c
Religious Affiliation in Win go County
1980
19
2000
2010
#
%
%
#
%
#
%
Evangelical
15,974
12.1%
18,751
13.4%
18,943
12.1%
23,938
14.3%
Protestant
Mainline
31,673
24.0%
31,044
22.1%
26,534
16.9%
21,022
12.6%
Protestant
Catholic
35,197
26.7%
39,842
28.4%
43,690
27.9%
36,514
21.9%
Other
252
0.2%
150
0.1 %
842
0.5%
1,359
0.8%
Total
Adherents:
83,096
63.1%
89,787
64.0%
90,009
57.4%
82,833
49.6%
Unclaimed
(% of total
48,607
36.9%
50,533
36.0%
66,754
42.6%
84,161
50.4%
population)
Total
131,703
100.0%
140,320
100.0%
156,763
100.0%
166,994
100.0%
Population
Source: The Association of Religion Data
The most common religious affiliation identified in Winnebago County in
1980 was "Unclaimed" with 48,607 non -adherents comprising of 36.9% of
the population. The second most common religious affiliation identified in
Winnebago County in 1980 was "Catholic" with 35,197 adherents
Analysis of Impediments to Fair Housing Choice 21 of 159
City of Oshkosh, WI
comprising 26.7% of the population. The "Mainline Protestant" religious
affiliation was comprised of 24.0%, or 31,673 adherents.
The most common religious affiliation identified in Winnebago County in
2010 was "Unclaimed" with 84,161 non -adherents comprising of 50.4% of
the population. The second most common religious affiliation identified in
the Winnebago County in 2010 was "Catholic" with 36,514 adherents
comprising of 21.9% of the population. The "Evangelical Protestant"
religious affiliation, although technically the third largest, should be noted
as well as 23,938 adherents comprising of 14.3% of the population
identified as "Evangelical Protestant".
There were two changes in proportional representation of the religious
groups in Winnebago County from 1980 to 2010 that were larger than 5.0
percentage points. First, there was a 13.5% increase in the number of
residents who identify as "Unclaimed" w ich included 48,607 persons, or
36.9%, in 1980 to 84,161 persons, or 4%, in 2010. Second, there was
a 11.4% decrease in the number esidents who identify as "Mainline
Protestant" which included 31,6 errs, or 24.0% in 1980 to 21,022
persons, or 12.6%, in 2010.
Analysis of Impediments to Fair Housing Choice 22 of 159
City of Oshkosh, WI
B. Households:
The following table highlights the changes in the number of households
and population in the area over the span of fifteen (15) years.
POPULATION
tearHOUSEHOLDS
#
Change
#
Change
2000
24,082
-
62,916
-
2010
26,138
8.5%
66,083
5.0%
2015
26,152
0.1 %
66,582
0.7%
Source: 2000 U.S. Census, 2010 U.S. Census, and 2011-2015 ACS
Household Tenure
According to the 2000 U.S. Cen!
the City of Oshkosh. Of these
occupied and 1,338 (5.3
units, 13,851 (57.5%) we o
renter -occupied. =,
According to
increased to
(92.8%)
V
occupied
11,445 (43.f
betwee% 00
ere were 25,420 housing units in
ing units, 24,082 (94.7%) were
pied. Of the occupied housing
Orpied and 10,231 (42.5%) were
01 Offi.S. sus, the total number of housing units
! crease. Of the total housing units, 26,138
,occupied and 2,041 (7.2%) were unoccupied. Of the
nits in 2010, 14,693 (56.2%) were owner -occupied and
are renter -occupied. The increase in housing units
?010 was 2,759 units.
According toW 2015 ACS 5-Year estimates, there were 28,214 housing
units in the City of Oshkosh; a 0.1 % increase. Of the total housing units,
26,152 (92.7%) were occupied and 2,062 (7.3%) were unoccupied. Of the
occupied housing units, 13,868 (53.0%) were owner -occupied and 12,284
(47.0%) were renter -occupied. From 2010 to 2015 there was: a 35 unit
increase in the total number of housing units; a 14 unit increase (0.1 %) in
the number of occupied units; and a 21 unit increase (0.1 %) in the number
of unoccupied housing units. The number of owner -occupied units
decreased by 825 units (5.6%) and the number of renter -occupied units
increased by 839 (7.3%).
The maps below illustrate the concentrations of owner -occupied and
renter -occupied housing units. Higher concentrations of a particular
housing type are accentuated by a darker color. In Oshkosh, owner -
Analysis of Impediments to Fair Housing Choice 23 of 159
City of Oshkosh, WI
occupied units increase towards the outskirts of the city and renter -
occupied units increase towards the city center.
Percentage Owner -Occupied Housing
Source: HUD CPD Maps
Analysis of Impediments to Fair Housing Choice 24 of 159
City of Oshkosh, WI
Percentage Renter -Occupied Housing
In 2000, the Werage household size was 2.31 persons and the average
family size was 2.95 persons. In 2010, the average household size was
2.24 persons and the average family size was 2.90 persons. In 2015, the
average household size was 2.26 persons and the average family size
was 2.94 persons.
Analysis of Impediments to Fair Housing Choice 25 of 159
City of Oshkosh, WI
Household Tenure by Size in Oshkosh
4-or-more-person household
3-person household
2-person household
1-person household
0 1,000 2,000 3,000 4,000 5,000 6,000
■ Renter Occupied ■ Owner Occ
Source: 2011-2015 ACS
Significant household shifts in OS osh included the 825 unit decrease in
owner -occupied units from 2010 to 2015 and the 839 increase in renter -
occupied units from 2010 to 2015. Family and household sizes have
increased since 2000. While owner -occupancy rates are declining, for an
urban city, there still is a healthy balance between owner -occupied and
renter -occupied housing units. The number of households has been
increasing over the past 15 years at the same time as the population has
increased. The increase in households and increase in population has put
more housing supply pressure on the renter -occupied housing market.
Household Tenure by Race and Ethnicity
The table below compares homeowners and renters by race and ethnicity
in Oshkosh. White households represent 95.6% of all households, 97.5%
of homeowners, and 93.5% of renters. Asian households represent 2.4%
of all households, 1.6% of homeowners, and 3.2% of renters. Black or
African American households represent 1.2% of all households, 0.2% of
homeowners, and 2.4% of renters. Hispanic or Latino households
represent 1.6% of all households, 1.0% of homeowners, and 2.2% of
renters.
Analysis of Impediments to Fair Housing Choice 26 of 159
City of Oshkosh, WI
Household Tenure by Race and Ethnicity in the City of Oshkosh
2010 U.S. Census
2011-2015 ACS
Cohort
Owner
Renter
Owner
Renter
Householder who is White
97.0%
92.2%
97.5%
93.5/° °
alone
Householder who is Black
0 4%
2 1 %
0.2 °
2.4 °
/°/°
or African American alone
Householder who is
American Indian and
0.3%
0.7%
0.1%
0.1%
Alaska Native alone
Householder who is Asian
1.5%
1.6%
3.2%
alone
.7%
Householder who is
Native Hawaiian and
0.0
0.
0.0%
0.0%
Other Pacific Islander
alone
Householder who is some
%
0.9%
0.1 %
0.2%
other race alone '4
Householder who is two or
0.5%
1.3%
0.5%
0.5%
more races
Householder who is
1.1 %
2.6%
1.0%
2.2/° °
Hispanic or Latino
Source: 2010 U.S. Census and 2011-2015 ACS
Homeownership rates continue to decline in the City. Homeowners
represented 57.6 percent (13,833 households) of all households in 2000,
56.2 percent (14,693 households) of all households in 2010, and 53.0
percent (13,868 households) of all households in 2015. In response, rental
rates increased in the City. Renters represented 42.4 percent (10,193
households) of all households in 2000, 43.7 percent (11,445 households)
of all households in 2010, and 47.0 percent (12,284 households) of all
households in 2015.
Analysis of Impediments to Fair Housing Choice 27 of 159
City of Oshkosh, WI
Significant shifts in the City of Oshkosh include the 825 unit decrease in
owner -occupied units from 2010 to 2015, which was a 6.0 percentage
point decrease and the 839 unit increase in renter -occupied units from
2010 to 2015 was an 8.0 percentage point increase.
Families
In 2000, there were a total of 24,082 households in Oshkosh. Non -family
households comprised 43.3% (10,429 households) of all households. In
2010, there were a total of 26,138 households, an increase of 2,056
households, and the percentage of non -family households had increased
to 47.0% (12,302 households). There was an increase of 1,873 non -family
households between 2000 and 2010. The increase in households was not
necessarily because of an increase of non -family households, but the net
increase of non -family households is 91.1 % of the net increase all
households. In 2015, there were a total of 26,152 households, of which
48.4% (12,662 households) were non -family households. The total
number of households in Oshkosh increased by 14 households from 2010
to 2017. as did the total number of -family households, an increase of
2.9% (360 households). non-f household is defined as a
householder living alone o i n related by family.
In 2015, non -family houselTs comprised 48.4% of all households,
married -couple family house s comprised 40.0% of all households,
female householders with no usband present comprised 11.5% of all
households, and male householders with no wife present comprised 4.1 %
of all households in the City. The chart below illustrates the breakdown of
households by type in the City of Oshkosh as of 2015 using data from the
2011-2015 ACS.
Analysis of Impediments to Fair Housing Choice 28 of 159
City of Oshkosh, WI
Households in Oshkosh
)uple family household
eholder, no wife present,
Behold
useholder, no husband
imily household
household
Source: 2011-2015 ACS
Analysis of Impediments to Fair Housing Choice 29 of 159
City of Oshkosh, WI
C. Income and Poverty:
Household Income
The median household income for the City of Oshkosh increased by 0.5
percent over the time period of 2010 to 2015 from $42,435 in 2010 to
$42,650 in 2015.
The median household income for Winnebago County increased by 2.0
percent over the same time period from $50,974 in 2010 to $52,018 in
2015.
The median household income for the State of Wisconsin increased by 3.4
percent over the same time period from $ 98 in 2010 to $53,357 in
2015.
The table below compares the distri on of h ehold income according
to the 2006-2010 American C unity Sury and the 2011-2015
American Community Survey.
Household Income in kosh. WI
MW
Items
J/N'
IL A V
2 006-2010 ACS
2011-2015 ACS
Number of
`Households
fl
percentage
Number of
Households
percentage
Total Households
25,081
-
26,152
-
Less than $10,000
1,574
6.30%
1,705
6.50%
$10,000 to $14,999
1,604
6.40%
1,873
7.20%
$15,000 to $24,999
3,840
15.30%
3,930
15.00%
$25,000 to $34,999
3,170
12.60%
3,337
12.80%
$35,000 to $49,999
4,122
16.40%
4,071
15.60%
$50,000 to $74,999
5,297
21.10%
5,347
20.40%
$75,000 to $99,999
2,718
10.80%
2,938
11.20%
$100,000 to $149,999
2,079
8.30%
2,080
8.00%
$150,000 to $199,999
360
1.40%
532
2.00%
$200,000 or more
317
1.30%
339
1.30%
Median Household Income
42,435
-
42,650
-
Source: 2006-2010 and 2011-2015 ACS
Analysis of Impediments to Fair Housing Choice 30 of 159
City of Oshkosh, WI
FY 2019 Income Limits Oshkosh -Neenah, WI MSA HUD Metro FMR Area
Income
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
7 Person
8 Person
Category
Extremely
Low
(30%)
$16,450
$18,800
$21,330
$25,750
$30,170
$34,590
$39,010
$43,430
Income
Limits
Very Low
(50%)
$27,400
$31,300
$35,200
$39,100
$42,250
$45,400
$48,650
$51,750
Income
Limits
Low
(80%)
$43,900
$50,200
$56,450
$62,700
$67,750
$72,750
$77,750
$82,800
Income
Limits
Source: U.S. Departtfi€nt using and Urban Development
On February 14, 2019, HUD released CPD-19-0 tice that updated the
Department's Low- and Moderate -Income Summary Data (LMISD) based
on the American Community Survey 2011-2015 5-year estimates (2015
ACS). These data will replace the prior LMISD based on the American
Community Survey 2006-2010 5-year estimates (2010 ACS) for the
purposes of demonstrating compliance with the CDBG National Objective
of providing benefit to low- and moderate -income persons on an area
basis ("Area Benefit" or LMA). The table below highlights the current low -
and moderate -income population in the City of Oshkosh, and in
Winnebago Courk. The block groups that have a population of more than
51 % to oderate-income are highlighted and bold. The City of
Oshk has an erall low- and moderate -income population of 50.81 %.
Analysis of Impediments to Fair Housing Choice 31 of 159
City of Oshkosh, WI
Low- and Moderate -Income Population FY 2019 for Oshkosh and
Winnebago County
PLACE
Oshkosh
COUNTY
Winnebago County
CT
100
BG
1
LIVIII
450
TOT
.O.
1,135
PERCENT
39.65%
Oshkosh
Winnebago County
100
2
480
1,100
43.64%
shkos
Winnebago County
100
77.42%
Oshkosh
Winnebago County
200
1
430
890
48.31%
Oshkosh
Winnebago County
200
2
290
780
37.18%
shkos
Winnebago County
200
,030
71.00%
Oshkosh
Winnebago County
300
1
350
875
40.00%
Oshkosh
Winnebago County
300
2
1,025
2,140
47.90%
Oshkosh
Winnebago County
300
3
160
1,145
13.97%
Oshkosh
Winnebago County
400
1
415
765
54.25%
Oshkosh
Winnebago County
400
2
820
1,220
67.21%
Oshkosh
Winnebago County
400
555
965
57.51%
Oshkosh
Winnebago County
500
1
625
1,265
49.41%
Oshkosh
Winnebago County
500
2
165
505
32.67%
Oshkosh
Winnebago County
500
3
1,295
1,455
89.00%
Oshkosh
Winnebago County
500
4
1,125
1,220
92.21%
Oshkosh
Winnebago County
500
51,
420
720
58.33%
Oshkosh
Winnebago Cgunty
Too
6
795
1,070
74.30%
Oshkosh
Winnebago County
700
1
755
855
88.30%
Oshkosh
Winnebago County
700
2
0
0
0.00%
Oshkosh
Winnebago County
700
3
1,095
1,215
90.12%
Oshkosh
Winnebago County
800
1
350
995
35.18%
Oshko
Winnebago County
800
2
665
1,175
56.60%
Oshkosh
Winnebago County
800
3
390
910
42.86%
Oshkosh
Winnebago County
900
1
620
1,645
37.69%
Oshkosh
Winnebago County
900
2
875
1,670
52.40%
Oshkosh
Winnebago County
1000
1
780
1,200
65.00%
Oshkosh
Winnebago County
1000
2
1,145
1,490
76.85%
Oshkosh
Winnebago County
1100
1
675
945
71.43%
hkosh
Winnebago County
1100
2
445
860
51.74%
Oshkosh
Winnebago County
1100
3
360
1,010
35.64%
Oshkosh
Winnebago County
1100
4
325
1,095
29.68%
Oshkosh
Winnebago County
1200
1
460
940
48.94%
Oshkosh
Winnebago County
1200
2
650
1,250
52.00%
Oshkosh
Winnebago County
1300
1
465
705
65.96%
Oshkosh
Winnebago County
1300
2
305
635
48.03%
Oshkosh
Winnebago County
1300
3
385
1,035
37.20%
Analysis of Impediments to Fair Housing Choice 32 of 159
City of Oshkosh, WI
Winnebago Count
1401
j§§F0
,040
dU3.46%
Oshkosh
Winnebago County
1400
2
305
770
39.61%
Oshkosh
Winnebago County
1400
3
650
1,585
41.01%
Oshkosh
Winnebago County
1400
4
305
825
36.97%
Oshkosh
Winnebago County
1500
1
735
1,035
71.01%
Oshkosh
Winnebago CountyMIL1500
11111MIJ5
1,180
56.36%
Oshkosh
Winnebago County
1500
3
335
1,085
30.88%
Oshkosh
Winnebago County
1600
1
880
2,110
41.71%
Oshkosh
Winnebago County
1600
2
275
585
47.01%
Oshkosh
Winnebago County
1700
1
155
1,130
13.72%
Oshkosh
Winnebago County
1700
2
215
390
55.13%
Oshkosh
Winnebago County
1700
3
580
1,030
56.31%
Oshkosh
Winnebago County
1700
4
75
330
22.73%
Oshkosh
Winnebago County
1801
1
155
2,865
5.41%
Oshkosh
Winnebago County
1801
2
630
1,270
49.61%
Oshkosh
Winnebago County
1801
3
270
1,225
22.04%
Oshkosh
Winnebago County
1803
1
475
2,285
20.79%
Oshkosh
Winnebago County
1803
1,055
2,290
46.07%
Oshkosh
Winnebago County
1803
675
1,525
44.26%
Oshkosh
Winnebago County
1804
2
355
1,085
32.72%
Oshkosh
Winnebago County
1900
,r"qw
680
1,760
38.64%
Oshkosh
Winnebago C
1900
2
395
1,785
22.13%
Sour:
U.S. Department of Housing and Urban Development
Analysis of Impediments to Fair Housing Choice 33 of 159
City of Oshkosh, WI
Low- and
ikosh
Source: U.S. Department of Housing and Urban Development
The low- and moderate -income census tracts are generally located in the
central and northern sections of the City. There is some overlap of higher
minority concentrations in the low- and moderate income census tracts in
the central and western sections of the City.
The percentage of families living in poverty experienced an increase from
8.1 % in 2010 to 9.5% in 2015, according to U.S. Census and ACS data.
Female head of household, no husband present, families with related
children under the age of 18 whose income was below poverty level was
37.3% in 2010 and 41.9% in 2015, according to U.S. Census and ACS
data.
Analysis of Impediments to Fair Housing Choice 34 of 159
City of Oshkosh, WI
There was a decrease in all people whose income level was below
poverty level from 18.8% in 2000 to 16.1 % in 2010 and then an increase
to 17.9% in 2015, according to ACS data. Individuals under the age of 18
whose income was below the poverty level was 8.6% in 2000, 14.2% in
2010 and 20.4% in 2015, according to U.S. Census and ACS data.
Family and Household Poverty
Oshkosh's poverty statistics for families with children are highlighted in the
chart below
Percentage of Families and Households in Poverty
in the City of Oshkosh, WI
Female head of household with related children
under 5 years only
Female head of household with related children
under 18 years
Families with female householder, no husband
present �I
Married couples with related children r 5
years only
Married couples with related chi un V
years
arried co fam s
Families with related children under 5 years only
Families with related children under 18 years
All families
0.00% 10.00% 20.00% 30.00% 40.00% 50.00% 60.00%
2015 2010
Source: 2006-2010 and 2011-2015 ACS
Analysis of Impediments to Fair Housing Choice 35 of 159
City of Oshkosh, WI
D. Employment:
Occupation
In 2010, according to 2010 ACS Estimates, the total number of eligible
workers (population 16 years and over) in the City of Oshkosh was 54,341
persons. In 2010, 63.9 percent (34,723 persons) of eligible workers were
active in the labor force and 6.3 percent (3,423 persons) of eligible
workers in the work force were unemployed.
In 2015, according to 2015 ACS Estimates, the total number of eligible
workers (population 16 years and over) in the City of Oshkosh was 55,751
persons. In 2015, 62.1 percent (34,621 persons) of eligible workers were
active in the labor force and 5.3 percent (2,955 persons) of eligible
workers in the work force were unemployed.
Workers in 2015 had a mean travel tiob to work of 17.1 minutes.
According to the 2011-2015 ArrV,
28.9 percent (7,563 households
receive income from Social Secui
2017 was $17,141. V%
The following
occupation.
bmmunity Survey, an estimated
seholds in the City of Oshkosh
mean Social Security Income for
distribution of Oshkosh workers by
in the City of Oshkosh 2015
■ Management, business,
science, and arts occupations
■ Service occupations
Sales and office occupations
Natural resources,
construction, and
maintenance occupations
Production, transportation,
and material moving
occupations
Source: 2011-2015 ACS
Analysis of Impediments to Fair Housing Choice 36 of 159
City of Oshkosh, WI
Worker Distribution by Occupation
in the City of Oshkosh
Production, transportation, and material moving
occupations
Natural resources, construction, and maintenance
occupations
Sales and office occupations
Service occupations
Management, business, science, and arts occupations
Worker Class in the
1.70%
6000 7000 8000 9000 10000
Porkers
2006-2010 ACS and 2011-2015 ACS
2011-2015 ACS
■ Employee of private company workers
■ Self-employed in own incorporated
business workers
® Private not -for -profit wage and salary
workers
Local, state, and Federal government
workers
Self-employed in own not
incorporated business workers and
unpaid family workers
Source: 2011-2015 ACS
Analysis of Impediments to Fair Housing Choice 37 of 159
City of Oshkosh, WI
Unemployment Rate — Oshkosh City, WI
The data is from January 2010 to September 2019.
The unemployment rate for the City is represented by the yellow line. The
data was provided as non -seasonally adjusted, so manual adjustment was
required for comparison. The non -seasonally adjusted City data was
manually adjusted to be seasonally adjusted by weighting each data point
against a moving pre-6th month and post-6th month average. By weighting
each data point against a moving average, the data becomes seasonally
adjusted by eliminating the consistent and cyclical increase in
unemployment that is observed during the December -January -February
month time frame.
The unemployment rate for the State of Wisconsin is represented by the
blue "State" line. The State data was provided by the Bureau of Labor
Statistics as seasonally adjusted, so manual adjustment was not required
for comparison.
The national unemployment rate is represented by the green "National"
line. The national data was rovided by the Bureau of Labor Statistics as
seasonally adjusted, so al atment was not required for
comparison.
Cit O cosh employment Rate
v
12
OM 10
a 8
v
E 6
o Ah"
-
a 4
E IL
v 2
c
M 0
C T Q C ? Q C T Q C T fl_ C T fl_ C ? Q C T Q C T Q C T Q C ? Q
(6 f6 N (6 f6 N (6 (6 N (6 (6 N /6 [6 N (0 c6 n (0 c6 d N c6 n N c6 Ql N Ql
o � N � m "I a � in N-4 io N-4 r N-4 x -4 M ti
o o o o o o o o o o o 0 o o 0 o o o o o o o
N O N N O �, N O n, N O n, N O n, N O N N O N N O N N O N N O N
N N N N N N N N N N
Date
—National Wisconsin Oshkosh
Source: Bureau of Labor Statistics
Data Analysis
From January 2010 to September 2019, the City unemployment rate was
slightly lower (an average of 1 percentage point) than the National
unemployment rate and was on average with the State unemployment
Analysis of Impediments to Fair Housing Choice 38 of 159
City of Oshkosh, WI
E.
rate. All three unemployment rates trended downwards at roughly the
same rate.
The trends suggest that the economic situation in the State of Wisconsin
and in the City of Oshkosh performed better than the national average.
Unemployment in Wisconsin and the City remained lower than the
national average through September 2019.
Additionally, as of February 2016, the City unemployment level dropped
below 4.0 percent, whereas the national and State unemployment level
remained above 4.0 percent until September 2016, and April 2018
respectively. The slope of the City unemployment rate trendline is flatter
than the slopes of the national and state trendlines, which could suggest
that there will be further separation between the City unemployment rate
and the state and national unemployment r s in the future.
Housing Profile:
Housing Profile
Nearly one-third (29.9 per 8,4 nits) of Oshkosh's housing stock
was built prior to 1939,V60r
o er 80 years old. The second
largest grouping (12.9 percent, 3,631 -units) of Oshkosh's housing stock
was built from 199 1999.
