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PC - Item 3A - Exhibit F - Appendix D - Fair Housing AssessmentRosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-1 APPENDIX D – FAIR HOUSING ASSESSMENT 1. Introduction and Overview of AB 686 In 2018, California passed Assembly Bill (AB 686) as the statewide framework to affirmatively further fair housing (AFFH) to promote inclusive communities, further housing choice, and address racial and economic disparities through government programs, policies, and operations. AB 686 defined “affirmatively furthering fair housing” to mean “taking meaningful actions, in addition to combat discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity” for persons of color, persons with disabilities, and other protected classes. The bill added an assessment of fair housing to the housing element that includes the following components: a summary of fair housing issues and assessment of the city’s fair housing enforcement and outreach capacity; an analysis of segregation patterns and disparities in access to opportunities, an assessment of contributing factors, and an identification of fair housing goals and actions. AB 686 also requires that preparation of the housing element land inventory and identification of sites occur through the lens of AFFH, and that the housing element include a program that promotes and affirmatively furthers fair housing opportunities throughout the community. The program should address the issues identified through the assessment. The program must include: 1) meaningful actions that address disparities in housing needs and in access to opportunity; 2) a timeline of concrete actions and a timeline for implementation; and 3) no actions inconsistent with AFFH. Housing Element Section 5 includes the required AFFH program, based on the recommendations of the AI and the additional analysis done for the 6th Cycle Housing Element update provided in this assessment. 2. Assessment of Fair Housing Issues The city has always had an ongoing commitment to prevent, reduce, and ultimately eliminate housing discrimination and other barriers related to equal opportunity in housing choice, and, as an entitlement city, prepared an updated Analysis of Impediments to Fair Housing Choice (AI) that was adopted in 2020. The city’s AI is a comprehensive review of policies, procedures, and practices within Rosemead that affect the location, availability and accessibility of housing and the current residential patterns and conditions related to fair housing choice. This AI study analyzed data (U.S. Census, fair housing complaints, city and federal government and Home Mortgage Disclosure Act) and conducted audit tests and surveys to identify barriers to fair housing. Fair housing choice should be understood as the ability of persons of similar incomes to have available to them the same housing choices regardless of race, color, religion, sex, disability, familial status, or national origin. An impediment to fair housing choice is an action, omission, or decision taken because of race, color, religion, sex, disability, familial status, or national origin that restricts housing choices or the availability of housing choice. It is also any action, omission, or decision that has this kind of effect. This analysis also relied on the AFFH Data and Mapping Resources provided by the California Department of Housing and Community Development (HCD Data Viewer), the 2021-2022 Annual Action Plan report to the U.S. Department of Housing and Urban Development (HUD) pertaining to the city’s Consolidated Plan (Con Plan), and the Consolidated Annual Performance and Evaluation Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-2 Report (CAPER) for city housing programs, American Community Survey 2014-2018 5-year estimates (ACS), Comprehensive Housing Affordability Strategy (CHAS) data, the “Pre-Certified Local Housing Data” prepared for the City of Rosemead by the Southern California Association of Governments (SCAG Report), and additional local sources of information. AB 686 requires that preparation of the housing element land inventory and identification of sites occur through the lens of AFFH. To meet this requirement, the city’s RHNA Sites Inventory has been mapped and overlaid onto the HCD Data Viewer maps to show where RHNA sites are located with respect to opportunity areas, segregation, and racially/ethnically concentrated areas of poverty (RECAPs) as further discussed in the related sections below. Accompanying tables provide additional specificity regarding the distribution of RHNA sites. Since the RHNA Sites Inventory was mapped and overlaid onto the HCD Data Viewer maps, and used to create the accompanying tables, there have been adjustments made to the RHNA sites. The changes are primarily to assume a higher realistic density for the Garvey Avenue Specific Plan area; to add additional sites for rezoning along Valley Boulevard, Montebello Boulevard, and Garvey Avenue; to remove sites from Rosemead Boulevard and Valley Boulevard; and to consolidate various sites along Garvey Avenue. The total result of the changes is an increase of 1,236 units. The distribution of units by area remains essentially unchanged as shown in Figure D-1B. As such, the following AFFH analysis considering the geographic distribution of RHNA sites throughout the city remains appropriate, even though some of the data presented in the figures and tables identifying RHNA sites have not been updated to reflect the latest sites inventory refinements. 2.1 Fair Housing Enforcement and Outreach The city has contracted with the Southern California Housing Rights Center (HRC) to implement its Fair Housing Program, and the availability of these services is promoted on the city’s website. The HRC works to enforce fair housing laws, including the Fair Housing Act (FHA) the California Fair Employment and Housing Act (FEHA), Source of Income and Section 8 protection laws, the Tenant Protection Act (AB 1482, 2019), the unlawful detainer process, COVID-19 tenant protections, and disability accommodations in housing. The HRC provides free fair housing services, including landlord/tenant counseling to answer questions about rights and responsibilities; investigation concerning allegations of housing discrimination, help for victims of discrimination; outreach, and education about Fair Housing laws and issues; and publication of a monthly rental listing of affordable housing opportunities. HRC has physical offices (in Los Angeles, Pasadena, and Van Nuys) that are currently closed due to the pandemic, but holds weekly online workshops, maintains a Housing Rights Hotline, and offers phone or online counseling. The city’s AI discussed federal laws, including the Civil Rights Act, the Fair Housing Act (as amended), the HUD Final Rule on Equal Access to Housing in HUD Programs, the Americans with Disabilities Act, and the Home Mortgage Disclosure Act, among others. State laws cited include the California Fair Employment and Housing Act (FEHA), SB 329 (2019), and multiple civil rights acts and laws protecting the rights of special needs groups. In addition, as a result of the AI, actions were adopted to overcome potential impediments to fair housing laws, as discussed in Section 2.7, Summary of Fair Housing Issues, below. The city’s 2019 CAPER identified 577 persons assisted through CDBG-funded fair housing services. Additional information on Fair Housing issues is available on the AFFH Data Viewer, which reports that there were 12 Fair Housing Enforcement and Outreach (FHEO) inquiries in Rosemead between 2013 and 2021: one was found to have “no valid basis;” five had “no valid issue;” and six were reported as “failure to respond.” Countywide, .01 FHEO cases were reported per thousand people, which was an improvement over 2010 data showing .025-.05 cases per thousand people. Programs to address fair housing enforcement and outreach are included in Program 14. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-3 2.2 Integration and Segregation The HCD Data Viewer, drawing from U.S. Census, ACS, and other data sources, provides a depth of resources to better understand patterns of affluence, poverty, segregation, and integration. In addition, the HUD dissimilarity index was reviewed. The dissimilarity index measures the relative separation or integration of groups across all neighborhoods of a city or a metropolitan area. The distribution of racial or ethnic groups across an area can be analyzed using an index of dissimilarity. This method allows for comparisons between subpopulations, indicating how much one group is spatially separated from another within a community. The index of dissimilarity is rated on a scale from 0 to 100, in which a score of 0 corresponds to perfect integration and a score of 100 represents total segregation. Typically, an index under 30 is considered low, between 30 and 60 is moderate, and above 60 is high. The city’s AI reports that in 2010, the dissimilarity indices countywide by census tract for all non-White groups were principally in the low range, except for the index for Hispanic/Latino (of any race) and non- Hispanic Asian populations (see Table D-1). By 2017, most of the indices had slightly increased with a small exception of Black/White index. Segregation can be reinforced both unintentionally and by deliberate actions. As reported in the AI, the increases in the dissimilarity indices are more likely the result of natural settlement patterns versus deliberate segregation. Severe segregation seems to be happening particularly when reviewing the race-based census maps. Many neighborhoods have high concentrations of non-Hispanic Asian and/or Hispanic/Latino (of any race) populations. Table D-1– Dissimilarity Indices Compiled for the Analysis of Impediments, 2020 Racial/Ethnic Dissimilarity Index 2000 2010 2017 Non-White/White 24.58 23.67 28.19 Black/White 24.32 17.59 33.00 Hispanic/White 26.93 25.21 30.01 Asian or Pacific Islander/White 22.85 23.01 27.80 Source: City of Rosemead AI, citing 2000, 2010 and 2013-2017 ACS, Affirmatively Furthering Fair Housing Note: When a group’s population is small, its dissimilarity index may be high, even if the group’s members are evenly distributed throughout the area. Thus, when a group’s population is less than 1,000, exercise caution in interpreting its dissimilarity indices. Race and Ethnicity The ethnic and racial composition of a region is useful in analyzing housing demand and any related fair housing concerns because it tends to demonstrate a relationship with other characteristics such as household size, locational preferences, and mobility. The city’s racial/ethnic composition has shifted over the past several decades. Following a trend that began in the 1990s, the proportion of non-Hispanic White community members has been decreasing in the city, accompanied by an increase in other racial/ethnic groups, primarily non-Hispanic Asian and Hispanic/Latino (of any race) community members. This trend can be seen in Housing Element Table 4 (found in Section 2), which compares data from the 2000 and 2010 Census data with data from the 2015-2019 American Community Survey (ACS). The ACS reports that the city’s largest racial demographic groups are non-Hispanic Asian at 62.6 percent; non-Hispanic White at 15.7 percent; and “other” at 21.6 percent. In addition, 32.6 percent of the population identify as Hispanic or Latino of any race. All of the RHNA inventory sites are located in communities of color (predominately non-Hispanic Asian Majority), as shown on Figure D-1A, Figure D-2, and Table D-2. Figure D-2 shows that almost the entire city is made up of non-Hispanic Asian Majority Tracts, with a “sizable gap” of 10 to 50 percent, and a small area of Hispanic/Latino (of any race) Majority Tracts near the city’s southern boundaries. Figure D-2 also shows the racial demographics of the broader San Gabriel Valley subregional area. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-4 Figure D-1A – Sites Inventory with Minority Concentrated Areas of Population, City of Rosemead Housing Element Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-5 Figure D-1B – Rosemead RHNA Sites Inventory Map Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-6 Figure D-2 – Racial Demographics, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-7 Table D-2 – Communities of Color Population (Percent of Total Non-White Population) Lower Income RHNA Units Moderate Income RHNA Units Above Moderate Income RHNA Units Total Units <20% - - - - 21% – 40% - - - - 41% – 60% - - - - 61% – 80% - - - - >81% 2,167 1,419 2,057 5,643 Total 2,167 1,419 2,057 5,643 The city recognizes the effect that discrimination has in limiting housing choice and equal opportunity in renting, selling and financing housing. To actively support and promote freedom of residence through education, advocacy, and litigation, to the end that all persons have the opportunity to secure the housing they desire and can afford, without regard to their race, color, religion, gender, sexual orientation, national origin, familial status, marital status, disability, ancestry, age, source of income or other characteristics protected by law, the City of Rosemead has contracted with the California Housing Rights Center (HRC) to implement its Fair Housing Program. In July 2021, the city distributed flyers in English, Chinese, Vietnamese, and Spanish to all residents in the city to inform them of our Owner Occupied Home Improvement Programs which consist of: • Emergency Grant: Emergency grants are available to eligible senior citizens (62 years and older) for corrections to emergency code deficiencies which constitute an immediate health and safety risk. • Handyman Grant: Grants are available to eligible senior citizens (62 years and older) or handicapped/disabled citizens who need financial assistance for critical health and safety related improvements. The grant may be used for repairs related to code deficiencies such as new roofs, smoke detectors, and exterior painting. • Deferred Loans: The Loan Program provides homeowners financial assistance for housing rehabilitation or reconstruction by providing a zero to three percent (0% to 3%) interest, deferred payment loan. To achieve greater integration, the Housing Element includes Program 3, which supports ADU development that could result in additional housing opportunities citywide. Program 3 also fosters infill and redevelopment opportunities to increase public and private investment in lower opportunity areas to improve opportunities and create a high quality of life that could attract all racial/ethnic groups. Program 14 includes actions addressing segregation by working with the HRC and affirmatively marketing available sites. Persons with Disabilities The 2019 ACS identifies persons with disabilities in Rosemead as shown on Table D-3 below. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-8 Table D-3 – Persons with Disabilities Disability Age Group 5-64 65 and older Number Percent Number Percent Hearing Disability 307 0.9% 942 10.4% Vision Disability 410 1.2% 429 4.7% Cognitive Disability 909 2.2% 1,133 12.5% Ambulatory Difficulty 725 1.7% 2,022 22.3% Self-Care Difficulty 440 1.1% 1,127 12.5% Independent Living Difficulty 812 2.4% 1,881 20.8% The California Department of Developmental Services (DDS) estimates that 1,402 developmentally disabled individuals live within the ZIP code areas that encompass the City of Rosemead, as stated in the SCAG Report. The housing needs of persons with disabilities vary, but generally include accessible and affordable housing, and access to supportive services. More severely disabled individuals may require a group living environment where supervision is provided, and the most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. The HCD Data Viewer maps show that that the percentage of the population with a disability is predominantly less than 10 percent but with substantial areas in the city’s northwestern tracts reporting between 10 and 20 percent in the city and subregion, as shown on Figure D-3. The majority (73 percent) of RHNA sites are located in areas with the lowest percentage of population with a disability, as shown on Table D-4. Table D-4 – Disability Concentrated Areas of Population Lower Income RHNA Units Moderate Income RHNA Units Above Moderate Income RHNA Units Total Units <10% 1,788 617 1,730 4,135 10% - 20% 378 802 327 1,507 20% - 30% - - - - 30% - 40% - - - - >40% - - - - Total 2,166 1,419 2,057 5,643 Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-9 Figure D-3 – Sites Inventory with Disability Concentrated Areas of Population, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-10 Familial Status Familial status refers to the presence of children under the age of 18, whether the child is biologically related to the head of household, and the martial status of the head of households. Families with children may face housing discrimination by landlords who fear that children will cause property damage. Some landlords may have cultural biases against children of the opposite sex sharing a bedroom. Differential treatments such as limiting the number of children in a complex, or confining children to a specific location, are also fair housing concerns. Single-parent households are also protected by fair housing law. Female-headed households with children require special consideration and assistance because of their greater need for affordable housing and accessible day care, health care, and other supportive services. Rosemead remains a predominantly family-oriented city with 88 percent of its households composed of families. According to ACS data (2019), 23.2 percent of the city’s households are married-couple families with children under 18 years, which is above the countywide estimate of 19.4 percent. The SCAG Report looks at the city’s households compared to the broader region. SCAG reports that 17.3 percent of the city’s households are female-headed (compared to 14.3 percent in the SCAG region), 7.0 percent are female-headed with children (compared to 6.6 percent in the SCAG region), and 1.2 percent are female- headed and with children under 6 (compared to 1.0 percent in the SCAG region). Figure D-4 shows the distribution of female-headed households with children in the city and Figure D-5 shows married couple households with children. There are no areas of the city where female-headed households with children represent more than 40 percent of the households. As shown in Table D-5 and Table D-6, RHNA sites are not concentrated by familial status. Programs that support lower income households as discussed below, would also benefit female-headed households with children. Table D-5– Familial Status - Children in Married Couple Households Lower Income RHNA Units Moderate Income RHNA Units Above Moderate Income RHNA Units Total Units <20% - - - - 20% - 40% - - - - 40% - 60% 188 563 123 874 60% - 80% 1,978 798 1,905 4,681 >80% - 58 29 87 Total 2,166 1,419 2,057 5,643 Table D-6– Familial Status – Children in Female Headed Households Lower Income RHNA Units Moderate Income RHNA Units Above Moderate Income RHNA Units Total Units <20% 1,651 626 1,663 3,940 20% - 40% 516 793 394 1,703 40% - 60% - - - - 60% - 80% - - - - >80% - - - - Total 2,167 1,419 2,057 5,643 Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-11 Figure D-4 – Sites Inventory with Familial Status – Children in Female-Headed Households, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-12 Figure D-5 – Sites Inventory with Familial Status – Children in Married-Couple Households, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-13 Income Level Identifying low- or moderate-income (LMI) geographies and individuals is important to overcome patterns of segregation. HUD defines a LMI area as a Census tract or block group where over 51 percent of the population is LMI (based on HUD income definition of up to 80 percent of the AMI). Household income is directly connected to the ability to afford housing. Higher income households are more likely to own rather than rent housing. As household income decreases, households tend to pay a disproportionate amount of their income for housing, and the number of persons occupying unsound and overcrowded housing increases. Figure D-6 shows that a majority of the city’s population is made up of households that are within either the 50-75 percent LMI group, or the 75-100 percent LMI block groups. Similar to citywide conditions, Table D-7 shows that 79 percent of the city’s RHNA sites are in the 50-75 percent LMI area. The section on “Cost Burden” below provides additional information on the city’s low-income households, and how they compare to the SCAG region. To assist lower income residents, Program 14 includes meaningful actions to increase access to opportunity and reduce displacement. In addition, Programs 3, 6 and 10 focus on providing additional opportunities for new affordable housing, and Programs 1, 2, and 12 address direct assistance to renters and owners. Table D-7– Low to Moderate Income Population Lower Income RHNA Units Moderate Income RHNA Units Above Moderate Income RHNA Units Total Units < 25% 25% – 50% 50% - 75% 1,665 881 1,925 4,471 75% - 100% 502 539 131 1,172 Total 2,167 1,420 2,056 5,643 Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-14 Figure D-6 – Sites Inventory with Low to Moderate Income Population, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-15 2.3 Racially and Ethnically Concentrated Areas Racially/Ethnically Concentrated Areas of Poverty In an effort to identify racially/ethnically concentrated areas of poverty (RECAPs), HUD has identified census tracts that have a majority non-White population (greater than 50 percent) and a poverty rate that exceeds 40 percent, or is three times the average tract poverty rate for the metro/micro area, whichever threshold is lower. The Los Angeles County AI reports that the largest groupings of RECAP Census tracts can be found in downtown Los Angeles and, to a lesser extent, to the south in Long Beach. There are a few tracts designated as RECAP near San Fernando and to the north in the Lancaster/Palmdale area. This is consistent with information provided in the HCD Data Viewer as shown on Figure D-7 and Figure D-8. While