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HomeMy WebLinkAboutItem No. 07 - Review Draft of FY 2020-2025 Consolidated Plan Page 1 Staff Report City of San Bernardino Request for Council Action Date: March 18, 2020 To: Honorable Mayor and City Council Members From: Teri Ledoux, City Manager By:Michael Huntley, Community & Economic Development Director Subject: Review Draft of FY 2020-2025 Consolidated Plan, Analysis of Impediments Associated with CDBG / HOME Recommendation It is recommended that the Mayor and City Council of the City of San Bernardino, California, conduct the first public hearing on the review of the draft Fiscal Year 2020- 2025 Consolidated Plan, Analysis of Impediments to Fair Housing (AI) and Fiscal Year 2020/21 Annual Action Plan (AAP) and provide recommendation or comments to the draft documents. Background The City of San Bernardino (City) must submit to HUD a Five-Year Consolidated Plan (ConPlan), Fiscal Year 2020-2025, that includes an Analysis of Impediments to Fair Housing document (AI), first-year Annual Action Plan (AAP), Fiscal Year 2020/21 that explains how the City intends to invest these federal funds toward meeting the City’s community development, affordable housing, and homeless prevention needs by May 15, 2020. The City hired a consultant, Michael Baker International Inc. (MBI), to assist in the preparation of the ConPlan, FY 2020-2025, that includes the AI, and the AAP, Fiscal Year 2020/21. MBI assisted in community engagement efforts. Community engagement is key for helping the City to identify needs, priorities, goals, strategies, and activities for future housing and community development activities over the next five - year ConPlan period. Engagement activities included a community survey, community meetings, pop-up events, a housing summit, and stakeholder consultations. As part of the stakeholder consultation process, the City consulted with a variety of stakeholders, including local and regional community-based organizations, health and mental and behavioral health care providers, and housing service organizations. Community engagement was achieved through engaging a diverse group of stakeholders to identify priorities, concerns, and values. The feedback provided through the community engagement process supported the development of this ConPlan, including the development of housing and community development needs, priorit ies, goals, and strategies for funding allocation. For the purposes of this plan, the stakeholders include all residents, business owners, 6639 Page 2 and interest groups. Targeted outreach was provided to youth, elderly, racial and ethnic minorities, residents, property owners, and business owners across the City. Leveraging existing stakeholder contacts, recognizing underrepresented stakeholders, and identifying new stakeholders was integral to the process of reaching the greater San Bernardino community and ensuring a broad depth of participation. The City announced the various community engagement opportunities through a social media campaign strategy and schedule, including announcements, project updates, and educational content for Twitter, Facebook, and Instagram posts. Announcements for the online survey and public comment periods were also promoted over email, where key stakeholder contacts were leveraged as liaisons to access larger stakeholder groups. Stakeholders had the following opportunities for participation and comment, all of which were offered throughout San Bernardino during the ConPlan process: Community Meeting: Walk-in meetings were held at six different locations across the City. Interactive engagement stations created opportunities to shar e personal stories, suggest ideas for strengthening neighborhoods and prioritizing community needs, and review ConPlan data and maps. Housing Summit: A housing summit was held for community leaders, agency representatives, service providers, planning professionals, land developers, and business owners to learn and exchange information about the current state of housing and development in the City. Stakeholder Interviews: Various local organizations were interviewed to receive feedback on the most pressing priorities and needs of target populations. Pop-Up Events: Structured for short interactions, the pop-up took the form of a booth set up at an event to allow access to a specific stakeholder group. Feedback provided at pop-up events was collected through interactive exercises (dot votes, etc.) or verbal responses to big picture questions. Online Feedback Collection (Survey and Form): To broadly access and efficiently obtain information from a large number of geographically distributed stakeholders, an online survey was prepared. The survey included specific and open-ended questions about the public review draft and provided an opportunity to leave additional, relevant comments. The survey was announced through City media outlets and disseminated through key community liaisons or stakeholders with access to resident and community groups, business owners, and interest groups. The ConPlan is designed to help the City assess their affordable housing and community development needs and market conditions, and to make data-driven, place- based investment decisions. Requirements for development and submission of the ConPlan are found at 24 CFR, Part 91. The consolidated planning process serves as the framework for a community-wide dialogue to identify housing and community development priorities that align and focus funding from the following formula block grant programs: 6639 Page 3 CDBG: The primary objective of the CDBG program is to develop viable urban communities by providing decent housing, a suitable living e nvironment, and expanded economic opportunities, principally for persons of low and moderate income. Jurisdictions receiving CDBG funds must use the funds to meet one of the three national objectives: 1. To benefit low and moderate-income persons; 2. To aid in the prevention or elimination of slums and blight; or 3. To meet community development needs having a particular urgency. HOME: The objectives of the program are: 1. To strengthen the ability of state and local governments to design and implemen t strategies for achieving adequate supplies of decent, affordable housing; 2. To provide assistance to participating jurisdictions for development of affordable housing; and 3. To strengthen partnerships among all levels of government and the private sector. ESG: The program provides funding for the: 1. Engagement of individuals and families living on the streets; 2. Improvement of homeless shelters and operation of shelters; or 3. Rapid re-housing of homeless persons and homeless prevention. An Analysis of Impediments (AI) is an assessment of a state or a unit of local government’s laws, ordinances, statutes, and administrative policies as well as local conditions that affect the location, availability, an accessibility of housing by examining barriers and impediments to fair housing choice. The development of an AI is part of the consolidated planning process required for all entitlement communities such that receive housing and community development funds from HUD. The ConPlan is carried out through AAPs, which provide a concise summary of the actions, activities, and the specific federal and non -federal resources that will be used each year to address priority needs and specific goals identified by the ConPlan. In order to continue receiving an allocation under CDBG, HOME and ESG, the City is required to submit an AAP to the United States Department of Housing and Urban Development (HUD). The Action Plan serves as the City’s grant application for the grant programs. The City of San Bernardino’s draft Fiscal Year 2020/21 AAP recommends projects that best meet identified community needs eligible under CDBG, HOME and ESG programs. Discussion The draft Consolidated Plan covers the period of Fiscal Year 2020/2021 through Fiscal Year 2024/2025. The draft Action Plan covers the period of Fiscal Year 2020/21. The purpose of the ConPlan is to guide a jurisdiction to: 6639 Page 4 Assess their affordable housing and community development needs and market conditions; Make data-driven, place-based investment decisions; and Conduct community-wide discussions to identify housing and community development priorities that align and focus on eligible activities for CDBG funding. The City must also prepare and submit to HUD, an AAP that describes, in detail, how the ConPlan will be carried out for each year. The AAP must provide a concise summary of the actions, activities, and the specific federal and non -federal resources that will be used each year to address the priority needs and specific goals identified by the ConPlan. The City’s Fiscal Year 2020/21 allocation was announced by HUD on February 14, 2020, and is receiving $3,405,816 in CDBG, $1,404,784 in HOME , and $295,799 in ESG. The Fiscal Year 2020/21 allocations represent a 1% increase from the current year allocation of $3,366,410. A summary of the recommended activities and funding levels is noted below: RECOMMENDED ACTIVITIES BY CATEGORY CDBG Ad Hoc Committee On February 26, 2020, the City Council’s CDBG Ad Hoc Committee met to discuss the programming for this Fiscal Year 2020/21 grant funding. Prior to meeting with the Ad Hoc Committee, Housing staff reviewed the eight (8) CDBG applications received for funding. Five (5) of the applications were submitted by the Public Works and Parks and Recreation Departments to fund various capital improvement projects, two (2) are related to funding Micro-Enterprise and the Inland Fair Housing and Mediation Board (IFHMB), and the final request is to fund the Section 108 Loan obligation . Provided 6639 Page 5 below is an overview of the above mentioned programs (please refer to Exhibit B): The public facility projects being recommended consist of the replacement of playground equipment in three parks: Meadowbrook Park, Nicholson Park and Anne Shirrell (please refer to Exhibit B), which is in keeping with previous Mayor and City Council direction. Nicholson Park will not only have the playground equipment replaced, but the existing baseball field will be converted into a Miracle League park to be ADA compliant. A Miracle League park removes the barriers that keep children and adults with mental and physical disabilities off the baseball field and lets them experience the field. Since the main barriers for the children and adults arise from the natural grass fields used in conventional leagues, Miracle League Teams play on a custom-designed, rubberized turf field that accommodates wheel chairs and other assertive devices while helping prevent injuries. In addition, the Encanto Community Center - Phase 1, will have roof replacement done and will be ADA compliant. The citywide concrete repairs project is to replace sidewalks and ADA accessibility for the Fifth Street Senior Center, Perris Hill Senior Center, Ruben Campos, Lytle Creek, Rudy Hernandez and Delmann Heights Community Cen ters. These projects would complete the comprehensive list of public facility projects being recommended for Fiscal Year 2020/21. The Micro-Enterprise Program is designed to foster the development, support, and expansion, of micro enterprise businesses. A microenterprise is defined by HUD as a commercial enterprise that has five (5) or fewer employees, one (1) or more of whom owns the enterprise. Inland Empire Small Business Development Center (IESBDC) works with the Mexican Consulate in providing workshops to potential entrepreneurs. The City funds Inland Fair Housing Mediation Board (IFHMB) to fund its Fair Housing and Landlord/Tenant mediation services: education, outreach, enforcement and administrative services. All these activities address fair housing issues encountered by City residents and assist the City of San Bernardino to support and sustain diversity in the neighborhoods. In Program Year 2018/19, Fair Housing serviced 394 clients; Landlord/Tenant serviced 2,363 clients, which makes a tota l of 2,757 clients served. As of January 2020 (YTD), 195 clients have been provided services for Fair Housing and 1,073 clients have been provided services for landlord/tenant issues for current Program Year 2019-2020. On September 16, 2006, the City of San Bernardino entered into a contract for loan guarantee assistance under Section 108 of the Housing and Community Redevelopment Act of 1974. The Section 108 Loan was specifically earmarked for the 17.43 acre commercial property located along Highland Avenue between Arden Street and Guthrie Street. The obligations under the contract were evidenced by a promissory note in the maximum principal amount of Seven Million Five Hundred Thousand Dollars ($7,500,000) on the property. This funding was specificall y used for land acquisition, relocation of tenants and the demolition of existing residential structures and infrastructure which was completed in 2012. The City continues to proceed with the liquidation of the property and the development of a multi-tenant commercial shopping center. Since 2006, the former Redevelopment Agency and City of San Bernardino 6639 Page 6 have continued to make the required debt services payments on the Section 108 Loan. 2020-2025 Key Strategic Targets and Goals The CDBG funding recommendations aligns with Key Target No. 2: Focused, Aligned Leadership and Unified Community by developing and implementing a community engagement plan and building a culture that attracts, retains, and motivates the highest quality talent; Key Target No. 3: Improved Quality of Life by reducing the burden of homelessness through engagement, collaboration, and alignment with other entities; and Key Target No. 4: Economic Growth & Development by updating the General Plan and Development Code. Fiscal Impact Approval of the draft Fiscal Year 2020-2025 ConPlan, Analysis of Impediments to Fair Housing (AI), and Fiscal Year 2020/21 AAP will not impact the General Fund since the staff time and consultant contract is funded by a Federal Grant Program. Conclusion It is recommended that the Mayor and City Council of the City of San Bernardino, California, conduct the first public hearing on the review of the draft Fiscal Year 2020 - 2025 Consolidated Plan, Analysis of Impediments to Fair Housing (AI) and Fiscal Year 2020/21 Annual Action Plan (AAP) and provide recommendation or comments to the draft documents. Attachments Attachment 1 Exhibit A Draft Fiscal Year 2020-2025 Consolidated Plan Exhibit A (1) Analysis of Impediments Attachment 2 Exhibit B Fiscal Year 2020-2021 Draft Funding Activity Recommendations Attachment 3 Exhibit C PowerPoint Presentation Ward: All Synopsis of Previous Council Actions: N/A EXHIBIT A Draft 2020 - 2025 Consolidated Plan │ 2 TABLE OF CONTENTS Executive Summary ................................................................................................................... 