The followingA e c*15.
the year that housing structures were built
in the City of Os Oa6s o
eaNStNuruilt in the City of Oshkosh
Year Structure BUT
u t
Number
Percentage
Built 2014 or Later
0
-
Built 2010 to 2013
150
0.5%
Built 2000 to 2009
2,771
9.8%
Built 1980 to 1999
6,211
22.0%
Built 1960 to 1979
6,226
22.19%
Built 1940 to 1959
4,433
15.7%
Built 1939 or Earlier
8,423
29.9%
Total
28,214
Source: 2011-2015 ACS
Analysis of Impediments to Fair Housing Choice 39 of 159
City of Oshkosh, WI
The majority of housing units in the City of Oshkosh are 1-unit attached
comprising 54.2 percent (28,214 units) of housing units. Multifamily
residential structures of 10 or more units represent only 4.9 percent (1,376
units) of housing units.
The following chart illustrates the composition of the housing stock in the
City of Oshkosh as of 2015. The subsequent chart on the next page
expands on this information, detailing the number of building permits
issued until 2019.
Housing Units in the City of Oshkosh 2015
1.4% 0.0%
1-unit, detached
1-unit, attached
2 units
■ 3 or 4 units
■ 5 to 9 units
■ 10 to 19 units
20 or more units
Mobile home
Boat, RV, van, etc.
Source: 2011-2015 ACS
Analysis of Impediments to Fair Housing Choice 40 of 159
City of Oshkosh, WI
The following table contains data on the number of permits for residential
construction issued by jurisdictions in the City.
Units Authorized by Building Permits — City of Oshkosh
YEAR
Total
Single
Family
Multi -Family
5+ Units
2019
21
21
0
0
2018
37
29
8
8
2017
168
31
137
129
2016
95
14
81
71
2015
275
17
258
248
2014
157
15
Iff
136
2013
87
23
64
64
2012
28
18
10
6
2011
195
12
183
181
2010
122
22
100
90
2009
73
13
60
52
2008
110
39
71
67
2007
150
78
72
72
2006
225
51
174
154
2005
130
67
63
23
2004
286
140
146
121
2003
497
159
338
285
2002
359
157
202
134
2001
446
121
325
278
Source: SOCDS Building Permits Database, HUD
Analysis of Impediments to Fair Housing Choice 41 of 159
City of Oshkosh, WI
600
500
*= 400
c
300
aj
;_
z 200
100
0
Units Authorized by Building Permits - Oshkosh, WI
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
Single Family
The Area has seen an overall decrease in the total number of new units
constructed, most notably for single family homes. Across the 19-year
period, an average of 70.0 percent of new units each year were for multi-
family units. As such, the trends seen in the total number of units
authorized is very closely correlated with number of multi -family units
authorized. Single-family units have decreased relatively slowly over the
past ninete ears, but had a massive spike in 2007.
The minimum p s Wthe data were all between the years of 2011 and
2012, which align with the general lowest point in the national economy
following the h ing market crash of 2008-2009. The year with the
highest number of units authorized was 2003 and the year with the highest
number of single-family units was also 2003. The average number of total
units authorized per year in the years following the 2008-2009 housing
crash are only one-third the average number of total units authorized per
year in the years preceding the 2008-2009 housing crash. In general, this
data would suggest that the City of Oshkosh housing market has not
recovered from the 2008-2009 market collapse.
Analysis of Impediments to Fair Housing Choice 42 of 159
City of Oshkosh, WI
F. Housing Costs:
Owner Costs
The median monthly housing cost for owner -occupied households was
$854 in 2000; $994 in 2010; and $928 in 2015. The median monthly
housing cost for owner -occupied households increased by 16.4 percent
($140) from 2000 to 2010, decreased by 6.6 percent ($66) from 2010 to
2015, and overall increased by 8.7 percent ($74) from 2000 to 2015.
The following table illustrates mortgage status and selected monthly
owner costs in 2010 and 2015.
Monthly Owner Costs in the City of Oshkosh
Monthly Owner Cost
2006-2010 ACS
2011-2015 ACS
Number of
Housing Units
percentage
AW
Number of
Housing Units
percentage
Owner -Occupied Housing Units
14,816
5 9. 1
13,868
53.0%
Less than $300
548
3.7
439
3.2%
$300 to $499
2,385
16.1 %
2,038
14.7%
$500 to $799
2,548
&014W
3,016
21.7%
$800 to $999
1,985
6.7%
2,415
17.4%
$1,000 to $1,499
4,756
32.1 %
4,005
28.9%
$1,500 to $1,999
2,015
13.6%
1,320
9.5%
$2,000 or more
78
3.9%
635
4.6%
No Cash Rent
-
-
-
Median (dollars)
99T
928
I Source: 2006-2010 and 2011-2015 American Community Survey
The following table illustrates housing costs for owner -households in 2010
and 2015 according to the 2006-2010 ACS and the 2011-2015 ACS.
Monthly Owner Costs as a Percentaae of Household Income in the Citv of Oshkosh
2006-2010 ACS
2011-2015 ACS
Owner Costs as a % of
Income
Number of
Number of
Housing Units
percentage
Housing Units
percentage
Owner -Occupied
14,816
59.1
13,868
53.0 /o
HousingUnits
Less than $20,000
1,319
8.9%
1,331
9.6%
Less than 20 percent
74
0.5%
69
0.5%
Analysis of Impediments to Fair Housing Choice 43 of 159
City of Oshkosh, WI
20 to 29 percent
207
1.4%
166
1.2%
30 percent or more
1,037
28.6%
1,081
7.8%
$20,000 to $34,999
2,193
14.8%
2,150
15.5%
Less than 20 percent
770
5.2%
472
3.4%
20 to 29 percent
474
3.2%
707
5.1 %
30 percent or more
948
6.4%
971
7.0%
$35,000 to $49,999
2,296
15.5%
1,969
14.2%
Less than 20 percent
711
4.8%
721
5.2%
20 to 29 percent
785
5.3%
707
5.1 %
30 percent or more
800
5.4%
541
3.9%
$50,000 to $74,999
4,030
27.2%
3,300
23.8%
Less than 20 percent
1,615
10.9%
1,761
12.7%
20 to 29 percent
1,793
12.1 %
1,290
9.3%
30 percent or more
622
4.2%
250
1.8%
$75,000 or more
4,934
33.3%
5,020
36.2%
Less than 20 percent
3,748
25.3%
3,924
28.3%
20 to 29 percent
1,066
7.2%
943
6.8%
30 percent or more
119
0.8%
166
1.2%
Zero or negative income
29.6
1 0.2%
97
%
No cash rent
-
-
-
10 and 2011-2015 American Community Survey
HUD definesXnof!
Orden as a household that pays over 30
percent or moo y income on housing costs. In 2010, 23.8
percent owner -occupied units were cost burdened and
21.7 percent s) of owner -occupied households in 2015 were
cost burdened.
Fore
According to RealtyTrac, the City of Oshkosh had 20 properties in some
stage of foreclosure in November 2019; a foreclosure rate of 1 in every
12,180 housing units. In October 2019, the number of properties that
received a foreclosure filing in Oshkosh was 66.7% lower than the
previous month and 83.3% lower than the same time last year. During the
past twelve months, foreclosures have averaged 5 with a high of 11
foreclosures in July 2019 and a low of 1 foreclosures in November 2018.
Analysis of Impediments to Fair Housing Choice 44 of 159
City of Oshkosh, WI
Analysis of Impediments to Fair Housing Choice 45 of 159
City of Oshkosh, WI
Renter Costs
The median monthly housing cost for renter -occupied households was
$612 in 2010; and $671 in 2015. The median monthly housing cost for
renter -occupied households increased by 9.6 percent ($59) from 2010 to
2015.
The following table illustrates mortgage status and selected monthly renter
costs in 2010 and 2015.
Selected Monthly Renter Costs in the Citv of Oshkosh
Monthly Renter Cost
2006-2010 ACS
2011-2015 ACS
Number of
Housing Units
percentage
Number of
Housing Units
percentage
Renter -Occupied Housing Units
10,265
40.9%
12,284
47.0%
Less than $300
1,379
5.5%
565
4.6%
$300 to $499
3,687
14.7%
1,314
10.7%
$500 to $799
13,669
54.5%
6,277
51.1 %
$800 to $999
3,235
12.99%
2,579
21.0%
$1,000 to $1,499
1,956
7.8Z.
1,154
9.4%
$1,500 to $1,999
326
1.3%
111
0.9%
$2,000 or more
3
1.5%
111
0.9%
No Cash Rent
451
1.8%
197
1.6%
Median (dollars)
$612
-
$671
-
ource: 2006-2010 and 2013-2017 American Community Survey
The following to illu rates housing costs for renter -households in 2010
and 2015 according to the 2006-2010 ACS and the 2011-2015 ACS.
Selected Monthly Renter Costs as a Percentage of Household Income in the Citv of Oshkosh
2006-2010 ACS
2011-2015 ACS
Renter Costs as a % of
Income
Number of
Number of
Housing Units
percentage
Housing Units
Percentage
Renter -Occupied
10,265
40.9%
12,284
47.0%
Housing Units
Less than $20,000
3,418
33.3%
4,140
33.70%
Less than 20 percent
123
1.2%
61
0.50%
20 to 29 percent
370
3.6%
393
3.20%
30 percent or more
2,936
28.6%
3,685
30.00%
$20,000 to $34,999
2,977
29.0%
2,935
23.90%
Analysis of Impediments to Fair Housing Choice 46 of 159
City of Oshkosh, WI
Less than 20 percent
349
3.4%
257
2.10%
20 to 29 percent
1,150
11.2%
1,216
9.90%
30 percent or more
1,478
14.4%
1,462
11.90%
$35,000 to $49,999
1,807
17.6%
2,088
17.00%
Less than 20 percent
893
8.7%
811
6.60%
20 to 29 percent
801
7.8%
1,069
8.70%
30 percent or more
113
1.1 %
221
1.80%
$50,000 to $74,999
1,263
12.3%
1,941
15.80%
Less than 20 percent
1,037
10.1 %
1,474
12.00%
20 to 29 percent
205
2.0%
393
3.20%
30 percent or more
21
0.2%
74
0.60%
$75,000 or more
503
4.9%
&835
6.80%
Less than 20 percent
482
4.7%
749
6.10%
20 to 29 percent
21
0.2%
73
0.60%
30 percent or more
0
0.0%
12
0.10%
Zero or negative income
103
1.007
14
1.20%
No cash rent
185
197
1.60%
Source: 2006-2010W011-2015 American Community Survey
Gross Rent as a Percentage of Household Income in the Citv of Oshkosh
Rental Cost as a % of
Income
2006-2010 ACS
2011-2015 ACS
Number of
Housing Units
_PercentageHousina
Number of
nits
Percentage
Rental Units paying rent
10,265
12,284
Less than 15 percent
4,156
11.3%
1,617
13.2%
15 to 19 percent
1729
16.8%
1,734
14.1 %
20 to 24 percent
11235
12.0%
1,757
14.3%
25 to 29 percent
1,310
12.8%
1,387
11.3%
30 to 34 percent
760
7.4%
814
6.6%
35 percent or more
3,782
36.84%
4,632
37.7%
Not computed
293
2.85%
343
2.79%
Source: 2006-2010 and 2011-2015 American Community Survey
HUD defines a housing cost burden as a household that pays over 30
percent or more of its monthly income on housing costs. In 2010, 44.25
percent (4,542 units) of renter -occupied units were cost burdened and
44.33 percent (5,446 units) of renter -occupied households in 2015 were
cost burdened.
Analysis of Impediments to Fair Housing Choice 47 of 159
City of Oshkosh, WI
In 2010, 23.8 percent (3,526 units) of owner -occupied households were
cost burdened whereas 44.25 percent (4,542) of renter -occupied
households were cost burdened.
In 2015, 21.7 percent (3,009 units) of owner -occupied households were
cost burdened whereas 44.33 percent (5,446 units) of renter -occupied
households were cost burdened.
FY 2020 Fair Market Rents (FMR) for Oshkosh -Neenah, WI
Rent
Efficiency
One-
Two-
Three-
Four -
Bedroom
Bedroom
Bedroom
Bedroom
Fair Market Rent
J
$546
$616
$787
$1,057
$1,307
Source: U.S. Department of Housing and Urban Development
Fair Market Rents (FMRs) are primarily used to determine payment
standard amounts for HUD assisted housing.
The area median rent is estimated to be $671 according to the 2011-2015
ACS data, which is approximately the cost of a two -bedroom rental and
within market expectations. The average rents posted commercially
exceed the area median rent and fair market rents but only by a small
factor. The rental market in the City of Oshkosh is competitive and
,
assisted renta ousing units do not disproportionately impact the market
forces dirt r n the City.
Analysis of Impediments to Fair Housing Choice 48 of 159
City of Oshkosh, WI
G. Household Housing Problems:
Summary of Housing Needs
There was a 5.8% increase in the City of Oshkosh's population between
the 2000 Census and 2011-2015 American Community Survey.
Households grew by 8.6% and household income increased by 13.3%.
According to the Bureau of Labor Statistics Consumer Price Index (CPI),
prices in 2015 are 12.41 % higher than average prices as compared to
prices in 2000. The dollar experienced an average inflation rate of 2.15%
per year during this period. This relationship equated to a decrease in
housing unit supply and an increase in housing demand. Unfortunately,
even with the increase in median household incomes, housing became
more expensive in terms of real dollars for the average household in the
County.
General Demographics for City of Oshkosh
Demographics
Base Year: 2009
Most Recent Year:
op 2015
% Change
Population
66,083
66,580
1 %
Households
24,715
26,150
6%
Median Income
,328
42,650
1%
rce: 2-2009S (Base Year) and 2011-2015 ACS (Most Recent Year)
The following da s prove ed by the U.S. Department of Housing and
Urban Developrhen UD) based on the 2011-2015 ACS data. The tables
disaggregate households and housing problems based on the area's
media usehol 'ncome (HAMFI).
Household Types
Iff
0-30%
HAMFI
>30-50%
HAMFI
>50-80%
HAMFI
>80-100%
HAMFI
>100%
HAMFI
Total Households
3,865
4,100
5,490
2,945
9,750
Small Family Households
910
1,090
1,430
1,040
4,780
Large Family Households
70
115
235
300
655
Household contains at least one
person 62-74 years of age
479
735
1,045
465
1,445
Analysis of Impediments to Fair Housing Choice 49 of 159
City of Oshkosh, WI
0-30%
>30-50%
>50-80%
>80-100%
>100%
HAMFI
HAMFI
HAMFI
HAMFI
dh
HAMFI
Household contains at least one
520
910
945
374
720
person age 75 or older
Households with one or more
553
500
725
465
854
children 6 years old or younger
Source: 2011-2015 CHAS
Housing Problems (Households with one of the listed needs)
Renter
Ailk Owner
>30-
>50-
>80-
0-
>30-
>50-
>80-
0-30%
50%
80%
100%
Total
30%
50%
80%
100%
Total
AMI
AMI
AMI
AMI
AMI
MI
AMI
AMI
Substandard
Housing - Lacking
complete
15
145
0
4
4
10
15
0
15
40
plumbing or
kitchen facilities
Severely
Overcrowded -
With >1.51 people
20
0
ON
20
0
0
0
0
0
per room (and
complete kitchen
and plumbing)
49,
Overcrowded -
With 1.01-1.5
people per room
20
5
40
115
0
4
0
10
14
(and none of the
above problems)
Housing cost
burden greater
than 50% of
2,020
3
45
10
2,465
500
355
180
10
1,045
income (and none
of the above
problems)
Housing cost
burden greater
than 30% of
515
1,320
730
4
2,569
80
555
545
230
1,410
income (and none
of the above
problems
Zero/negative
Income (and none
145
0
0
0
145
90
0
0
0
90
of the above
problems)
Source: 2011-2015 CHAS
Analysis of Impediments to Fair Housing Choice 50 of 159
City of Oshkosh, WI
Housing Problems (Households with one or more Severe Housing Problems:
Lacks kitchen or complete plumbing, severe overcrowding, severe cost burden)
Renter
Owner
0-
>30-
>50-
>80-
0-
>30-
>50-
>80-
30%
50%
80%
100%
Total
30%
50%
80%
100%
Total
AMI
AMI
AMI
AMI
AMI
AMI
AMI
AMI
Having 1 or more of
2,070
590
45
55
2,760
510
370
180
35
1,095
four housing problems
Having none of four
870
2,015
3,005
1,230
7,120
180
1,120
2,265
13625
5,190
housing problems
Household has
negative income, but
145
0
0
0
145
90
0
0
0
90
none of the other
housing problems
Source: 2011-2015 CHAS
Cost Burden Greater Than 30%
Renter
Owner
0-30%
>30- >50-
50% 80%
AMI
Nall
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
Small Related
710
550 130
1,390
85
260
285
630
Large Related
70
49 0
119
0
24
35
59
Elderly
360
515 310
1, VW
310
445
230
985
Other Ali
1,435
7 334
2,534
180
195
175
550
Total need by incon11111111111111111
2,575
jj79 11 774
5,228
575
924
725
2,224
1%6A 0?1 Source: 2011-2015 CHAS
ost Burden Greater Than 50%
°
AMI °
_
Renter
Owner
>30-
50%
AMI
>50-
80%
AMI
Total
°
OAM I °
>30-
50%
AMI
>50-
80%
AMI
A
Small Related 600 ®
25
0
625
75
100
65
240
Large Related 50
1 4
0
54
0
4
0
4
Elderly 235
260
40
535
260
130
100
490
Other 1,175
210
4
1,389
165
125
15
305
Total need by inco 2,060
499
44
2,603
500
359
180
1,039
Source: 2011-2015 CHAS
Analysis of Impediments to Fair Housing Choice 51 of 159
City of Oshkosh, WI
Crowding (More than one person per room)
Renter
Owner
0-
>30-
>50-
>80-
0-
>30-
>50-
>80-
30%
50%
80%
100%
Total
30%
50%
80%
100%
Total
AMI
AMI
AMI
AMI
AMI
AMI
AMI
AMI
Single family households
40
55
0
40
135
10
4
0
10
24
Multiple, unrelated family
households
0
0
0
0
0
0
0
0
0
0
Other, non -family
households
0
0
0
0
0
0
0
0
0
0
Total need by income i
40
55
0
40
135
10
4
0
10
24
Source: 2011-2015 CHAS
The largest housing problem in the City of Oshkosh is housing
affordability. According to the 2011-2015 ACS, 42.6% of all renter
households are cost burdened by 30% or more and 24.8% of owner
households with a mortgage are cost burdened by 30% or more. Cost
burdens are especially affecting the 0-30% AMI households.
Additional housing problems that were recorded in consultations and
citizen comments included handicap accessible housing, availability of
senior housing, availability of group homes or communal living
arrangement housing, housing density issues, and code compliance for
housing. LoweZesed6w.Waawoblems.
me ouseholds and renter households are more likely
to be affected
Analysis of Impediments to Fair Housing Choice 52 of 159
City of Oshkosh, WI
H. Racial and Ethnic Housing Problems:
Housing needs disaggregated by racial and ethnic cohorts were analyzed
to determine if a racial or ethnic group disproportionately experienced a
housing need as compared to the City's overall housing needs. A
disproportionately greater need was identified when a racial or ethnic
group experienced a 10 percentage points or higher occurrence rate of
housing problems. A housing problem is defined as one of the four
following housing problems: 1. housing lacks complete kitchen facilities; 2.
housing lacks complete plumbing facilities; 3. housing has more than 1
person per room; and 4. housing cost burden is over 30%. The following
tables comprised of 2011-2015 CHAS and ACS data identify the
disproportionate housing needs in the City ohkosh.
0%-30% of Area Median&icome
Household has
Has one or more
Has none of the
no/negative
Housing Problems
of four housing
four housing
income, but
none of the
problems
problems
other housing
problems
Jurisdiction as a whole
3,170
460
235
White
2,915
415
165
Black / African American
111L 7jr
0
0
Asian JIV
j 1121L
35
50
American Indian, Alaska Nativ
0
0
Pacific Islander
0
0
Hispanic
40
10
15
D W#
30%-50% of Area Median Income
Source: 2011-2015 CHAS
Household has
Has one or more
Has none of the
no/negative
Housing Problems
of four housing
four housing
income, but
none of the
problems
problems
other housing
problems
Jurisdiction as a whole
2,840
1,260
0
White
2,580
1,200
0
Black / African American
70
35
0
Asian
80
0
0
American Indian, Alaska Native
0
0
0
Pacific Islander
0
0
0
Hispanic
65
0
0
Source: 2011-2015 CHAS
Analysis of Impediments to Fair Housing Choice 53 of 159
City of Oshkosh, WI
50%-80% of Area Median Income
Household has
Has one or more
Has none of the
no/negative
Housing Problems
of four housing
four housing
income, but
none of the
problems
problems
other housing
problems
Jurisdiction as a whole
1,500
3,995
0
White
1,375
3,820
0
Black / African American
15
45
0
Asian
59
49
0
American Indian, Alaska Native
15
10
0
Pacific Islander
0
0
0
Hispanic
29
50
0
Source: 2011-2015 CHAS
80%-100% of Area Median Income
Household has
Has one or more
Has none of the
no/negative
Housing Problems
of four housing
four housing
income, but
none of the
problems
problems
other housing
problems
Jurisdiction as a whole
325
2,620
0
White
325
2,460
0
Black / African American
0
39
0
Asian
0
34
0
American Indian, Alaska NativRE0
0
0
Pacific Islander
0
0
0
Hispanic
0
90
0
Source: 2011-2015 CHAS
The racial/ethnic household composition of the City of Oshkosh according
to the 2011-2015 ACS was 91.7% White, 3.5% Black/African American,
2.7% Asian, 0.5% American Indian Alaska Native, 0.0% Pacific Islander
and 3.0% Hispanic. There were no (0) disproportionately impacted groups
in terms of housing problems.
A severe housing problem is defined as one of the four following housing
problems: 1. housing lacks complete kitchen facilities; 2. housing lacks
complete plumbing facilities; 3. housing has more than 1.5 persons per
room; and 4. housing cost burden is over 50%. There were three (3)
disproportionately impacted groups in terms of severe housing problems;
the 0%-30% of Area Median Income Black/African American group that
experienced 45.2% of the housing problems of the income group, the
80%-100% of Area Median Income Black/African American group that
experienced 55.0% of the housing problems of the income group, and the
Analysis of Impediments to Fair Housing Choice 54 of 159
City of Oshkosh, WI
80%-100% of Area Median Income Hispanic group that experienced
24.0% of the housing problems of the income group.
Analysis of Impediments to Fair Housing Choice 55 of 159
City of Oshkosh, WI
I. Racial and Ethnic Housing Cost Burden:
Housing needs disaggregated by racial and ethnic cohorts were analyzed
to determine if a group disproportionately experienced a housing cost
burden as compared to the City's overall housing cost burdens. A
disproportionately greater need was identified when a racial or ethnic
group experienced a 10 percentage points or higher occurrence rate
of housing cost burdens. A housing cost burden is defined as household
paying over 30% of household AMI on housing costs. The following table
evaluating the 2011-2015 CHAS and ACS data address housing cost
burdens in Winnebago County.
Housing Cost Burden
Housing Cost Burden
<=30%
30-50%
>50%
No / negative
income (not
computed
Jurisdiction as a whole
17,895
4,320
3,700
235
White
17,105
3,975
3,420
165
Black / African American
140
84
65
0
Asian
310
100
160
50
American Indian, Alaska
Native
10 10,111111-
15
0
0
Pacific Islander
0 A
e-10
0
0
Hispanic
100
30
15
` Source: 2011-2015 CHAS
The racial/ethni .. eho mposition of the City of Oshkosh according
to the 2011-2015 was 91.7% White, 3.5% Black/African American,
2.7% Asian, 0.5% American Indian Alaska Native, 0.0% Pacific Islander
and 3.0% Hispanic. None (0) of the racial/ethnic groups were
disproportionately affected by housing cost burdens.
Analysis of Impediments to Fair Housing Choice 56 of 159
City of Oshkosh, WI
J. Disabled Households:
The following table includes the 2011-2015 ACS estimates for the number
of disabled individuals in the City of Oshkosh. The total population of
disabled persons in the City of Oshkosh is estimated to be 7,431 persons
which represents 12.0 percent of the total population of the City. The two
largest disability types are cognitive and ambulatory difficulties.
