HomeMy WebLinkAbout05. 20-108 MARCH 24, 2020 20-108 RESOLUTION
(CARRIED 7-0 LOST LAID OVER WITHDRAWN )
PURPOSE: ACCEPT & APPROVE 2020 ANALYSIS OF IMPEDIMENTS
TO FAIR HOUSING CHOICE AS AN ELEMENT OF THE
COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM
INITIATED BY: COMMUNITY DEVELOPMENT
WHEREAS, as a community development block grant entitlement community,
the City of Oshkosh is required to certify to the US Department of Housing and Urban
Development (HUD) that it will affirmatively further fair housing; and
WHEREAS, Urban Design Ventures was hired to complete an Analysis of
Impediments (AI) to Fair Housing Choice and said Al identifies fair housing concerns
and impediments, and recommends planning strategies that the City can undertake to
further fair housing within the community.
NOW, THEREFORE BE IT RESOLVED by the Common Council of the City of
Oshkosh that the City hereby accepts the 2020 Analysis of Impediments to Fair Housing
Choice, on file at the City Clerk's office.
BE IT FURTHER RESOLVED that the Common Council affirmatively furthers fair
housing opportunities within the City by approving the 2020 Analysis of Impediments,
on file at the City Clerk's Office, as an element of the Community Development Block
Grant Program, and authorizes the proper City officials to notify HUD of its acceptance
and approval.
MARCH 24, 2020 20-108 RESOLUTION
CONT'D
BE IT FURTHER RESOLVED that the proper City officials are hereby authorized and
directed to take those steps necessary to implement the recommendations to address
impediments to fair housing in Oshkosh as identified in the 2020 Analysis of
Impediments to Fair Housing Choice.
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Est. 1853
DEPARTMENT OF CO ` M VELOPMENT
FY LYSIS OF IMPEDIMENTS
TO I OUSING 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
Executive Summary.........................................................................................................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 Burden:.......................................................56
J. Disabled Households:....................................................................................57
III. Review/Update to Original Plan.............................................................................59
A. Summary of Impediments:.............................................................................59
IV. Impediments to Fair Housing 2020........................................................................66
A. Fair Housing Complaints: ..............................................................................66
B. Public Sector:.................................................................................................72
C. Private Sector: .............................................................................................106
D. Citizen Participation: ....................................................................................149
V. Actions and Recommendations ...........................................................................152
VI. Certification..........................................................................................................155
VII. Maps....................................................................................................................156
VIII. Appendix..............................................................................................................157
Analysis of Impediments to Fair Housing Choice 1 of 161
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 that the jurisdictions will affirmatively further fair housing. This means
that the entitlement communities will conduct an Analysis of Impediments to Fair Housing
Choice, take appropriate actions to overcome the effects of any impediments identified
through the Al, and maintain records reflecting what analysis and corrective actions were
taken.
The City of Oshkosh previously prepared
an Analysis of Impediments to Fair
Housing Choice in March 2013. On July
16, 2015, the U.S. De artment of .
p d I
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 ` `t
the AFH Tool, and requiring communities
to revert back to the preparation of an
Analysis of Impediments to Fair Housing i :
Choice.
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Google.(n.d.).City of Oshkosh, Wl. Retrieved from
https://www.google.com/maps/place/Oshkosh
Analysis of Impediments to Fair Housing Choice 2 of 161
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.
lip
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The methodology employed to undertake this Analysis of Impediments included:
• Research
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.
- Review of the residential segregation data from PolicyMap.
Analysis of Impediments to Fair Housing Choice 3 of 161
City of Oshkosh, WI
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 owner-occupied and renter-occupied housing
units were identified and mapped.
- Fair housing awareness in the community was evaluated.
- Distribution by location of public and assisted housing units were
analyzed and mapped.
- The location of CDBG expenditures throughout the area were
analyzed.
- CDBG/HOME Five Year Goals and Objectives were reviewed.
• Potential Impediments
Public sector 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 AI
were placed on public display to encourage citizen input.
The public survey was available at the following link
https://www.surveVmonkey.com/r/OSHCDBG from September 1,
2019 until November 1, 2019.
Analysis of Impediments to Fair Housing Choice 4 of 161
City of Oshkosh, WI
• 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 improve the knowledge and understanding concerning
the rights and responsibilities of individuals, families, members of the
protected classes, landlords, real estate professionals, and public officials
under the Fair Housing Act (FHA).
Goal: Improve the public's knowledge and awareness of the Fair Housing
Act, related laws, regulations, and requirements to affirmatively further fair
housing in the community.
Strategies: In order 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).
- 1-113: 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-D: 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 5 of 161
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City of Oshkosh, WI
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• 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 private developers and non-profit
housing providers to create, through construction or rehabilitation,
affordable and mixed-income housing.
- 2-B: Support and encourage the rehabilitation of existing renter-
occupied and owner-occupied housing units in the City for
households below 80% AMI.
- 2-C: Support homebuyer education, training programs, and closing
cost/down payment assistance to increase the number of owner-
occupied housing units.
- 2-D: 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.
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 6 of 161
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
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The City Zoning Ordinance needs additional 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-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.
4-13: Encourage LMI, minority, and protected class resident
participation in the various City Boards and Commissions.
Analysis of Impediments to Fair Housing Choice 7 of 161