6 ES-05 Executive Summary - 24 CFR 91.200(c), 91.220(b) ..................................................... 6 The Process ..............................................................................................................................11 PR-05 Lead & Responsible Agencies 24 CFR 91.200(b) .......................................................11 PR-10 Consultation – 91.100, 91.110, 91.200(b), 91.300(b), 91.215(I) and 91.315(I) ............12 PR-15 Citizen Participation – 91.105, 91.115, 91.200(c) and 91.300(c) .................................17 Needs Assessment ...................................................................................................................18 NA-05 Overview ....................................................................................................................18 NA-10 Housing Needs Assessment - 24 CFR 91.205 (a,b,c) .................................................22 NA-15 Disproportionately Greater Need: Housing Problems – 91.205 (b)(2) .........................29 NA-20 Disproportionately Greater Need: Severe Housing Problems – 91.205 (b)(2) .............33 NA-25 Disproportionately Greater Need: Housing Cost Burdens – 91.205 (b)(2) ...................37 NA-30 Disproportionately Greater Need: Discussion – 91.205(b)(2) ......................................38 NA-35 Public Housing – 91.205(b) ........................................................................................40 NA-40 Homeless Needs Assessment – 91.205(c) .................................................................46 NA-45 Non-Homeless Special Needs Assessment - 91.205 (b,d) ..........................................48 NA-50 Non-Housing Community Development Needs – 91.215 (f) ........................................51 Market Analysis .........................................................................................................................54 MA-05 Overview ....................................................................................................................54 MA-10 Number of Housing Units – 91.210(a)&(b)(2) .............................................................55 MA-15 Housing Market Analysis: Cost of Housing - 91.210(a) ..............................................58 MA-20 Housing Market Analysis: Condition of Housing – 91.210(a) ......................................62 MA-25 Public and Assisted Housing – 91.210(b) ...................................................................65 MA-30 Homeless Facilities and Services – 91.210(c) ............................................................68 MA-35 Special Needs Facilities and Services – 91.210(d) .....................................................71 MA-40 Barriers to Affordable Housing – 91.210(e) ................................................................74 MA-45 Non-Housing Community Development Assets – 91.215 (f) .......................................76 MA-50 Needs and Market Analysis Discussion ......................................................................81 MA-60 Broadband Needs of Housing occupied by Low- and Moderate-Income Households - 91.210(a)(4), 91.310(a)(2) .........................................................................................83 MA-65 Hazard Mitigation - 91.210(a)(5), 91.310(a)(3) ...........................................................84 Draft 2020 - 2025 Consolidated Plan │ 3 Strategic Plan ...........................................................................................................................85 SP-05 Overview ....................................................................................................................85 SP-10 Geographic Priorities – 91.215 (a)(1) ..........................................................................86 SP-25 Priority Needs - 91.215(a)(2) ......................................................................................87 SP-30 Influence of Market Conditions – 91.215 (b)................................................................92 SP-35 Anticipated Resources - 91.215(a)(4), 91.220(c)(1,2) .................................................93 SP-40 Institutional Delivery Structure – 91.215(k) .................................................................96 SP-45 Goals Summary – 91.215(a)(4)...................................................................................99 SP-50 Public Housing Accessibility and Involvement – 91.215(c) ........................................ 102 SP-55 Barriers to affordable housing – 91.215(h) ................................................................ 103 SP-60 Homelessness Strategy – 91.215(d) ......................................................................... 104 SP-65 Lead based paint Hazards – 91.215(i) ...................................................................... 106 SP-70 Anti-Poverty Strategy – 91.215(j) .............................................................................. 107 SP-80 Monitoring – 91.230 .................................................................................................. 108 List of Tables Table 1 – Responsible Agencies ...............................................................................................11 Table 2 – Agencies, groups, organizations who participated .....................................................15 Table 3 – Other local / regional / federal planning efforts ..........................................................16 Table 4 – Citizen Participation Outreach ...................................................................................21 Table 5 - Housing Needs Assessment Demographics ...............................................................22 Table 6 - Total Households Table .............................................................................................22 Table 7 – Housing Problems Table ...........................................................................................23 Table 8 – Housing Problems 2 ..................................................................................................24 Table 9 – Cost Burden > 30% ...................................................................................................24 Table 10 – Cost Burden > 50% .................................................................................................25 Table 11 – Crowding Information – 1/2 .....................................................................................25 Table 12 – Crowding Information – 2/2 .....................................................................................25 Table 13 - Disproportionally Greater Need 0 - 30% AMI ............................................................29 Table 14 - Disproportionally Greater Need 30 - 50% AMI ..........................................................30 Table 15 - Disproportionally Greater Need 50 - 80% AMI ..........................................................30 Table 16 - Disproportionally Greater Need 80 - 100% AMI ........................................................31 Table 17 – Severe Housing Problems 0 - 30% AMI ..................................................................33 Draft 2020 - 2025 Consolidated Plan │ 4 Table 18 – Severe Housing Problems 30 - 50% AMI ................................................................34 Table 19 – Severe Housing Problems 50 - 80% AMI ................................................................34 Table 20 – Severe Housing Problems 80 - 100% AMI ...............................................................35 Table 21 – Greater Need: Housing Cost Burdens AMI ..............................................................37 Table 22 - Public Housing by Program Type .............................................................................40 Table 23 – Characteristics of Public Housing Residents by Program Type ...............................41 Table 24 – Race of Public Housing Residents by Program Type ..............................................42 Table 25 – Ethnicity of Public Housing Residents by Program Type .........................................43 Table 26 – Household Size .......................................................................................................48 Table 27 – Female-headed Households ...................................................................................49 Table 28 – Residential Properties by Unit Number ....................................................................55 Table 29 – Unit Size by Tenure .................................................................................................56 Table 30 – Cost of Housing .......................................................................................................58 Table 31 – Rent Paid ................................................................................................................58 Table 32 – Housing Affordability ...............................................................................................58 Table 33 – Monthly Rent ...........................................................................................................59 Table 34 – Condition of Units ....................................................................................................62 Table 35 – Year Unit Built .........................................................................................................63 Table 36 – Risk of Lead-Based Paint ........................................................................................63 Table 37 - Vacant Units .............................................................................................................63 Table 38 – Total Number of Units by Program Type .................................................................65 Table 39 – Public Housing Condition ........................................................................................66 Table 40 – Facilities and Housing Targeted to Homeless Households ......................................68 Table 41 – Business Activity .....................................................................................................76 Table 42 - Labor Force ..............................................................................................................77 Table 43 – Occupations by Sector ............................................................................................77 Table 44 - Travel Time ..............................................................................................................77 Table 45 – Educational Attainment by Age ................................................................................78 Table 46 – Priority Needs Summary ..........................................................................................91 Table 47 – Influence of Market Conditions ................................................................................92 Table 48 - Anticipated Resources .............................................................................................94 Table 49 - Institutional Delivery Structure ..................................................................................96 Table 50 - Homeless Prevention Services Summary.................................................................97 Draft 2020 - 2025 Consolidated Plan │ 5 Table 51 – Goals Summary ..................................................................................................... 