Disabled Persons in the City of Oshkosh
Disability Status of the Civilian
Non -Institutional Population
2011-2015 ACS
Total Civilian Population
62,149
Total Population with a disability
7,43
12.0%
Population under 5 years
3,533
5.7%
With a hearing difficulty
0
0.0%
With a vision difficulty
31
0.9%
NK
Population 5 to 17 years
8,801
14.2%
With a hearing difficulty
24
0.2%
With a vision difficulty
31
0.4%
With a cognitive difficulty
-
-
With an ambulat ry difficulty
-
With a self -car - 'fficult ;
-
-
Population 18 to 64 ye rs
41,729
67.1 %
With a hearing difficullL569
1.4%
With a vision difficult
488
1.2%
With agggnitive diffi` ulty
2,128
5.1%
With an ulatory difficulty
1,928
4.6%
With a self -care difficulty
630
1.5%
With an independent living
difficulty
1,419
3 4%
Population 65 years and over
8,086
13.0%
With a hearing difficulty
1,331
16.5%
With a vision difficulty
665
8.2%
With a cognitive difficulty
697
8.6%
With an ambulatory difficulty
1,926
23.8%
With a self -care difficulty
654
8.1%
With an independent living
difficulty
1,183
14.6%
SEX
Male Population with a disability
3,266
5.2%
Female Population with a disability
4,165
6.7%
HISPANIC/LATINO ORIGIN
White alone
7,239
11.6%
Analysis of Impediments to Fair Housing Choice 57 of 159
City of Oshkosh, WI
Black or African American alone
79
0.1 %
American Indian and Alaska
0
0.0%
Native alone
Asian alone
27
0.04%
Native Hawaiian and Other Pacific
0
0.0%
Islander alone
Some other race alone
26
0.04%
Two or more races
60
0.1 %
White alone, not Hispanic or
7,165
11.5%
Latino
Hispanic or Latino (of any race)
95
0.1 %
Source: 2011 — 2015 American Community Survey
Analysis of Impediments to Fair Housing Choice 58 of 159
City of Oshkosh, WI
III. Review/Update to Original Plan
The City of Oshkosh's current Analysis of Impediments to Fair Housing Choice
was dated accepted and approved in March 2013. City staff reviews the progress
in addressing the goals of the Al twice a year during the preparation of the
Annual Action Plan and the Consolidated Annual Performance Evaluation
Reports (CAPER). The Analysis of Impediments to Fair Housing Choice
identified the following impediments, as well as created goals and strategies to
address each impediment.
A. Summary of Impediments:
Impediment 1: Administrative Impediments (Public and Private)
Poor Understanding of Fair Housing Rights and Complaint Procedures
The low numbers of complaints and the focus group discussions strongly
reinforce the need for more robust education efforts. There are too many
landlords that don't know fair housing law, very few residents that know it,
and fear or ignorance of the complaint process among residents. This is
having the greatest impact on residents with low incomes or poor credit
who are sometimes choosing to live in substandard units because they
feel they have no viable alternative. It is imperative that the City actively
affirmatively further fair housing and this means making sure that City
residents are informed of their fair housing rights and how to file a claim.
Suggested Actions:
• Offer varied outreach activities throughout the year to reach both
landlords and residents. Collaborate with the Housing Coalition and
Student Legal Services to co-sponsor and promote outreach
events.
• Revise the City website to make information about fair housing
rights easier to find. Many people do not know that housing
discrimination issues are referred to as "fair housing", nor is it
intuitive to look for this information under "Planning Services". It is
recommended that all housing -related topics currently listed under
"Inspection Services" and "Planning Services" be consolidated in
some way at a higher level in the directory structure, and "Fair
Housing" be revised to "Fair Housing Rights" or similar.
• Include more examples of illegal discrimination in outreach
activities and materials, especially highlighting situations known to
have occurred in Oshkosh. Based on complaints received and the
Analysis of Impediments to Fair Housing Choice 59 of 159
City of Oshkosh, WI
experience of housing -related professionals, examples should be
sure to highlight the rights of
disabled residents and families with children, and the rights and
responsibilities of duplex (or multi -unit) owner -occupants with
regard to who they are (and are not) allowed to turn away.
Update:
The City has contracted with the Milwaukee Fair Housing Council for
several years and the City's Fair Housing Ordinance was revised to reflect
the current structure for investigation and disposition of complaints
through a third -party contractor (Fair Housing Council) as needed.
The City of Oshkosh continues to administer a voluntary Residential
Rental Registration and Inspection Program. The City-wide program is
voluntary and provides for the registration and inspection of residential
rental dwelling units in the City to ensure units provide safe, decent and
sanitary living conditions for tenants to prevent further deterioration of
those units. This program went into effect January 1, 2018.
Inadequate Support for Non -English Speaking Residents
Staff reported uncertainty regarding who to call for translation assistance.
Focus group participants reported landlord uncertainty as well, and
resistance to reaching out due to the assumption that they would need to
pay for su as tance. Language barriers are a clear impediment to
housing. esidents who do not speak English are typically
immigrants fro they countries and are typically non -white, and are
therefo,Vtecticlasses.
Suggested Actions:
• Identify reliable translation assistance services that can be utilized
by City staff and by landlords, realtors, lenders, etc. (especially
Spanish and Hmong) and establish funding for that assistance as
necessary.
• Enhance landlord and renter education materials and training to
incorporate information about translation services, including cost,
and continue to offer fair housing materials in Hmong and Spanish.
Update:
The City created a Rental Housing Advisory Board whose purpose is to
advise staff on the creation of rental housing educational materials and
residential rental training programs for landlords and tenants, to review
Analysis of Impediments to Fair Housing Choice 60 of 159
City of Oshkosh, WI
and make recommendations regarding City policy or changes to the
Municipal Code pertaining to rental housing.
Impediment 2: Regulatory Impediments (Public)
Misleadina Fair Housina Ordinance
The City's current Fair Housing ordinance includes an exemption for
owner -occupied buildings with four or fewer units. This exemption
matches Federal law but is inconsistent with State law, which has no such
exemption. Both laws apply in Oshkosh and the exemption should be
removed. Also, the City ordinance does not include all of the protected
classes identified by state law. While the City has been accurately
representing all of the state's protected classes in its fair housing
literature, its own ordinance should be updated to match state law, to
eliminate any confusion and as a ma r of good policy. Finally, the City's
ordinance describes the establish and function Oshkosh Commission
on Equal Opportunity in Housin ut i ractice there is no functioning
commission. There is no require ave such a commission.
Suggested Actions:
• Amend Section 16-4 City -Municipal Code to incorporate all of
the prote sse dentified by State Statute 106.5. The
amendAlsh ad arital status; sexual orientation; lawful
source o and status as a victim of domestic abuse,
se ._ual abuse, or stalking; and should add definitions for these
s.
end Section 16-5 of the City Municipal Code to remove the
mption for owner -occupied dwellings.
• Amend Sections 16-3, 16-7 and 16-8 to eliminate the Commission
on Equal Opportunity in Housing.
Update:
The City of Oshkosh has revised its Fair Housing Ordinance in 2016 to
include transgender individuals as a protected class. The City has
contracted with the Milwaukee Fair Housing Council for several years, and
the City's Fair Housing Ordinance was revised to reflect the current
structure for investigation and disposition of complaints through a third -
party contractor (Milwaukee Fair Housing Council) as needed.
Analysis of Impediments to Fair Housing Choice 61 of 159
City of Oshkosh, WI
Impediment 3: Quality Impediments (Private)
Poor Condition of Housina Stock
There is broad concern about living conditions for those with limited
financial means. Many apartments are substandard in some way and
protected classes are more likely than others to rent such units and
experience poorer living conditions.
Suggested Actions:
• Create a rental registry program that ensures proactive inspections
of units for safety and code compliance. Incorporate fair housing
information into the registration materials and process.
• Enhance landlord and renter education materials and training to
incorporate information about mold, including health risks,
prevention, and clean-up res es.
Update:
The City created a Rent ing ory Board whose purpose is to
advise staff on the creatio o h sing educational materials and
residential rental training p s landlords and tenants, to review
and make recommendations regarding City policy or changes to the
Municipal Code pertaining to rental housing.
The City continues to implement applicable HUD lead paint regulations in
owner and renter -occupied housing rehabilitation projects. The City
collaborates with the County Health Department to provide CDBG
rehabilitation assistance to income qualified owner -occupied households
with children who have elevated lead blood levels. The City's Housing
Rehabilitation Specialist is trained to use the City's XRF lead testing
machine.
In every assisted project, the participants, whether homeowners, renters,
landlords or contractors, are notified and advised of the hazards of lead
based paint. All contractors used to perform lead hazard reduction work
must be trained and certified by the State in a lead hazard reduction
discipline and associated with a certified lead company. The City prefers
to work with State Certified general contractors as part of the housing
improvement programs, as most projects disturb lead based paint or
control/abate lead paint hazards. However, the general contractor may
subcontract the lead work to a certified lead subcontractor.
Analysis of Impediments to Fair Housing Choice 62 of 159
City of Oshkosh, WI
Impediment 4: Supply Impediments (Private)
Inadequate Supply of Appropriate Housing for Residents with Disabilities
The greatest number of recorded complaints over the past 5+ years are
related to disability. Focus group participants reinforced this finding,
reporting limited options for disabled residents, and especially low-income
disabled residents because most of the accessible units are newer and
more expensive than the older, inaccessible units. This is an impediment
that disproportionately affects older residents due to the prevalence of
disability among residents over age 65.
Suggested Actions:
• Continue to offer home improvement loans to income -qualified
residents to assist with the cost of accessibility retrofits, and require
or encourage that funded projects result in "visitability", which
includes a no -step entry, one wheelchair accessible bathroom, and
32" doorways and on the main level.
• Encourage the development of more units in the City that
incorporate universal design principles. Create a pamphlet that
describes universal design, the need for more units that
accommodate residents with disabilities, and identifies design
support resources.
• Work with local developers and builders to offer training in universal
design techniques and encourage their application in all new
development, not just designated "accessible units".
Update:
The City collaborated with Habitat for Humanity and the Housing Authority
to construct an ADA compliant twindominium for income eligible handicap
homeowners.
The City collaborated with ADVOCAP on the construction of a single-
family ADA compliant house for income eligible homeowners through
ADVOCAP's Youth Build program.
Impediment 5: Transportation Impediments (Public)
Lack of Adequate Transportation Options in Some Parts of the City
Alternative transportation resources for residents who cannot drive are
generally adequate, with some important exceptions. There are some key
streets and neighborhoods that have neither sidewalks nor good bus
Analysis of Impediments to Fair Housing Choice 63 of 159
City of Oshkosh, WI
service. A noteworthy example is the multifamily apartments on Logan
Drive, off of North Jackson Street. These units include handicap -
accessible units at reasonable prices, but the lack of sidewalks or frequent
bus service limits the options for some residents to adequately meet their
daily needs.
Suggested Actions:
Work with GO Transit to review transit accessibility across the City,
and especially in Census Tracts 16 and 17. Evaluate the feasibility
of reducing headway on service to northern parts of the city to 30
minutes.
Ensure the provision of complete streets, including safe bike and
pedestrian pathways, whenever streets are built or reconstructed.
Work with the adjoining town governments and Winnebago County
to ensure adequate bike and pedestrian linkages where pockets of
Town land remain within the ity's growth area, especially to
establish connectivity from4Cnor side (tracts 16 and 17) to other
parts of the City.
Update:
The City's Transportatic
transportation service areas.
annually reviews the public
Impediment 6: Financial Impediments (Private)
Lack of Loans to Minorities
The HMDA data show that minorities, especially African Americans, are
less likely to originate a conventional loan. If they secure a loan, it is more
likely to be a non -conventional loan. The inability to secure a mortgage,
refinance, or home improvement loan is clearly a barrier to housing
choice. If this barrier is higher for members of a protected class, it is an
impediment that the City should work to eliminate.
Suggested Actions:
Provide more credit and home -buying education to citizens,
especially minority residents.
Provide education and information for local lenders on predatory
lending practices, to ensure that efforts to reduce the racial
disparities in loan origination do not have the unintended
Analysis of Impediments to Fair Housing Choice 64 of 159
City of Oshkosh, WI
Update:
The City contracts with the Fair Housing Center of Northeast Wisconsin, a
satellite office of the Metropolitan Milwaukee Fair Housing Council a
private, non-profit organization, to provide comprehensive fair housing
enforcement, outreach and education and technical assistance services to
Oshkosh residents. During the 2018 program year, 2 housing complaints
were investigated, provided referrals to 15 persons with non -fair housing
issues, conducted a fair housing presentation to 18 rental property owners
and managers. The Fair Housing Council also distributed fair housing
education materials to six organizations as well as made community
outreach contacts to the general public, civic organizations, social service
agencies and governmental staff.
In considering the factors affecting poverty that may be impacted by the
existing housing programs of the City, it appears that coordination of
production and preservation of affordable housing as well as the Public
Service programs and services targeted to special needs populations
benefit and help to reduce the numbers of families below the poverty level.
While these activities may not increase the income of these persons, the
activities aid in reducing their cost burden.
The City will be reducing the housing cost burden on these households to
some extent in completing rehabilitation projects on properties owned by
households below the poverty level limits. The reduction in housing cost
burden will result from actions that reduce energy costs and reduce the
cost of repairs needed to keep the home in habitable condition. The City
recognizes that while this in itself will not increase the level of income of
these households, it will make more domestic funds available to cover
other expenses.
Additionally, the City requires owner -occupants applying for CDBG
housing rehabilitation programs who have a large volume of debt to
participate in free budget counseling as a condition of housing
rehabilitation loan approval. This policy is based on the position that the
rehabilitation loan is a partnership effort with the City and bringing the
house into livable condition while attempting to ensure that the owner is in
a financial position to keep up the home may reduce the possibility of the
house falling into future disrepair.
Analysis of Impediments to Fair Housing Choice 65 of 159
City of Oshkosh, WI
IV. Impediments to Fair Housing 2020
Impediments to fair housing choice are defined as:
• Any actions, omissions, or decisions taken because of race, color, religion,
sex, disability, familial status, or national origin that restrict housing
choices or the availability of housing choice
• Any actions, omissions, or decisions that have this effect. In order to
determine if any impediments to fair housing choice exist, interviews and
meetings were conducted, surveys were distributed, Census data was
reviewed, and an analysis of the fair housing complaints in the City of
Oshkosh was undertaken.
A. Fair Housing Complaints:
1. Metropolitan Milwaukee Fair Ho ng Council air Housing Center
of Northeast Wisconsin
Metropolitan Milwaukee air ng
Council (MMFHC) is Onp Fair Housing Center of
organization providing nt nd Northeast Wisconsin
counseling, education, outreach, 4321 West College Ave, suite 200
professional support, and fai nding and Appleton, WI 54914
inclusive communities program MMFHC 920-560-4620
has a satelite office in Appleton, WI, called www.fairhousinciwisconsin.com
Fair Housing Center of Northeast
Wisconsin (FHCNW). The City contracts with FHCNW for fair housing
services. FHCNW provides intake and counseling services, investigative
services for persons who allege housing discrimination, referrals to
attorneys, and systemic investigations of institutional discrimination within
its Enforcement Program. The FHCNW Outreach & Education Program
provides fair housing training for interested parties, fair housing technical
assistance for government agencies, development and distribution of fair
housing educational materials, and presentations to the general public.
The mission of FHCNW is to promote fair housing throughout the State of
Wisconsin by combating illegal housing discrimination and by creating and
maintaining racially and econmically integrated housing patterns.
From January 1, 2014, through November 19, 2019, MMFHC conducted
intake of a total of 53 complaints in Winnebago County, as outlined below.
Twenty-three (23) of these complaints were sent to Oshkosh's Equal
Opportunity in Housing Commission and were subsequently referred to
MMFHC; these are included in the larger Winnebago County number.
Analysis of Impediments to Fair Housing Choice 66 of 159
City of Oshkosh, WI
2014-2019 Complaints by Protected Class*
Protected Class
Oshkosh
Winnebago
County
Age
2
5
Disability
11
29
Familial/Family Status
3
7
Lawful Source of Income
2
3
National Origin
1
4
Race
7
14
Sex
-
1
Sexual Orientation
-
1
Status as a Victim of
Domestic Abuse, Sexual
Assault, or Stalking
-
1
*As complaints can be filed on the basis of multiple protected classes, the number of
protected classes claimed is greater than the total mber of complaints filed.
2014-2019 Complaints by Prohibited Practice:
Prohibited Practice
Oshkosh
Winnebago
County
Discriminatory advertising 1&
1
1
Engaging in harassment, coercion, or
intimidation
6
13
Refusal to allow reasonable accommodation
5
13
Refusal to renew a lease or causing eviction
7
17
Refusal to rent/sell/finance/insure/construct
4
9
Two (2) of tV53mplaints remain open and ongoing assistance is being
provided. these open complaints is located in Oshkosh.
Of the 51 complaints that were closed, three (3) were closed as the result
of successful resolutions outside of administrative or judicial processes,
and an additional two (2) were closed as the result of a formal settlement
through the HUD administrative enforcement process. These two (2)
settled complaints and one (1) of the three successfully resolved cases
were in the City of Oshkosh.
All MMFHC/FHCNW complainants receive technical assistance as to their
rights under the fair housing laws and information as to their potential
options for pursuing a complaint. The remaining closed complaints were
closed after such technical assistance was provided. On a case -by -case
basis, MMFHC also provides investigative services in response to
complaints. The remaining 46 complaints were generally closed because
the complainant chose not to pursue the matter or after the complainant
Analysis of Impediments to Fair Housing Choice 67 of 159
City of Oshkosh, WI
was referred to an appropriate community resource or agency to pursue
the matter further.
2. Legal Action of Wisconsin
Legal Action of Wisconsin is a non-profit
law firm that has been serving low-income Legal Action of Wisconsin
individuals within the State of Wisconsin 404 North Main Street
since 1968. The Oshkosh office is currently Oshkosh, WI
working on a special project regarding 920-233-6521
homeowners being threatened with loss of
www.legalaction.ong
housing. The staff will provide foreclosure
defense, and a small part of the work is focused on eviction, repair issues
for tenants, and social security disability.
Legal Action of Wisconsin's goal is r t clients from becoming
homeless. Legal Action typically takes cases cerning housing, public
benefits, family law, health insura , Social Security, license revocations
and suspensions, and inaccurat rimiriW, background records and arrest
records.
Criminal background re d st records remain important
because Wisconsin had o of ost open record systems in the
country; a person with a past criminal record may find it harder to obtain
housing in OsYW
Because Legansin serves low income individuals, it does
not charge feices to income -eligible persons. Legal Action of
Wisconsin draws the majority of its funding from the Legal Service
Corporation, an independent nonprofit established by Congress in 1974.
3. Fair Housing Assistance Program (FHAP) Agencies
The Fair Housing Assistance Program offers grants to state and local
agencies that have sufficiently demonstrated to HUD that they support or
enforce a fair housing law that is substantially equivalent to the Fair
Housing Act. FHAP agencies carryout fair housing activities such as
enforcement and education in order to protect families and individuals who
believe that they have been the victims of housing discrimination.
However, there are no FHAP agencies or Substantially Equivalent
Agencies within Wisconsin. The Department of Housing and Urban
Development (HUD) refers the aforementioned Metropolitan Milwaukee
Fair Housing Council/Fair Housing Center of Northeast Wisconsin as
resources.
Analysis of Impediments to Fair Housing Choice 68 of 159
City of Oshkosh, WI
4. Fair Housing & Equal Opportunity (FHEO-HUD)
The U.S. Department of Housing and Urban
Development's (HUD's) Office of Fair Housing & Equal
Opportunity (FHEO) receives complaints regarding alleged
violations of the Fair Housing Act. According to the HUD
EQUAL HOUSING FHEO complaint tracking system, the following complaints
OPPORTUNITY were filed from January 1, 2014 until October 24, 2019:
HUD REPORTED FAIR HOUSING COMPLAINTS 2014 - 2019
City of Oshkosh - January 1, 2014 - October 24, 2019
Violation
Violation State
Filing
Closure
Closure Reason
Basis
Issues
City
and County
Date
Date
Wisconsin -
Disability
Discrimination in
Oshkosh
Winnebago
05/29/14
11/21/14
Administrative Closure
, Familial
terms/conditions/privileges relating
Status
to rental
Discriminatory refusal to rent;
Wisconsin -
Discrimination in
Oshkosh
Winnebago
07/22/14
02/08/16
No aII'
Disability
terms/conditions/privileges relating
to rental; Otherwise deny or make
housing unavailable
Discrimination in
Oshkosh
Wisconsin -
10/14/15
01/10/16
Conciliation/
Disability
terms/conditions/privileges relating
Winnebago
Settlement
to rental; Failure to make
reasonable accommodation
Discrimination in
Oshkosh
Wisconsin -
10/14/15
01/10/16
Conciliation/
Disability
terms/conditions/privileges relating
Winnebago
Settlement
to rental; Failure to make
reasonable accommodation
Oshkosh
Wisconsin -
04/25/17
07/13/17
Withdrawn after
Disability
Discriminatory refusal to rent and
Winnebago
Resolution
negotiate for rental
Discriminatory refusal to rent and
negotiate for rental; Discrimination
Oshkosh
Wisconsin -
09/28/17
03/05/19
Administrative Closure
Disability
in terms/conditions/privileges
Winnebago
relating to rental; Steering; Failure
to make reasonable
accommodation
The fair housing complaints over the past five years covered disability and
familial status. The majority of reported issues were on the basis of
disability; in particular, "discriminatory refusal to rent."
National Trends
The U.S. Department of Housing and Urban Development (HUD) funds
the Office of Fair Housing and Equal Opportunity (FHEO), whose mission
is to eliminate discrimination, promote economic opportunity, and achieve
diversity. FHEO leads the nation in the enforcement, administration,
development, and public understanding of Federal fair housing policies
and laws. FHEO enforces laws that protect people from discrimination on
the basis of race, color, religion, sex, national origin, disability, and familial
status. FHEO releases annual reports to Congress, which provide
information regarding complaints received during the particular year. The
Analysis of Impediments to Fair Housing Choice 69 of 159
City of Oshkosh, WI
following table highlights the frequency of such housing complaints for the
years of 2014, 2015, 2016, and 2017 (most recent year available)
organized by basis of complaint.
HUD and FHAP Housing Complaints Nationwide
FY 2014
FY 2015
FY 2016
FY 2017
Basis
Number of
Complaints
% of
Total
Number of
Complaints
% of
Total
Number of
Complaints
% of
Total
Number of
Complaints
% of
Total
Disability
4,621
41%
4,605
42%
4,908
45%
4,865
59%
Race
2,383
21 %
2,291
21 %
2,154
20%
2,132
26%
Familial Status
1,051
9%
1,031
9%
882
8%
871
11 %
National Origin
1,067
9%
898
8%
917
8%
834
10%
Sex
879
8%
915
8%
800
7%
826
10%
Religion
223
2%
225
2%
204
2%
800
10%
Color
146
1 %
151
1%
143
1 %
232
3%
Retaliation
867
8%
832
8%
785
7%
192
2%
Number of
Complaints
filed
11,237 411111111
il�
1
10,793
M
8,186
Source: HUD FY 2014-2017 Annual Reports on Fair Housing
Note: Complaints o Ilege more t one (1) basis of discrimination, and each base is counted as a complaint.
The majon of e HUD complaints filed nationwide in 2017 were on the
basis of disability, making up 59% of all complaints received. Race was
next, making up 26% of all complaints, followed by familial status at 11 %.
The housing complaints filed in the City of Oshkosh were primarily based
on disability, which is consistently the most common causes for
complaints across the nation. Note, the percentages for each year do not
equal 100% and the number of complaints each year do not equal the
total complaints across all areas. This is because there is often more than
one basis for the filing of a fair housing complaint.