no RECAPs are identified in the City of Rosemead, the HCD AFFH Data and Mapping Resources Data Viewer (Data Viewer) does show Census Tract 4823.04 as the only area of High Segregation and Poverty in the City. This tract is made up primary of multi-family residences, mobile homes, and discontinued businesses situated on large parcels along Garvey Avenue. Racially Concentrated Areas of Affluence While RECAPs have long been the focus of fair housing policies, racially concentrated areas of affluence (RCAAs) must also be analyzed to ensure housing is integrated, a key to fair housing choice. According to a policy paper published by HUD, RCAA is defined as “affluent White communities.”1 According to HUD’s policy paper, non-Hispanic Whites are the most racially segregated group in the United States, and in the same way neighborhood disadvantage is associated with concentrated poverty and high concentrations of people of color, conversely, distinct advantages are associated with residence in affluent non-Hispanic White communities. The AFFH Guidance Memo issued by HCD discusses research from the University of Minnesota as follows: “RCAAs are defined as census tracts where 1) 80 percent or more of the population is white, and 2) the median household income is $125,000 or greater (slightly more than double the national median household income in 2016). While this is a useful measure nationwide, HCD has adjusted the RCAA methodology to better reflect California’s relative diversity.” The AFFH Guidance Memo encourages jurisdictions to refer to the HCD Data Viewer for HCD’s adjusted definition of RCAAs, along with RCAA maps and accompanying data. However, the RCAA data layer is not currently available, and the HCD definition is not provided. Using data that is available on the Data Viewer, this fair housing assessment uses the percentage of non-Hispanic White population and median household income to identify potential areas of affluence. The city has no identified areas of affluence. 1 Goetz, Edward G., Damiano, A., & Williams, R. A. (2019) Racially Concentrated Areas of Affluence: A Preliminary Investigation.’ Published by the Office of Policy Development and Research (PD&R) of the U.S. Department of Housing and Urban Development in Cityscape: A Journal Policy Development and Research (21,1, 99-123). Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-16 Figure D-7 – Sites Inventory with Racially or Ethnically Concentrated Areas of Poverty, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-17 Figure D-8 – RECAPS 2013 – Regional, Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-18 2.4 Access to Opportunities TCAC/HCD Opportunity Area Maps To assist in this analysis, HCD and the California Tax Credit Allocation Committee (TCAC) convened in the California Fair Housing Task force to “provide research, evidence-based policy recommendations, and other strategic recommendations to HCD and other related state agencies/departments to further the fair housing goals (as defined by HCD).” The Task Force created Opportunity Area Maps to identify resources levels across the state “to accompany new policies aimed at increasing access to high opportunity areas for families with children in housing financed with 9 percent Low Income Housing Tax Credits (LIHTCs).” These opportunity area maps are made from composite scores of three different domains made up of a set of indicators. Table D-8 shows the full list of indicators. The opportunity area maps include a measure or “filter” to identify areas with poverty and racial segregation. To identify these areas, census tracts were first filtered by poverty and then by a measure of racial segregation. The criteria for these filters were: • Poverty: Tracts with at least 30 percent of population under federal poverty line • Racial Segregation: Tracts with location quotient higher than 1.25 for non-Hispanic Blacks, Hispanics/Latinos of any race, non-Hispanic Asians, or all people of color in comparison to the county Table D-8 – Domains and Indicators for Opportunity Area Maps Domain Indicator Economic Poverty Adult education Median home value Environmental CalEnviroScreen 3.0 (now uses 4.0) pollution Indicators and values Education Math proficiency, reading proficiency High school graduation rates Student poverty rates Transportation Employment job proximity High quality transit Source: California Fair Housing Task Force, Methodology for the 2020 TCAC/HCD Opportunity Maps, December 2020 The TCAC Opportunity Area Maps are available in the HCD AFFH Data and Mapping Resources Data Viewer (Data Viewer) and were used for this analysis. Higher composite scores mean higher resources. A review of composite scores shows that most of Rosemead is within the “moderate” resource area category, with a small “high” resource area located in the southern extent of the City. High Segregation and Poverty Areas The HCD Data Viewer identifies Census Tract 4832.04 as an area of “High Segregation and Poverty” (Figure D-9). The 1990 Census reported the City of Monterey Park to be 57% percent Asian, making it the first U.S. city with a majority Asian population. However, as Monterey Park became increasingly crowded, the Asian population turned their sights to neighboring cities such as Rosemead, Alhambra, San Gabriel, Montebello, and San Gabriel with wealthier Asians choosing to settle in Arcadia, San Marino, and Pasadena. As a result, Census Tract 4823.04 located in the City of Rosemead, which directly abuts the City of Monterey Park, gained an influx of a predominately low-income Asian population. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-19 Aiding the economic decline with the Census Tract 4823.04 was the loss of several large businesses and employment centers, including an auto dealership which provided generously to the City’s annual budget. For example, 8001 Garvey Avenue, formally known as the Los Angeles Auto Auction site, is located in Census Tract 4823.04. The economic recession of 2009 and the downward spiral automotive industry at that time caused the business to subside. As a result, dozens of surrounding business, which thrived for years on the auction’s activity, began to suffer, and eventually ceased. There have been numerous pursuers hoping to purchase and develop the now vacant site; however, due to the increase in the price of land throughout the entire San Gabriel Valley, it has been extremely difficult for potential buyers to acquire. In addition, the majority of the mobile home parks that are located in the City of Rosemead are within Census Tract 4823.04. This area is home to 3 large mobile home parks and is a contributing factor to the perpetuation of segregated and low-income households in this neighborhood. A majority of the parcels that are located in the area identified as “High Segregation and Poverty” are within in the Garvey Avenue Specific Plan (GASP). In 2018, the City of Rosemead adopted the GASP in an effort to revitalize and strengthen the identity and image of Garvey Avenue, as well as expand opportunities for concentrated commercial, industrial and residential uses that contribute to jobs and tax revenues to the community. The GASP transformed what was once a commercial corridor, which did not permit residential use, to a dynamic corridor which allows for a mix of residential and commercial uses. Today, multiple mixed-use projects in the GASP area have either been approved or in review. These mixed-use projects provide community benefits such as public parking, larger units for family-friendly development, and additional open space. In addition, developers have the option to incorporate SB 1818, which provides affordable housing for lower income and special groups, as well as take advantage of development incentives when property owners incorporate a variety of Community Benefits into their projects. Examples of Community Benefits include: • Providing public parking • Providing public open space • Providing family friendly developments such as units with three bedrooms or more, tot lots, libraries, and community gardens The City of Rosemead has several planning efforts underway that are located in High Segregation and Poverty Areas to address many of the housing challenges residents living in this area face including providing equitable housing choices and larger unit sizes to reduce overcrowding as 27 percent of renter- occupied households in the City experience this condition. Currently, there are six mixed-use projects under review (three approved by the Planning Division and in Building Plan Check) within the GASP and all the projects are proposing to utilize the above Community Benefits. The quality of life in the surrounding area should increase as the residents will have more opportunities to resources, and the area will be economically viable. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-20 Figure D-9 – Sites Inventory with TCAC Opportunity Areas, 2021, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-21 The city’s RHNA sites are predominantly (80 percent) located in “moderate” resource areas (Table D-9) According to the Data Viewer, Rosemead’s regional location within the San Gabriel Valley portion of Los Angeles County has a wide variety of rankings (Figure D-10). A closer look by topic area reveals that the city offers a mix of levels related to Environmental Outcomes (Figure D-11), and most of the city’s tracts are within the lower scoring categories for Positive Economic Outcomes (Figure D-12). The Education layer shows a large area of the city with fairly Positive Outcomes (Figure D-13). The Transportation layer shows block groups on the western portion of the city scoring between 20 and 40 percent, which indicates lower access to employment opportunities, while the central and eastern portions for the city generally have better access to employment opportunities (Figure D-14). Additionally, the lack of effective public transportation can be a factor that contributes to fair housing issues. However, as show in Figure D-15, a majority of residents in the city are within a half mile walk of a high-quality transit corridor. While CalEnviroScreen 4.0 data is incorporated into the environmental score shown in Figure D-11, Figure D-16 and Table D-10 provide a focus on Environmental Justice communities to further illuminate environmental conditions in the city and the relationship to the RHNA sites inventory; 88 percent of the city’s RHNA sites are within areas scoring between 71 and 90 percent, which indicates a high pollution burden. However, almost the entire city is considered an Environmental Justice community, so actions to improve environmental quality are needed citywide. To address this issue, the city is currently updating its Public Safety Element to address environmental justice goals, policies and actions. Environmental justice is an interdisciplinary issue that is additionally addressed in multiple elements of the city’s General Plan. Table D-11 shows where environmental justice topics are addressed in the General Plan, including the anticipated update to the Public Safety Element. In addition, the Housing Element has a wide