100 Draft 2020 - 2025 Consolidated Plan │ 6 EXECUTIVE SUMMARY ES-05 Executive Summary - 24 CFR 91.200(c), 91.220(b) The City of San Bernardino (City) is an entitlement City that receives federal funding from the US Department of Housing and Urban and Development (HUD). The City receives funds through the Community Development Block Grant (CDBG) program, HOME Investment Partnerships Program (HOME), and the Emergency Solutions Grant (ESG). The CDBG entitlement program provides formula funding to cities and counties to address community development needs. Seventy percent of gross funding must be used to serve low- to moderate-income households. Eligible activities must meet one of the following national objectives for the program:  Benefit low- and moderate-income persons;  Prevent or eliminate slums or blight; or  Address community development needs having a particular urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community for which other funding is not available. The HOME entitlement program provides formula grant funding for a wide range of activities including building, purchasing, and/or rehabilitating affordable housing for rent or homeownership and providing direct rental assistance to low-income households. The program’s flexibility allows states and local governments to use HOME funds for grants, dir ect loans, loan guarantees or other forms of credit enhancements, or rental assistance or security deposits.1 The ESG program provides formula grant funding to cities and counties to engage homeless individuals and families living on the street, rapidly re-house homeless individuals and families, help operate and provide essential services in emergency shelters for homeless individuals and families, and prevent individuals and families from becoming homeless. The Consolidated Plan (ConPlan) is a five-year planning document. This plan covers the period of fiscal year 2020-21 through fiscal year 2024-25. The purpose of the ConPlan is to guide a jurisdiction to:  Assess their affordable housing and community development needs and market conditions;  Make data-driven, place-based investment decisions; and  Conduct community-wide discussions to identify housing and community development priorities that align and focus on eligible activities for CDBG funding. 1 HUD. Home Reinvestments Partnership Program. https://www.hud.gov/program_offices/comm_planning/affordablehousing/programs/home/ Draft 2020 - 2025 Consolidated Plan │ 7 Recipients of CDBG and HOME funding must also prepare and submit to HUD an Annual Action Plan (AAP) that describes in detail, each year, how the ConPlan will be carried out. The AAP must provide a concise summary of the actions, activities, and the specific federal and non-federal resources that will be used each year to address the priority needs and specific goals identified by the ConPlan.2 Additionally, at the end of each fiscal year, jurisdictions must complete and submit to HUD a Consolidated Annual Performance and Evaluation Report (CAPER) to report on the accomplishments and progress toward the ConPlan’s goals. The City anticipates approximately $13,200,000 in CDBG funds, $4,800,000 in HOME funds, and $1,120,000 in ESG funds during the 2020-2025 ConPlan period. Summary of the objectives and outcomes identified in the Plan Needs Assessment Overview The objective of the Needs Assessment is to gather information from the community and all partners, as well as demographic and economic data regarding the City’s homelessness, need for affordable housing, special needs, and community development needs. This information is used to make data-driven decisions to establish priority community needs and strategies based on current conditions, expected funds, and local capacity. Through data collection, outreach, and analysis presented in this plan, a clear outline of the City’s priority needs is formed, along with the projects and facilities that are most likely to aid in the City’s development. A summary of needs identified in the City of San Bernardino include:  Affordable housing for low- and moderate-income households and those with special needs;  Rehabilitation of existing single-family housing;  Transitional and permanent housing and services for homeless individuals;  Support services, including mental health, job training, and homeless navigation; and  Youth services. See Needs Assessment section for additional discussion on these identified needs. Evaluation of past performance The City’s CDBG, HOME, and ESG funds successfully contributed to several projects over the last five years. Those projects have contributed to improved housing affordability and expanded economic opportunities for low- and moderate-income households. Affordable Housing HOME funds were used to construct new homeowner housing and CDBG funds were used to rehabilitate existing housing. For example, in FY 2018-2019, three new homeowner units were added and seven homeowner houses were rehabilitated. 2 HUD. CPD Consolidated Plans, Annual Action Plans, and CAPERs. https://www.hudexchange.info/programs/consolidated-plan/con-plans-aaps-capers/ Draft 2020 - 2025 Consolidated Plan │ 8 Fair Housing CDBG funds were used to contract with the Inland Fair Housing Mediation Board to provide fair housing services, including landlord/tenant mediation, housing counseling, alternative dispute resolution, and senior services to San Bernardino residents. For example, in FY 2018-2019, approximately 2,700 residents were served. Homelessness ESG funds were used to provide public services to homeless individuals, street outreach, rapid rehousing, emergency shelter, and homeless prevention services. As of FY 2018-19, 1,039 people were served through these programs. Additionally, in FY 2018-2019, the City assisted in the acquisition and rehabilitation of a 38-unit apartment complex to assist homeless households into permanent supportive housing. Summary of citizen participation process and consultation process Robust community engagement was achieved through engaging a diverse group of stakeholders to identify priorities, concerns, and values. The feedback provided through the community engagement process supported the development of this ConPlan, including the development of housing and community development needs, priorities, goals, and strategies for funding allocation. For the purposes of this plan, the stakeholders include all residents, business owners, and interest groups. Targeted outreach was provided to youth, elderly, racial and ethnic minorities, residents and property owners, and business owners across the City. Leveraging existing stakeholder contacts, recognizing underrepresented stakeholders, and identifying new stakeholders was integral to the process of reaching the greater San Bernardino community and ensuring a broad depth of participation. Opportunities for community outreach were tailored to stakeholder groups (residents and property owners, business owners, community groups, and public agencies and officials) to allow efficient and effective engagement, including offering digital (e.g., online survey) and in - person formats (e.g., community meetings). In-person meetings were held at a variety of locations and times to increase opportunities for participation. The City announced the various community engagement opportunities through a social media campaign strategy and schedule, including announcements, project updates, and educational content for Twitter, Facebook, and Instagram posts. Announcements for the online survey and public comment periods were also promoted over email, where key stakeholder contacts were leveraged as liaisons to access larger stakeholder groups. Stakeholders had the following opportunities for participation and comment, all of which were offered throughout San Bernardino during the ConPlan process:  Community Meeting: Walk-in meetings held at six different locations across the City. Interactive engagement stations created opportunities to share personal stories, suggest Draft 2020 - 2025 Consolidated Plan │ 9 ideas for strengthening neighborhoods and prioritizing community needs, and review ConPlan data and maps.  Housing Summit: A housing summit was held for community leaders, agency representatives, service providers, planning professionals, land developers, and business owners to learn and exchange information about the current state of housing and development in the City.  Stakeholder Interviews: Various local organizations were interviewed to receive feedback on the most pressing priorities and needs of target populations.  Pop-Up Events: Structured for short interactions, the pop-up took the form of a booth set up at an event to allow access to a specific stakeholder group. Feedback provided at pop-up events was collected through interactive exercises (dot votes, etc.) or verbal responses to big picture questions.  Online Feedback Collection (Survey and Form): To broadly access and efficiently obtain information from a large number of geographically distributed stakeholders, an online survey was prepared. The survey included specific and open-ended questions about the public review draft and provided an opportunity to leave additional, relevant comments. The survey was announced through City media outlets and disseminated through key community liaisons or stakeholders with access to resident and community groups, business owners, and interest groups. A detailed summary of community engagement, including participation, methods, and feedback, can be found in Sections PR-10 (Consultations) and PR-15 (Citizen Participation) of this ConPlan. Summary of public comments The regional meetings yielded numerous public comments that identified priorities for residents of the City. High priorities identified during the meetings included:  Affordable housing;  Housing and mental health programs for people with disabilities;  Veterans homelessness assistance;  Street outreach to homeless individuals;  Jobs;  Neighborhood revitalization; and  Pedestrian and traffic improvements. Stakeholders provided feedback on the priority needs of the City. Priority needs related to housing, services, and public facilities were summarized into several overarching themes including:  Increase affordable housing;  Increase housing opportunities and services for homeless individuals, including homeless prevention;  Provide respite care for homeless individuals discharged from hospitals; and Draft 2020 - 2025 Consolidated Plan │ 10  Emergency/natural disaster resiliency for homeless individuals and low-income families. [Additional details will be added upon completion of community engagement] Summary of comments or views not accepted and the reasons for not accepting them The City did not receive any public comments that were not accepted. The City attempted to incorporate all feedback received through outreach efforts into the plan. Summary This 2020-2025 ConPlan combines resident feedback, demographic data and analysis, community stakeholder input, and consideration of City resources, goals, other relevant plans, and policies. The results of this combined effort and analysis is the City’s five -year Strategic Plan for the allocation of CDBG, HOME, and ESG funds and activities. These funds will focus on preserving affordable housing, providing public services to homeless individuals, and improving neighborhood conditions. Draft 2020 - 2025 Consolidated Plan │ 11 The Process PR-05 Lead & Responsible Agencies 24 CFR 91.200(b) Describe agency/entity responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source The City of San Bernardino’s Housing Division is the agency responsible for preparing the Consolidated Plan and administering the City’s CDBG, , HOME, and ESG grants, as shown in Table 1. Agency Role Name Department/Agency Lead Agency SAN BERNARDINO CDBG Administrator SAN BERNARDINO Community and Economic Development Department HOME Administrator SAN BERNARDINO Community and Economic Development Department ESG Administrator SAN BERNARDINO Community and Economic Development Department Table 1 – Responsible Agencies Narrative Lead and Responsible Agency The City of San Bernardino (City) is the lead and responsible agency for the US Department of Housing and Urban Development’s (HUD) entitlement programs in San Bernardino. The City’s Housing Division is responsible for administering the City’s HUD entitlement grants, including CDBG, HOME, and ESG. Entitlement jurisdictions receive entitlement funding (i.e., non-competitive, formula funds) from HUD. By federal law, the City is required to submit a five-year ConPlan and Annual Action Plan to HUD listing priorities and strategies for the use of its federal funds. The ConPlan helps local jurisdictions to assess their affordable housing and community development needs and market conditions to meet the housing and community development needs of its populations. Consolidated Plan Public Contact Information Gretel K. Noble Housing Division Manager Community & Economic Development Department 201 North E Street 3rd Floor San Bernardino, CA 92401 Tel: (909) 384-7268 Email: Noble_Gr@SBCity.org Website: www.ci.san-bernardino.ca.us Draft 2020 - 2025 Consolidated Plan │ 12 PR-10 Consultation – 91.100, 91.110, 91.200(b), 91.300(b), 91.215(I) and 91.315(I) Introduction Provide a concise summary of the jurisdiction’s ac tivities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(I)). The City of San Bernardino hired Michael Baker International to assist in community engagement efforts. Community engagement is key for helping the City to identify needs, priorities, goals, strategies, and activities for future housing and community development activities over the five-year Consolidated Plan period. Engagement activities included a community survey, community meetings, pop-up events, a housing summit, and stakeholder consultations. As a part of the stakeholder consultation process, the City consulted with a variety of stakeholders, including local and regional community-based organizations, health and mental and behavioral health care providers, and housing service organizations. Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness During the development of its ConPlan and Annual Plans and as a general practice, the City coordinated with a variety of housing/shelter organizations, public and mental health agencies, and service providers to discuss community needs. Their collective feedback was especially valuable in gathering information and shaping priorities for this plan as it relates to special needs populations, general health, and mental health services in the City. Through this process, the City interviewed the Continuum of Care (CoC) to ascertain the needs of homeless individuals throughout the City as well as the organizational needs and challenges of the CoC itself. The CoC’s feedback will be used to shape the goals identified in this ConPlan, which will then address the needs of homeless individuals in the City. Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards and evaluate outcomes, and develop funding, policies and procedures for the administration of HMIS The San Bernardino County Homeless Partnership (SBCHP) is the administrator of the regional CoC, which serves the entire County. The City continuously coordinates with the CoC to end and prevent homelessness in the County. The CoC is a group composed of stakeholders throughout the County, including governmental agencies, homeless service and shelter providers, homeless persons, housing advocates, affordable housing developers, and various private parties, including businesses and foundations. Draft 2020 - 2025 Consolidated Plan │ 13 The SBCHP is a collaboration among community and faith-based organizations, educational institutions, nonprofit organizations, private industry, and federal, state, and local governments. The partnership focuses on addressing issues of homelessness within the County. The SBCHP was developed to direct the planning, development, and implementation of the County’s 10-year Strategy to end chronic homelessness. The partnership leads the creation of a comprehensive network to deliver much-needed services to the homeless and to families and individuals at risk of homelessness through careful planning and coordination among all entities that provide services and resources to prevent homelessness. The City’s ConPlan is aligned with the SBCHP’s 10-year Strategy to end chronic homelessness. According to the City’s ESG Policies and Procedures, consultation takes place with participation of City officials, staff serving on the CoC Governance Board and the Advisory Committee of the CoC Board. In these roles, the City participates in setting local priorities, certifying need, and the annual review of ESG programs. The Community & Economic Development Department serves as the Administrative Entity for the ESG grant and compiles program documentation which includes information about the responsibilities of the CoC and ESG programs, HUD regulations and policy statements such as coordinated entry system, prioritization and HMIS participation. Compiled data is used to report on project outcomes to HUD through the ESG CAPER. Describe Agencies, groups, organizations and others who participated in the process and describe the jurisdictions consultations with housing, social service agencies and other entities Participating Agencies, Groups and Organizations 1 Agency/Group/Organization Dignity Health Agency/Group/Organization Type Services - Health What section of the Plan was addressed by Consultation? Homeless Needs – Chronically, Families with Children, Veterans, Unaccompanied Youth Market Assessment How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) attended at least one community meeting and provided input to help prioritize the City’s community needs. 2 Agency/Group/Organization National CORE Agency/Group/Organization Type Services - Children What section of the Plan was addressed by Consultation? Non-Housing Community Development Strategy How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) attended at least one community forum and provided input to help prioritize the City’s community needs. 3 Agency/Group/Organization Neighborhood Partnership Services (NPHS) Agency/Group/Organization Type Housing Draft 2020 - 2025 Consolidated Plan │ 14 What section of the Plan was addressed by Consultation? Homeless Needs – Chronically Homeless, Families with Children, Veterans, Unaccompanied Youth Homeless Strategy How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) attended at least one community forum and provided input to help prioritize the City’s community needs. 4 Agency/Group/Organization OmniTrans Agency/Group/Organization Type Other (Transit Agency) What section of the Plan was addressed by Consultation? Homeless Needs – Chronically Homeless How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. 5 Agency/Group/Organization Continuum of Care Agency/Group/Organization Type Publicly Funded Institution/System of Care What section of the Plan was addressed by Consultation? Homeless Needs – Chronically Homeless, Families with Children, Veterans, Unaccompanied Youth Homeless Strategy How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. 6 Agency/Group/Organization San Bernardino County Department of Behavioral Health Agency/Group/Organization Type Health Agency Services - Health What section of the Plan was addressed by Consultation? Homeless Needs – Chronically Homeless, Families with Children, Veterans, Unaccompanied Youth How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. 7 Agency/Group/Organization Project Fighting Chance Agency/Group/Organization Type Services - Children What section of the Plan was addressed by Consultation? Non-Housing Community Development Strategy How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. 8 Agency/Group/Organization Inland Fair Housing and Mediation Board Agency/Group/Organization Type Service – Fair Housing What section of the Plan was addressed by Consultation? Housing Needs Assessment Draft 2020 - 2025 Consolidated Plan │ 15 Table 2 – Agencies, groups, organizations who participated Identify any Agency Types not consulted and provide rationale for not consulting No agency types were excluded from engagement. Other local/regional/state/federal planning efforts considered when preparing the Plan Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Continuum of Care Continuum of Care Potential funding allocations to address homeless needs will complement the CoC strategy. How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. 9 Agency/Group/Organization Salvation Army – Hospitality House Agency/Group/Organization Type Services - Homeless What section of the Plan was addressed by Consultation? Homeless Needs – Chronically Homeless, Families with Children, Veterans, Unaccompanied Youth How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. 10 Agency/Group/Organization Center for Employment Opportunities Agency/Group/Organization Type Services – Employment What section of the Plan was addressed by Consultation? Non-Housing Community Development Strategy How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. 11 Agency/Group/Organization Inland Valley Recovery Services Agency/Group/Organization Type Services - Health What section of the Plan was addressed by Consultation? Homeless Needs – Chronically Homeless, Families with Children, Veterans, Unaccompanied Youth How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. 12 Agency/Group/Organization Dr. Tom Pierce, CSU San Bernardino Agency/Group/Organization Type Civic Leader What section of the Plan was addressed by Consultation? Market Analysis How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Representative(s) contributed narrative and data to answer questions relevant to the Consolidated Plan. Draft 2020 - 2025 Consolidated Plan │ 16 10 Year Strategy to End Homelessness Continuum of Care Potential funding allocations to address homeless needs will be consistent with the 10-Year Strategy to End Homelessness. 2015-2023 Housing Element City of San Bernardino Barriers to and opportunities for affordable housing development analyzed in this plan were considered in the Market Assessment. Table 3 – Other local / regional / federal planning efforts Describe cooperation and coordination with other public entities, including the State and any adjacent units of general local government, in the implementation of the Consolidated Plan (91.215(l)) The collaborative implementation of this ConPlan over the course of the next five years begins with the coordinated efforts of multiple public agencies working together to gather feedback and information for regional and local community needs and priorities. Once needs and priorities are identified, they are then incorporated into the City’s ConPlan, forming both regional and local strategies for addressing those needs and priorities. Furthermore, community outreach to local leaders, stakeholders, and residents is a critical first step in implementing this plan’s desired community changes. By successfully establishing relationships and trust between the government, those providing services or community improvements, and the beneficiaries of these services or improvements, the City and community can move toward a joint vision for what and how to make community improvements. The agencies, groups, and organizations who participated are listed in Table 2. Other local/regional/federal planning efforts can be found in Table 3. Narrative (optional): City staff, with assistance from consultants, worked to involve housing, social service, and other agencies in the community engagement process including direct solicitation for these agencies to participate in the community survey, community meetings, and stakeholder interviews. Stakeholders were asked questions and provided feedback on priorities, issues, and solutions in relation to CDBG- and HOME-eligible activities including housing, neighborhood revitalization, and low- to moderate-income household issues. They were asked about their top priorities, neighborhood revitalization, housing problems and their solutions, local organization support, families vulnerable to crisis, broadband internet issues, and how the jurisdiction should spend CDBG and HOME funding. Draft 2020 - 2025 Consolidated Plan │ 17 PR-15 Citizen Participation – 91.105, 91.115, 91.200(c) and 91.300(c) Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal setting Outreach is essential to the City’s ability to create an accurate and effective plan, and to allocate resources appropriately. The City attempted to reach as many residents as possible within specific demographics, such as low-income families, disabled persons, seniors, female-headed households, and parents/guardians of children. Receiving feedback from residents, especially those who may receive assistance from grant funds, is critical to the success of the CDBG program. The City reached out to practitioners, agencies, leaders, organizations, and companies who may have the specialized knowledge, experience, resources, and capacity to discuss needs, opportunities, solutions, investments, and how community improvements can be made. All City residents were encouraged to provide input on community needs through citizen participation opportunities. The City organized various methods for participation and public comment throughout the development of the ConPlan. The following is a summary of the efforts made to broaden citizen participation through the ConPlan process. Citizen Participation Outreach, Table 4, provides additional detail on the types of outreach conducted and, where applicable, a summary of the comments received. Community Needs Survey This community survey was noticed through the newspaper, the City’s website, and distribution of flyers in both English and Spanish. The online and paper survey was made available to the public between January 7, 2020, and , 2020. The survey was provided in English and Spanish. Data gathered from the survey provided community feedback needs for housing, public facilities, infrastructure, homelessness, economic development, and community services, as well as on local demographic data. A copy of the survey, along with the final results, can be found at the end of the document under Appendix Community Engagement