Analysis of Impediments to Fair Housing Choice 70 of 159
City of Oshkosh, WI
5. Local Human Rights Commissions
The City of Oshkosh does not have a Human Rights Commission, but
does have a newly formed Diversity Committee and an Equal Opportunity
in Housing Commission. The Equal Opportunity in Housing Commission
receives all complaints alleging any discriminatory practice prohibited by
the Fair Housing Ordinance within the Oshkosh Municipal Code. The
Commission convenes only when there are complaints, and seeks
settlements that are agreeable to both complainant and respondent.
The City has ordinances concerning discrimination and housing under
Chapter 16 - Housing Section 16-4. The City of Oshkosh recognizes the
following protected classes, "age, color, disability, domestic abuse, sexual
assault and stalking victims, family status, gender identity and/or gender
expression, lawful source of income, marital status, national origin,
ancestry, race, religion, sex, sexual orientation, and ancestry." Section 16-
6.1 outlines enforcement of the requirements, including the use of a third
parties for some or all of the responsibilities necessary to take meaningful
actions to affirmatively further fair housing.
6. Housing and Human Se Pan'Within
e s
The City of Oshkosh inta ties offering housing and human
services within the City, the Winnebago County in order to
obtain their input and gain insight into potential impediments to fair
housing. The following agencies participated in the information gathering
throu^Agingand
cussions, individual meetings, or through surveys:
•
• sability Resource Center
• Boys and Girls Club
• Christine Anne Domestic Abuse Services
• Committee on Aging
• Day by Day Warming Shelter
• Equal Opportunity in Housing Commission
• Fair Housing Council of Northeast Wisconsin
• Forward Service Corporation
Oshkosh Area School District
• Oshkosh Food Coop
• Oshkosh Habitat for Humanity
Oshkosh Healthy Neighborhoods
Oshkosh/Winnebago County Housing Authority
• Salvation Army
Trinity Lutheran Church & School
• Winnebago Apartment Association
Analysis of Impediments to Fair Housing Choice 71 of 159
City of Oshkosh, WI
• Winnebago County Health Department
• Winnebago County Human Services
• Winnebagoland Housing Coalition
• World Relief
Each of these agencies provided feedback on their and their clients'
experiences concerning housing -related issues in the City of Oshkosh.
Below is a list of key points from each of the meetings.
• Need for affordable housing
• Need for supportive services
• Need for employment opportunities
• Need for public transportation
Many agencies also provided suggestions of how to address the identified
areas of inequality or discrimin in he City. Commonly suggested
strategies to further fair housing i e are included below:
• Provide more affordable hous
• Provide financial assis�tanc _ housing more affordable
• Provide education and%Feach on fair housing
B. Public Sector:
The Analysis of Impediments examines public policies of the jurisdiction and the
impact of those policies on fair housing choice. The City government controls
land use and development through its comprehensive plan, zoning regulations,
subdivision regulations, and other laws and ordinances passed by the Common
Council. These regulations and ordinances govern the types of housing that may
be constructed, the density of housing, and the various residential uses in a
community. Local officials and policies determine the community's commitment
to housing goals and objectives; therefore, determining if fair housing is to be
promoted or passively tolerated.
This section of the Analysis of Impediments evaluates the City's policies to
determine if there is a commitment to affirmatively further fair housing.
1. CDBG Program
The City of Oshkosh receives Community Development Block Grant
(CDBG) funds from HUD under the CDBG program. The City will receive
Analysis of Impediments to Fair Housing Choice 72 of 159
City of Oshkosh, WI
approximately $841,094 in CDBG funds for FY 2020. The City anticipates
that CDBG funding levels will remain in flux for the foreseeable future.
The City annually allocates its CDBG funds to a number of eligible
projects such as: public facility/infrastructure improvements, public
services, the removal of slum and blight, and housing activities. For FY
2020, the City has proposed to allocate its estimated CDBG funds to the
projects listed in the table below.
FY 2020 Estimated CDBG Allocation for the City of Oshkosh
COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG)PROGRAM
Central City Redevelopment
$ 150,000.00
Housing Rehabilitation
$ 205,094.00
Code Violation
$ 50,000.00
Rental Rehabilitation
$ 200,000.00
Public Services
$ 118,000.00
Neighborhood Initiatives
$ 25,000.00
Program Administration
$ 74,000.00
Fair Housing
$ 19,000.00
The majority of the activiti ted bove are undertaken in low/mod
income areas of City, as t is a high priority for the City. Additionally,
each activity is t atio Objectives of serving a low/mod area,
low/mod peopl r reducing slum/blight. Many activities in
each funding category specifically work to increase the supply of quality
affordable housing units, as well as promote fair housing choice in the
City.
The City of Oshkosh's FY 2020-2024 Five Year Consolidated Plan
identified the following six (6) strategies to address the priority needs in
the City:
Housing Strategy —
Priority Need: There is a need for decent, safe and sanitary housing that
is affordable and accessible to homebuyers, homeowners and renters.
Goals:
HS-1 Housing Support — Assist low- and moderate -income
households to access decent, safe and sanitary housing that is
affordable and accessible for rent or for sale through housing
counseling, down payment/closing cost assistance.
Analysis of Impediments to Fair Housing Choice 73 of 159
City of Oshkosh, WI
• HS-2 Housing Construction — Encourage the construction of new
affordable renter and owner occupied housing units.
• HS-3 Housing Rehabilitation — Conserve and rehabilitate existing
affordable housing units occupied by owners and renters by
addressing code violations, emergency repairs and handicap
accessibility.
Homeless Strategv —
Priority Need: There is a need for housing, services, and facilities for
homeless persons and persons at -risk of becoming homeless.
Goals:
• HO-1 Housing — Support the Continuum of Care's efforts to provide
emergency shelter, transitionalj� using, rapid rehousing, utility
support, permanent suppokapersons
using, and other permanent
housing opportunities.
• HO-2 Operation/Support social service programs and
facilities for the homele or families at -risk of
becoming homeless.
Other Saecial Needs Stra v
Priority Need: TI27 a nl% for housing, services, and facilities for
persons with special n s.
Goals:
• SN-1 Housing — Support an increase in the supply of decent, safe
and sanitary housing that is affordable and accessible for the
elderly, persons with disabilities, persons with HIV/AIDS, victims of
domestic violence, persons with alcohol/drug dependency, and
persons with other special needs through rehabilitation and new
construction of housing units.
• SN-2 Social Services — Support social service programs and
facilities for the elderly, persons with disabilities, persons with
HIV/AIDS, victims of domestic violence, persons with alcohol/drug
dependency, and persons with other special needs.
Community Development Strategv —
Priority Need: There is a need to improve the community facilities,
infrastructure, public services, and quality of life in the City.
Analysis of Impediments to Fair Housing Choice 74 of 159
City of Oshkosh, WI
Goals:
• CD-1 Community Facilities and Infrastructure — Improve the City's
public facilities and infrastructure through rehabilitation,
reconstruction, and new construction.
• CD-2 Public Safety — Support the City's public safety organizations.
• CD-3 Public Services — Improve and enhance the public and
community development services in the City.
• CD-4 Accessibility — Improve public and common use areas to be
readily accessible and usable by persons with disabilities.
• CD-5 Clearance/Demolition — Remove and eliminate slum and
blighting conditions in the City.
Economic Development Strategy —
Priority Need: There is a need to encourage employment and to promote
economic opportunities in the City.
Goals:
• ED-1 Employment — Support and promote job creation, job
retention, and skills training programs.
• ED-2 Redevelopmefft4tPlariN, and promote the development,
redevelopment, an re on of vacant commercial and
industrial areas.
• ED-3 Financial Assista e — Promote new economic development
through local, state, and federal tax incentives and programs.
• ED-4 Access to Transportation — Support the expansion of
multimodal transportation services to assist the needs of the City.
Administration, Planning, and Management Strategy —
Priority Need: There is a need for planning, administration, management,
and oversight of federal, state, and local funded programs.
Goals:
• AM-1 Overall Coordination — Provide program management and
oversight for the successful administration of federal, state, and
local funded programs, including planning services for special
studies, environmental clearance, fair housing activities, and
compliance with all federal, state, and local laws and regulations.
2. HOME Program
The City of Oshkosh is not a HOME entitlement city. The City may apply
for HOME funds on a competitive basis through State of Wisconsin,
Analysis of Impediments to Fair Housing Choice 75 of 159
City of Oshkosh, WI
C3
4.
5.
Division of Housing. The City has not applied for HOME funds for FY
2020, and has no current plans to apply for HOME funds during the next
five (5) years.
Emergency Solutions Grant (ESG) Funds
The Winnebagoland Housing Coalition, the local Continuum of Care
agency, applies each year on a competitive basis to the Wisconsin
Department of Administration (DOA) for Emergency Solutions Grant
(ESG) Funds to assist local agencies that participate in the Continuum of
Care. Members of the Winnebagoland Housing Coalition must vote each
year on which agency should act as lead agency or fiscal agent for the
funds. The ESG funds received by the CoC are then awarded to homeless
service provider agencies that serve the CoC area. For the FY 2019 grant
year, the sub -recipient in Oshkosh ' he Day by Day Warming Shelter,
which received $12,500 for s er services. ADVOCAP received
$$92,829 for Rapid Rehousing t an ecurity deposits, and $5,700 in
prevention funds; these amounts shared among homeless service
provider agencies within th�oC's th -county operating jurisdiction.
• Day by Day Warmin hre 2�,500
• Rapid Rehousing, renty deposits - $92,829
• Homeles�reveloion p$5,700
The CoC expec� u levels to at least remain level or increase
somewhat in c g fiscal year.
Housing Opport ity for Persons with AIDS (HOPWA) Funds
The City of Osh h does not receive HOPWA funds.
Other Funds
Other resources available to help Oshkosh address its housing and
community development needs include funds from the Wisconsin
Department of Administration, such as low interest mortgage finance
(HOME funds), housing rehabilitation money, Housing Cost Reduction
Initiative (HCRI) Program funds, lead -based paint reduction funds
(Abatement Grant), first-time homebuyer settlement expenses, rental
allowance funds (Rental Housing Development), and neighborhood
stabilization program (NSP) funds.
Oshkosh has successfully obtained funding from Oshkosh Area
Community Foundation, Winnebago County, Wisconsin Public Service,
Analysis of Impediments to Fair Housing Choice 76 of 159
City of Oshkosh, WI
and other state and local entities. To help with crime reduction and
revitalization activities the City has received funds through the Department
of Justice.
The following list outlines the state and federal grant funds that the City of
Oshkosh expects to use in FY 2020 to address its community
development and crime prevention/reduction needs:
Parks Department
FY20 - Winnebago County - Supplements programs and services
FY20 - Kuettner Family Grant - Programs for older adults
FY20 - Ladies Benevolent Society - Eat and Greet meals
FY20 - Friends of Oshkosh Seniors Center - Program and Operational
Funding for Oshkosh Seniors Center
FY20 - Private donations directed to the Oshkosh Senior Center - Funding
for Oshkosh Seniors Center
FY20 - Oshkosh Area Community Foundation - Forestry Department
FY20 - State of Wisconsin Department of Natural Resources - Urban
Forestry Grant
FY20 -Oshkosh Area Community F dation -Pollock Community Water
Park Maintenance Endow
FY20 - Oshkosh Area F dation - Leach Amphitheater
Maintenance Endowment
FY20 -Oshkosh Recreation'Q*rtme -Pollock Community Water Park
Support
FY20 - Stanhilber Fund - Park beautification
FY20 - Harenberg Fund - Menominee Park Zoo enhancements
FY20 - "nnebago Community Credit Union - Pollock Community Water
Park
FY20 erve Credit Union - Leach Amphitheater Tuesday Night Concerts
FY20 - Oshkosh Area Community Foundation - Pollock Community Water
Park Low Income Season Pass/Community Program Passes
FY20 - Wisconsin Public Service - Leach Amphitheater Tuesday Night
Concern Family Activity
FY20 - Oshkosh Area Community Foundation - Youth Grant for Snooze at
the Zoo
FY20 - Oshkosh Corporation - Touch a Truck Event
FY20 - Cellcom - Winter Events
FY20 - Cliff Bar - Zoo Education Programs
Police Department
FY20 - Department of Justice: Edward Byrne Memorial Justice Assistance
Grant - Portable Radio battery replacements
FY20 - Department of Justice: Bulletproof Vest Partnership Grant
Analysis of Impediments to Fair Housing Choice 77 of 159
City of Oshkosh, WI
6. Public Housing, HUD Assisted Housing, and Low Income Housing
Tax Credits
The City of Oshkosh has a variety of affordable housing options, including
public housing managed by the Oshkosh/Winnebago County Housing
Authority. There are also several privately managed HUD -assisted
developments throughout the City. These affordable housing
developments and Section 8 Vouchers are located across the City in
areas of varying income, demographics, and housing tenure.
Housing Choice Voucher usage, Public Housing developments, and Low
Income Housing Tax Credit (LIHTC) developments are distributed
throughout the City. Illustrated in the map below, there are no distinct
patterns of concentration of HUD assisted housing units. The City, as well
as the Housing Authority, is aware of the concerns of concentrating low-
income housing units within closgkroximity of each other. Both entities
encourage new affordable hou developments outside of areas of
existing HUD assisted housing bu Iso providing financial investments
into the existing HUD assisted a�rd housing units.
Analysis of Impediments to Fair Housing Choice 78 of 159
City of Oshkosh, WI
Concentration of HUD Assisted Housing
Source: HUD CPD Maps
Housin_g Authority
The Oshkosh/Winnebago County Housing Authority (OHAWCHA) is the
Public Housing Authority serving the City of Oshkosh and Winnebago
County. OHAWCHA owns and manages 571 units of public housing, of
which 457 units are in the City of Oshkosh. Additionally, the OHAWCHA
administers 425 Housing Choice Vouchers, all of which are currently
under contract.
Analysis of Impediments to Fair Housing Choice 79 of 159
City of Oshkosh, WI
The Housing Authority administers the following programs:
• Family Self -Sufficiency Program
• Family Housing Resources
• Winnebago Homebuyer Program - Downpayment Assistance
• Winnebago Homebuyer Program - Home Rehab Financing
• Winnebago Homebuyer Program - Accessible Homes
• Capital Fund Program
• Housing Choice Vouchers Program
The Housing Authority owns and manages the following Public Housing
Units:
• Scattered Sites - 156 units general occupancy
• Court Tower - 104 units, 100 Court Street, Oshkosh, WI 54901
• Raulf Place - 104 units, 530 N Main Street, Oshkosh, WI 54901
• Marian Manor - 121 units for elderly and disabled residents, 600
Merritt Avenue, Oshkosh, WI 54901
• Fox View Apartments - 31 units for elderly residents, 330 West
Main Street, Omro, WI 54963
• Riverside Commons - 30 units, 101 North Second Street,
Winneconne, WI 54986
• Cumberland Court Apartments - 72 units, 1030 Cumberland Trail,
Oshkosh, WI 54904
• Waite Rug Apartments - 56 units for elderly, disabled, or veteran
residents 300 East Custer, Avenue, Oshkosh, WI 54901
• Willow artments - 13 units, 210 S 5t" Street, Winneconne, WI
54986
Acco g to t Ho ng Authority of the City of Oshkosh and the
Housi uthorit f Winnebago County's Five -Year Plans covering 2020-
2024, th issio f both Housing Authorities is to promote adequate and
affordable housing, economic opportunity and a suitable environment free
from discrimination for all.
According to the Housing Authority's waiting lists as of January 2020,
there are approximately 375 (22%) individuals with a disability on the
public housing waiting list and approximately 157 (22%) individuals with a
disability on the housing choice voucher waiting list.
As of January 2020, there were 1,706 individuals on the Oshkosh.
Winnebago County Housing Authority's Public Housing Waiting List. Of
those families on the waiting list: 1,470 (86%) were extremely low-income;
209 (12%) were very low-income; and 27 (2%) were low-income. The
largest demand for affordable housing on the waiting list is for affordable
housing for extremely low-income households.
Analysis of Impediments to Fair Housing Choice 80 of 159
City of Oshkosh, WI
As of January 2020, there were 1,020 families on the Oshkosh/Winnebago
County Housing Authority's Housing Choice Voucher Waiting List. Of
those families on the waiting list: 862 (85%) were extremely low-income;
145 (14%) were very low-income; and 13 (1 %) were low-income. The
largest demand for affordable housing on the waiting list is for affordable
housing for extremely low-income households.
The most immediate needs of the families on the waiting list include:
decent, safe, sanitary and affordable housing; supportive services such as
employment training; access to transportation for commuting to work,
shopping, and medical services; and living wage job opportunities.
Homeless Facilities
The following is a list of CoC member supported facilities:
Day by Day Warming Shelter
Day by Day Warming Shelter is open from October 15 through April 15
every year. The shelter has twenty-five beds (25), and offers services
during its open season, as well as during its off season in limited
engagements such as offering laundry throughout the summer, as well as
hygiene and cleaning supplies. Shelter staff would like to expand its
operations. The shelter receives CDBG funds annually; the most recent
year Day by Day r $9,000.
Father Carr
Father Carr' Pla offers food, shelter, and a free clinic with licensed
doctors an s. Father Carr's operates a men's shelter with thirty-four
(34) beds, and omen and family shelter with 105 beds. According to
ADVOCAP, a me ber of the Winnebagoland CoC, it is important to note
that while Father Carr's shelters show a significant number of beds
available, the occupancy rate is only between 25%-40%. Father Carr's
policies regarding acceptable behavior limits the number of occupants
eligible for their services.
Christine Ann Domestic Violence Shelter
Christine Ann has thirty-seven (37) beds, and also offers counseling
services to individuals or families that are not staying within the shelter.
ADVOCAP
ADVOCAP, currently the CoC's fiscal agent, operates two (2) transitional
housing projects within Winnebago County, as well as supportive housing
projects and rapid re -housing projects, some of which are in Oshkosh.
Analysis of Impediments to Fair Housing Choice 81 of 159
City of Oshkosh, WI
Low Income Housing Tax Credit (LIHTC) Housing
The following is a list of Low Income Housing Tax Credit housing in the
City of Oshkosh, WI.
LIHTC PROJECTS IN OSHKOSH
Project
Project
Total
Total Low -
HUD ID Number
Project Name
Project Address
Project City
State
ZIP Code
Number of
Income
Units
Units
HOME
619 W Ninth
WIA19880070
OPPORTUNITIES
Ave
Oshkosh
WI
54902
2
2
INC
WIA19900030
618 E PKWY AVE
618Avekwy
Oshkosh
WI
54901
1
1
WIA19900035
ADVOCAP
219 Oxford Ave
Oshkosh
WI
54901
1
1
PROJECT #4
WIA19940195
SUMMERFIELD
3329 Logan Dr
Oshkosh
54901
120
120
PLACE APTS
WIA19940075
JACKSON FARM
3409 Logan Dr
Oshkosh
54901
60
60
APTS
WIA19970065
DIVISION STREET
545 Division St
Oshkosh
WI
54901
23
11
APTS
WIA19990075
IRVING PLACE
645 Division St
Oshkosh
WI
54901
24
16
APTS
WIA20020100
LAKEFRONT
651 Oak St
Oshkos
WI
54901
66
58
MANOR
WIA20070165
MARIAN MANOR
600
OSHKOSH
WI
54901
121
3
AVERITT
THE RIVERS
475 MARION
WIA20110065
SENIOR LIVING
RD
OSHKOSH
WI
54901
60
9
WIA20120055
FAIR ACRES
VW35 N,&AIN
OSHKOSH
WI
54901
55
12
TOWNHOMES
WIA20160015
THE RIVERS
4 RION
OSHKOSH
WI
54901
40
17
PHASE II
CUMBERLAND
1000-1014
WIA20161006
REDEVELOPMENT,
CUMBERLAND
OSHKOSH
WI
54904
32
2
PHASE 1, LLC
TRAIL
TOWER
COURT
WIA20123039
REDEVELOPMENT'
;100
OSHKOSH
WI
54901
51
2
LLC
STREET
TOWER
100 COURT
WIA20130021
REDEVELOPMENT
STREET
OSHKOSH
WI
54901
53
5
PHASE 2 LLC
WIA20160005
JACKSON SQUARE
2490
OSHKOSH
WI
54901
54
17
JACKSON ST
Source: https://Iihtc.huduser.gov/
There are sixteen (16) LIHTC projects with 763 units of affordable rental
housing in the City.
Analysis of Impediments to Fair Housing Choice 82 of 159
City of Oshkosh, WI
Multifamily Housin_g
The following is a list of HUD Multifamily housing in the City of Oshkosh:
TOTAL
TOTAL
HUD ID
PROPERTY NAME
ADDRESS
CITY
STATE
ZIP
ASSISTED
UNITS
ASSISTANC
UNITS
800022904
CAMELOT COURT
515/517 CAMELOT
Oshkosh
WI
54901
40
40
Subsidized, No HUD
CT
Financing
CUMBERLAND COURT
1030
Subsidized -
800022957
APTS
CUM
Oshkosh
WI
54904
72
72
Previously Insured
TRLLAND
800023031
GILEAD APARTMENTS
200 JOSSLYN ST
Oshkosh
WI
54901
15
16
Subsidized -
Previously 202/811
800023158
MARIAN MANOR
600 MERRITT AVE
Oshkosh
WI
5 1
121
121
Subsidized, No HUD
.
Financing
800023303
CLARITY CARE
930 MALLARD AVE
Oshkosh
WI
54901
16
16
Subsidized -
Previously 202/811
800023354
SIMEANNA APARTMENTS
155 N EAGLE ST
Oshkosh
I
54901
64
81
Subsidized -
Previously Insured
800023355
SIMEANNA III
151 N EAGLE ST
Oshk
WI
54901
77
78
Insured -Subsidized
800023356
SIMEANNA SOUTH
145 N EAGLE ST
Oshko
54901
60
61
Insured -Subsidized
800023505
WILLO APARTMENTS
202 E TAVE ENNESSEE
Oshkosh
54901
12
12
Insured -Subsidized
800023512
WINNEBAGO COUNTY
1721 MARICOPA
Oshk
W
54904
105
105
Subsidized, No HUD
HOUSING
DR
Financing
800069932
GILEAD II
622 West 5th Street
Oshkosh
WI
54902
8
9
202/811
800112372
GILEAD III, APARTMENTS
401 Ohio Street
Oshkosh
WI
54902
6
6
202/811
800212989
JOMAR OF ZION
521 W. 16th Street
Oshkosh
WI
54901
15
16
202/811
800219157
CIMARRON COURT
10 1 -180 Cimarron
Oshkosh
WI
54902
0
96
Insured-Unsubsidized
APARTMENTS
Co
LAKEFRONT MANOR AND
651 & 68i1.,k
SOD233509
VILLAS ,
Street `
Oshkosh
WI
54901
0
66
Insured Unsubsidized
800236553
Oakwood Mano
2675 Omro Road
Oshkosh
WI
54904
0
20
Insured-Unsubsidized
800239843
Centennial Inn Assisted
1628 North Main
Oshkosh
WI
54901
0
18
Insured-Unsubsidized
Living
Street
Source: https://www.hud.gov/program off ices/housing/mfh/presrv/mfhpreservation
There are ten (17) active HUD Multifamily Housing projects with 611 units
of affordable rental housing in the City.
Housing Choice Voucher usage, Public Housing developments, and Low
Income Housing Tax Credit (LIHTC) developments are distributed
throughout the City. Illustrated in the maps below, there are no distinct
patterns of concentration of HUD assisted housing units. The City, as well
as the Housing Authority, is aware of the concerns of concentrating low-
income housing units within close proximity of each other. Both entities
encourage new affordable housing developments outside of areas of
Analysis of Impediments to Fair Housing Choice 83 of 159
City of Oshkosh, WI
existing HUD assisted housing but are also providing financial investments
into the existing HUD assisted affordable housing units.