range of programs that focus on preserving and enhancing existing housing and producing new affordable housing, as further discussed in Section 2.7, Summary of Fair Housing Issues of this assessment. Table D-9 – TCAC Opportunity Areas, 2021 Lower Income RHNA Units Moderate Income RHNA Units Above Moderate Income RHNA Units Total Units High Resource - 241 56 297 Low Resource - - - - Moderate Resource 1,978 626 1923 4,527 High Segregation & Poverty 189 552 77 819 Total 2,167 1419 2,063 5,643 Table D-10 – Environmental Justice Communities (CalEnviroScreen 4.0) Lower Income RHNA Units Moderate Income RHNA Units Above Moderate Income RHNA Units Total Units 61% - 70% 327 - 260 587 71% - 80% 912 1,030 342 2,284 81% - 90% 928 332 1,425 2,685 91% - 100% - 58 29 87 Total 2,167 1,419 2,057 5,643 Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-22 Figure D-10 – TCAC Opportunity Areas, 2021 – Regional Composite, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-23 Figure D-11 – TCAC Opportunity Areas, 2021 – Environmental, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-24 Figure D-12 – TCAC Opportunity Areas, 2021 – Economic, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-25 Figure D-13 – TCAC Opportunity Areas, 2021 – Education, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-26 Figure D-14– Job Proximity Index, 2014-2017, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-27 Figure D-15– High Quality Transit Areas, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-28 Figure D-16 – Sites Inventory with Environmental Justice Communities Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-29 Table D-11 – Environmental Justice in the General Plan Environmental Justice (EJ) Topic General Plan Element EJ Area of Focus Overview Introduction The General Plan vision expressed as “Envision Rosemead” is for the city to become a place “where people have many options for housing, employment, shopping, and recreation; where businesses create a strong economic foundation for high quality municipal services; where parks and recreational facilities offer opportunities for a diverse population to exercise and interact; where schools and teachers educate and inspire youth; and where the natural environment is protected and enhanced.” A specific vision is identified to “enhance parks and recreational space in underserved neighborhoods.” Population and Socioeconomic Characteristics Housing Identifies overall demographics and includes analysis of communities of color, low-income, cost-burdened, and special needs households. These populations often face a greater exposure to pollution and vulnerability to climate hazards and lack resources to adapt. Affirmatively Furthering Fair Housing (AFFH) Housing Section 2.I, Program 14, and Appendix D provide a comprehensive assessment of fair housing issues and meaningful actions. EJ goals overlap with AFFH goals as both initiatives are concerned with addressing inequities and fostering opportunities. Pollution Exposure Public Safety – EJ Section Goal 5 and related policies address pollution exposure and climate vulnerability. Actions prohibit new businesses that produce or transport hazardous wastes from locating in or adjacent to residential neighborhoods. Resources Management Goal 1 and related policies are to provide high-quality parks, recreation, and open space facilities to meet the needs of all Rosemead residents. Policy 1.3 addresses underserved needs. Goal 3 and related policies are to manage the use of and protect water resources, including eliminating groundwater and urban runoff pollution. Goal 4 addresses air quality and energy conservation and includes Policy 4.1 to integrate air quality planning with city land use, economic development, and mobility planning efforts. Land Use Policy 4.3 is to exclude commercial and industrial activities that adversely impact the city and its residents without providing corresponding benefits. Public Facilities Land Use Makes connections between the city’s economic health and the availability of public facilities and services. Public Safety Addressed comprehensively, with the Goal 6 section focusing on facilities from an EJ perspective. Resources Management Goal 1 calls quality parks, recreation, and open space facilities to meet the needs of all Rosemead residents. See also the Physical Activity row below. Food Access Public Safety – EJ Section Goal 5 includes a subsection supporting access to healthy food. Safe and Sanitary Homes Housing The provision of safe, sanitary and affordable housing is addressed throughout the Element. Land Use Fosters mixed-use and transit-oriented development along major corridors to provide opportunities for higher density residential development and enhanced economic development. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-30 Environmental Justice (EJ) Topic General Plan Element EJ Area of Focus Public Safety Policies under Goal 3 are to further community policing, education, and crime prevention programs through the County Sheriff’s Department. Physical Activity Introduction The General Plan focuses on the connections between residential neighborhoods and adjacent commercial centers that may lead to a healthier lifestyle for residents by creating opportunities to walk within the city that did not exist before. Circulation Goal 2 plus related policies and actions support development of infrastructure and services for active modes of travel including pedestrian and bicycle access, and strives for connectivity and amenities. Land Use Goal 3 and associated policies promote pedestrian-friendly mixed- use projects with public spaces and lively street fronts where people can meet and interact. Resource Management Plans for parkland and recreational open space. Goal 1 is to provide parks, recreation and open space to meet the needs of all residents. Policy 1.3 is to look for opportunities to establish public parks and other useable open space areas in those parts of Rosemead underserved by such facilities. Goal 2 is to increase greenspace throughout to improve community aesthetics, encourage pedestrian activity and provide passive cooling benefits. Action 2.8 is to connect parks and open space through shared pedestrian/bike paths and trails to encourage walking and bicycling. Land Use Action 5.20 supports bicycle and walking access. Civic Engagement Housing Section 1.E describes the importance of public input and how it influenced policies and programs. Public Safety Addresses equitable and effective civic engagement. Including Goal 6 and associated policies. Goal 4 includes policies for community engagement related to climate vulnerabilities. Resource Management Action 1.5 is to emphasize the need for citizen participation in reducing vandalism in city parks through the city’s Neighborhood Watch programs. Needs of Disadvantaged Communities Public Safety – EJ Section Identifies Rosemead’s disadvantaged community areas and addresses issues through Goals 5 and 6 and associated policies and actions. Land Use – Goal 5 and Actions Sets forth targeted land use changes that improve housing and economic opportunities. Calls for green buildings, energy and water efficiency and shade producing trees, and developing a heat island mitigation plan. Resource Management Goal 2 calls for increased greenspace throughout Rosemead to improve community aesthetics, encourage pedestrian activity, and provide passive cooling benefits. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-31 2.5 Disproportionate Housing Needs The AFFH Rule Guidebook defines “disproportionate housing needs” as “a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing needs when compared to the proportion of a member of any other relevant groups or the total population experiencing the category of housing need in the applicable geographic area.” (24 C.F.R. §5.152) The analysis is completed by assessing cost burden, severe cost burden, overcrowding, and substandard housing. Cost Burden A household is considered cost burdened if it spends more than 30 percent of its income in housing costs, including utilities. Reducing housing cost burden can also help foster more inclusive communities and increase access to opportunities for persons of color, persons with disabilities, and other protected classes. HUD Comprehensive Housing Affordability Strategy (CHAS) data demonstrates the extent of housing problems and housing needs, particularly for low-income households. Extremely low-income households represent the highest need group in terms of affordable housing, as the greatest subsidies are needed to make housing affordable for this group. As shown on Table D-12, there are 4,031 (27.4 percent) extremely low-income households in Rosemead. Of these, 3,030 are renter occupied and 1,000 are owner occupied. Table D-12 also provides a breakdown of extremely low-income households by race and ethnicity. The race/ethnicity with the highest share of extremely low-income households in Rosemead is Hispanic (32.6 percent compared to 27.4 percent of total population). In the SCAG region, the highest share of extremely low-income households is Black, non-Hispanic (27.1 percent compared to 17.7 percent of total households). CHAS data also reports that 64.5 percent (2,320) of the city’s extremely low-income households has at least one of four housing problems (incomplete kitchen facilities; incomplete plumbing facilities, more than 1 person per room; and cost burden greater than 30 percent). Table D-12 – Extremely Low-Income Housing Needs Total Households Households below 30% HAMFI Share below 30% HAMFI White, non-Hispanic 1,058 189 17.9% Black, non-Hispanic 30 0 0.0% Asian and other, non-Hispanic 8,727 2,243 25.7% Hispanic 4,909 1,599 32.6% Total 14,724 4,031 27.4% Renter-occupied 7,800 3,030 38.8% Owner-occupied 6,930 1,000 14.4% Total 14,730 4,030 27.4% HUD CHAS, 2012-2016. HAMFI refers to Housing Urban Development Area Median Family Income. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-32 The HCD Data Viewer provides a visual assessment of overpayment by homeowners and renters, by census tracts. Figure D-18 shows that in most of the city, 40 to 60 percent of Owner Households have monthly costs that are 30 percent or more of household income, using ACS (2015-2019) data. Figure D-20 shows that renters are more cost burdened than owners for the same period, as all census tracts show that 40 to 80 percent of renter households have monthly costs that are 30 percent or more of household income. However, overpayment by both owners and renters generally has generally gone down throughout the city since 2014, as the proportion of residents in higher income groups has increased (Figure D-17 through Figure D-20). Median household income in the city increased by approximately 60.3 percent from 2000 - 2019, closely tracking the trend in the county as a whole (61.2 percent) but continued to be lower than the county median income (for more details see Housing Element Table 12). The rise of higher income groups raises risks of displacement. In response, the city has provided Programs 4, 5, 6, 10, 11 and 14 that focus on maintaining existing housing and providing assistance to lower income and special needs households. For example, Program 12 addresses housing vouchers. The city’s 2020- 2025 Con Plan reported that the Section 8 Housing Choice Vouchers have continued to be administered by the Los Angeles County Development Authority (LACDA) on behalf of the City of Rosemead, offering tenant assistance for those qualifying low- to moderate-income residents. Voucher funds were used to provide rental assistance to very low-income residents within the city. The 2019 CAPER reports that 347 families received housing assistance. Of this, 83 families were Hispanic or Latino (of any race) and 264 were considered Non-Hispanic. The average contract rent was $1,503. The average Housing Assistance Payment was $1,025. Overcrowding HCD defines overcrowding as housing units occupied by more than one person per room in a dwelling unit, excluding kitchen and bathrooms, and severe overcrowding as more than 1.5 occupants per room. The most commonly occurring household size in Rosemead is two people (24.7 percent). However, when categories are combined, households of four to seven or more people make up 43.8 percent of the total households. The percent of households with four or more people is much higher in Rosemead than the county overall (29.3 percent in 2019). Large households often live in overcrowded conditions due to both the lack of units of appropriate size, and insufficient income to afford available units of adequate size. In Rosemead, 792 owner-occupied households (11.3 percent) and 2,105 renter-occupied households (27.4 percent) had more than 1.0 occupants per room, compared to 4.9 percent for owners and 15.6 percent for renters, respectively, in the SCAG region. 174 owner-occupied households (2.5 percent) and 648 renter-occupied households (8.4 percent) had more than 1.5 occupants per room, compared to 1.3 percent and 6.4 percent, respectively, in the SCAG region. Overcrowded households in the city within a regional context is shown on Figure D-21, which generally shows more overcrowding in the City of Los Angeles, and a wide range of conditions within the San Gabriel Valley. The city’s efforts to increase capacity for residential development through the Garvey Avenue Specific Plan, as well as new mixed-use zoning overlays, provide for more opportunities for a range of housing types suitable for various household types and income levels to be provided. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-33 Figure D-17 – Overpayment by Homeowners – 2014, City of Rosemead Figure D-18 – Overpayment by Homeowners – 2019, City of Rosemead Figure D-19 – Overpayment by Renters – 2014, City of Rosemead Figure D-20– Overpayment by Renters – 2019, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-34 Figure D-21 – Overcrowded Households – Regional, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-35 Substandard Conditions Because Rosemead is a mature community, the vast majority of its housing stock is 30 years of age or older. The advanced age of the majority of Rosemead’s housing stock indicates the significant need for continued code enforcement, property maintenance, and housing rehabilitation programs to stem housing deterioration. The ACS includes surveys about three factors of what may be considered substandard housing. Of these, as stated in the SCAG Report, Rosemead has 389 units that lack telephone service, 77 units that lack plumbing facilities, and 268 units that lack complete kitchen facilities. The City of Rosemead’s 2019 CAPER reported 1,306 code enforcement cases. The Data Viewer shows that the entire city falls within the category that indicates 20 to 40 percent of all households have any of the four severe housing problems monitored by CHAS (incomplete kitchen facilities, incomplete plumbing facilities, more than one person per room, and cost burden greater than 50 percent). Figure D-22 provides a city and regional view of incidence of severe housing problems. To maintain adequate housing conditions, the city operates an active Owner Occupied Housing Rehabilitation Program aimed at eliminating blight and improving the quality of life in Rosemead neighborhoods. The city’s 2020-2025 Con Plan reported that major activities focused on preservation of the city’s affordable housing stock through rehabilitation performed through grant and little to no interest deferred loan programs. The improvements ranged from basic health and safety improvements to full scale renovation projects to eliminate blighted conditions. Figure D-23 shows all property owners who applied for the city’s Owner Occupied Home Improvement Programs. As depicted, home improvement loans are distributed throughout the city, and there does not appear to be an overconcentration in any single neighborhood. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-36 Figure D-22 – Households with Severe Housing Problems – Regional, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-37 Figure D-23 – Properties Requesting Assistance from Owner-Occupied Home Improvement Programs Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-38 Displacement Risk The HCD Data Viewer, citing the UC Berkley Urban Displacement Project, shows that tracts in the northern and southern areas of the City contain “Sensitive Communities” that are identified as “Vulnerable” (see Figure D-24). Communities were designated Sensitive if they met the following criteria: • They currently have populations vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost. • Vulnerability is defined as: • Share of very low-income residents is above 20 percent, and • The tract meets two of the following criteria: • Share of renters is above 40 percent • Share of people of color is above 50 percent • Share of very low-income households (50 percent AMI or below) that are severely rent burdened households is above the county median • They, or areas in close proximity have been experiencing displacement pressures Additional local and regional data that informs displacement risk and helps shape program development includes: • State law requires an analysis of existing assisted rental units that are at risk of conversion to market rate. This includes conversion through termination of a subsidy contract, mortgage prepayment, or expiring use restrictions. The current at-risk analysis covers the period of 2021 through 2031. There are no at-risk units during this planning period and for the following ten years. • Housing security can depend heavily on housing tenure. Rosemead’s housing stock consists of 14,712 total units, 7,016 of which are owner-occupied and 7,696 of which are renter- occupied. The share of renters in Rosemead is higher than in the SCAG region overall (ACS 2014-2018). • In many places, housing tenure varies substantially based on the age of the householder. In Rosemead, the age group where renters outnumber owners the most is 15-24 (by 59.1 percent). The age group where owners outnumber renters the most is 60-64 (by 25.1 percent). • The SCAG Report, using 2012-2016 CHAS data, reports that 40.4 percent of Rosemead's elderly households earn less than 30 percent of the surrounding area income (compared to 24.2 percent in the SCAG region), and 62.4 percent earn less than 50 percent of the surrounding area income (compared to 30.9 percent in the SCAG region). Elderly households on fixed incomes may face a higher displacement risk as housing costs rise. In response, the city has provided Housing Element Programs 4, 5, 6, 9, 10, 11 and 12 that focus on maintaining existing housing and providing assistance to lower income and special needs households. For example, Program 1 seeks to assist low- and moderate-income households in repairing or improving their homes, Program 9 calls for zoning amendments that facilitate development of needed housing, Program 10 focuses on development of housing for extremely low-income households, and Program 12 addresses housing choice vouchers to provide direct assistance to qualified households. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-39 Figure D-24 – Sensitive Communities, City of Rosemead Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-40 2.6 Outreach State law requires that the preparation, adoption, and implementation of a housing element include a diligent effort to include public participation from all economic segments of the community. A diligent effort means going beyond simply giving the public an opportunity to provide input and should be proactively and broadly conducted through a variety of methods to assure access and participation. AB 686 also requires jurisdictions to include a summary of their fair housing outreach capacity. To address these requirements, the housing element must describe meaningful, frequent, and ongoing public participation with key stakeholders. In addition to outreach conducted specifically for preparation of the Housing Element update (and described in Housing Element Section 1.E), the update was also informed by public input received for the 2021-2022 Annual Action Plan report to the HUD pertaining to the city’s Con Plan. During the development of the Con Plan, the city solicited input from residents to identify and prioritize the various community needs. Furthermore, the city consulted with local public and private service providers to assess the housing and community development needs of low- to moderate-income households and special needs households. The city consulted with the Los Angeles County Development Authority (formerly the Los Angeles County Development Commission) and nonprofit organizations to determine funding needs for housing and services for homeless persons, low- to moderate-income persons, and low-income neighborhoods. As a result of the outreach, the Action Plan calls for concentrating resources to address the following goals: • Expand Fair Housing choice and access; • Expand affordable housing opportunities; • Maintain viable and energy efficient housing and commercial areas; • Maintain safe and green neighborhoods; and • Provide vital public services. These goals are reflected in the 6th Cycle Housing Element goals, policies and programs. 