Summary. Pop-Up Events Pop-up events are temporary events held in public areas. Pop-up events are useful to help provide the public with general information and awareness of the ConPlan process and engage community members with the community survey. Short dialogue and feedback were also obtained from the public. Three pop-up/tabling events were held throughout the City: a football game at San Bernardino High School on November 1, 2019, the San Bernardino Airshow on November 2, 2019, and the City of San Bernardino Winter Wonderland on December 14, 2019. Flyers announcing community engagement meeting dates and locations were distributed. Surveys were distributed at the pop-up events and a total of 314 residents responded to the survey. See Appendix Community Engagement Summary for surveys and pop-up locations. Draft 2020 - 2025 Consolidated Plan │ 18 Public Meetings Six regional forums were held in different cities in the County of San Bernardino. Flyers were posted beforehand to inform the public of the meetings. It was also advertised in the local news newspapers. To maximize attendance, they were offered at different locations and times of the day. Three meetings were held during the day and three were held in the evening. Appendix Community Engagement Summary includes a flyer of the public meetings listed. A total of 61 people attended these forums. Those in attendance included local residents, service providers, and members of the business community. The notes and feedback were helpful in identifying priorities, creating a dialogue with the attendees, and gaining input from stakeholders and the public. Six community engagement meetings were held in January 2020:  Akoma Unity Center, 1367 N. California Street, San Bernardino, Saturday, January 18, 2020, 9:30 AM-11:30 AM, 15 people in attendance  Rezek Center – St. Bernardine Medical Center, 2101 N. Waterman Ave., San Bernardino, Tuesday, January 21, 2020, 11 AM–1 PM, 15 people in attendance  Maplewood Homes, 906 Wilson St., San Bernardino, Wednesday, January 22, 2020, 4 PM–5 PM, 20 people in attendance  Olive Meadows, 610 East Olive Street, San Bernardino, Thursday, January 23, 4 PM–5 PM, 2 residents in attendance  Valencia Vista, 950 N. Valencia Ave., San Bernardino, Thursday, January 23, 2020, 5 PM–6:30 PM, X people in attendance  San Bernardino Valley College, 701 S. Mt. Vernon Ave., San Bernardino, Friday, January 24, 2020, 9 AM – 10:30 PM, 9 people in attendance Stakeholder Consultations A combination of in-person meetings, one-on-one phone conversations, and emails were held as consultations with various service providers to obtain feedback. The feedback was especially helpful in identifying gaps in services, trends in the local community, and needs relating to specific services and populations. The agencies that provided feedback are listed in Table 2. A sample list of questions that were asked during the stakeholder interviews can be found in Appendix Community Engagement Summary. Public Hearings and 30-Day Public Review Period of Draft Consolidated Plan The City will hold a Council public hearing on March 18, 2020 to review the draft ConPlan, and on April 15, 2020 to review and approve the final plan. The City posted notice of the public hearings and draft ConPlan on February 27th for the first public hearing and March 12th for the second hearing. The 30-day public review period began on March 12, 2020 and ended on April 15, 2020. Draft 2020 - 2025 Consolidated Plan │ 19 Housing Summit A housing summit was held on February 6, 2020, from 8 AM to 12 PM. The summit gathered community leaders, agency representatives, service providers, planning professionals, land developers, business owners, and others to learn the current state of housing, jobs, and development opportunities. The summit also identified public safety concerns, the need for diverse housing options (both emergency and long-term), ways to develop new and improve existing housing stock, how to expand opportunities to advance workforce and build community wealth, and community health including physical, mental, and emotional well-being. The summit was also held to help build partnerships to address the City's most immediate needs and learn new ideas for long-range planning. Citizen Participation Process Impact on Goal Setting Feedback from the citizen participation process is essential to setting goals and strategic planning as it relates to the ConPlan. For example, comments from stakeholders provided feedback for the Needs Assessment and Market Analysis in the ConPlan, especially concerning special needs populations, non-housing community development, and barriers to affordable housing. The results from the survey and comments from the public also helped identify areas of concern for housing, public services, and community development needs as related to local data. The feedback was especially useful in assessing the priority needs and goal setting for the Strategic Plan section of the Consolidated Plan. Additionally, input obtained from community engagement offered more insight into priority needs and areas needing the most neighborhood revitalization. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 20 Citizen Participation Outreach Sort Orde r Mode of Out reach Target of Ou treach Summary o f response/a ttendance Summary of comments re ceived Summary of co mments not accepted and reasons URL (If applica ble) 1 Public meetings Non- targeted/broad community A total of 35 individuals attended one community forum held in June 2019. The priority needs discussed at the meetings were: Housing: Housing programs for people with disabilities and mental health services Affordable housing N/A N/A Homeless: Veteran’s homeless assistance Outreach to people on the streets Services: Jobs – Need to bring more businesses to San Bernardino At-risk youth Public Facilities: Facilities for At- risk youth Programs for low-income communities, e.g., Olive Meadows and Valencia City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 21 Sort Orde r Mode of Out reach Target of Ou treach Summary o f response/a ttendance Summary of comments re ceived Summary of co mments not accepted and reasons URL (If applica ble) Public Improvements: Downtown Rehabilitation – Look at what is working in other areas and implement it in downtown. Bring more social and community events. Need for pedestrian and traffic calming amenities on 9th Street and Olive Street and Valencia Ave 2 Community Survey Non- targeted/broad community 752 (to be updated) responses to the survey Survey results provided input regarding needs for public services, facilities, infrastructure, and housing needs. N/A N/A 3 Pop-up Event Survey Non- targeted/broad community 314 responses to the survey Survey results provided input regarding needs for public services, facilities, infrastructure, and housing needs. N/A N/A 4 Newspaper ad and email to advertise public meetings Non- targeted/broad community Providers of services to community citizens Representati ves from community service organizations attended public meetings. Provided by city clerk’s office in response to legal public noticing Provided by city clerk’s office in response to legal public noticing N/A Table 4 – Citizen Participation Outreach City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 18 NEEDS ASSESSMENT NA-05 Overview Needs Assessment Overview The Needs Assessment collects and analyzes data to demonstrate the extent of housing problems and housing needs for residents of the City of San Bernardino. The assessment focuses on affordable housing, special needs housing, community development, and homelessness. The information in this section was gathered from HUD’s Comprehensive Housing Affordability Strategy (CHAS) data, American Community Survey (ACS) data, and various other online and City resources. Salient findings are summarized below, followed by definitions of commonly used terms. NA-10 Housing Needs Assessment As seen in Table 5, San Bernardino has a population of 214,115 persons and a total of 57,547 households. Nearly 59 percent of households in San Bernardino (33,760 total) qualify as low- to moderate- income, earning up to 80 percent of HUD Area Median Family Income (HAMFI).  Low-income households experience housing problems (substandard housing, overcrowded and severely overcrowded housing, cost burden, and severe cost burden) at a greater rate, with 90 percent of households experiencing housing problems qualifying as low income (Table 7).  Housing cost burden is the most common housing problem in the City. The majority of low income households (72.6 percent) experiencing housing problem are affected with housing cost burden, which represent almost 20 percent of all San Bernardino households (Table 7).  The majority (42 percent) of San Bernardino’s extremely low-income households are small families (four persons or less) (Table 6). NA-15 Disproportionately Greater Need: Housing Problems Building on the identified housing characteristics, this assessment examines whether housing problems are concentrated among minority groups. Disproportionate need occurs when the rate of a housing problem within a certain group is 10 percent greater than the jurisdiction rate.  American Indian, Alaska Native households experience housing problems at a disproportionate rate across all income brackets (Tables 13, 14, 15 and 16). NA-20 Disproportionately Greater Need: Severe Housing Problems This section identifies minority racial and ethnic groups of different income categories that experience disproportionate need specifically for severe housing problems: severe City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 19 overcrowding and severe cost burden. A household is considered severely overcrowded when there are more than 1.5 persons per room and severely cost burdened when paying more than 50 percent of household income toward housing costs.  Asian households are disproportionately affected by severe housing problems. Overall, 49 percent of low-moderate income (LMI) Asian households have at least one severe housing problem compared to all LMI households in the jurisdiction (Table 19). NA-25 Disproportionately Greater Need: Housing Cost Burden As housing cost burden is the most common housing problem experienced by households in the City, this section evaluates the minority racial and ethnic groups that exhibit disproportionate need compared to the jurisdiction as a whole. A household is considered to experience housing cost burden when at least 30 percent of the monthly income is required to cover housing costs.  As a whole, 23 percent of households in the City are cost burdened and 26 percent are severely cost burdened (Table 21).  While no households experience disproportionate need, black households have the highest rates of severe cost burden at 33 percent (Table 21). NA-30 Disproportionately Greater Need: Discussion San Bernardino’s minority racial and ethnic groups were found to experience housing problems at a greater rate of incidence than the region as whole, often exhibiting disproportionate need.  Asian, black, American Indian/Alaskan Native, and Pacific Islander households are disproportionately affected by housing problems in the City. Overall, 76 percent of LMI Black/African American households, 65 percent of LMI Asian households, 82 percent of LMI American Indian and Alaskan Native households, and 90 percent of LMI Pacific Islander households have at least one housing problem (NA-15).  Stakeholder consultations conducted with public agencies, advocates, and local experts have identified the need for transit, workforce training, additional affordable housing in safe areas, and rehabilitation of existing units for low- to moderate-income households. NA-35 Public Housing The City does not have its own housing authority; instead, housing choice vouchers are administered by the Housing Authority of the County of San Bernardino (HACSB). While there are no public housing units in the City, there are approximately 2,600 voucher holders living in the City. This assessment examines the characteristics of public housing units in San Bernardino County and identifies challenges facing voucher holders and public housing residents.  The average annual income of all vouchers holders is approximately $14,084, which indicates these voucher holders have limited income to cover basic transportation, medical, food, and personal needs (Table 23).  5,277 voucher holders (37 percent) have requested some type of accessible feature, indicating high demand for affordable housing and permanent housing that is equipped City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 20 to support special needs populations, such as persons with disabilities and elderly persons. NA-40 Homeless Needs Assessment The extent and nature of homelessness in San Bernardino is discussed in the assessment, including the chronically homeless, families with children, veterans, and unaccompanied youth. The City’s understanding of the homeless population primarily relies on the annual San Bernardino County Homeless Point-In-Time Count, which provides data specific to the City.  