Location of Assisted Housing
Source: HUD CPD Maps
Analysis of Impediments to Fair Housing Choice 84 of 159
City of Oshkosh, WI
Voucher Concentration
Source: HUD CPD Maps
7. Planning, Zoning, and Building Codes
Zoning Ordinances can be overtly discriminatory by limiting development
or occupancy of housing based on a resident's race, sex, religion, national
origin, color, disability, or familial status. Additionally, discrimination, albeit
unintentional, can occur when a facially neutral ordinance has a disparate
impact on a protected class. An example of this has been litigated over
limitations in the definition of a family as 4 or fewer unrelated adults. A
ceiling of four or fewer unrelated individuals in a household may be
considered discriminatory if it can be proven that this limitation
disproportionately affects minorities, large families with children, or
individuals with disabilities. The Fair Housing Act also makes it unlawful to
refuse to make reasonable accommodations, or changes to rules, policies
Analysis of Impediments to Fair Housing Choice 85 of 159
City of Oshkosh, WI
practices, or services, when such accommodations are necessary to allow
a person with a disability an equal opportunity to use or enjoy a dwelling.
Under the Fair Housing Act, an accommodation is considered reasonable
if it does not impose an undue financial or administrative burden and it
does not fundamentally alter the zoning ordinance.
City of Oshkosh
The City's Comprehensive Plan appears to be in compliance with the
federal regulations governing fair housing. There was previously a need to
update the City's Zoning Ordinance to bring it into compliance with the
City's 2005 Comprehensive Plan.
The City of Oshkosh, Wisconsin has codified its ordinances. The City last
amended its zoning code in 2016, which became effective on January 1,
2017. The Zoning Ordinance is listed as Chapter 30 Zoning Ordinance,
under the City's Municipal Code. It can be found in its entirety online under
the Planning Services page.
In reviewing the City's Zoning Ordi , e, it is recommended that there is
a need to add informati finitio and provisions concerning Fair
Housing.
It is recommende e C include language in the Zoning Ordinance
stating the City' om ent affirmatively further fair housing through
its land use reg do Iic policies, such as zoning, to promote fair
housing c'e I residents in the City of Oshkosh. The statement
should inc en of the Fair Housing Act of 1968, the Americans
with Disabilities ' t 1990, as well as identification of the Federal
protect\cclassesThe Cg Ordinance does not appear to contain any specific
discriminatory language; however, the definitions under "Chapter 30 -
Article I — Introduction and Definitions" should be reviewed and
consideration should be given to including additional definitions.
The City should consider including the following definitions: "Fair Housing
Act", "Americans with Disabilities Act", "Handicap", and "Reasonable
Accommodation."
The Zoning Ordinance defines "Family" as:
A person living as an individual or any of the following groups living
together as a single nonprofit housekeeping unit and sharing common
living, sleeping, cooking and eating facilities:
Analysis of Impediments to Fair Housing Choice 86 of 159
City of Oshkosh, WI
1
E
3
4
5
0
7
Any number of people related by blood, marriage, domestic
partnership, legal adoption, guardianship or other duly -authorized
custodial relationship;
Two (2) unrelated adult individuals and the minor children of each.
For the purpose of this Section, "children' means natural children,
grandchildren, legally adopted children, stepchildren, foster
children, or a ward as determined in a legal guardianship
proceeding;
Three (3) unrelated adult individuals;
Up to four (4) unrelated persons who have disabilities/are disabled
or handicapped under the Fair Housing Amendment Act (FHAA) or
the Americans with Disabilities Act (ADA), are living in a single
household because of their disability, and require assistance from a
caregiver.
Up to two (2) personal attendants who provide services for family
members or roomers who are disabled or handicapped under the
Fair Housing Amendment Act (FHAA)or the Americans with
Disabilities Act (ADA) and need assistance with the activities of
daily living shall be considered part of a family. Such services may
I, meal preparation, laundry or
uals living together in a single
equivalent of a family, whether
►d, marriage or other legal
nal family."
loes not include:
/sorority, association, lodge,
i, or similar organization; and
;e association is temporary or
Definitions that have a limit of four or fewer unrelated adults may be
considered discriminatory as the limitation may have an adverse impact
on minorities or people with disabilities.
The Federal Courts have ruled that four to six persons with a disability
living together in a single-family residence, should be considered a
"family" and thereby be permitted to live together as a family in any zoning
district that permits residential uses.
The City should consider adopting a written reasonable accommodation
policy that allows for changes in rules and procedures to afford persons
with disabilities equal opportunity to housing, as required by the Fair
Housing Act. A reasonable accommodation policy would allow the City
flexibility in the application of zoning and land use, as well as providing
housing developers guidance in requesting reasonable accommodations.
Analysis of Impediments to Fair Housing Choice 87 of 159
City of Oshkosh, WI
City of Oshkosh Building Codes
The City of Oshkosh uses the following building codes:
• International Building Code 2015 Edition
• State of Wisconsin Uniform Dwelling Code
• International Mechanical Code, 2015 Edition
• International Energy Conservation Code 2015 Edition
• State of Wisconsin Electrical Code
• State of Wisconsin Plumbing Code
• International Fuel Gas Code 2015 Edition
• ADA Standards for Accessible Design 2009 ICC/ANSI A117.1
• State of Wisconsin, Division of Safet nd Professional Services
Administrative Codes (DSPS)
• Wisconsin Enrolled Building Cod
• National Fire Protection Association (N incorporated standards
• International Fire Code 2015 Edition - in place of DSPS Chapter
314, Subchapter I, Section 314.001(2).
The International Building Code (new construction) and the International
Existing Building Code (renovation/rehabilitation) are model codes and are
in compliance with the federal laws and regulations governing fair housing
and accessibility.
Building inspections are administered by the Inspection Division. The
Building Codes are enforced through plan review and inspections.
Interviews with the Inspection Division staff indicated that developers and
contractors are abiding by the State and Federal accessibility regulations
and there does not appear to be any blatant violations.
Accessibility Regulations
HUD encourages its grantees to incorporate "visitability" principles into
their designs. Housing that is "visitable" includes the most basic level of
accessibility that enables persons with disabilities to visit the home of a
friend, family member, or neighbor. "Visitable" homes have at least one
accessible means of egress/ingress for each unit, and all interior and
bathroom doorways have at least a 32-inch clear opening. As a minimum,
HUD grantees are required to abide by all Federal laws governing
accessibility for disabled persons. The City of Oshkosh appears to be in
full compliance with the HUD visitability standards.
Federal laws governing accessibility requirements include Section 504 of
the Rehabilitation Act, the Americans with Disabilities Act, and the Fair
Housing Act.
Analysis of Impediments to Fair Housing Choice 88 of 159
City of Oshkosh, WI
Section 504 of the Rehabilitation Act (24 CFR Part 8), known as "Section
504" prohibits discrimination against persons with disabilities in any
program receiving Federal funds. Specifically, Section 504 concerns the
design and construction of housing to ensure that a portion of all housing
developed with Federal funds is accessible to those with mobility, visual,
and hearing impairments.
The Americans with Disabilities Act (42 U.S.C. 12131; 47 U.S.C. 155, 201,
218, and 225) (ADA) prohibits discrimination against persons with
disabilities in all programs and activities sponsored by state and local
governments. Specifically, ADA gives HUD jurisdiction over housing
discrimination against persons with disabilities.
The Fair Housing Act prohibits discrimination in the sale or rental of
housing. It also requires that landlords must make reasonable
modifications dwellings and common use areas to accommodate persons
who have a disability. For all new residential buildings of four or more
units built after March 13, 1991: public and common areas must be
accessible to persons with disabilities; doors and hallways must be wide
enough for wheelchairs; all housing units must have accessible routes into
and through the unit; there must be accessible light switches, outlets,
thermostats; bathroom walls must be reinforced to allow for the installation
of grab bars; and kitchens and baths must be accessible so they can be
used by persons in wheelchairs.
Analysis of Impediments to Fair Housing Choice 89 of 159
City of Oshkosh, WI
Limited English Proficiency (LEP) Persons
Section 601 of Title VI the Civil Rights Act of 1964 is the federal law that
protects individuals from discrimination on the basis of their race, color, or
national origin in programs or activities that receive federal financial
assistance. One type of national origin discrimination is discrimination
based on a person's inability to speak, read, write, or understand English.
In certain situations, failure to ensure that persons who are LEP can
effectively participate in, or benefit from, federally assisted programs may
violate the Civil Rights Act.
According to the 2011-2015 American Community Survey for the City of
Oshkosh, 5.0% of residents speak a language other than English at home.
Of those residents, 28.9% report that they speak English less than "very
well." The following languages are spoken at home:
English 95.0%
Spanish 1.5%
Other Indo-European Ian es
Asian and Pacific Island Ian s
Other languages
The two largest non-Englis
and Hmong spear
Four Facto nE
1.3%
2.0%
0.3%
lations in the City are Spanish
The City as a CDBG Mitlement community is required to develop a plan
for persons of different national origins that cannot speak, read, write, or
understand English to ensure that LEP persons have meaningful access
to CDBG funded programs and services, as well as all City programs and
services. As such, the City has updated its Four Factor Analysis. The
purpose of the Four Factor Analysis is to determine the reasonableness of
language assistance for LEP persons based on the following:
1. Number or Proportion of LEP persons in the population to be
served. It is estimated that the City has a non-English speaking
population that exceed the 5% or 1,000 person LEP limit. Those non-
English speaking populations are most likely Hmong speakers. There are
additional non-English speakers in the City but in limited numbers.
2. Frequency with which LEP persons come into contact with the
program activity or service. The City of Oshkosh Economic
Development Division uses CDBG funds for activities that directly assist
City residents, such as housing and public service activities, primarily
Analysis of Impediments to Fair Housing Choice 90 of 159
City of Oshkosh, WI
through subrecipient non-profit provider agencies. Residents are likely to
have ongoing direct contact with the City's CDBG Program staff.
According to the FY 2018 CAPER and Report PR-23, the total
beneficiaries of CDBG assistance in FY 2018 were 74 individuals; 10 were
Black/African American, 61 were White, 2 were Asian, and 1 was Other,
Multi -Racial.
3. Importance of the service, information, program, and/or activity.
The City's CDBG housing and public service activities are critical to the
City's residents for access to decent, safe, sanitary, and affordable
housing, as well as necessary in terms of supportive services to
maintaining residents' quality of life. The City, local advocacy groups and
organizations, and its subrecipient agencies must be able to outreach and
interact with LEP persons to make G programs and services
accessible to LEP persons. %�
4. Resources, financial and hA n, available to the recipient.
Translation and interpretive services are vital for housing and public
services activities and would be provided by the City, either through City
staff or a community liaison, to any beneficiary that requires those
services. Additionally, CDBG citizen participation materials and public
notices will be published with the statement, "Any non-English speaking
person wishing to the public hearing should contact Ms. Darlene
Brandt at leas even 7) calendar days prior to the meeting and a
(Language) in re ill be provided. This document and program
materials ar_va in (Language) upon request."
The C111r doe
to the CDBC
language ass
Ma formal written Language Access Plan
im, its staff and subrecipients, utilize the
plan to assist LEP persons:
Specific
following
• Engaging advocacy groups to promote services available through
the CDBG Program
• Interpretation and translation services by partnering with LEP
groups, faith based organizations, and schools
• Referrals to community liaisons proficient in the language of LEP
persons
• Notices and training to staff of the availability of LEP services
• Advertising language services in outreach documents
• Utilize HUD translated documents found at:
https://www.hud.gov/program offices/fair housing equal opp
/17lep
Analysis of Impediments to Fair Housing Choice 91 of 159
City of Oshkosh, WI
10. Taxes
While real estate tax rates may not be an impediment to fair housing
choice, the amount and method of calculation of taxes impacts the
affordability of housing especially as it relates to housing in the
surrounding area.
The following table shows the millage rates for the City of Oshkosh.
Tax Rates in the City of Oshkosh for 2019-2020
2019 Assessed Rate
2018 Assessed Rate
County
5.284
5.352
Area Schools
9.959
9.424
Area Vocational
1.105
1.114
City
10.903
10.582
State School Credit
1.719
1.725
Total
25.533
24.747
Source: City of Oshkosh
Real estate tax are highest in the Cities as compared to the
County. shown that property values tend to appreciate
slower in areas of higher effective property tax rates as compared to areas
of lower effective property tax rates. This is of course contingent on the
real tax rate as it relates to assessed home values.
11. Comprehensive Plan
In 2018, the City of Oshkosh updated its Comprehensive Plan. The goals
identified for the City are divided according to subject, and are as follows:
Analysis of Impediments to Fair Housing Choice 92 of 159
City of Oshkosh, WI
Goals —
1. Housing
• Develop policies and programs to create housing products to
address unmet needs as market conditions evolve.
• Maintain or rehabilitate the City's existing housing stock.
• Enhance environmental quality, promote good design, and
eliminate and lessen land use conflicts throughout the community.
• Ensure ongoing communication regarding housing issues and
activities.
2
3
Land Use
• Provide sufficient land area with adequate services to meet
projected land demand for various types of land uses.
• Encourage the efficient and compact utilization of land.
• Encourage compatible land use development.
• Encourage redevelopment to be oriented toward the waterfront and
increase public access where appropriate.
• Maintain, preserve and enhance the availability of existing
neighborhood development.
• Promote environmentally sensitive and responsible utilization of
land, incorporating permanent open space and natural resources.
TransportatiCei
• Provi dell -designed collector and arterial streets
and h.
• cre a the efficiency and "reduce friction" on principal arterial
stree hich form the primary circulation system.
Maintai efficiency of the regional highway system for high
eed ' racity transportation.
• adequate parking is available throughout the City.
• Pro ide quality public transit and paratransit services.
• Provide facilities for pedestrian and bicycle circulation.
• Maintain adequate and efficient aviation facilities serving the
Oshkosh area.
• Encourage the establishment of passenger rail service in the
Oshkosh area.
4. Economic Development
• Leverage the collective assets of the broader region for
increased economic prosperity within the City of Oshkosh.
• Promote and support diversification of the industrial and
manufacturing employment base in order to have a more
resilient local and regional economy.
Analysis of Impediments to Fair Housing Choice 93 of 159
City of Oshkosh, WI
• Have a strong core of stable employers within the City of
Oshkosh.
• Support the growth of entrepreneurship activities and new
companies within the City of Oshkosh.
• Promote Oshkosh as a regional economic center within the
larger Fox Valley/1-41 Corridor market.
• Develop physical facilities within designated Economic Activity
Zones and other parts of Oshkosh which support economic
development linking Oshkosh to the regional and global
network.
• Promote destination tourism for individuals, or group activities
such as conferences, recreational activities, and special events.
• Support programs designed to Zal
ce and develop workforce
skills and productivity.
• Increase the economic and opportunities within the
downtown, central city and waterfront areas.
• Strengthen and improve major entryways into the City as well as
other commercial and retail corridors within the City.
• Maintain and improve the uality of the City's neighborhoods.
• Celebrate the overall high lity of life and sense of place that
the City of Oshk urr ing region have to offer.
• Continue to impr th overall aesthetic quality.
5. Utilities and Community F ities
• Expand and maint utility and community facilities and
services provided by both public and private entities that support
A*Womic and residential development.
Design facilities and services for an adequate level of service,
Nbased on standards for population and demand for those
cilities and services.
• romote neighborhoods designed to include pedestrian and
bicycle friendly facilities and public gathering places.
• Promote growth and redevelopment of property included within
the service areas of the existing infrastructure and service
system.
• Utilize environmentally sensitive methods and systems.
• Ensure ongoing communication regarding Utilities and
Community Facilities issues and activities.
6. Agricultural, Natural, and Cultural Resources
• Promote the development of urban agricultural programs and
activities.
• Protect and preserve the wetlands, shore lands, and other
environmentally sensitive areas.
Analysis of Impediments to Fair Housing Choice 94 of 159
City of Oshkosh, WI
7
• Protect aquatic and wildlife habitat when managing
development in proximity to environmental corridors, riparian
areas, and woodlands.
• Protect and develop passive and active recreation resources
(e.g. parks, trails, hunting and fishing opportunities).
• Promote and aesthetically pleasing natural environmental
throughout the City.
• Promote the on -going viability of publicly and privately owned
cultural resources.
• Create a strong and vibrant cultural tourism program.
• Promote and publicize cultural events and sites within the City.
• Encourage preservation and protection of the historic built
environment.
• Maintain, improve, and increase public access to the waterfront.
• Continue to improve the City's overall aesthetic quality.
• Ensure ongoing communication regarding agricultural, natural,
and cultural resource iss and activities.
Intergovernmental Cooperatio
• Establish mutually-bene relations with local public,
parochial, technical and univ ity educational systems.
• Establish mutually -beneficial relations with other jurisdictions.
• Adopt d maintain intergovernmental agreements with all
surro ng towns.
• Ensu ongoing communication regarding intergovernmental
issues ctivities.
e s—
ObjectivI
For Oshko.
while balan
JFthe framework to reach the City of Oshkosh's goals.
le objectives work to ensure orderly and efficient growth
the welfare of its residents.
• Conduct housing/market studies as needed to better understand
housing needs.
• Develop a variety of housing types to address unmet housing
needs.
• Make land use decisions, which fulfill the City's demand for
residential and non-residential land.
• Revise the City's Official Map to reflect essential linkages and
future roads and capacity expansions between economic activity
centers, residential neighborhoods, and regional highways.
• Coordinate the economic planning efforts of Oshkosh with other
community organizations in Oshkosh as well as other Fox Valley
communities.
Analysis of Impediments to Fair Housing Choice 95 of 159
City of Oshkosh, WI
• Promote economic development that increases the types of jobs
available in all sectors.
• Provide ongoing support to existing businesses in order to retain
them and assist in their expansion needs.
• Support programs and services that increase entrepreneurial
success.
• Create a positive image/identity for the City, in the context of the
Fox Valley Region / 1-41 Corridor, in order to attract high -quality
talent and high paying jobs.
• Develop tools to assess and evaluate facilities in concentrated
economic zones.
• Work closely with the Oshkosh Convention & Visitors Bureau to
ensure a city-wide strategy exists to draw special events to the City.
• Support educational and training programs that increase workforce
skills and productivity, including literacy.,
• Develop tools and support programs tftLfoster the redevelopment
and revitalization of older idential d employment areas
within/near the central city.
• Develop programs and i ti that decrease consumption of
new land and new material reutilizes existing buildings to the
extent practicable.
• Explore opportunitie vi direct routes into and through
the City.
• Develop an rograms that increase viability of
neighborhoods, i ludin esidences and business owners.
• Promote the di o recreation and lifestyle opportunities that
Oshkosh has to offer.
• Utilize tools and programs that enhance the City's attractiveness.
• Develop and implement plans for future facilities.
• Develop facilities and services that accommodate future population
and business needs.
• Develop neighborhoods that foster social and recreational
opportunities for citizens.
• Develop property in a manner that lessens the need for facility and
service extensions.
• Develop facilities and systems that protect the environment and
complement the existing aesthetics of the community.
• Adopt policy to verify ongoing communication with Utility and
Community Facilities stakeholders.
• Support agricultural opportunities for the community.
• Participate in programs that protect and conserve environmentally
sensitive areas.
• Develop programs that protect the environmental features during
development.
Analysis of Impediments to Fair Housing Choice 96 of 159
City of Oshkosh, WI
• Coordinate park purchases and programs that increase the amount
of and connect recreational opportunities within the City and with
other agencies and local units of government.
• Develop programs that address the aesthetic quality of new and
existing development.
• Develop partnerships and programs that promote local resources to
citizens and visitors.
• Coordinate events and advertising of cultural events for visitors.
• Develop programs that increase awareness of local events and
sites.
• Develop programs that identify and promote local historic
resources.
• Continue to provide and promote opportunities
• Continue to provide and promote opportunities for recreational
events on and public access to the Lake Winnebago and Fox River
system.
• Develop programs that update and create standards to address the
aesthetic quality of new and existing development.
• Adopt policy to verify ongoing communication with agricultural,
natural, and cultural resource stakeholders.
• Provide efficient and coordinated services.
• Establish effective intergovernmental land use policies within the
extraterritorial jurisdiction area.
• Explore intergovernmental agreements and contracts for services
outside of land use (police, garbage, etc.)
• Establish effective intergovernmental agreements that benefit long-
range planning efforts to define agreed upon jurisdictional
bound , land uses, and service levels.
. dopt icy to verify ongoing communication with
rg wer ental stakeholders.
The City's rehensive Plan does not contain any policy that would
impede fair housing choice.
12. Section 3
HUD's definition of Section 3 is:
Section 3 is a provision of the Housing and Urban Development Act
of 1968. The purpose of Section 3 to ensure that employment and
other economic opportunities generated by certain HUD financial
assistance shall, to the greatest extent feasible, and consistent with
existing Federal, State and local laws and regulations, be directed
to low- and very low income persons, particularly those who are
recipients of government assistance for housing, and to business
Analysis of Impediments to Fair Housing Choice 97 of 159
City of Oshkosh, WI
13
14.
concerns which provide economic opportunities to low- and very
low-income persons.
The City has identified the following Section 3 Goals:
All CDBG-funded construction contracts that are subject to Section 3 will
include the following documents in the attachments to the bid package —
• CDBG Entitlement Program — Oshkosh, WI — Special Conditions
(for applicable Program Year funding)
• Federal Labor Standards Provisions — HUD-4010
• Supplementary Conditions of the Contract for Construction — HUD-
2554
• Copy of Wage Decision for the Project — General Decision Number
— Publication Date
• §135.38 Section 3 Clause
• Employee Rights Under the Davis -Bacon Act — English & Spanish
Versions (posters to be displayed at the job site)
• Payroll Reporting Form WH347 (with instructions)
• Record of Employee Interview — HUD-11
• Record of Employee Interview — HUD-11 (in Spanish, including
instructions)
• Certified Payroll Form — Signature Authorization form
• Certificate g Compliance — Section 3
• Contract/Subcontractor's Statement of Workforce Needs
• Contract /Subcontractor's Estimated Project Workforce
During R its Ana ol%npediments study, no impediments or complaints
were tinned o iled based on Section 3 Requirements.
Section 504 4
The City does not have a Section 504 Plan, though it complies with
Section 504 of the Americans with Disabilities Act through its Code and
policies. It is recommended that the City adopt a formal Section 504 Plan
Transportation
Renting or owning an affordable home is not the only factor in a resident's
quality of life and access to fair housing. Having access to transportation,
whether it is a private vehicle or a public bus, is just as important as the
price of a rent or mortgage. Mobility determines whether a resident can
access work, education, services, or healthcare.
Analysis of Impediments to Fair Housing Choice 98 of 159
City of Oshkosh, WI
City of Oshkosh Transportation Department
The local bus and paratransit system in Oshkosh are served by GO
Transit which is funded by the City of Oshkosh, Winnebago County, the
State of Wisconsin and the Federal Government. GO Transit operates
buses within the City beginning at 6:15 A.M. and ending between 6:15
P.M. and 6:45 P.M., depending on the route. All routes run Monday
through Saturday, with no services on Sundays. GO Transit offers ten bus
routes that run throughout the City. All buses are accessible and
equipped with kneeling capability, wheelchair ramps and include bike
racks. GO Transit also offers a paratransit service named GO Plus to
assist individuals with disabilities who may not be able to ride a traditional
bus. The City's 10-year sidewalk plan ensures that all fixed bus routes are
accessible for all residents.
The City of Oshkosh and GO Transit completed an update to the Transit
Development Plan in 2018. GO Transit utilized surveys, advertisements
and other forms of outreach to the public for comment. The main results
of the plan were an increase in the adult fare and changes to the monthly
pass system; these changes were enacted in January 2019. GO Transit
also made the following recommendations in the 2018 Transit
Development Plan:
• Upgrades in IT systems
• Route 10 Deviation
o Could involve possible changes to route
o Could partner with Valley Transit
• Participating in 2018-2019 Commuter Feasibility Study
• Continued participation in Winnebago County Rural Transportation
Initiative and Feonix Mobility Rising pilot project
• Continue regional coordination with Valley Transit system in
Appleton
o Possibility that the Appleton and Oshkosh urban areas could
combine
• Improved coordination with Oshkosh Area School District to assist
students
• Improve coordination with City Planning, Public Works and
Engineering Departments regarding road reconstruction projects.