2.7 Summary of Fair Housing Issues The overlap of low resources, high segregation, and lower income households throughout most of the city indicates a need for comprehensive and place-based land use planning programs to remedy existing problems and work toward improving future opportunities and conditions. To address these needs, a significant city accomplishment was the adoption of the Garvey Avenue Specific Plan in 2018, which includes part of the area identified as a TCAC Area of High Segregation and Poverty (see Figure D-9). The Specific Plan vision is to “revitalize the Garvey Avenue corridor from a commercial/industrial area into a vibrant commercial, residential, and mixed-use district, with a complement of local and subregional serving retail, entertainment, and service businesses, office space, and community uses, all tied together with public improvements that create a vibrant and enjoyable pedestrian environment.” In addition, the City of Rosemead is now considering a Freeway Corridor Mixed-Use Overlay zone in targeted areas in and around the Interstate 10 (I-10) Freeway, which includes RHNA inventory sites along Del Mar Avenue, San Gabriel Boulevard, Walnut Grove Avenue, Valley Boulevard, Temple City Boulevard, and Rosemead Boulevard as shown on Figure D-9. The primary goal of this effort is focused on creating usable and modern development standards and guidelines, streamlining review procedures, and integrating implementation focused strategies. The city envisions transforming the identified opportunity areas into multi-modal, multi-use areas, where new residential development may be Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-41 incorporated. In addition, fostering investments in opportunity sites along the I-10 Freeway supports Strategy 1 of the City of Rosemead’s Strategic Plan 2018-2020. Strategy 1 focuses on aggressively pursuing economic development to enhance local shopping and dining options, encourage new high quality and affordable housing stock, beautify commercial corridors, create jobs, and increase General Fund revenues to sustain service levels and maintain public facilities. Completion of the FCMU Zone is anticipated to occur in 2021. Additional Zoning Code amendments described in Program 9 would, over time, result in incremental change citywide. As stated in the AI, the city’s accomplishments in affirmatively furthering the goal of fair housing choice, and eliminating impediments for fair housing choice, include continuing to contract with the HRC, a fair housing organization. HRC provided materials addressing disability, familial status, HRC services and protected individuals in multiple languages. In addition, housing, supportive services, and case management were provided to homeless persons through several of the city’s subrecipients such as Family Promise of San Gabriel Valley and Los Angeles Homeless Service Authority. Emergency, transitional, and permanent support was provided based on client need. Funding of nonprofit facilities that serve the homeless and other eligible recipients and neighborhoods align with the goals and strategies outlined in the Con Plan. In addition, the city continued to offer housing programs without impediments based on race, color, religion, sex, disability, familial status, or national origin. The city also strived to increase the awareness of the availability and benefits of city programs regarding housing choice, housing assistance, and landlord/tenant counseling through public information to the community. This information was distributed to the community in several ways, including notices placed in the city's newsletter, website, other social media outlets (i.e., Facebook, Instagram, Twitter), and community events. This proved to have a positive impact on the community by ensuring that the community is aware of the different services provided in works with the HRC on behalf of the City of Rosemead. The city also made significant progress in terms of land use and housing planning, including a Zoning Code Update as described in Appendix A, and adoption of the Garvey Avenue Specific Plan as previously discussed. Summary of Additional Fair Housing Concerns Priority areas of need as determined from public participation and research for the Con Plan include: 1. Preserve the city’s existing affordable housing stock for low- and moderate-income households (LMI) in the 0 to 80 percent of Area Median Income (AMI) category; 2. Promote, increase, maintain homeownership for LMI households; 3. Provide safe, affordable, decent housing for LMI renters; 4. Assist with energy efficient improvements; 5. Provide supportive services for non-homeless persons with special needs; and 6. Promote fair housing among all income categories. Housing, supportive services, and case management were provided to homeless persons through several of the city's subrecipients such as Family Promise of San Gabriel Valley and Los Angeles Homeless Service Authority. Emergency, transitional, and permanent support was provided based on client need. Funding of non-profit facilities that serve the homeless and other eligible recipients and neighborhoods align with the goals and strategies outlined in the Con Plan. These priority areas were incorporated into the Housing Element Section 5, Program 14 - Fair Housing Program. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-42 2.8 Local Data and Knowledge / Other Relevant Factors The City of Rosemead’s General Plan expresses an overall vision for the city to become a place “where people have many options for housing, employment, shopping, and recreation; where businesses create a strong economic foundation for high quality municipal services; where parks and recreational facilities offer opportunities for a diverse population to exercise and interact; where schools and teachers educate and inspire youth; and where the natural environment is protected and enhanced.” A specific vision is identified to “enhance parks and recreational space in underserved neighborhoods.” In addition, concurrent with the Housing Element update, the city has undertaken a focused Public Safety Element update that includes adoption of environmental justice policies and actions (see Table D-11). Specific Housing Element programs implemented in accordance with the 2014-2021 Housing Element that further fair housing included a Comprehensive Zoning Code Update and adoption of the Garvey Avenue Specific Plan. Through the Specific Plan, the city pre-entitled the development of 892 residential units and approximately 1.18 million square feet of commercial development. As such, new developments are not required to go through a lengthy and time-consuming planning entitlement process and additional environmental studies such as Environmental Impact Report. Together, these citywide plus place-based initiatives help foster a comprehensive approach to furthering fair housing goals. Segregation and Poverty The closure of the 17-acre Los Angeles Auto Auction along Garvey Avenue within a census tract identified as containing High Segregation and Poverty resulted in dozens of surrounding businesses that thrived for years on the auction’s activity to close. It is this elimination of capital and investment that has disproportionately impacted lower income Asian residents by reducing access to neighborhood services and opportunities, eliminate jobs in the community, and increasing commute times. There have been numerous developers looking to purchase and develop the 17-acre site; however, due to the increase in the price of land throughout the entire San Gabriel Valley, market conditions have made extremely difficult for potential buyers to acquire the property for redevelopment. To address this, the City offers numerous development targeted incentives via the Garvey Avenue Specific Plan to encourage development of housing and neighborhood-serving commercial on this site and through-out the specific plan area. In addition, the majority of the mobile home parks that are located in the City of Rosemead are within Census Tract 4823.04. This area is home to 3 large mobile home parks, and is considered a contributing factor to the perpetuation of segregated and low-income households in this neighborhood. Neighborhood Accessibility Improvements The City of Rosemead 2021-2022 Consolidated Plan includes priority needs identified via community engagement activities and data collection and analysis. One of those priorities includes maintaining safe and green neighborhoods in geographic areas consisting of low- and moderate-income households. The City anticipates obtaining approximately $1,100,000 in federal funding by 2025 for community park improvements, creating green streets, establishing new sidewalks and/or safe routes to schools, street lighting and other infrastructure upgrades. Housing Conditions The advanced age of the majority of Rosemead’s housing stock indicates the significant need for continued code enforcement, property maintenance, and housing rehabilitation programs to stem housing deterioration. Insights on housing conditions were gained through a recent 2022 citywide windshield survey conducted by the City’s Code Enforcement Division. According to the survey, approximately 3 Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-43 percent of homes were considered in need of rehabilitation or replacement. These homes are located throughout the city, with a majority located south of the I-10 Freeway in the central, western, and southern portions of Rosemead (Figure D-25). Figure D-25 – Citywide Housing Conditions, Windshield Survey – April 2022 Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-44 Additionally, Code Enforcement Division records shows a higher number of cases related to property maintenance occurred within the census tract (4823.04) identified as a High Segregation and Poverty area than other neighborhoods within the city. From January 1, 2021 to December 15, 2021, Census Tract 4823.04 had 62 code enforcement cases related to illegal construction, property maintenance, zoning, and construction projects. Of the 62 cases, 55 of those cases dealt with property maintenance. Code Enforcement and Neighborhood Preservation Programs are aimed at eliminating blight and improving the quality of life in Rosemead neighborhoods. Through these programs, residents are encouraged to become educated on the city’s municipal and zoning codes and to establish neighborhood and other community partnerships to find ways to keep their neighborhoods blight-free. The City of Rosemead’s 2019 CAPER reported 1,306 code enforcement cases, when only 1,000 were expected. The data shows the city opened 532 CDBG case for the 2018/2019 fiscal year with 496 of the CDBG cases have been close and 36 remain active. The city did not refer any cases to the City Attorney. For 2020, 746 residential code enforcement cases have been opened. 3. Sites Inventory RHNA Sites and AFFH Analysis Figure D-1b of this appendix shows the sites inventory for the 6th Cycle RHNA. The City of Rosemead is a highly urbanized community that has few vacant parcels. As such, most of the opportunities for affordable housing growth lie in supporting continued infill and ADU development, along with the recycling of currently underutilized properties at higher densities, in accordance with the city’s new mixed use zoning regulations. In total, vacant sites and potentially recyclable sites, plus ADU projections as detailed in Chapter 4 – Housing Resources, account for a maximum potential of 9,915 units at various income levels (with a realistic capacity of 6,879 units), which substantially exceeds the city’s RHNA allocation of 4,612 units as shown in Table D-13. Table D-13 Housing Projections, 6th Cycle Housing Element Update: Rosemead Area Area Name/ Unit Type Maximum Units Realistic Capacity4 Income - VL/L Income - Mod Income - Above % of RHNA (at 70%) Vacant Vacant Sites 1,857 1,091 232 286 572 23.7% Non-Vacant Non-Vacant Sites 7,674 5,404 1,783 991 2,631 117.2% Accessory Dwelling Units ADU Accessory Dwelling Units 384 384 262 8 114 8.3% Grand Totals 9,915 6,879 2,277 1,285 3,317 149.2% The following is a summary of comparing the proposed RHNA site locations with the AFFH data presented in this Appendix. • The entire City of Rosemead is made up of non-Hispanic Asian Majority census tracts; therefore, all of the projected 6,879 RHNA units are located in communities of color (predominately non- Hispanic Asian Majority) which are geographically dispersed throughout the City, as shown in Figure D-1A of this Appendix. • Approximately 1,507 units are anticipated on RHNA sites in census tracts that contain between 10 percent and 20 precent of persons with disabilities as shown in Figure D-3 of this Appendix. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-45 Of the 1,507 units, 1,180 units are assumed for lower- and moderate-income households located in Census Tracts 4823.04, 4824.01, and 4825.02. The City anticipates targeting lower income areas with greater opportunities and access for disabled residents by facilitating production of affordable housing options and street infrastructure improvements such as streets, sidewalks, curbing, as discussed earlier in this Appendix. • Census Tracts 4823.04, 4825.02, 4825.03, and 4329.02 contain the highest percentage of female- headed households (20 percent to 40 percent) in the City. Approximately 1,871 RHNA units are projected to be located in these four tracts, increasing housing options and resources for female- headed households. • Most of the City contains census tracts where the Low-Moderate Income Population is between 50 percent and 100 percent. However, approximately 1,632 RHNA units are projected in Census Tracts 4329.01 and 4329.02 located in the northeast portion of the City with Low-Moderate Income Population less than 50 percent. • No RECAPs are identified in the City. However, Census Tract 4823.04 has been identified as an area of High Segregation and Poverty. This tract is made up primary of multi-family residences with discontinued businesses on large parcels along Garvey Avenue. The Garvey Avenue Specific Plan which covers this entire tract is intended to expand opportunities for concentrated commercial, industrial and residential uses that contribute to jobs and increase housing opportunities in the community. • An overwhelming majority of RHNA sites are located in census tracts identified as having either High or Moderate resource levels. • Only Census Tract 4823.04 is designated as a High Segregation and Poverty Area (Figure D-9). This tract encompasses the entirety of the Garvey Avenue Specific Plan area where 183 lower income RHNA units and 402 moderate income RHNA units are anticipated to address various housing needs in this tract. • Nearly 32 percent of the projected RHNA units are proposed in Census Tracts 4823.04, 4824.01, and 4825.03 which will assist in addressing high levels of overcrowded conditions by facilitating development of 1,786 new units in these three tracts alone. • All but three Census Tracts (4329.02, 4813, and 4824.02) in the City contain populations vulnerable to displacement risk due to increased home values, rental rates, and potential gentrification. • Rosemead offers residential financial assistance via the HOME Investment Partnership (HOME) and Down Payment Assistance programs which provides rental assistance and low interest deferred payment loans to homebuyers. Table D-14 City of Rosemead Sites Inventory AFFH Analysis Census Tract RHNA Units (Realistic Capacity) Capacity AFFH Indicators Lower Moderate Above Moderate Communities of Color Low- Mod Income TCAC Ovrpmt (Rent) Ovrpmt (Own) Ovrcrwd 4823.03 553 400 0 153 61.5% 73.7% Moderate 51.9% 51.9% 18.5% 4823.04 993 183 402 408 51.4% 74.3% High Segregation & Poverty 66.3% 75.8% 40.8% 4825.02 55 0 10 45 67.4% 79.1% High 51.8% 42.1% 8.63% 4825.03 310 0 232 78 63.1% 81.6% High 52.3% 71.1% 29.4% Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-46 4824.01 483 190 197 96 58.6% 75.3% Moderate 66.4% 9.9% 28.9% 4824.02 73 0 52 21 58.5% 57.1% Moderate 58.5% 52.7% 9.3% 4336.02 577 489 0 88 58.2% 75.3% Moderate 61.8% 47.0% 11.6% 4322.01 141 125 0 16 63.7% 62.3% Moderate 56.7% 47.1% 20.4% 4322.02 144 46 82 16 55.9% 54.2% Moderate 49.0% 41.8% 7.9% 4329.01 1,630 439 69 1,122 64.2% 48.5% Moderate 53.5% 46.6% 18.2% 4329.02 494 254 0 240 51.3% 47.7% Moderate 56.1% 33.6% 7.7% 4813 190 0 1 189 62.7% 55.7% Moderate 46.2% 46.8% 10.4% TOTAL 5,643 2,126 1,045 2,472 Table D-14 above further evaluates the geographic distribution of sites by projected income category and socio-economic characteristics of census tract that contain selected RHNA sites. The City of Rosemead Housing Element sites inventory accomplishes this goal by providing zoning for a variety of housing types throughout the community. As discussed previously, Census Tract 4823.04 is the only tract in the City identified as a High Segregation and Poverty area where 74 percent of the residents in that tract are considered low and moderate incomes earners, and where overpayment (cost burden) conditions for both renters (66 percent) and homeowners (76 percent) are the highest in the City. Rosemead anticipates targeting this tract with increased housing opportunities and capacity, projecting nearly 1,000 RHNA units through various planning strategies including creation of new specific plans that foster mixed-income residential projects leading to better socio-economically integrated communities. Moreover, the City projects over 800 moderate- and above moderate-income units to be developed in Census Tract 4823.04 which has the potential to sharply improve the resource level of an area identified as containing High Segregation and Poverty. There are also over 900 new units projected in areas where households earning Low and Moderate incomes are the highest in the City at over 73 percent. This additional residential supply will assist in making home and rental prices more affordable to residents in tracts 4823.03, 4823.04, 4825.02, and 4825.03. Lastly, over a third of RHNA sites assumed to accommodate lower income residents are located in tracts identified as Moderate or High resource areas where proximity to higher preforming schools, jobs and economic opportunities, and better environmental conditions exist. 4. Identification and Prioritization of Contributing Factors In January 2020, the city adopted an AI. Through data analysis and community engagement activities the following barriers to fair housing were identified: • Low number of affordable housing units. • High housing land, construction and labor costs. • Lack of rent control/stabilization policies particularly for single parent households, persons with disabilities and seniors. • Stagnant salaries compared to the rising cost of housing. • Lack of time or finances for increased education. • Safe crosswalks and guards on routes to school. • Access to the internet for school-age children. • Limited amount of recreation and open play areas and public spaces. • Lack of funding and knowledge about existing housing placement services, rental assistance, and rent deposit services/programs. • Lack of individual and local resources to maintain housing stock. • Lack of wrap-around services for families purchasing homes for the first time. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-47 • Lack of local housing agencies’ capacity for family placement services and to create more housing opportunities in the city. • Lack of implementation of local housing policies for affordable housing development. The final chapter of the AI discusses the ways and means the city can begin to remediate or reduce the barriers to affordable housing, which were used to inform the city’s Five Year Con Plan (2020-2025). The 2020-2025 Con Plan included priority areas of need and a set of goals which are listed below and were determined from public participation, including a Community Needs Survey, and research for the Con Plan, which included review of the AI. Priority Needs 1. Provide ongoing assistance to combat discrimination through the promotion of fair housing education, legal representation, local support for affordable housing development projects, and counseling and financial training services. 2. Build new affordable housing units, acquire lands for affordable housing projects, affordable housing programs, homebuyer and rental assistance programs. 3. Combat housing purchase and development costs by partnering with public and private developers and supporting programs and projects that further collaboration. 4. Support social service agencies and nonprofit development corporations that provide innovative services and provide housing for homeless or those at risk for homelessness. 5. City capital improvement projects, social service agency capital projects, street infrastructure improvements such as streets, sidewalks, curbing and other public facilities, safe routes to school infrastructure, and addressing public safety concerns. 6. Support future capital recreation improvement projects throughout the city as well as connection points to and from LMI neighborhoods and schools. 7. Support social service agencies that provide shelter space and services that address homeless needs. 8. Continue to fund housing and commercial property rehabilitation initiatives including the city’s housing improvement program, residential (or commercial) façade improvement programs, housing acquisition and rehab; lead-based paint testing and abatement; commercial façade program; and supported project work. Goals 1. Expand Fair Housing choice and access 2. Expand affordable housing opportunities 3. Maintain viable and efficient energy efficient housing and commercial areas 4. Maintain Safe and Green Neighborhoods 5. Provide Vital Public Services 6. Planning and Administration-Efficient and effective administration of planning and execution of community development and housing rehabilitation 5. Summary and Conclusions The overall conclusion of the AFFH assessment is that there is a need for additional affordable housing and actions to address environmental justice. Environmental justice is addressed in the Public Safety Element and throughout the General Plan. Regarding housing, the city’s built-out nature means that it can only make incremental additions to the housing supply. Focused initiatives to increase housing Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-48 capacity, such as the Garvey Avenue Specific Plan, help to address the challenge, but the number of units ultimately added will likely be insufficient to affect the larger regional housing market. Programs to increase affordable housing supply and affordability include Program 3 actions to support infill development and site recycling, and Program 6 to provide adequate sites to support efforts for the city to meet its fair share of the regional housing need. In addition, Program 10 addresses development of for lower income housing using HOME funds, and other State and federal loans and grants, according to the specific nature of the project. The city will also provide regulatory incentives, such as implementing the density bonus program. Program 12 addresses use of Housing Choice Vouchers to support low-income renters. Since housing voucher assistance is provided on behalf of the family or individual, participants are able to find their own housing, including single-family homes, townhouses, and apartments. The participant is free to choose any housing that meets the requirements of the program and is not limited to units located in subsidized housing projects, which could help the city meet integration goals. The identification of contribution factors and additional meaningful actions to address them are included in Housing Element Section 5.B, Program 14. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-49 6. Fair Housing Program The city has had an ongoing commitment to prevent, reduce, and ultimately eliminate housing discrimination and other barriers related to equal opportunity in housing choice, and adopted an updated Five Year Analysis of Impediments to Fair Housing Choice (AI) in January 2020. Affirmatively furthering fair housing (AFFH) requires taking meaningful actions to address impediments identified in the AI, and to additionally address other impediments that were discovered through the AB 686 assessment completed as a part of the Housing Element Update. The AFFH Assessment is provided as Appendix D, and the resulting programs are identified as follows. Fair Housing Issue Contributing Factor Priority Meaningful Action Outreach and Enforcement Implementation of fair housing laws Lack of public awareness of fair housing laws and affordability housing advocacy Lack of funding and knowledge about existing housing placement services, rental assistance, and rent deposit services/ programs. Medium Continue to work with the Housing Rights Center (HRC) to expand its Fair Housing Program in Rosemead to: • Develop a local outreach program about the positive impacts of affordable housing. • Begin educational programs that promote the positives of integrated income neighborhoods to change local attitudes about affordable housing. • Annually review and report on apartment rental advertisements released by private housing companies. Continue to Provide CDBG funding to the HRC to handle fair housing cases and education. Assist 10 households and conduct 5 tenant or landlord training sessions between 2023 and 2029 included targeted outreach in census tract 4832.04. Also see: • Program 5 - Community Housing Development Organization (CHDO) Construction Program • Program 8 - Opportunity Sites Marketing and Outreach Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-50 Fair Housing Issue Contributing Factor Priority Meaningful Action Segregation and Integration Housing Mobility Increasing levels of segregation with high concentrations of Asian and/or Hispanic populations, but is likely the result of natural settlement patterns. All census tracts have a high concentration of minority residents. High By end of 2023, adopt an official affirmative marketing policy designed to attract renters and buyers of protected classes. Assign HRC, as a part of its Fair Housing Contract, to annually review and report on apartment rental advertisements released by private housing companies. When holding community meetings, proactively outreach to a wide range of community groups. Through these steps, the City’s goal will be to raise community awareness and access to information by at least 20 percent. Also see: • Program 8 - Opportunity Sites Marketing and Outreach • Program 12 - Section 8 Rental Assistance Payments/Housing Vouchers R/ECAP and Access to Opportunity City has a TCAC area of High Segregation and Poverty. City has no R/ECAPs, but is in a region with R/ECAPs Low homeownership Difficulty in securing housing using Housing Choice Vouchers Enhance place-based investments Barriers to mobility Lack of opportunities for residents to obtain housing in higher opportunity areas High Starting in 2022, provide more outreach and education to housing providers and potentially qualified residents regarding Housing Choice Voucher program. Through these steps, the City’s goal will be to increase participation in the voucher program by 10 percent annually, specifically targeting Census Tract 482303. By early 2023, pursue community revitalization through development in the mixed-use overlay zones and the Garvey Avenue Specific Plan (GASP). Increase public investment to provide public services, “green” characteristics, public amenities and overall characteristics that foster positive economic, environmental and educational opportunities. Continue to accommodate persons with disabilities who seek reasonable waiver or modification of land use controls and/or development Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-51 Fair Housing Issue Contributing Factor Priority Meaningful Action standards pursuant to procedures and criteria set forth in the Municipal Code and process 100% of received requests. By end of 2022, identify vacant residential properties for targeted rehabilitation, and support infill, site recycling and ADU development. Stimulate economic growth by providing low interest loans to business owners using CDBG funds, including two business owners in TCAC areas. Also see: • Program 3 - Infill Housing Development and Site Recycling • Program 6 - Adequate Sites Inventory and Monitoring for No Net Loss • Program 8 - Opportunity Sites Marketing and Outreach Safe and Green Neighborhoods Land use planning and economic development decisions Limited amount of recreation and open play areas and public spaces Medium Evaluate all proposed amendments to the General Plan’s Land Use Map and the Zoning Map for their effect on AFFH. Pursue funding to assist neighborhoods of concentrated poverty for investment in factors such as rehabilitation, parks, transit, and active transportation. Ensure economic development plans reflect the needs of lower-opportunity neighborhoods. Also see: • Program 3 - Infill Housing Development and Site Recycling • Program 6 - Adequate Sites Inventory and Monitoring for No Net Loss Disproportionate Housing Needs and Displacement Risk Displacement in Vulnerable Communities Lack of affordable housing in a range of sizes Land use and zoning laws High housing land, construction and labor costs High cost of repairs High By end of 2024, increase City efforts to enable and promote residential development through use of the mixed-use overlay zones, the Small Lot Ordinance and GASP. These initiatives provide new opportunities for a variety of residential Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-52 Fair Housing Issue Contributing Factor Priority Meaningful Action Displacement risk as higher- income households move into the community development types and prices, and include areas where residential development was previously not allowed. By end of 2022, promote use of the State Density Bonus Law through website materials and counter assistance. Preserve the City's existing affordable housing stock for low- and moderate- income households (LMI) in the 0 to 80 percent of Area Median Income (AMI) category, with targeted efforts in census tracts 4336.02, 4823.04, 4824.01, and 4825.03. Acquire land for affordable housing using CDBG funding to assist 20 low- income families. By end of 2023, review ways to control rent and or housing sale costs for City rehabbed properties throughout the community. To assist in the housing needs for persons with developmental disabilities, the City will implement programs to coordinate housing activities and outreach with the Eastern Los Angeles Regional Center (ELARC), encourage housing providers to designate a portion of new affordable housing developments for persons with disabilities, especially persons with developmental disabilities, specifically targeting Census Tracts 481300, 482304, 482401, and 482502, and pursue funding sources designated for persons with special needs and disabilities by the end of 2025. Continue to provide low interest loans to five low- to moderate-income homeowners of single-family home and condominiums to make home repairs using HOME funds. Promote, increase, maintain homeownership for LMI households, with targeted efforts in census tracts 4336.02, 4823.04, 4824.01, and 4825.03. Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-53 Fair Housing Issue Contributing Factor Priority Meaningful Action Continue to monitor and preserve affordable senior housing units for lower income elderly households throughout the community. Promote fair housing among all income categories throughout the community. Also see: • See Program 1 - Owner Occupied Rehabilitation Program • See Program 2 - Down Payment Assistance Program • See Program 3 - Infill Housing Development and Site Recycling • See Program 9 - Special Housing Needs and Zoning • See Program 12 - Section 8 Rental Assistance Payments/Housing Vouchers • See Program 13 - Mobile Home Park Assistance Program (MPAP) Access to services Medium Provide more outreach and education to extremely low-income households regarding Housing Choice Voucher and other supportive programs. Through these steps, the City’s goal will be to increase participation in the voucher program by 10 percent annually, specifically targeting Census Tract 482303. Provide supportive services for non- homeless persons with special needs. • Provide nutritious meals to 50 seniors each week. • Provide employment opportunities for 15 high school-aged youth annually. • Coordinate housing activities and outreach with ELARC and pursue funding sources designated for persons with special needs and disabilities Also see: • See Program 12 - Section 8 Rental Assistance Payments/Housing Vouchers Rosemead 2021-2029 Housing Element Appendix D – Fair Housing Assessment  D-54 Fair Housing Issue Contributing Factor Priority Meaningful Action Rental housing conditions Medium By end of 2023, review the feasibility of establishing city-wide rental property inspection programs as a way to combat issues of blight and deterioration in rental housing. A local program could be created with other jurisdictions to share costs. Enforce routine rental inspections throughout the community that encourage landlords make financial decisions to either reinvest or to sell. Aging housing stock High Continue and expand rehabilitation programs based on available funding, including CDBG funding to rehabilitate 10 units. Assist with energy efficient improvements annually. Through this step, the City’s goal will be to provide assistance to 5-8 households annually. By end of 2023, develop innovative code enforcement methods to create a larger pool of decent housing options. By early 2023, review the feasibility of establishing a city-wide rental property inspection program as a way to combat issues of blight and deterioration in rental housing. • A local program could be created with other jurisdictions to share costs. • Enforces routine rental inspection that encourage landlords make financial decisions to either reinvest or to sell. By end of 2025, create a revolving loan fund for homes with dire code violations so that properties could be available for purchase or rent. Also see: • Program 1 - Owner Occupied Rehabilitation Program • Program 5 - Community Housing Development Organization (CHDO) Construction Program