As of 2019, there are an estimated 890 persons experiencing homelessness in the City of San Bernardino; 639 of these individuals are unsheltered homeless and 251 are sheltered homeless.  Seventy-one percent of the City’s homeless population reported to have lived in San Bernardino before becoming homeless. NA-45 Non-Homeless Special Needs Assessment This assessment identifies special needs populations that are more vulnerable to homelessness, including elderly, frail elderly, persons with disabilities, single-parent households, large family households, persons with HIV/AIDS and their families, public housing residents, and victims of domestic and other similar types of violence.  Based on the consultations with local San Bernardino agencies and service providers, the City’s services and assistance programs, including those for new immigrants, persons with mental illness and substance abuse, and persons fleeing domestic violence, are inadequate to the rising number of persons burdened by these issues. NA-50 Non-Housing Community Development Needs Lastly, the Needs Assessment will address the need for public facilities, public improvements, public services, and other eligible Community Development Block Grant (CDBG) uses. This information is compiled from the results of the community survey and consultation responses.  In total, 1,011 survey responses were received and approximately 12 stakeholder organizations participated in the process. Several residents provided feedback at community meetings and pop-up events.  Priority projects identified by community meeting participants included facilities for at-risk youth, pedestrian improvements, and traffic-calming measures. Definitions: The following are definitions of housing problems and family type that will be further analyzed in the sections below. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 21 Income: Low- to Moderate-Income (LMI) – HUD classifies LMI individuals and households as those whose incomes are at or below 80 percent of the area median family income (AMI). Extremely low-income – Households earning 0 percent to 30 percent of the AMI. Very low-income – Households earning 30 percent to 50 percent of the AMI. Low-income – Households earning 50 percent to 80 percent of the AMI. HUD Area Median Family Income (HAMFI) – For the purposes of this Needs Assessment, the terms “area median income” (AMI) or “median family income” (MFI) used in CHAS data sources refers to HAMFI. Housing Problem(s) or Condition(s): Substandard Housing – Lacking complete plumbing or kitchen facilities. This includes households without hot and cold piped water, a flush toilet and a bathtub or shower; or kitchen facilities that lack a sink with piped water, a range or stove, or a refrigerator. Overcrowded – Households having complete kitchens and bathrooms but housing more than 1.01 to 1.5 persons per room, excluding bathrooms, porches, foyers, halls, or half- rooms. Severely Overcrowded – Households having complete kitchens and bathrooms but housing more than 1.51 persons per room, excluding bathrooms, porches, foyers, halls, or half-rooms. Housing Cost Burden – This is represented by the fraction of a household’s total gross income spent on housing costs. For renters, housing costs include rent paid by the tenant plus utilities. For owners, housing costs include mortgage payment, taxes, insurance, and utilities.  A household is considered to be cost burdened if the household is spending more than 30 percent of its monthly income on housing costs.  A household is considered severely cost burdened if the household is spending more than 50 percent of its monthly income on housing costs. Family Type(s): Small Related – The number of family households with two to four related members. Large Related – The number of family households with five or more related members. Elderly – A household whose head, spouse, or sole member is a person who is at least 62 years of age. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 22 NA-10 Housing Needs Assessment - 24 CFR 91.205 (a,b,c) Summary of Housing Needs Demographics Base Year: 2009 Most Recent Year: 2015 % Change Population 209,924 214,115 2% Households 57,547 57,580 0% Median Income $39,405.00 $37,047.00 -6% Table 5 - Housing Needs Assessment Demographics Data Source: 2005-2009 ACS (Base Year), 2011-2015 ACS (Most Recent Year) Number of Households Table 0-30% HAMFI >30-50% HAMFI >50-80% HAMFI >80-100% HAMFI >100% HAMFI Total Households 13,335 9,795 10,630 6,275 17,550 Small Family Households 5,535 4,230 4,845 2,535 8,815 Large Family Households 2,765 2,225 2,574 1,404 3,150 Household contains at least one person 62-74 years of age 1,735 1,815 1,974 1,199 3,765 Household contains at least one person age 75 or older 1,085 975 895 509 1,350 Households with one or more children 6 years old or younger 4,204 2,905 3,040 1,610 2,319 Table 6 - Total Households Table Data Source: 2011-2015 CHAS Draft 2020 - 2025 Consolidated Plan │ 23 Housing Needs Summary Tables Housing Problems (Households with one of the listed needs) Renter Owner 0-30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Total 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Total NUMBER OF HOUSEHOLDS Substandard Housing - Lacking complete plumbing or kitchen facilities 355 100 120 20 595 40 0 45 4 89 Severely Overcrowded - With >1.51 people per room (and complete kitchen and plumbing) 1,060 490 145 200 1,895 90 90 245 150 575 Overcrowded - With 1.01-1.5 people per room (and none of the above problems) 1,535 905 735 335 3,510 250 375 575 380 1,580 Housing cost burden greater than 50% of income (and none of the above problems) 5,310 2,510 370 25 8,215 1,390 1,110 744 170 3,414 Housing cost burden greater than 30% of income (and none of the above problems) 555 1,860 2,454 815 5,684 300 785 1,540 804 3,429 Zero/negative Income (and none of the above problems) 920 0 0 0 920 185 0 0 0 185 Table 7 – Housing Problems Table Data Source: 2011-2015 CHAS Draft 2020 - 2025 Consolidated Plan │ 24 Housing Problems 2 (Households with one or more Severe Housing Problems: Lacks kitchen or complete plumbing, severe overcrowding, severe cost burden) Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Total 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Total NUMBER OF HOUSEHOLDS Having 1 or more of four housing problems 8,265 4,005 1,370 580 14,220 1,770 1,575 1,604 710 5,659 Having none of four housing problems 1,525 2,525 4,059 2,480 10,589 670 1,685 3,590 2,505 8,450 Household has negative income, but none of the other housing problems 920 0 0 0 920 185 0 0 0 185 Table 8 – Housing Problems 2 Data Source: 2011-2015 CHAS Cost Burden > 30% Renter Owner 0-30% AMI >30- 50% AMI >50- 80% AMI Total 0-30% AMI >30- 50% AMI >50- 80% AMI Total NUMBER OF HOUSEHOLDS Small Related 3,905 2,870 1,635 8,410 705 745 1,165 2,615 Large Related 2,120 1,120 674 3,914 435 685 655 1,775 Elderly 895 830 245 1,970 630 515 524 1,669 Other 1,575 840 680 3,095 230 270 260 760 Total need by income 8,495 5,660 3,234 17,389 2,000 2,215 2,604 6,819 Table 9 – Cost Burden > 30% Data Source: 2011-2015 CHAS Cost Burden > 50% Renter Owner 0-30% AMI >30- 50% AMI >50- 80% AMI Total 0-30% AMI >30- 50% AMI >50- 80% AMI Total NUMBER OF HOUSEHOLDS Small Related 3,710 1,475 245 5,430 595 425 380 1,400 Large Related 1,810 520 35 2,365 345 365 160 870 Elderly 745 495 50 1,290 460 325 194 979 Other 1,385 465 90 1,940 210 145 25 380 Draft 2020 - 2025 Consolidated Plan │ 25 Renter Owner 0-30% AMI >30- 50% AMI >50- 80% AMI Total 0-30% AMI >30- 50% AMI >50- 80% AMI Total Total need by income 7,650 2,955 420 11,025 1,610 1,260 759 3,629 Table 10 – Cost Burden > 50% Data Source: 2011-2015 CHAS Crowding (More than one person per room) Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Total 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Total NUMBER OF HOUSEHOLDS Single family households 2,310 1,215 695 340 4,560 210 365 530 330 1,435 Multiple, unrelated family households 280 215 230 150 875 100 100 290 195 685 Other, non-family households 65 0 0 39 104 30 0 0 10 40 Total need by income 2,655 1,430 925 529 5,539 340 465 820 535 2,160 Table 11 – Crowding Information – 1/2 Data Source: 2011-2015 CHAS Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI Total 0- 30% AMI >30- 50% AMI >50- 80% AMI Total Households with Children Present - - - - - - - - Table 12 – Crowding Information – 2/2 Describe the number and type of single person households in need of housing assistance. According to the ACS 2014-2018 5-Year Estimates, there are 11,511 single-person households in the City, which represents 19 percent of households in San Bernardino (Table 5). Based on the ACS 2014-2018 5-Year Estimates, single-person households are primarily persons between 35 and 64 years of age (49 percent); however, persons over 65 years make up 38 percent of single-person households. The housing needs of seniors may be more problematic to meet than for other residents since seniors are often living on a fixed income and many have special housing and care needs. The ACS 2014-2018 5-Year Estimates shows that 17.2 percent of persons living below the poverty level are seniors over the age of 65 years. Draft 2020 - 2025 Consolidated Plan │ 26 Estimate the number and type of families in need of housing assistance who are disabled or victims of domestic violence, dating violence, sexual assault and stalking. Persons with Disabilities: According to the ACS 2014-2018 5-Year Estimates, approximately 12.5 percent (26,221 persons) of the population living in San Bernardino was affected by one or more disabilities. The most prevalent disability affecting this population is ambulatory difficulties, with 53 percent of persons experiencing disabilities have an ambulatory difficulty. This is closely followed by cognitive difficulty at 47 percent. The symptoms and functional impairments that result from disabling health and behavioral health conditions can make it difficult for people to earn income from employment. Incom e from disability benefits, such as Supplemental Security Income, is not always sufficient to afford rent without additional assistance. Of 348 survey respondents in the 2019 San Bernardino Homeless Point-In-Time Count, 26 unsheltered adults (7.5 percent) in the City reported to have developmental disabilities and 79 unsheltered adults (22.7 percent) reported to have a mental health disability or disorder that affect their ability to live independently. Victims of Domestic Violence: California Department of Justice data reports that calls for services related to domestic violence in San Bernardino County increased by 51 percent since 2014, with 12,012 calls documented in 2017. This reflects the larger trend of a rise in violent crime in San Bernardino County. The San Bernardino County Community Indicator Report finds that violent crime has increased by 20 percent since 2014, and specifically the rate of rape increased 74 percent since 2014 (California Department of Justice, 2017 data). Domestic violence, dating violence, sexual assault, and stalking can be precursors to homelessness. The 2019 San Bernardino Homeless Point-In-Time survey identified 35 persons residing in the City who were experiencing homelessness due to fleeing domestic violence, dating violence, sexual assault, and stalking, representing 10.1 percent of the 348 persons experiencing homelessness residing in the City that participated in survey. . What are the most common housing problems? As shown in Table 7 (Housing Problems Table), housing cost burden is the most common housing problem experienced by both renters and homeowners. Of the 57,580 households in the city, 20 percent experience severe cost burden (more than 50 percent of monthly earnings going toward housing costs) and 16 percent experience cost burden (more than 30 percent of monthly earnings going toward housing costs). Are any populations/household types more affected than others by these problems? Across all categories (substandard housing, overcrowding, and cost burden), renter households consistently experience housing problems at a greater rate than owner-occupied households (Table 7 – Housing Problems Table). The disparity between renters and homeowners is most significant for households experiencing severe housing cost burden (more than 50 percent of monthly earnings going toward housing costs), where of the 11,629 households experiencing severe cost burden, 71 percent are renting. This is followed by housing cost burden (more than Draft 2020 - 2025 Consolidated Plan │ 27 30 percent of monthly earnings going toward housing costs), where 62 percent of the total number of households experiencing cost burden are renting. As discussed in the previous question, housing cost burden represents the most common housing challenge. Housing problems are predominantly experienced by extremely low-income households (see Table 7), particularly extremely low-income renters. With the exception of housing cost burden, where low-income (50 to 80 percent AMI) households make up the majority of renting households experiencing cost burden, extremely low-income households consist of at least 40 percent of renters experiencing each housing problem. Further, extremely low-income households (renter and owner-occupied households) are more likely to experience more than one housing problem, with over half of households (55 percent) experiencing more than one housing problem falling within the extremely low-income bracket. Describe the characteristics and needs of Low-income individuals and families with children (especially extremely low -income) who are currently housed but are at imminent risk of either residing in shelters or becoming unsheltered 91.205(c)/91.305(c)). Also discuss the needs of formerly homeless families and individuals who are receiving rapid re-housing assistance and are nearing the termination of that assistance Just over 23 percent of households in San Bernardino (13,335 households) qualify as extremely low-income (Table 6), largely unchanged since 2015 when the 2015-2019 Consolidated Plan was prepared. Small families (families of four persons or less) comprise 42 percent (5,535 households) of the City’s extremely low-income households. Further, almost a third (4,204) extremely low-income households have at least one child six years or younger. Compounding financial demands that affect low-income families with small children can lead to a high risk of homelessness. Families that rely on low-wage jobs often work nonstandard and/or inflexible hours, which can be restrictive to families with both school-age and young children. Additionally, low-wage jobs have less access to paid leave or health insurance as compared to high-wage jobs, further exacerbating stress on families with limited resources whe n children experience injuries and illness. As evidenced by the number of extremely low-income households experiencing housing cost burden and severe cost burden, affordable housing is a significant need for extremely low- income households in the City. Additionally, supportive services such as access to affordable health care, childcare, nutrition assistance, public transportation, and short-term financial assistance (first/last month’s rent, security deposit, and moving costs) relieve the financial burden for extremely low-income families and can help prevent homelessness. Rapid rehousing assistance is an integral component of San Bernardino County’s response to homelessness. Based on the Rapid Rehousing Program Standards, Practices, & Model Guidelines adopted by the San Bernardino County Homeless Partnership in January 2019, the program prioritizes a “housing first” approach to assisting homeless families with children, recognizing that the crisis of homelessness is preventative to obtaining housing and maintaining stability (such as finding affordable housing, employment, assistance programs, etc.). By providing permanent housing quickly, the family is more likely to establish a stable housing situation and avoid returning to homelessness. Rapid rehousing provides community benefits Draft 2020 - 2025 Consolidated Plan │ 28 through improving the effectiveness of the County’s homeless services and reducing demand for shelters and other temporary solutions. If a jurisdiction provides estimates of the at-risk population(s), it should also include a description of the operational definition of the at-risk group and the methodology used to generate the estimates: The City generally defines those households of extremely low incomes and those living below the poverty status to be at risk of becoming homeless. The estimates are based on CHAS data provided by HUD and on ACS data by the US Census Bureau, respectively. Specify particular housing characteristics that have been linked with instability and an increased risk of homelessness As shown in Tables 8, 9, 10, and 11, housing problems and severe housing problems occur at a higher rate among very low- and extremely low-income households. Cost burden, overcrowding, and poor housing conditions, particularly for renters, all link to an instability in housing that can lead to homelessness. Many low‐income households have difficulty finding reasonably affordable, suitable rental housing. The lack of options available for these populations leads to housing problems and severe housing problems. Households in the very low- and extremely low-income categories live in housing above their means and face cost burden. Alternatively, they avoid high housing costs by living in substandard housing or with other families or extended families, which contributes to overcrowding. Discussion Overall, this assessment finds that low-income households experience housing problems at a greater rate than households that do not fall in low-income categories. Housing problems are more frequent among households that rent their home as compared to households that own their home. Further, extremely low-income renters make up the majority of household types experiencing housing problems. Extremely low-income households, for both renter and owner- occupied households, are more likely to experience more than one housing problem, with over half of the households (55 percent) experiencing more than one housing problem falling within the extremely low-income bracket. The above findings indicate a lack of affordable housing available to low-income renters, but especially housing that would be affordable to extremely low-income households. Results from the community meeting corroborate these findings. Attendees identified affordable housing and, specifically, housing programs that support persons with disabilities and mental health issues as priority housing needs for the City. Draft 2020 - 2025 Consolidated Plan │ 29 NA-15 Disproportionately Greater Need: Housing Problems – 91.205 (b)(2) Assess the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole. Introduction For the purposes of this ConPlan, disproportionately greater need is assumed to exist when the percentage of persons in a category of need who are members of a particular racial or ethnic group is at least 10 percentage points higher than the percentage point of persons in the category as a whole. A household is considered to have a housing problem when their home lacks complete kitchen or plumbing facilities, when there is more than one person per room, or when a cost burden (30% or more of income toward housing) exists. Tables 13, 14, 15, and 16 demonstrate the disproportionately greater need across the lower - income levels (0%–30%, 30%–50%, and 50%–80% of AMI). Consistently, across each of the income brackets shown below, American Indian, Alaska Native households experience housing problems at a disproportionate rate. Conversely, white households never exceed the jurisdictional rate for housing problems across all households. It should be noted that the sample sizes for both American Indians, Alaska and Pacific Islander households are comparatively small, which may mean the data is not accurate. 0%-30% of Area Median Income Housing Problems Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Jurisdiction as a whole 10,885 1,340 1,105 White 1,760 255 365 Black / African American 2,400 325 335 Asian 395 165 70 American Indian, Alaska Native 8 0 0 Pacific Islander 10 0 4 Hispanic 6,110 565 255 Table 13 - Disproportionally Greater Need 0 - 30% AMI Data Source: 2011-2015 CHAS *The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost burden greater than 30% Draft 2020 - 2025 Consolidated Plan │ 30 30%-50% of Area Median Income Housing Problems Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Jurisdiction as a whole 8,225 1,575 0 White 1,360 360 0 Black / African American 1,405 390 0 Asian 230 95 0 American Indian, Alaska Native 15 0 0 Pacific Islander 10 0 0 Hispanic 4,925 695 0 Table 14 - Disproportionally Greater Need 30 - 50% AMI Data Source: 2011-2015 CHAS *The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost burden greater than 30% 50%-80% of Area Median Income Housing Problems Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Jurisdiction as a whole 6,968 3,660 0 White 1,109 920 0 Black / African American 1,120 445 0 Asian 225 125 0 American Indian, Alaska Native 50 15 0 Pacific Islander 20 0 0 Hispanic 4,279 2,080 0 Table 15 - Disproportionally Greater Need 50 - 80% AMI Data Source: 2011-2015 CHAS *The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost burden greater than 30% Draft 2020 - 2025 Consolidated Plan │ 31 80%-100% of Area Median Income Housing Problems Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Jurisdiction as a whole 2,909 3,360 0 White 555 855 0 Black / African American 470 355 0 Asian 135 185 0 American Indian, Alaska Native 25 0 0 Pacific Islander 0 0 0 Hispanic 1,729 1,945 0 Table 16 - Disproportionally Greater Need 80 - 100% AMI Data Source: 2011-2015 CHAS *The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost burden greater than 30% Discussion The following summarizes the needs of racial and ethnic households by income bracket. Racial and ethnic household groups that experience housing problems at disproportionate rates are bolded. Eighty-two percent of households with 0%-30% AMI experience at least one severe housing problem:  One hundred percent of American Indian, Alaska Native households experience at least one housing problem.  Seventy-one percent of Pacific Islander households experience at least one housing problem.  Seventy-eight percent of black households experience at least one housing problem.  Seventy-four percent of white households experience at least one housing problem.  Sixty-three percent of Asian households experience at least one housing problem.  Eighty-eight percent of Hispanic households experience at least one severe housing problem. Eighty-four percent of households with 30%-50% AMI experience at least one housing problem:  One hundred percent of American Indian, Alaska Native households experience at least one housing problem.  One hundred percent of Pacific Islander households experience at least one housing problem. Draft 2020 - 2025 Consolidated Plan │ 32  Seventy-eight percent of black households experience at least one housing problem.  Seventy-nine percent of white households experience at least one housing problem.  Seventy-one percent of Asian households experience at least one housing problem.  Eighty-eight percent of Hispanic households experience at least one severe housing problem. Sixty-six percent of households with 50%-80% AMI experience at least one housing problem:  Seventy-seven percent of American Indian, Alaska Native households experience at least one housing problem.  One hundred percent of Pacific Islander households experience at least one housing problem.  Seventy-two percent of black households experience at least one housing problem.  Fifty-five percent of white households experience at least one housing problem.  Sixty-four percent of Asian households experience at least one housing problem.  Sixty-seven percent of Hispanic households experience at least one severe housing problem. Forty-six percent of households with 80%-100% AMI experience at least one housing problem:  One hundred percent of American Indian, Alaska Native households experience at least one housing problem.  There is no data for Pacific Islander households in this income bracket.  Fifty-seven percent of black households experience at least one housing problem.  Thirty-nine percent of white households experience at least one housing problem.  Forty-two percent of Asian households experience at least one housing problem.  Forty-seven percent of Hispanic households experience at least one severe housing problem. In summary, American Indian, Alaska Native are disproportionately affected by housing problems across all categories. Pacific Islander households are disproportionately affected in almost every category where there is data for their households, with exception for extremely low-income households (0%-30% AMI). Draft 2020 - 2025 Consolidated Plan │ 33 NA-20 Disproportionately Greater Need: Severe Housing Problems – 91.205 (b)(2) Assess the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole. Introduction: A household is considered severely overcrowded when there are more than 1.5 persons per room and severely cost burdened when paying more than 50 percent of household income toward housing costs. For renters, housing costs include rent paid by the tenant plus utilities. For owners, housing costs include mortgage payment, taxes, insurance, and utilities. Per HUD definitions, disproportionate housing needs are defined as “significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups or the total population experiencing that category of housing need in the applicable geographic area” (24 CFR § 5.152). For the purposes of this ConPlan, a disproportionate need refers to a group that has housing needs which are at least 10 percentage points higher than the total population. 