• Develop a transit marketing plan
GO Transit has also made changes to Route 9, which has historically has
been an underperforming route compared to others and regularly review
their routes to ensure that the needs of the community are being met.
Additionally, GO Transit through the MPO have a pilot program called
Winnebago Catch -A -Ride for the whole county, the program is a volunteer
rider program. Through the GO PLUS program low-income residents that
Analysis of Impediments to Fair Housing Choice 99 of 159
City of Oshkosh, WI
do not have reasonable access to the bus can receive service through a
ride sharing program in order to get to work. GO Transit uses the
programs in order to try to fill in service gaps that are not filled by the
standard bus service. The largest service needs are evening service and
service on Sundays.
15. Education
School districts, particularly "good" school districts, is an oft -cited reason
for families to move into an area. There are fourteen (14) public
elementary schools, five (5) middle schools, and two (2) high schools.
Wisconsin Department of Public Instruction (DPI) used the Wisconsin
Accountability Report Cards to assess a school's performance until 2018.
The purpose of the Report Cards was to provide accountability by
measuring multiple indicators of success. The indicators are rated on a
scale ranging from "Fails to Meet Expectation" to "Significantly Exceeds
Expectations." Oshkosh Area School District has an overall score of 74.0,
which is designated "Exceeds Expectations". In the categories of District
Growth, Closing Gaps, On -Track and Postsecondary Readiness, the
Oshkosh Area School District surpasses the State's overall score.
Oshkosh Area School District is less than a point off from meeting the
State's score in Student Achievement.
• 9,95 isi nrollment
• 0.4 o is dian or Alaskan Native
7.3% Asia
• 5.2% Blac r African American
• 5.1 % His is/Latino
77.8% White
• 4.2% Two or More Races
• 15.3% Students with Disabilities
41.1 % Economically Disadvantaged
5.5% English Learners
In the fall of 2019, DPI will feature ACT Aspire testing data, which
measures student readiness in reading, writing, English, mathematics, and
science for 9th and loth graders. According to the 2011-2015 ACS Data,
the City of Oshkosh has a slightly lower percentage of residents with a
high school degree (89.3%) than Winnebago County (92.0%) and the
State of Wisconsin (91.0%). There is a larger percentage of City of
Oshkosh residents without a high school degree in which poverty has
been determined (22.3%) than in Winnebago County (20.9%).
Analysis of Impediments to Fair Housing Choice 100 of 159
City of Oshkosh, WI
High school graduates that will stay local can go on to trade schools like
Fox Valley Tech, or to the University of Wisconsin -Oshkosh.
16. Nutrition - Food Deserts
Access to healthy, nutritious food is vital to a child's development, and
access to healthy, nutritious food is critical in preventative healthcare for
elderly residents. Purchasing or renting a home in an area without a
grocery store can often mean long trips via public transit to the next
neighborhood or town, reliance on the charity of neighbors, or letting a
child go malnourished. These trips can be costly in time and resources,
and the alternative is potentially a lifetime of chronic illness.
According to the United States Department of Agriculture (USDA), the
Treasury, and Health and Human Services (HHS), food deserts are
defined as low-income census tracts with a substantial number or share of
residents with low levels of access to retail outlets selling healthy and
affordable foods. In acknowledging that people live within census tracts of
varying densities, "low levels of access" can be defined as 33 percent of a
population (or at least 500 persons) either living more than half a mile (0.5
mi) from a supermarket or large grocery store in urban areas, or living ten
(10) miles in the case of rural Census Tracts.
Policy Map has several layer functions that map out Food Deserts as well
as maps utilizing Low Income and Low Access designations. The Food
Desert map is based on the Healthy Foods Financing Initiative in 2006,
which used a 1-kilometer square grid for analysis. That map is listed first
below. The map immediately following the 2006 Food Desert Map is the
Low Income and Low Access Map, which utilized 2015 USDA data, as
well as the new model of using Census Tracts as the basis for analysis.
The City's central business district boasts several restaurants, but notably
lacks a large grocery store. There is a Saturday Farmers Market held
downtown, as well as an Asian goods store, but neither one meets the
USDA criteria for a supermarket, supercenter, or large grocery store.
Analysis of Impediments to Fair Housing Choice 101 of 159
City of Oshkosh, WI
Healthy Foods Financing Initiative Designated Food Deserts, as of 2006. Food Desert
_ Sear:
Shadedd by: by: Census Tract, 2000
Insufficient Data
a�...e«• n Food Desert
Not Food Desert
Source. CDFI Fund and 1'olicyMap
WWNcA /.re EMwtl¢k Ave
are Cnv A
Ceurs OelWoe�Me :'Pr• A S Z� �
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I
F �
Analysis of Impediments to Fair Housing Choice 102 of 159
City of Oshkosh, WI
POLrCYi4J
The 2015 Low Income and
considered a "food desert".
Low Access map shows an increase in areas
Analysis of Impediments to Fair Housing Choice 103 of 159
City of Oshkosh, WI
C. Private Sector:
The private sector has traditionally generated the most easily recognized
impediments to fair housing choice in regard to discrimination in the sale, rental
or advertising of dwellings; the provision of brokerage services; or in the
availability of financing for real estate purchases. The Fair Housing Act and local
laws prohibits such practices as the failure to give the same terms, privileges, or
information; charging different fees; steering prospective buyers or renters
toward a certain area or neighborhood; or using advertising that discourages
prospective buyers or renters because of race, color, religion, sex, handicap,
familial status, and national origin.
1. Real Estate Practices
The Winnebago Apartment Association provides ethical and responsible
education and representation for landlords operating within Winnebago
County and the Greater Oshkosh area. The Association educates its
members on numerous rules and regulations, including Fair Housing and
Housing First practices. The Association holds monthly meetings that aid
in the dissemination of information for its members.
The Wisconsin Realtors Association has issued a Fair Housing
Declaration, which states, "Equal opportunity in housing is still not a reality
for many people. This goal will not be achieved until we have a housing
market which is free from discriminatory preferences and which respects,
understands and welcomes cultural diversity. To this end, each real estate
professional in our community must take a positive approach and practice
our profession in keeping with the letter and the spirit of fair housing law."
Members are expected to provide equal professional service without
regard to an individual's class as protected by law, keep informed about
fair housing laws and practices, develop fair housing policies and
practices within the real estate firm, inform clients and customers about
their rights and responsibilities, and refuse to tolerate non-compliance with
fair housing law.
2. Real Estate Advertising
Under Federal Law, no advertisement with respect to the sale or rental of
a dwelling unit may indicate any preference, limitation, or discrimination
because of race, color, religion, sex, handicap, familial status, or national
origin. Under the Fair Housing Act Amendments, descriptions are listed in
regard to the use of words, photographs, symbols or other approaches
that are considered discriminatory.
Analysis of Impediments to Fair Housing Choice 104 of 159
City of Oshkosh, WI
Real estate advertisements were reviewed from several electronic sources
such as: Facebook, Craigslist, Realtor.com, Rent.com, Zillow.com. Some
of the sources included a disclaimer from the publisher indicating that
each advertisement is subject to the Federal Fair Housing Act and that all
dwellings advertised are available on an equal opportunity basis. Most of
the sources included the Fair Housing logo. None of the publications
appeared to contain discriminatory language nor prohibited occupancy by
any protected class.
3. Private Financing
The Financial Institutions Reform, Recovery, and Enforcement Act of 1989
(F.I.R.R.E.A.) requires any commercial institution that makes five (5) or
more home mortgage loans, to report all home loan activity to the Federal
Reserve Bank under the Home Mortgage Disclosure Act (HMDA). The
annual HMDA data can be found online at www.ffiec.ciov/hmda/. The
most recent HMDA Data for the Oshkosh- Neenah Metropolitan Statistical
Area (MSA) is that of 2018, but the City used the 2015 HMDA data for this
analysis. The following tables provide an analysis of the HMDA data in the
Oshkosh -Neenah (MSA). T MSA includes the Cities of Oshkosh and
Neenah. The boundarie n the City and the County are
noncontiguous and Censu Tr can include both City and County
residents. The ho s i ed in this report represent loans on 1- to
4-family and m act d ho s from the following loan types: 1) FHA,
FSA/RHS an A; tional; 3) Refinancings; and 4) Home
Improvement.
Analysis of Impediments to Fair Housing Choice 105 of 159
City of Oshkosh, WI
The table below lists the lending activity that occurred during 2015 in the
area.
Home Loans Purchased by Location of Property and Type of Loan
Census
Tract
FHA, FSA/RHS &
VA
Conventional
Refinancing
Home Improvement
Loans
#
Amount
#
Amount
#
Amount
#
Amount
0001.00
5
705,000
26
2,103,000
34
2,750,000
8
600,000
0002.00
6
680,000
21
1,986,000
36
8
595,000
0003.00
10
1,217,000
51
6,082,000
k,351,000
00
10
277,000
0004.00
13
1,211,000
22
1,800,000
2,562,000
13
611,000
0005.00
9
666,000
50
51
14,416,000
11
408,000
0007.00
-
-
C
2,00 0
9
9,472,000
1
20,000
0008.00
8
829,000
00
39
7,059,000
11
564,000
0009.00
7
,000
3,115,000
41
4,106,000
6
359,000
0010.00
7
669,N
18
1,723,000
17
1,409,000
6
131,000
0011.00
11
1,209,000
28
2,347,000
39
3,400,000
6
286,000
0012.00
6
481,000
17
1,051,000
18
1,042,000
7
151,000
0013.00
7
932,000
33
2,548,000
38
3,392,000
9
379,000
0014.00
13
1,437,000
52
4,039,000
46
3,795,000
6
316,000
0015.00
9
944,000
33
2,871,000
40
3,532,000
8
345,000
Analysis of Impediments to Fair Housing Choice 106 of 159
City of Oshkosh, WI
0016.00
5
612,000
26
3,218
31
4,063
8
544
0017.00
6
858,000
33
4,988,000
56
10,182,000
7
409,000
0018.01
11
1,901,000
68
9,724,000
76
9,317,000
18
768,000
0018.03
11
1,980,000
47
6,946,000
62
8,866,000
8
360,000
0018.04
8
1,106,000
89
17,874,000
97
15,477,000
17
1,262,000
0019.00
6
837,000
58
9,936,000
97
10
1,477,000
0020.00
20
2,447,000
72
10,894,000
1400
kJ41101,000
30
1,139,000
0021.00
4
497,000
35
6,489,000,
8,554,000
11
451,000
0022.01
17
2,295,000
68
14,079,000
14,905,000
15
1,738,000
0022.02
11
1,872,000
9,854,000
59
8,307,000
6
210,000
0023.00
12
2,120,000
17,640,000
139
25,975,000
18
1,385,000
0024.00
19
8,000
1
18,369,000
175
24,237,000
22
1244
0025.00
10
1,387,
8
3,069,000
40
4,250,000
6
330,000
0026.01
9
1,136,000
23
2,793,000
64
6,358,000
8
560,000
0026.02
25
3,281,000
24
2,886,000
62
5,976,000
13
484,000
0027.00
18
1,722,000
23
1,854,000
35
3,352,000
8
318,000
0028.00
23
2,100,000
43
3,465,000
63
5,440,000
11
603,000
0029.00
7
726,000
8
593,000
21
1,481,000
1
13,000
Analysis of Impediments to Fair Housing Choice 107 of 159
City of Oshkosh, WI
0030.00
5
545,000
13
1,764,000
18
2,705,000
7
304,000
0031.00
6
804,000
19
2,874,000
31
3,461,000
8
171,000
0032.00
17
1,762,000
27
3,096,000
42
4,145,000
8
320,000
0033.00
18
1,622,000
29
2,669,000
37
3,233,000
10
211,000
0034.00
16
1,260,000
44
3,488,000
62
4,129,000
7
189,000
0035.00
6
665,000
12
1,115,000
35
015,000
5
198,000
0036.00
13
1,940,000
53
9,004,000
,000
12
530,000
0037.01
17
2,141,000
38
4,145,00
42
3,814,000
14
472,000
0037.02
34
6,266,000
181
3
IL 190
28,456,000
36
2,690,000
MSA/MD
Total
465
59,083,000
1,741
7,17 00
2,350
314,859,000
434
23,422,000
City of
low
Oshkosh
Loans as
33.98%
32.29%
43.60%
36.41 %
38.64%
39.32%
41.01 %
39.79%
a % of
MSA
Loans
Source: https://www.ffiec.gov/hmdaadwebreport/AggTableList.aspx
Analysis of Impediments to Fair Housing Choice 108 of 159
City of Oshkosh, WI
The table below lists the lending activity that occurred during 2015 in the
area.
Home Loans Purchased by Location of Property and Type of Loan
Loan
Loans
Originated
Approved,
Not Accepted
Applications
Denied
Applications
Withdrawn
File Closed for
Incompleteness il
FHA,
Oshkosh
158
1
18
11
4
FSA/RHS &
VA
MSA
465
5
53
36
10
Oshkosh
759
33
74
59
16
Conventional
MSA
1,741
55
197
177
28
Oshkosh
908
33
269
188
61
Refinancings
MSA
2,350
78 4
644
449
141
Home
Oshkosh
178
1
34
14
3
Improvement
Loans
MSA
434
75
34
11
Source: https://www.ffiec.gov/hmdaadwebreport/AggTableList.aspx
The table bel lists he lending activity by income group to establish a
baseline for len ivity per income.
Disposition of Loan Applications by Income of Applicant
Total
Approved
Applications
Applications
Files Closed for
Loan
Income
A s
PP
Loans Originated
But Not
Denied
Withdrawn
Incompleteness
p
Accepted
#
#
Mmijim,
#
%
#
%
#
%
#
%
Less than
50% of
112
90
80.36%
13
11.61 %
6
5.36%
3
2.68%
MSA/MD
a
median
M
50-79% of
m
MSA/MD
215
180
83.72%
2
0.93%
17
7.91 %
14
6.51 %
2
0.93%
ui
median
x
Q
80-99% of
LL
MSA/MD
100
83
83.00%
0.00%
6
6.00%
9
9.00%
2
2.00%
a
median
x
LL
100-119%
of
58
44
75.86%
1
1.72%
9
15.52%
3
5.17%
1
1.72%
MSA/MD
median
Analysis of Impediments to Fair Housing Choice 109 of 159
City of Oshkosh, WI
120% or
more of
77
65
84.42%
2
2.60%
6
7.79%
2
2.60%
2
2.60%
MSA/MD
median
Less than
50% of
MSA/MD
272
189
69.49%
6
2.21 %
53
19.49%
20
7.35%
4
1.47%
median
50-79% of
MSA/MD
494
379
76.72%
16
3.24%
52
10.53%
40
8.10%
7
1.42%
median
m
c
0
80-99% of
a
MSA/MD
274
217
79.20%
5
1.82%
26
9.49%
23
8.39%
3
1.09%
>
median
c
0
v
100-119%
of
214
174
81.31 %
5
2.34%
14
6.54°
21
9.81 %
0.00%
MSA/MD
median
120% or
more of
MSA/MD
714
596
83.47%
22
3.08%
3�
5.18%
56
7.84%
3
0.42%
median
Less than
50% of
MSA/MD
455
249
54.73%
12
2.64%
125
27.47%
49
10.77%
20
4.40%
median
50-79% of
MSA/MD
734
452
61.58%
13
77 0
148
20.16%
91
12.40%
30
4.09%
median
a)
a
80-99% of
=
MSA/MD
462
309
n10
1.9
76
16.45%
58
12.55%
10
2.16%
median
x
100-119%
of
377
1.86%
53
14.06%
48
12.73%
11
2.92%
MSA/MD
VN
median
120% or
more of
1,178
6 %
25
2.12%
176
14.94%
132
11.21%
31
2.63%
MSA/MD
median
Less than
50% of
54
31
57.41 %
1
1.85%
18
33.33%
2
3.70%
2
3.70%
MSA/MD
median
d
50-79% of
E
MSA/MD
116
82
70.69%
2
1.72%
22
18.97%
7
6.03%
3
2.59%
d
>
0
median
a
£
80-99% of
£
MSA/MD
85
67
78.82%
1
1.18%
12
14.12%
5
5.88%
0.00%
0
median
x
100-119%
of
59
48
81.36%
0.00%
5
8.47%
5
8.47%
1
1.69%
MSA/MD
median
Analysis of Impediments to Fair Housing Choice 110 of 159
City of Oshkosh, WI
120% or
more of
208
171
82.21 %
3
1.44%
16
7.69%
13
6.25%
5
2.40%
MSA/MD
median
Less than
50% of
MSA/MD
893
559
62.60%
19
2.13%
209
23.40%
77
8.62%
29
3.25%
median
50-79% of
MSA/MD
1,559
1,093
70.11%
33
2.12%
239
15.33%
152
9.75%
42
2.69%
median
80-99% of
MSA/MD
921
676
73.40%
15
1.63%
120
13.03%
95
10.31%
15
1.63%
median
0
~
100-119%
of
708
524
74.01 %
13
1.84%
81
11.44°
77
10.88%
13
1.84%
MSA/MD
median
120% or
more of
MSA/MD
2,177
1,646
75.61%
52
2.39%
20
10.799
203
9.32%
41
1.88%
median
TOTAII
6,258
4,498
71.88%
132
2.11%
884
h.13%
604
9.65%
140
2.24%
ource: https://www.ffiec.gov/hmdaadwebreport/AggTableList.aspx
The table below e g activity by racial/ethnic group.
6
Disposition of Loan Applications by Race/Ethnicity of Applicant
Total
Loans
Approved But
Applications
Applications
Files Closed for
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
Loan
Cohort
American
Indian/Alaska
Native
a
a
Asian
9
7
77.8%
1
11.1 %
1
11.1 %
ui
2
a
a
Black or African
U-
American
8
4
50.0%
1
12.5%
2
25.0%
1
12.5%
d
LL
Native Hawaiian
or Other Pacific
Islander
Analysis of Impediments to Fair Housing Choice 111 of 159
City of Oshkosh, WI
White
515
430
83.5%
3
0.5%
44
8.5%
30
5.8%
8
1.6%
2 or more
minority races
-
-
-
-
-
-
-
-
-
-
-
Joint
(White/Minority
6
5
83.3%
-
-
1
16.7%
-
-
Race)
Race Not
Available
31
19
61.3%
6
19.4%
5
16.1%
1
3.2%
Hispanic or
Latino
15
12
80.0%
3
20.0%
-
-
-
-
American
Indian/Alaska
6
5
83.3%
-
-
1
16.7%
Native
Asian
19
25
21
84%
1
1
4.0°
1
1 A&
4.0%
I
8.0%
-
-
I
Black or Africa
American
3
1
33.3%
-
-
66.7%
Native Hawaiian
or Other Pacific
4
3
75.0%
25.0%
Islander
m
c
0
White
1,852
4
1,9°
79.
.5%
159
8.6%
152
8.2%
15
0.81%
c
0
U
2 or more
minority races
-
-
Joint
(White/Mmont
29
21
2.4%
2
6.9%
1
3.4%
5
17.2%
-
-
Race)
Race Not
Available
279
210
75.3%
6
2.2%
33
11.8%
18
6.5%
12
4.3%
Hispanic or
Latino
16
7
-
-
5
4
-
-
American
Indian/Alask
5
2
40%
1
20%
1
20%
1
20%
Native
U
_
Asia
33
16
48.5%
11
33.3%
5
15.2%
1
3.0%
w
a�
Black or African
American
10
5
5
Analysis of Impediments to Fair Housing Choice 112 of 159
City of Oshkosh, WI
Native Hawaiian
or Other Pacific
3
1
33.3%
-
2
66.7%
-
-
Islander
White
3,245
2,135
67
542
385
116
2 or more
minority races
'I
-
-
1
100%
-
-
-
-
-
-
Joint
(White/Minority
28
17
60.7%
1
3.6%
5
17.9%
4
14.3%
1
3.6%
Race)
Race Not
Available
337
174
51.6%
9
2.7%
78
23.1%
54
16.0%
22
6.5%
Hispanic or
Latino
33
16
48.5%
1
3.0%
12
4%
3
10.0%
1
3.0%
American
Indian/Alaska
1
1
100.0%
-
-
-
-
-
-
-
Native
'z
1�
Asian
6
1
16.7%
-
33.3%
2
33.3%
1
16.7%
Black or Afric"
American
2
-
-
100.0%
-
-
-
-
Native Hawaiian.
or Other Pacific
2
1 P
50.0°
-
1
50.0%
Islander
E
°
a
White
4
378
78.8 /0
6
o
1.25 /0
62
o
12.9 /0
24
a
5.0/0
10
a
2.1 /o
E
d
E
2 or more
=
minority races
-
Joint
(White/Minority
1
-
-
-
-
-
-
1
100.0%
Race)
Race Not
Available
69
53
76.8%
1
1.4%
8
11.6%
7
10.1%
Hispanic or
Latino
13
6
46.2%
-
-
4
30.8%
3
23.1%
American
Indian/Alaska
12
8
66.7%
1
8.3%
1
8.3%
2
16.7%
Native
m
0
F-
Asian
73
45
61.6%
2
2.7%
15
20.5%
9
1.2%
2
2.7%
Analysis of Impediments to Fair Housing Choice 113 of 159
City of Oshkosh, WI
Black or African
American
23
10
43.5%
1
4.3%
11
47.8
1
4.3%
Native Hawaiian
or Other Pacific
9
5
55.6%
-
-
4
44.4%
-
-
Islander
White
6,092
4,423
72.6%
122
2.0%
807
13.2%
591
9.7%
149
2.4%
2 or more
minority races
1
-
-
1
100%
-
-
-
-
-
-
Joint
(White/Minority
64
43
67.2%
3
4.7%
6
9.4%
11
17.2%
1
1.5%
Race)
Race Not
Available
716
456
63.7%
16
2.2%
125
17.5%
84
11.7%
35
4.9%
Hispanic or
Latino
77
41
53.2%
1
1.3%
24
31.1%
10
13.0%
1
1.3%
Total
7,067
5,031
71.2%
146
2.
993
14.1 %
706
10.0%
191
2.7%
https.ffiec.gov/hmdaadwebreport/AggTabIeList.aspx
The following A
s wi omp denial rates per racial/ethnic group and
income to id at may have higher denial rates than
another. Higher rates are highlighted.
Dispos on of Loan Applications by Race/Ethnicity and Income of Applicant
Less than 50% of MSA/MD Median - Oshkosh, Neenah MSA
Total
Loans
Approved But
Applications
Applications
Files Closed for
Loan
Cohort
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
a
American
>
Indian/Alaska
c
m
Native
ui
=
Asian
2
2
100.0%
N
U-
Black or African;
1
1
1 D0.0%
U-
American
Analysis of Impediments to Fair Housing Choice 114 of 159
City of Oshkosh, WI
Native Hawaiian
or Other Pacific
-
-
-
-
-
-
-
-
-
Islander
White
103
84
81.6%
11
10.7%
5
4.9%
3
2.9%
2 or more
minority races
_
Joint
(White/Minority
-
-
-
-
-
-
-
Race)
Race Not
Available
6
3
50.0%
2
33.3%
1
16.7%
Hispanic or
1
1
100.0%
-
-
Latino
American
Indian/Alaska-
Native
Asian
4
3
75.0%
-
-
1
25.0%
-
Black or African
American
-
Native Hawaiian
or Other Pacific
1
1
Islander
R
c
0
y
White
248
177
0
6
2.4%
42
16.9%
20
8.1%
3
1.2%
c
0
c.�
2 or more
minority races
Joint
(White/Minority
4
75.0%
1
25.0%
-
-
-
Race)
Race Not
15
5
33.3%
9
0.60%
-
1
6.7%
Available
Hispanic or
Latino
3
1
333% .
