CITY COUNCIL AGENDA ITEM
ACTION REQUESTED:
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Accept the 2017 Analysis of Impediments to Fair Housing Choice Report.
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DEPARTMENT: City Clerk’s Office
SUBMITTED BY: Ruth Broder, Community Planner/Community Grants Coordinator
BOARD/COMMISSION REVIEW:
N/A.
BACKGROUND:
The request to accept the 2017 Analysis of Impediments to Fair Housing Choice Report first appeared on the April 5, 2017 City Council agenda. By consensus Council tabled the item to the May 16 meeting.
All communities receiving Community Development Block Grant (CDBG) funds from the U.S. Department of Housing and Urban Development (HUD) must certify that they will affirmatively further fair housing, as required by the Housing and Community Development Act of 1974. To meet this obligation, cities must periodically conduct an Analysis of Impediments to Fair Housing Choice (AI). The AI assesses the conditions, both public and private, that affect equal and free access to residential housing for all persons, regardless of race, color, religion, sex, disability, familial status or national origin. The AI identifies impediments to fair housing choice and provides an Action Plan to guide the community as it works toward eliminating these obstacles.
DISCUSSION:
The City of Naperville prepared AI reports in 1996 and in 2007. In its Program Year 2013 Year End Review in 2014, HUD recommended that Naperville prepare an updated AI. The new AI was delayed while the City and HUD reviewed the impact of HUD’s new fair housing rule, adopted in 2015. HUD recommended to prepare the AI as originally planned. The City issued a Request For Proposals (RFP) and received five responses. Three consultants were interviewed by a staff committee composed of employees of the City Clerk’s Office and the TED Business Group. In March, 2016, the City awarded the contract to Mullin & Lonergan Associates, Inc., a Pennsylvania-based firm with extensive background in fair housing and HUD community development programs. Mullin & Lonergan (M&L) also had previous experience preparing AI’s and other HUD reports for several municipalities and counties in northeastern Illinois.
M&L analyzed Naperville’s demographic and housing market data, interviewed staff and municipal officials, and conducted an online resident survey. They also conducted interviews with a variety of stakeholders, including housing agencies, affordable housing providers, disability advocacy organizations, fair housing advocates, and homeless assistance and human services provider organizations. Preliminary data were presented at a public meeting sponsored by the Housing Advisory Commission (HAC) on July 11, 2016.
M&L produced several draft documents based on continued research. They were reviewed by staff and by the HAC. An initial final draft was made available for public comment from January 23, 2017 to February 21, 2017. Mullin & Lonergan returned to Naperville to present this draft at a second HAC public meeting on February 2. Public comments received were considered, and the final draft was revised to incorporate this input.
The final report presents findings on demographic and housing market trends, including income and poverty, housing affordability, segregation/integration, mortgage approvals/denials, publicly supported housing, disability, and areas with high concentrations of racial/ethnic minorities and poverty-level households. The report also presents data on fair housing complaints and their disposition.
The report finds that racial and ethnic diversity have increased significantly in Naperville over the past decade, and that households generally have high median incomes compared to state and national averages. The level of racial/ethnic segregation is relatively low and there have been few verified discrimination complaints. However, there are income disparities between different groups and some groups, such as female-headed households and persons with disabilities, are overrepresented among persons below poverty level. The report also identifies several areas with higher than average percentages of racial/ethnic minorities and households in poverty.
To address these issues, the AI identifies four impediments to fair housing choice:
• Impediment #1: Fair housing education and outreach efforts continue to be necessary to educate residents about their rights and responsibilities and to deter housing discrimination.
• Impediment #2: Persons with limited English proficiency may not be able to fully access Naperville’s housing and community development programs and services for which they are eligible due to language barriers.
• Impediment #3: An inadequate supply of affordable housing exists throughout Naperville.
• Impediment #4: The public transportation system within Naperville restricts housing choice and access to employment and education opportunities for residents who are transit-dependent.
These impediments are described in detail in the AI report, along with 12 proposed actions designed to reduce the impediments. Goals and Action Items are shown in the Fair Housing Action Plan (attached) and on pages 103-104 of the AI. The Action Items are also categorized by complexity, cost, funding source, timeframe and implementation partners.
Following adoption of the AI, the HAC will begin to implement the Action Items, starting with the items that can be implemented within a year. These items, to be determined by the HAC, include education, outreach and training targeted towards various groups, homebuyer education, and reviewing procedures for investigating fair housing complaints. $6,000 of the 2017 CDBG funds have been allocated to support these efforts.
Actions and progress taken to address the impediments to fair housing choice will be reported to HUD each year with the Consolidated Annual Performance and Evaluation Report (CAPER).
FISCAL IMPACT:
$6,000 of 2017 CDBG funds have been allocated for educational, training, and outreach programs. Future program initiatives may be eligible for CDBG funding or would require City Council approval through the annual budget process.