2
°
66.7 /°
American
Indian/Alaska
-
-
-
-
-
Native
d
c
c
Asian
3
1
33.3%
1
33.3%
1
33.3%
w
a�
Black or African
2
2
100.0%
American
Analysis of Impediments to Fair Housing Choice 115 of 159
City of Oshkosh, WI
Native Hawaiian
or Other Pacific
1
-
-
-
-
1
100.0%
-
-
-
-
Islander
White
414
237
57.2%
11
2.7%
103
24.9%
46
11.1 %
17
4.1 %
2 or more
minority races
Joint
(White/Minority
-
-
-
-
-
-
-
-
-
-
-
Race)
Race Not
Available
35
11
31.4%
1
2.9%
18
51.4%
2
5.7%
3
8.6%
Hispanic or
6
1
16.7%
-
-
4
66.7%
1
16.7%
-
-
Latino
American
Indian/Alaska-
Native
Asian
1
-
1
100.0%
-
Black or African
American
1
-
100.0%
-
Native Hawaiian
or Other Pacific
-
-
-
-
-
°1
E
Islander
m
0
a.
White
50
30
T o
17
2.0%
15
30.0%
2
4.0%
2
4.0%
E
0
2 or more
=
minority races
Joint
(White/Minorit-
Race)
Race Not
2
1
50.0%
1
50.0%
Available
Hispanic or
Latino
2
1
50. 0%
1
50.0%
American
Indian/Alaska
-
-
-
-
-
Native
R
6
Asian
10
6
60.0%
3
30.0%
1
10.0%
H
Black or African
American
4
1
25.0%
3
75.0%
-
-
Analysis of Impediments to Fair Housing Choice 116 of 159
City of Oshkosh, WI
Native Hawaiian
or Other Pacific
2
1
50.0%
-
-
1
50.0%
-
-
-
-
Islander
White
815
528
64.8%
18
2.2%
171
21.0%
73
9.0%
25
3.1%
2 or more
minority races
Joint
(White/Minority
4
3
75.0%
-
-
1
25.0%
-
-
-
-
Race)
Race Not
Available
58
20
34.5%
1
1.7%
30
51.7%
3
5.2%
4
6.9%
Hispanic or
Latino
12
4
33.3%
-
-
7
5AV.
1
8.3%
-
-
Total
905
563
62.2%
19
2.1%
2
78
8.6%
29
3.2%
Source: https://www.ffiec.gov/hmdaadwebreport/AggTableList.aspx
For loan applicants under 50% of MSA/MD Median income the following
groups had denial rates tj&Lwere 10% higher than the average denial
rate:
• Race Not Avaiile F SA/RHS/, and VA loan denial rates of
33.3% (11.61% erag
• Hispania r Leat' Tonal loan denial rate of 66.7% (19.49%
Average)
• Black or Afrl American refinance loan denial rate of 100.0%
(27.47% Average)
• Native Hawaiian or other Pacific Islander refinance loan denial rate
of 100.0% (27.47% Average)
• Race Not Available refinance loan denial rate of 51.4% (27.47%
Average)
• Hispanic or Latino refinance loan denial rate of 66.7% (27.47%
Average)
• Asian home improvement loan denial rate of 100.0% (33.33%
Average)
• Black or African American home improvement loan denial rate of
100.0% (33.33% Average)
• Race Not Available home improvement loan denial rate of 50.0%
(33.33% Average)
• Hispanic or Latino home improvement loan denial rate of 50.0%
(33.33% Average)
Analysis of Impediments to Fair Housing Choice 117 of 159
City of Oshkosh, WI
Disposition of Loan Applications by Race/Ethnicity and Income of Applicant
50-79% of MSA/MD Median
Total
Loans Originated
Approved But
Applications
Applications
Files Closed for
Loan
Cohort
Apps
Not Accepted
Denied
Withdrawn
Incompleteness
American
Indian/Alaska
-
-
-
-
-
Native
Asian
4
3
75.0%
1
25.0%
-
-
-
-
Black or ;4trican
American
3
1
33.3%
-
1
3.3%
1
33.3%
Q
Native awaftan
>
or Other Pacific
-
-
-
-
-
-
-
c
Islander
uS
x
White
193
166
86.0%
1
0.5
14
7.3%
12
6.2%
(n
LL
LL
a
2 or more
LL
minority races
Joint
(White/Minority
1
1
100%
-
-
-
Race)
Race Not
14
°o
-
2
14.3%
2
14.3%
1
7.1 %
Available
Hispanic or
9
2
18.2%
-
-
-
-
Latino
.8%
American
IV
Indian/Alaska
4
75.0%
-
-
1
25.0%
Native
Asian
6
6
100.0%
Black or African
1
1
0
100.0/a
0
American
c
cNative
Hawaiian
0
or Other Pacific
-
-
-
-
-
-
-
v
Islander
White
460
360
78.3%
14
3.0%
45
10.0%
36
7.8%
5
1.1%
2 or more
minority races
Analysis of Impediments to Fair Housing Choice 118 of 159
City of Oshkosh, WI
Joint
(White/Minority
6
4
66.7%
1
1.7%
-
-
1
1.7%
-
-
Race)
Race Not
Available
17
6
35.3%
1
5.9%
6
35.3%
3
17.6%
1
5.9%
Hispanic or
8
4
50.0%
-
-
2
25.0%
2
25.0%
-
-
Latino
American
Indian/Alaska
Native
Asian
5
2
40.0%
3
60.0%
Black or African
American
Native Hawaiian
or Other Pacific
2
1
50.0%
-
1
50:0%
Islander
d
c
=
White
673
426
63.3%
13
125
18.6%
82
12.2%
27
4.0%
a)
d
2 or more
minority races
Joint
(White/Minority
2
2
All
-
-
-
-
-
-
-
Race)
Race Not
Available
51
21
0
18
35.3%
9
17.6%
3
5.9%
Hispanic or
4C
4
0.0%
-
3
37.5%
-
-
1
12.5%
Latino
American
14
Indian/Alaska
1
NOIF100.0%
-
-
-
-
-
-
Native
Asian
2
1
50.0%
1
50.0%
c
a)
E
Black or African
>
American
0
a
E
Native Hawaiian
a)
or Other Pacific
E
0
2
Islander
White
105
78
74.3%
2
1.9%
17
16.2%
5
4.8%
3
2.9%
2 or more
minority races
Analysis of Impediments to Fair Housing Choice 119 of 159
City of Oshkosh, WI
Joint
(White/Minority
Race)
Race Not
8
3
37.5%
4
50.05%
1
12.5%
Available
Hispanic or
7
3
42.9%
4
57.1%
1
14.3%
Latino
American
Indian/Alaska
5
4
80.0%
-
-
-
-
1
20.0%
Native
Asian
17
11
64.7%
1
5.9%
3
17.6%
1
5.9%
1
5.9%
Black or African
4
1
25.0%
-
-
2
%
-
-
1
25.0%
American
Native Hawaiian
or Other Pacific
2
1
50.0%
1
°o
Islander
White
1,431
1,030
72.0%
30
/6
201
14.0%
135
9.4%
35
2.4%
m
0
~
2 or more
minority races
Joint
(White/Minority
9
7
77.8%
N7_0%
1
11.0%
-
-
Race)
Race Not
90
39
43.3°/
1
30
33.3%
15
1.7%
5
5.6%
Available
.1%
Hispanic or
Latino
34
-
-
11
32.0%
3
8.8%
1
2.9%
Total
1, 92
1,113
.9%
33
2.0%
248
15.6%
155
9.7%
44
2.8%
Source: https://www.ffiec.gov/hmdaadwebreport/AggTableList.aspx
For loan applicants 50-79% of MSA/MD Median income the following
groups had denial rates that were 10% higher than the average denial
rate:
• Black or African American FHA, FSA/RHS, and VA loan denial rate of
33.33% (7.91 % Average)
• Hispanic or Latino FHA, FSA/RHS, and VA loan denial rate of 18.2%
(7.91 % Average)
• Black or African American Conventional loan denial rate of 100.00%
(10.53% Average)
• Race Not Available Conventional loan denial rate of 35.3% (10.53%
Average)
Analysis of Impediments to Fair Housing Choice 120 of 159
City of Oshkosh, WI
• Hispanic or Latino Conventional loan denial rate of 25.0% (10.53%
Average)
• Asian Conventional loan denial rate of 25.0% (10.53% Average)
• Native Hawaiian or other Pacific Islander Conventional loan denial rate of
50.0% (10.53% Average)
• Asian Refinance loan denial rate of 60.0% (20.16% Average)
• Native Hawaiian or other Pacific Islander Refinance loan denial rate of
50.0% (20.16% Average)
• Race Not Available Refinance loan denial rate of 35.3% (20.16%
Average)
• Hispanic or Latino Refinance loan denial rate of 37.5% (20.16% Average)
• Race Not Available Home Improvement loan denial rate of 50.05%
(18.97% Average)
• Hispanic or Latino Home Improvement loa enial rate of 57.1% (18.97%
Average)
Disposition of Loan Applications by Race/Ethnicity and Income of Applicant
80-99% of MSA/MD Median
Total
Loans
Approved But
Applications
Applications
Files Closed for
Loan
Cohort
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
American
Indian/Alaska
-
-
-
-
Native
Asian
1
14.
100.0%
-
Black or African
American
a
>
Native Hawaiian:®
c
or Other Pacific
-
`6
Islander
ui
x
a
White
92
7
83.7%
5
5.4%
8
8.7%
2
2.2%
'a
LL
2 or more minority
Q
x
races
LL
Joint
(White/Minority
2
2
100.0%
Race)
Race Not
5
3
60.0%
1
20.0%
1
20.0%
Available
Hispanic or Latino
1
1
100.0%
-
-
-
-
American
Indian/Alaska
2
2
100.0%
m
=
0
Native
15
Asian
3
2
66.7%
1
33.3%
c
U
Black or African
American
Analysis of Impediments to Fair Housing Choice 121 of 159
City of Oshkosh, WI
Native Hawaiia
or Other Pacifi
1
1
100.0%
-
-
-
-
-
-
-
Islander
White
256
204
79.7%
4
1.6%
24
9.4%
21
8.2%
3
1.1 %
2 or more minori"
races
Joint
(White/Minority
1
1
100.0%
-
-
-
-
Race)
Race Not q1
11
7
63.6%
1
9.1 %
2
1
Available
Hispanic or Latin .
2
1
50.0%
-
-
-
1
50.0%
-
American
Indian/Alaska
2
1
50.0%
-
-
-
1
50.0%
Native
Asian
3
1
33.3%
1
3.3 0
1
33.3%
Black or African
American di
1
10
Native Hawaiian
or Other Pacific
-
-
m
Islander
c
White
425
289
68.0%
7
1.6%
69
16.2%
53
12.5%
7
1.6%
w
a�
2 or more minority
races
Joint
(White/Minority
3
3
100.0%
-
-
-
-
Race)
Race Not
28
15
53.6%
2
5
17.9%
5
17.9%
1
3.6%
Available
.1%
Hispanic or Lati
3 lip,
1
33.3°
2
66.7%
-
-
-
-
American
Indian/Alaska
-
-
-
Native
Asian
2
50.0%
-
1
50.0%
Black or African
American
=
Native Hawaiian
°1
or Other Pacific
Islander
2White
78
63
80.8%
1
1.3%
11
14.1 %
3
3.8%
E2
or more minority
x
races
-
-
-
-
-
-
-
-
-
-
-
Joint
(White/Minority
Race)
Race Not
Available
5
3
60.0%
1
20.0%
1
20.0%
Hispanic or Latino
1
-
-
1
100.0%
-
-
Analysis of Impediments to Fair Housing Choice 122 of 159
City of Oshkosh, WI
American
Indian/Alaska
4
3
75.0%
-
-
-
1
25.0%
Native
Asian
9
5
55.6%
1
11.1 %
2
22.2%
1
11.1 %
Black or Africa
14
1
-
-
1
100.0%
-
-
-
-
American
Native Hawaiian
or Other Pacific
1
1
100.0%
-
-
-
-
-
-
-
-
Islander
White
851
633
74.4%
12
1.4%
109
12.8%
85
10.0%
12
1.4%
0
~
2 or more minority
races
Joint
(White/Minority
3
3
100.0%
-
-
-
-
-
-
-
Race)
Race Not
49
28
57.1 %
3
6.1 %
9
8
16.3%
1
2.0%
Available
.4%
Hispanic or Latino
7
3
42.9%
-
-
°o
1
14.3%
-
-
Total
925
676
73.1%
15
1.2
123
13.3%
96
10.3%
15
1.6%
For loan applicants 80-
groups had denial rates
rate:
Source: https://www.ffiec.gov/hmdaadwebreport/AggTableList.aspx
QQMedian income the following
igher than the average denial
• Race No Avail le FHW FSA/RHS, and VA loan denial rate of
20.0% (6- °/
• Asian Refinance loan denial rate of 33.3% (16.45% Average)
• Black or African American Refinance loan denial rate of 100.0%
(16.45% Average)
• Hispanic or Latino Refinance loan denial rate of 66.7% (16.45%
Average)
• Hispanic or Latino Home Improvement loan denial rate of 100.0%
(14.12% Average)
Disposition of Loan Applications by Race/Ethnicity and Income of Applicant
100-119% of MSA/MD Median
Total
Loans
Approved But
Applications
Applications
Files Closed for
Loan
Cohort
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
American
N Q
Indian/Alaska
Native
a_ Q c
LL 14
Asian
1
1
100.0%
Analysis of Impediments to Fair Housing Choice 123 of 159
City of Oshkosh, WI
Black or African
1
1
100.0%
American
Native Hawaiian
or Other Pacific
-
-
-
-
-
-
-
-
-
Islander
White
52
41
78.8%
1
1.9%
8
15.4%
1
1.9%
1
1.9%
2 or more
minority races
Joint
(White/Minority
3
2
66.7%
1
33.3%
Race)
Race Not
1
1
100.0%
Available
Hispanic or
2
1
50.0%
1
50.0%
-
-
Latino
American
Indian/Alaska
2
2
100.0%
-
-
-
Native
Asian
3
2
66.7%
-
-
-
1
33.3%
Black or African
American
41�
Ilk -
Native Hawaiia
or Other Pacific
-
-
-
c
0
Islander
aci
White
198
163
5
12
18
c
U
2 or more
minority races
Joint
(White/Minority
4
4
100.0%
-
-
-
-
-
Race)
Race Not
Available
9
55.6%
-
2
22.2%
2
22.2%
Hispanic or
Latino
American
Indian/Alaska
2
1
50.0%
1
50.0%
Native
Asian
5
4
80.0%
1
20.0%
Black or African
American
Native Hawaiian
or Other Pacific
Islander
c
w
White
341
240
70.4%
5
1.5%
45
13.2%
41
12.0%
10
2.9%
2 or more
minority races
Joint
(White/Minority
4
1
25.0%
1
25.0%
1
25.0%
1
25.0%
-
-
Race)
Race Not
25
12
48.0%
1
4.0%
5
20.0%
6
24.0%
1
4.0%
Available
Analysis of Impediments to Fair Housing Choice 124 of 159
City of Oshkosh, WI
Hispanic or
4
2
50.0%
2
50.0%
Latino
American
Indian/Alaska
-
-
-
-
-
Native
Asian
Black or African
American
c
Native Hawaiian
£
or Other Pacific
1
1
100.0%
Islander
0
E
White
54
45
83.3%
4
7.4%
4
7.4%
1
1.9%
am
£
2 or more
2
minority races
Joint
(White/Minority
-
-
-
Race)
Race Not
4
3
75.0%
-
-
1
25.0%
Available
Hispanic or
Latino
American
Indian/Alaska
4
3
75.0%
-
1
25.0%
-
-
Native
Asian
9
6
66.7%
%2
22.2%
1
11.1 %
Black or African
1
1-
American
Native Hawaiian
or Other Pacific
1
-
-
1
100.0%
-
-
Islander
m
White
645
489
75-
11
1.7%
69
10.7%
64
9.9%
12
1.9%
0
~
2 or more
minority races
Joint
(White/Minority
11
7
3.6%
1
9.1%
1
9.1%
1
9.1%
-
-
Race)
Race Not
39
216
51.3%
1
2.6%
7
17.9%
10
25.6%
1
2.6%
Available
Hispanic or
6
3
50.0%
-
3
50.0 /°
-
-
-
-
Latino
Total
716
529
73.9%
13
1.8%
84
11.7%
76
10.6%
13
1.8%
Source: https://www.ffiec.gov/hmdaadwebreport/AggTableList.aspx
For loan applicants 100-119% of MSA/MD Median income the following
groups had denial rates that were 10% higher than the average denial
rate:
• Hispanic or Latino FHA, FSA/RHS, and VA loan denial rate of
50.0% (15.52% Average)
Analysis of Impediments to Fair Housing Choice 125 of 159
City of Oshkosh, WI
• Race Note Available Conventional loan denial rate of 22.2% (6.54%
Average)
• American Indian/Alaskan Native Refinance loan denial rate of
50.0% (14.06% Average)
• Joint (White/Minority Race) Refinance loan denial rate of 25.0%
(14.06% Average)
• Hispanic or Latino Refinance loan denial rate of 50.0% (14.06%
Average)
• Native Hawaiian or other Pacific Islander Home Improvement loan
denial rate of 100.0% (8.47% Average)
Disposition of Loan Applications by Race/Ethnicity and Income of Applicant
120% or More of MSA/MD Median
Total
Loans
Approved But
Applications
Applications
Files Closed for
Loan
Cohort
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
American
Indian/Alaska
-
-
-
-
Native
Asian
1
1
100.0%
-
Black or African
3
1
33.3%
1
33.3%
1
33.3%
American
a
Native Hawaiian
>
or Other Pacific
-
-
-
=
m
Islander
ui
White
68
59
86.8%
1
1.5%
4
5.9%
2
2.9%
2
2.9%
a
in
LL
Q
2 or more
LL
minority races
Joint
(White/Minority
-
-
-
-
-
Race)
Race Not
5
4
80.0%
1
°
20.0/°
Available
Hispanic or
Latino
American
c
2
Indian/Alaska
C
Native
U
Analysis of Impediments to Fair Housing Choice 126 of 159
City of Oshkosh, WI
Asian
8
7
87.5%
1
12.5%
-
-
Black or African
2
1
50.0%
-
1
50.0 /o
American
Native Hawaiian
or Other Pacific
2
1
50.0%
-
-
1
50.0%
Islander
White
655
557
85.0%
17
2.6%
31
4.7%
49
7.5%
1
0.2%
2 or more
minority races
Joint
(White/Minority
14
9
64.3%
1
7.1%
-
4
28.6%
Race)
Race Not
Available
33
21
63.6%
3
9.1 %
004
12.
3
9.1 %
2
6.1 %
Hispanic or
Latino
2
1
50.0%
1
50.0%
American
Indian/Alaska
-
-
-
-
Native
Asian
15
7
46.7%
-
5
33.3%
3
20.0%
Black or African
5
3
60.0%
2
40.0%
-
-
American
Native Hawaiian
or Other Pacific
-
Islander
d
U
c
White
1,063
70.9%
23
2.2%
149
14.0%
113
10.6%
24
2.3%
w
a�
2 or more
minority races
Joint
(White/Minority
15
10
66.7%
-
-
3
20.0%
1
6.7%
1
6.7%
Race)
Race Not
80
40
50.0%
2
2.5%
17
21.3%
15
18.8%
6
7.5%
Available
Hispanic or
7
5
71.4%
-
-
-
2
28.6 /o
-
-
Latino
au > r
American
ca 4)
Indian/Alaska
_ E £
Native
Analysis of Impediments to Fair Housing Choice 127 of 159
City of Oshkosh, WI
Asian
1
-
1
100.0%
Black or African
1
-
1
100.0%
American
Native Hawaiian
or Other Pacific
1
1
100.0%
-
-
-
-
Islander
White
186
156
83.9%
2
1.1 %
14
7.5%
10
5.4%
4
2.2%
2 or more
minority races
Joint
(White/Minority
1
-
-
-
-
t-
1
100.0%
Race)
Race Not
Available
18
14
77.8%
1
7.1 %
1
7.
2
11.1
Hispanic or
Latino
3
2
66.7%
1
33.3%
American
Indian/Alaska
-
Native
Asian
25
15
1
0%
5
20.0%
3
12.0%
1
4.0%
Black or African
11
5
5.
1%
5
45.5%
-
-
-
-
American
Native Hawaiia
or Other Pacific
2
6.
-
-
1
33.3%
-
-
-
-
Islander
White
1,971
,526
.4%
43
2.2%
198
10.0%
174
8.8%
31
1.6%
R
0
~
2 or more
minority races
Joint
(White/Minority
30
19
63.3%
1
3.3%
3
10.0%
6
20.0%
1
3.33%
Race)
Race Not
136
79
58.1%
6
4.4%
23
16.9%
20
14.7%
8
5.9%
Available
Hispanic or
12
8
66.7%
-
-
1
8.3%
3
25.0%
-
-
Latino
Total
2,186
1,654
75.7%
52
2.4%
236
10.8%
206
9.4%
41
1.9%
Source: https://www.ffiec.gov/hmdaadwebreport/AggTableList.aspx
Analysis of Impediments to Fair Housing Choice 128 of 159
City of Oshkosh, WI
For loan applicants 120% and over MSA/MD Median income the following
groups had denial rates that were 10% higher than the average denial
rate:
• Black or African American FHA, FSA/RHS, and VA loan denial rate
of 33.3% (7.79% Average)
• Race Not Available FHA, FSA/RHS, and VA loan denial rate of
20.0% (7.79% Average)
• Black or African American Conventional loan denial rate of 50.0%
(5.18% Average)
• Native Hawaiian or Other Pacific Islander Conventional loan denial
rate of 50.0% (5.18% Average)
• Hispanic or Latino Conventional loan kdaial te of 50.0% (5.18%
Average)
• Asian Refinance loan denial rate .94% Average)
• Black or African American Refi nceial rate of 40.0%
(14.94% Average)
• Black or African America me provement loan denial rate of
100.0% (7.69% Average)
Analysis of Impediments to Fair Housing Choice 129 of 159
City of Oshkosh, WI
Disposition of Loan Applications by Characteristics of Census Tract
FHA, FSA/RHS and VA Loans
Total
Loans
Approved But
Applications
Applications
Files Closed for
Cohort
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
Less than 10%
359
296
82.5%
4
31
22
6
minority
c
0
10-19% minority
189
153
81.0%
-
19
13
4
0
a
E
0
L)
20-49% minority
21
16
76.2%
1
3
1
.E
r
w
50-79% minority
-
-
01
-
m
80-100% minority
-
-
-
Low income
-
N
U
.y
Moderate income
84
71
84.5%
3
.6%
5
6.0%
4
4.8%
1
1.2%
U
R
`m
s
U
am
Middle income
390
317
°0
2
0.5%
39
10.0%
26
6.7%
6
1.5%
E
0
c
Upper income
95
77
.1 %
9
9.5%
6
6.3%
3
3.2%
Less than 10%
minority
10-19% minority
-
d
E
0
c
20-49% minorit
0
0
J
50-79°!o minorit
80-100% minority
Analysis of Impediments to Fair Housing Choice 130 of 159
City of Oshkosh, WI
101
Less than 10%
48
42
87.5%
2
4.2%
1
2.1 %
2
4.2%
1
2.1 %
minority
10-19%minority
22
19
86.4%
-
-
2
9.1%
1
4.5%
-
-
E
0
NOW
c
20-49%minorit.`
14
10
71.4%
1
7.1%
2
14.3%
1
7.1%
0
a`)
0
50-79% minority
80-100% minority
Less than 10%
216
177
81.9%
2
0.9%
21
%
14
6.5%
2
0.9%
minority
10-19% minoritA
167
134
80.2%
-
-
#0
10.
12
7.2%
4
2.4%
a)
E
0
=
20-49% minority
7
6
85.7%
14.3%
d
50-79% minorit
-
80-100% minority
-
-
Less than 10%
minoritY
95
77
81.1%
, -
9
9.5%
6
6.3%
3
3.2%
10-190% minori
-
d
E
20-49% minority
-
0
c
`m
a
50-79% minority
80-100% minority
Total
569
465
81.7%
5
0.9%
53
9.3%
36
6.3%
10
1.8%
Analysis of Impediments to Fair Housing Choice 131 of 159
City of Oshkosh, WI
Disposition of Loan Applications by Characteristics of Census Tract
Conventional Loans
Total
Loans
Approved But
Applications
Applications
Files Closed for
Cohort
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
Less than 10%
1,565
1,261
80.6%
41
2.6%
128
8.2%
122
7.8%
13
0.8%
minority
c
0
10-19%minority
544
419
77.0%
12
2.2%
55
10.1%
43
7.9%
15
2.8%
0
a
E
0
L)
20-49% minority
89
61
68.5%
2
2.3%
14
0
.7%
12
13.5%
r
w
50-79% minority
-
-01
-
m
80-100% minority
-
Low income
in
U
.y
Moderate incom
222
169
76.1 %
5
.3%
19
8.6%
22
9.9%
7
3 2%
R
`m
s
U
am
Middle income
1,444
1,134
78.5°0
35
2.4%
145
10.0%
112
7.8%
18
1.2%
o
c
Upper income
438
0.3%
15
2.8%
33
6.2%
43
8.1%
3
0.6%
Less than 10%
minority
10-19% minority
d
E
0
r-
20-49% minority
3
0
J
50-79% minority
80-100% minority
Analysis of Impediments to Fair Housing Choice 132 of 159
City of Oshkosh, WI
Less than 10%
110
95
86.3%
1
0.9%
6
5.5%
5
4.5%
3
2.7%
minority
10-19%minority
67
46
68.7%
2
3.0%
6
9.0%
9
13.4%
4
6.0%
E
0
c
w;
20-49%minority
45
28
62.2%
2
4.4%
7
15.6%
8
17.8%
0
a`)
M
0
50-79%minority
80-100% minority
Less than 10%
923
728
78.9%
25
2.7%
89
%
74
8.0%
7
0.8%
minority
10-19% minority
477
373
78.2%
10
2.1 %
00
10.
34
7.1 %
11
2.3%
a)
E
0
=
20-49%minority
44
33
75.0%
15.9%
4
9.0%
d
50-79% minority
-
-
80-100% minority
�-
-
Less than 10%
532
438
82.3%
15
.8%
33
6.2%
43
8.1 %
3
0.6%
minority
t
10-19%minority
-
-
-
-
d
E
0
20-49%minority
c
`m
a
50-79%minority
80-100% minority
Total
2,198
1,741
79.2%
55
2.5%
1997
9.0%
177
8.1%
28
1.3%
Analysis of Impediments to Fair Housing Choice 133 of 159
City of Oshkosh, WI
Disposition of Loan Applications by Characteristics of Census Tract
Refinancing Loans
Total
Loans
Approved But
Applications
Applications
Files Closed for
Cohort
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
#
%
#
%
#
%
#
%
#
%
Less than 10%
2560
1649
64.4%
52
2.0%
435
17.0%
325
12.7%
99
3.9%
nori mity
c
0
10-19%minorit
966
605
62.6%
25
2.6%
188
19.5%
108
11.2%
40
4.1%
0
a
E
0
20-49% minority
136
96
70.6%
1
0.7%
21
.4%
16
11.8%
2
1.5%
s
W
50-79% minorit
-
as
80-100% minority
Low income
-
cn
V
.N
L
a
Moderate income
397
240
60.5%
8
.0%
85
21.4%
48
12.1 %
16
4.0%
m
s
U
m
Middle income
2558
1621
63.4%
59
2.3%
463
18.1%
311
12.2%
104
4.1%
E
0
c
Upper income
707
489
69.2%
11
1.6%
96
13.6%
90
12.7%
21
3.0%
Less than 10%
minority
10-19% minority
a)
E
0
0
=
20-49% minority
3
0
J
50-79% minorit "
80-100% minority
m 0
E
a) 0
Less than 10%
218
125
57.3%
5
2.3%
54
24.8%
26
11.9%
8
3.7%
c
minority
Analysis of Impediments to Fair Housing Choice 134 of 159
City of Oshkosh, WI
10-19% minority
128
75
58.6%
3
2.3%
25
19.5%
17
13.3%
8
6.3%
20-49% minority
51
40
78.4%
-
-
6
11.8%
5
9.8%
-
-
50-79% minority
-
-
-
-
-
-
-
80-100%minority
-
-
-
-
-
-
-
-
-
-
-
Less than 10%
1635
1035
63.3%
36
2.2%
285
17.4%
209
12.8%
70
4.28%
minority
10-19% minority
838
530
63.2%
22
2.6%
163
19.5%
91
10.9%
32
3.82%
d
E
0
=
20-49% minority
85
56
65.9%
1
1.2%
15
17.6%
11
12.9%
2
2.35%
d
50-79% minority
-
80-100% minority
-
-
Less than 10%
707
489
69
11
%
6
13.6%
90
12.7%
21
3.0%
minority
10-19% minority
-
-
d
£
0
20-49% minority
-
c
d
a
50-79% minority
80-100%minority
-
-
-
-
-
-
-
-
-
-
Total
3,662
2,350
64.2%
78
2.1%
644
17.6%
449
12.3%
141
3.9%
Analysis of Impediments to Fair Housing Choice 135 of 159
City of Oshkosh, WI
Disposition of Loan Applications by Characteristics of Census Tract
Home Improvement Loans
Total
Loans
Approved But
Applications
Applications
Files Closed for
Cohort
Apps
Originated
Not Accepted
Denied
Withdrawn
Incompleteness
Less than 10%
368
290
78.8%
6
1.6%
45
12.2%
17
4.6%
10
2.7%
minority
c
0
10-19%minority
175
131
74.9%
1
0.6%
26
14.9%
16
9.1%
1
0.6%
0
a
E
0
20-49% minority
18
13
72.2%
4
2%
1
5.6%
s
W
50-79% minorit
-
-
-
-
-
5
80-100% minority
-
Low income
-
cn
.NV
L
Moderate income
73
52
:f2j%1
.4%
12
16.4%
8
11.0%
s
Awl
U
m
Middle income
380
291
5
1.3%
57
15.0%
20
5.3%
7
1.8%
E
0Upper
J76.6%
income
91.3%
1
0.9%
6
5.6%
6
5.6%
4
3.7%
Less than 10%
minority
10-19% minorit
a)
E
0
c
20-49% minorit
3
0
J
50-79% minorit
80-100% minority
-
-
-
-
-
-
-
-
-
m 0
E
m 0
Less than 10%
40
30
75.0%
1
2.5%
5
12.5 /°
4
°
10.0 /°
c
minority
Analysis of Impediments to Fair Housing Choice 136 of 159
City of Oshkosh, WI
10-19% minority
24
16
66.7%
5
20.8%
3
12.5%
20-49% minority
9
6
66.7%
2
22.2%
1
11.1 %
50-79% minority
-
-
-
-
-
-
-
80-100%minority
-
-
-
-
-
-
-
Less than 10%
220
169
76.8%
4
1.8%
34
15.5%
7
3.2%
6
2.7%
minority
10-19% minority
151
115
76.2%
1
0.7%
21
13.9%
13
8.6%
1
0.7%
d
E
0
c
20-49% minority
9
7
77.8%
2
22.2%
d
50-79% minority
-
80-100% minority
-
-
Less than 10%
108
91
84.3%
1
0.9%
6
5.6%
6
5.6%
4
3.7%
minority
10-19% minority
-
-
-
-
-
-
-
-
-
-
-
d
£
0
20-49% minority
c
d
a
50-79% minority
80-100%minority
-
-
-
-
-
-
-
-
-
-
-
Total
561
434
77.4%
7
1.2%
75
13.4%
34
6.1%
11
2.0%
The following tables list reasons for denial by race, ethnicity, gender, and income.
Analysis of Impediments to Fair Housing Choice 137 of 159
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City of Oshkosh, WI
4. Insurance
There was not suitable data available to determine if discrepancies existed
in the rates and amounts of insurance coverage available to minority
households in the City of Oshkosh. Further investigation and assessment
are needed to determine if there is a barrier to fair housing choice.
Analysis of Impediments to Fair Housing Choice 146 of 159
City of Oshkosh, WI
D. Citizen Participation:
The City of Oshkosh developed the Analysis of Impediments with input received
through individual meetings and public meetings with a variety of stakeholders
and representatives of the community which included representatives from the
City and County; Housing Authority; community, social service, and advocacy
agencies; and non-profit and for profit entities.
In compliance with the City's Citizen Participation Plan, the City held its first
Needs Public Hearing on September 23, 2019, a Neighborhood Hearing on
March 11, 2020, a Plan Commission meeting on March 17, 2020, and its second
Public Hearing on March 24, 2020. These Hearings provided residents and
stakeholders the opportunity to discuss the City's BG program and provide
input concerning the funding priorities.
The Needs Public Hearing advertiseme as blished in the Oshkosh
Northwestern on September 4, 201 nd the second Public Hearing
advertisement was published in the os orthwestern on March 2 and
March 9, 2020 and announced the avai i o review the draft plan on March
6, 2020.
A "draft" of the Analysis of Impe en i Housing Choice was placed on
public display from March�Z020 pril 2020 at the following locations for
review: �\
• City of Oshkosh ommunity Development - 215 Church
Avenue, h, 54903-1130
• City of Oshkos b (www.ci.oshkosh.wi.us) Government section of
the website unde Economic Development Division"
• Oshkosh&ublic ary - 106 Washington Avenue, Oshkosh, WI 54901
In the "Citizen P icipation" section of the Appendix is the complete
documentation of the input received.
The City ran an extensive resident survey campaign, utilizing Survey Monkey,
Polco, and paper surveys that were sent through the mail with water bills. There
were a total of 989 survey responses entered into Survey Monkey, which
included an online link sent to stakeholders throughout the community and
featured on the City's website, as well as survey responses from residents from
the mailing campaign that had been entered into Survey Monkey. There was a
total of 121 survey responses entered into Polco, which was also featured on the
City's website and shared with stakeholders.
Some of the notable characteristics of respondents included (as a percentage of
those that answered each question):
Analysis of Impediments to Fair Housing Choice 147 of 159
City of Oshkosh, WI
• The majority of respondents were female at 61.98% and 96.93% of
respondents were White and 85.00% were Non -Hispanic or Latino.
• 61.39% of respondents were 60 years old or older.
• Of those that answered the question, 45.11 % were low- to moderate
income for their family size.
• The majority of respondents, 77.22%, come from one or two -person
households.
• 87.50% were homeowners.
Some of the needs identified by respondents included problems with the
following (as a percentage of those that answered each question):
• Public Safety - 16.88%
• Streets - 27.09%
• Curbs/Sidewalks - 14.47%
• Handicap Access - 3.53%
• Parking - 17.07%
• Traffic - 23.01 %
0
< IV
• Storm Sewers - 9.65 /o
• Sanitary Sewers - 2A1
• Litter - 13.73%
• Property Maintenanc 8.5 o
The following is a of es associated with different areas of
community and econo velopm nt. Values were calculated as a percentage
of those that ar��ea uestion.
Recreation
• 28.37XO/otio n property maintenance as an issue.
• 27.09% would like more streets to be repaired.
• 23.01 % would prefer less traffic disturbances.
Social Services
• 40.13% of respondents are concerned with the issues of aging
• 30.57% would like more help with their disability
• 28.66% mention a desire for more social services centered on providing
medical aid.
Public Transportation
• 52.56% of respondents would like an increase in service hours.
• 24.36% complained about a "lack of parking".
Analysis of Impediments to Fair Housing Choice 148 of 159
City of Oshkosh, WI
Crime
77.80% of respondents state that there is an issue with drugs in the
community.
60.37% would like more theft deterrence.
The following situations result in further discriminations and/or barriers to fair housing in
the City of Oshkosh:
Strongly
Agree
Neutral/Unsure
Disagree
Strongly
Agree
Disagree
Concentration of
subsidized housing in
13.18%
28.46%
49.52%
5.79%
3.05%
certain neighborhoods
Lack of affordable
17.08%
36.49%
'
35.09%
8.23%
3.11 %
housing in certain areas
Lack of accessible
IV
housing for persons
11.60%
27.740
51.88°0
6.43%
2.35%
with disabilities
Lack of accessibility in
neighborhoods (i.e. curb
5.62%
5.89%
57.14%
17.17%
4.17%
cuts)
Lack of fair housing
12.07°
/0
48.59%
7.05%
2.82%
education
Lack of fair housing
7 87%
19. %
60.83%
8.03%
3.53%
organizations in the City
State or local laws or
policies that limit
01111tX2
15.19%
63.81 %
12.44%
2.75%
housing choice
Lack of knowledge
among residents
4%
34.07%
41.29%
6.12%
2.98%
regarding fair housing
Lack of knowledge
among landlords and
11.50%
28.82%
43.94%
10.71 %
5.04%
property managers
regarding fair housing
Lack of knowledge
among real estate
7.14%
17.86%
56.12 /°
13.95 /°
4.93/° °
agents regarding fair
housing
Lack of knowledge
among bankers/lenders
7.77%
15.37%
59.22%
13.27%
4.37%
regarding fair housing
Other barriers
6.15%
5.88%
81.28%
4.01 %
2.67%
Analysis of Impediments to Fair Housing Choice 149 of 159
City of Oshkosh, WI
V. Actions and Recommendations
The following impediments to fair housing choice and recommendations are
presented to assist the City of Oshkosh to affirmatively further fair housing in the
community. The previously identified impediments to fair housing choice were
discussed in Section III and progress was reported for each impediment. New
and carried over impediments to Fair Housing Choice are presented in chart
format on the pages that follow.
The City of Oshkosh's FY 2020-2024 Analysis of Impediments to Fair Housing
Choice has identified the following impediments, as well as defined specific goals
and strategies to address each impediment.
• Imoediment 1: Need for Fair Housina Education and Outreach
* There is a need to improve the knowtige an derstanding concerning
the rights and responsibilities o ` dividuals, families, members of the
protected classes, landlords, rea tat ofessionals, and public officials
under the Fair Housing Act (FHA).
Goal: Improve the public's e a awareness of the Fair Housing
Act, related laws, regulation a ements to affirmatively further fair
housing in the cone.
Strategies: I rde this goal, the following activities and
strategies shoul nderta c n:
- 1 to idents of their rights under the Fair Housing Act
(FHA) an e A ericans with Disabilities Act (ADA).
- 1-B: Edu realtors, bankers, housing providers, and other real
estate prd essional of their responsibilities under the Fair Housing
Act (FHA) and the Americans with Disabilities Act (ADA).
- 1-C: Educate policy makers and city staff about the Fair Housing
Act (FHA) and the Americans with Disabilities Act (ADA).
- 1-11): Support Fair Housing organizations and legal advocacy
groups to assist persons who may be victims of housing
discrimination.
- 1-E: Identify the language and communication needs of LEP
persons to provide the specific language assistance that is
required.
- 1-F: Continue to partner with regional jurisdictions and housing
providers to encourage fair housing choice throughout
Winnebagoland.
Analysis of Impediments to Fair Housing Choice 150 of 159
City of Oshkosh, WI
Impediment 2: Need for Affordable Housing
Almost half (45.6%) of all renter households are paying over 30% of their
monthly incomes on housing costs. A quarter (25.0%) of all owner
households with a mortgage are paying over 30% of their monthly income
on housing costs. The number of households that are housing cost
burdened significantly increases as household income decreases.
Goal: Increase the supply of decent, safe and sanitary housing that is
affordable and accessible through the new construction and rehabilitation
of various types of housing, especially housing that is affordable to lower
income households.
Strategies: In order to meet this goal, the following activities and
strategies should be undertaken:
- 2-A: Support and encourage rivate developers and non-profit
housing providers to create rough construction or rehabilitation,
affordable and mixed-inco. housing.
- 2-13: Support and encoura a rehabilitation of existing renter -
occupied and ow ccupi housing units in the City for
households below 8
- 2-C: Support homeb _. duca ion, training programs, and closing
cost/down,&aynWt asWtance to increase the number of owner-
occupie fffousi nits.
and local funding in response to HMDA
to support higher loan to value ratios
event, safe, and sanitary housing that is
it households below 80% AM I.
Impediment 3: Need for Accessible Housing
There is a lack of accessible housing units in the City of Oshkosh as the
supply of accessible housing has not kept pace with the demand of
individuals desiring to live independently.
Goal: Increase the supply of accessible housing through new construction
and rehabilitation for persons with disabilities.
Strategies: In order to meet this goal, the following activities and
strategies should be undertaken:
Analysis of Impediments to Fair Housing Choice 151 of 159
City of Oshkosh, WI
- 3-A: Promote the need for accessible and visitable housing by
supporting and encouraging private developers and non -profits to
develop, construct, or rehabilitate housing that is accessible to
persons with disabilities.
- 3-B: Provide financial assistance for accessibility improvements to
renter -occupied and owner -occupied housing units to enable
seniors and persons with disabilities to remain in their homes.
- 3-C: Promote and enforce the ADA and Fair Housing requirements
for landlords to make "reasonable accommodations" to their rental
properties so are accessible to tenants.
Impediment 4: Public Policy
The City Zoning Ordinance needs additional definitions and provisions
concerning Fair Housing.
Goal: Revis
various types
Strategies:
strategies sh,
promote the development of
ut the City.
(lowing activities and
- 4-A: Refe thff Citylgoning Ordinance to include additional
definitions, sta eme 7, a d revisions.
- 4-B: Adopt a written Reasonable Accommodation Policy for
housing developers and the Planning/Zoning Commission to follow
when reasonable accommodation requests are made concerning
zoning and land use as it applies to protected classes under the
Fair Housing Act.
- 4-C: Develop financial incentives to encourage developers and
housing providers to offer more affordable housing options in the
City.
- 4-D: Encourage LMI, minority, and protected class resident
participation in the various City Boards and Commissions.
Analysis of Impediments to Fair Housing Choice 152 of 159
City of Oshkosh, WI
VI. Certification
Signature Page:
I hereby certify that this FY 2020-2024 Analysis of Impediments to Fair Housing
Choice is in compliance with the intent and directives of the Community
Development Block Grant Program regulations.
Mark Rohloff, City Manager, City of Oshkosh, WI
Date
Analysis of Impediments to Fair Housing Choice 153 of 159
City of Oshkosh, WI
VII. Maps
The following maps are attached:
Percent White Population by Block Group
Percent Minority Population by Block Group
Percent Population Age 65 and Over by Block Group
Housing Density by Block Group
Percent Owner Occupied Housing Units by Block Group
Percent Renter Occupied Housing Units by Block Group
Low- and Moderate -Income Percentage by Block Group
Low- and Moderate -Income and Minority Percentage by Block Group
Analysis of Impediments to Fair Housing Choice 154 of 159
LEGEND:
Census Trac
Major Roads
City Streets
Railroads
Water
Block Group:
Source: 2013 2n17r
V V.JO V.l:J I.J L.L:J J
Miles
CITY OF OSHKOSH, WINNEBAGO COUNTY, WI
WHITE POPULATION BY B.G.
11
LEGEND:
Census Trac
Major Roads
City Streets
Railroads
Water
Block Group:
Source: 2013 2n17r
V V.JO U.I J I .J 4.41 J
Miles
CITY OF OSHKOSH, WINNEBAGO COUNTY, WI
MINORITY POPULATION BY B.G.
11
LEGEND:
Census Trac
Major Roads
City Streets
Railroads
Water
Block Group:
Source: 2013 2n17r
V V.JO V.l:J I.:J L.L:J J
Miles
CITY OF OSHKOSH, WINNEBAGO COUNTY, WI
PERCENT POPULATION AGED 65+ BY B.G.
11
LEGEND:
Census Trac
Major Roads
City Streets
Railroads
Water
Block Group:
Source: 2013 2n17r
V V.JO V.l:J I.:J L.L:J J
Miles
CITY OF OSHKOSH, WINNEBAGO COUNTY, WI
HOUSING UNIT DENSITY BY B.G.
LEGEND:
Census Trac
Major Roads
City Streets
Railroads
Water
Block Group:
Source: 2013 2n17r
V V.JO V.l:J I.:J L.L:J J
Miles
CITY OF OSHKOSH, WINNEBAGO COUNTY, WI
OWNER -OCCUPIED UNITS BY B.G.
11
LEGEND:
Census Trac
Major Roads
City Streets
Railroads
Water
Block Group:
Source: 2013 2n17r
V V.JO V.l:J I.:J L.L:J J
Miles
CITY OF OSHKOSH, WINNEBAGO COUNTY, WI
RENTAL UNITS BY B.G.
C.T. 16
B.G. 2 B.G. 4 47.0%
B.G.'I 55.104 B.G. V
C.T. 17
13.7% 22.7% B.G. 2
41.7%
56.3%
B.G.-3
B.G.
J2 B.G. 1-
37.6,o u 54.2%3
52.4%
B.G.1 C.T: 9 C.T } 47.9%
76.8% 56.60% B.G. 67.20 B.G.2
B.G. 2 35.10 C T B.
s C..Ta 3 B.G. 3
B`G. ,8 2 57 13.9%
C'T.10 1 42.8
C.T. ITER ° 4% 40%
° 88.3 /o o' ��
B.G. 2 32.7% 65 /o /o B.G.- r
G`I q 5 B.G- f
B:G. 2 B.G. 1 3 1 B.G! 1
B.G.. 3 74.3-/�
B.G.1 B.G.2 9 /0 71%
4�% 7--1:�4% 51.7% 0% , i- C.T 2
C.T. 1�03 B: C:T. 5 , 37*1 % 48.3%
B.G. 1 C.T.11 G. 52% B.G. 3 _o BrG:2 39:6% B.G. 1
i I 2% 29.6% $.9% 89 /o C.T�1
20.7% 0
B.G-4 -60o B:G.1 B:Gr3443.6% B.G.2
49.600 B(G 65'.9% 71.0% 77.4%
:0%
B.G/1
B.6.2 .1 36'.9% 63.49 B.G.
2 37 /o I -� 12
G.4 B.G.
56.3%
0 C.T. 14
5,41 %
.G. 1 B: i . 3 30:80o
C.T� I15
G.1 ti"G.
22.1
LEGEND:
Census Tracts
C.T. 19
Major Roads LOW/Mod Income
City Streets By Block Group
Railroads Less Than 51 %
Water 0 51 % or More n I
Block Groups 38.6% 1 V
Source: 2011-2015 ACS 0 0.38 0.75 1.5 2.25 3
Miles
CITY OF OSHKOSH, WINNEBAGO COUNTY, WI PERCENT LOW/MOD INCOME BY B.G. EON
a
LEGEND:
Census Trac
Major Roads
City Streets
Railroads
Water
Block Group;
Source: 2011-2015
2013-2017 ACS 5 Year Estimates
V V.JO V.l:J I.:J L.L:J J
Miles
CITY OF OSHKOSH, WINNEBAGO COUNTY, WI
LOW/MOD AND MINORITY POP BY B.G.
City of Oshkosh, WI
VIII. Appendix
The following documents are attached:
• U.S. Census Data
• CHAS Data
• HMDA Data
• Citizen Participation
Analysis of Impediments to Fair Housing Choice 155 of 159
City of Oshkosh, WI
U.S. Census Data
Analysis of Impediments to Fair Housing Choice 156 of 159
City of Oshkosh, WI
Analysis of Impediments to Fair Housing Choice 157 of 159
City of Oshkosh, WI
Analysis of Impediments to Fair Housing Choice 158 of 159
City of Oshkosh, WI
Citizen Participation
Analysis of Impediments to Fair Housing Choice 159 of 159