0%-30% of Area Median Income Severe Housing Problems* Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Jurisdiction as a whole 10,035 2,195 1,105 White 1,480 540 365 Black / African American 2,280 450 335 Asian 325 230 70 American Indian, Alaska Native 8 0 0 Pacific Islander 10 0 4 Hispanic 5,750 925 255 Table 17 – Severe Housing Problems 0 - 30% AMI Data Source: 2011-2015 CHAS *The four severe housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost burden over 50% 30%-50% of Area Median Income Severe Housing Problems* Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Draft 2020 - 2025 Consolidated Plan │ 34 Severe Housing Problems* Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Jurisdiction as a whole 5,580 4,210 0 White 930 790 0 Black / African American 970 825 0 Asian 140 185 0 American Indian, Alaska Native 10 4 0 Pacific Islander 10 0 0 Hispanic 3,295 2,320 0 Table 18 – Severe Housing Problems 30 - 50% AMI Data Source: 2011-2015 CHAS *The four severe housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost burden over 50% 50%-80% of Area Median Income Severe Housing Problems* Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Jurisdiction as a whole 2,974 7,649 0 White 414 1,615 0 Black / African American 285 1,280 0 Asian 180 175 0 American Indian, Alaska Native 19 50 0 Pacific Islander 20 0 0 Hispanic 2,020 4,339 0 Table 19 – Severe Housing Problems 50 - 80% AMI Data Source: 2011-2015 CHAS *The four severe housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost burden over 50% 80%-100% of Area Median Income Severe Housing Problems* Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems Jurisdiction as a whole 1,290 4,985 0 Draft 2020 - 2025 Consolidated Plan │ 35 Severe Housing Problems* Has one or more of four housing problems Has none of the four housing problems Household has no/negative income, but none of the other housing problems White 140 1,265 0 Black / African American 155 665 0 Asian 80 245 0 American Indian, Alaska Native 25 0 0 Pacific Islander 0 0 0 Hispanic 890 2,779 0 Table 20 – Severe Housing Problems 80 - 100% AMI Data Source: 2011-2015 CHAS *The four severe housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost burden over 50% Discussion: The following is an analysis of the rates of severe housing problems amongst racial and ethnic minorities of different income categories in comparison to the overall rate of severe housing problems. Racial and ethnic household groups that experience severe housing problems at disproportionate rate are bolded. Overall, Asian households earning between 50-80 percent AMI disproportionately experience severe housing problems. Seventy-five percent of households with 0%-30% AMI experience at least one severe housing problem:  Seventy-four percent of black households experience at least one severe housing problem.  Sixty-two percent of white households experience at least one severe housing problem.  Fifty-two percent of Asian households experience at least one severe housing problem.  Eighty-three percent of Hispanic households experience at least one severe housing problem. Fifty-seven percent of households with 30%-50% AMI experience at least one severe housing problem:  Fifty-four percent of black households experience at least one severe housing problem.  Fifty-four percent of white households experience at least one severe housing problem.  Forty-three percent of Asian households experience at one severe housing problem.  Fifty-nine percent of Hispanic households experience at least one severe housing problem. Twenty-eight percent of households with 50%-80% AMI experience at least one severe housing problem: Draft 2020 - 2025 Consolidated Plan │ 36  Eighteen percent of black households experience at least one severe housing problem.  Twenty percent of white households experience at least one severe housing problem.  Fifty-one percent of Asian households experience at least one severe housing problem.  Thirty-two percent of Hispanic households experience at least one severe housing problem. In summary, Asian households are disproportionately affected by severe housing problems. Overall, 49 percent of LMI Asian households have at least one severe housing problem. Draft 2020 - 2025 Consolidated Plan │ 37 NA-25 Disproportionately Greater Need: Housing Cost Burdens – 91.205 (b)(2) Assess the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole. Introduction: A household is considered cost burdened if they pay more than 30 percent of their household income toward housing costs. Per HUD definitions, disproportionate housing needs are defined as “significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups or the total population experiencing that category of housing need in the applicable geographic area” (24 CFR § 5.152). For the purposes of this ConPlan, a disproportionate need refers to a group that has housing needs which are at least 10 percentage points higher than the total population. Housing Cost Burden Housing Cost Burden <=30% 30-50% >50% No / negative income (not computed) Jurisdiction as a whole 28,175 13,053 15,039 1,315 White 8,355 2,655 2,520 440 Black / African American 3,869 2,325 3,259 335 Asian 1,415 380 595 90 American Indian, Alaska Native 85 30 60 0 Pacific Islander 35 20 20 4 Hispanic 13,940 7,414 8,160 365 Table 21 – Greater Need: Housing Cost Burdens AMI Data Source: 2011-2015 CHAS Discussion: As a whole, 23 percent of households are cost burdened and 26 percent are severely cost burdened. Approximately 19 percent of white households, 24 percent of black households, 15 percent of Asian households, and 25 percent of Hispanic households are cost burdened. No households are disproportionately cost burdened or severely cost burdened. Overall, there is a high rate of cost burden within the City; however, black households have the highest rates of severe cost burden at 33 percent. Draft 2020 - 2025 Consolidated Plan │ 38 NA-30 Disproportionately Greater Need: Discussion – 91.205(b)(2) Are there any Income categories in which a racial or ethnic group has disproportionately greater need than the needs of that income category as a whole? Asian, black, American Indian and Alaskan Native, and Pacific I slander households are disproportionately affected by housing problems in the City. Overall, 76 percent of LMI Black/African American households, 65 percent of LMI Asian households, 82 percent of LMI American Indian and Alaskan Native households, and 90 percent of LMI Pacific Islander households have at least one housing problem. Asian households are disproportionately affected by severe housing problems. Overall, 49 percent of LMI Asian households have at least one severe housing problem compared to all LMI households in the jurisdiction. Citywide, 23 percent of households are cost burdened and 26 percent are severely cost burdened. Approximately a quarter of Hispanic households and one-third of all black households are cost burdened. However, no racial or ethnic groups are disproportionately cost burdened or severely cost burdened. Please see discussions in NA-15, NA-20, and NA 25 for more information. If they have needs not identified above, what are those needs? Stakeholder consultations have identified the need for transit, workforce training, additional affordable housing in safe areas, and rehabilitation of existing units for low- to moderate-income households. Are any of those racial or ethnic groups located in specific areas or neighborhoods in your community? Minority concentration is defined as a census tract where the percentage of individuals of a particular racial or ethnic minority group is at least 20 percentage points higher than the citywide average. Minority refers to all ethnic groups other than non-Hispanic white. The City of San Bernardino is 60 percent white, 16.7 percent black/African American, 5.7 percent Asian, and 64.3 percent Hispanic (regardless of race). The map below displays census tracts in the City that have a minority concentration. As displayed in Map 1, five census tracts have a Hispanic minority concentration. Draft 2020 - 2025 Consolidated Plan │ 39 Map 1 – Areas of Minority Concentration Draft 2020 - 2025 Consolidated Plan │ 40 NA-35 Public Housing – 91.205(b) Introduction The HACSB is the regional entity that manages and maintains housing units and administers Housing Choice Voucher programs across the County, including the City of San Bernardino. There are approximately 2,600 voucher holders in the City of San Bernardino. The HACSB does not operate any public housing units in the City. Over 10,700 housing vouchers are currently active countywide. The majority of voucher holders have a tenant-based voucher, which is a type of voucher that allows the holder to use the voucher at any housing unit where the landlord will accept it. Currently, there are approximately 31,000 households on the Housing Choice Voucher waiting list for project-based and 23,023 for tenant-based vouchers. Some households are duplicates. The following tables describe the number of housing vouchers in use within the County and the demographics of those receiving vouchers. Data on the number of vouchers in use within the City is unavailable. Totals in Use Program Type Certificate Mod- Rehab Public Housing Vouchers Total Project - based Tenant - based Special Purpose Voucher Veterans Affairs Supportive Housing Family Unification Program Disabled * # of units vouchers in use 0 0 1,177 5,277 517 4,660 54 0 0 Table 22 - Public Housing by Program Type *includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Data Source: PIC (PIH Information Center) Draft 2020 - 2025 Consolidated Plan │ 41 Characteristics of Residents Program Type Certificate Mod- Rehab Public Housing Vouchers Total Project - based Tenant - based Special Purpose Voucher Veterans Affairs Supportive Housing Family Unification Program Average Annual Income 0 0 13,755 14,084 14,172 13,978 14,467 0 Average length of stay 0 0 6 6 1 7 0 0 Average Household size 0 0 3 2 1 2 1 0 # Homeless at admission 0 0 0 30 1 22 7 0 # of Elderly Program Participants (>62) 0 0 239 1,122 357 754 3 0 # of Disabled Families 0 0 200 1,284 39 1,200 28 0 # of Families requesting accessibility features 0 0 1,177 5,277 517 4,660 54 0 # of HIV/AIDS program participants 0 0 0 0 0 0 0 0 # of DV victims 0 0 0 0 0 0 0 0 Table 23 – Characteristics of Public Housing Residents by Program Type Data Source: PIC (PIH Information Center) Race of Residents Program Type Race Certificate Mod- Rehab Public Housing Vouchers Total Project - based Tenant - based Special Purpose Voucher Veterans Affairs Supportive Housing Family Unification Program Disabled * Draft 2020 - 2025 Consolidated Plan │ 42 Program Type Race Certificate Mod- Rehab Public Housing Vouchers Total Project - based Tenant - based Special Purpose Voucher Veterans Affairs Supportive Housing Family Unification Program Disabled * White 0 0 644 2,226 372 1,791 38 0 0 Black/African American 0 0 425 2,911 114 2,763 16 0 0 Asian 0 0 57 94 21 70 0 0 0 American Indian/Alaska Native 0 0 3 27 5 22 0 0 0 Pacific Islander 0 0 29 12 3 9 0 0 0 Other 0 0 19 7 2 5 0 0 0 *includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Table 24 – Race of Public Housing Residents by Program Type Data Source: PIC (PIH Information Center) Ethnicity of Residents Program Type Ethnicity Certificate Mod- Rehab Public Housing Vouchers Total Project - based Tenant - based Special Purpose Voucher Veterans Affairs Supportive Housing Family Unification Program Disabled * Hispanic 0 0 504 1,326 167 1,132 14 0 0 Not Hispanic 0 0 670 3,951 350 3,528 40 0 0 *includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Draft 2020 - 2025 Consolidated Plan │ 43 Table 25 – Ethnicity of Public Housing Residents by Program Type Data Source: PIC (PIH Information Center) Draft 2020 - 2025 Consolidated Plan │ 44 Section 504 Needs Assessment: Describe the needs of public housing tenants and applicants on the waiting list for accessible units: As shown in Table 23, the average annual income of all vouchers holders is approximately $14,084, which indicates these voucher holders have limited income to cover basic transportation, medical, food, and personal needs. As indicated in Table 23, 5,277 voucher holders (37 percent) have requested some type of accessible feature, demonstrating a need. Also, given the number of persons with disabilities across the County, the need for accessible units would be great. Households in California with at least one member living with a disability have a median household income of $56,600, approximately $26,000 less than the median household income ($82,000) of all households.3 Consequently, the need for accessible affordable units would be high. Additionally, for disabled persons already on the HACSB waiting list, there is a need for case management and comprehensive support services. Most immediate needs of residents of Public Housing and Housing Choice voucher holders The most immediate need is finding housing units and owners that will accept vouchers. Additionally, stakeholder interviews identified that housing program waiting lists are too long. Furthermore, stakeholders identified a need for assistance in the housing program application process. As a Moving-to-Work agency, the HACSB is implementing activities designed to increase the cost effectiveness of federal programs and increase the amount of affordable, quality housing units. As such, the HACSB is implementing a local project-based voucher program designed to increase the number of affordable units, a local family self -sufficiency program to increase household income, and the No Child Left Unsheltered program which provides Housing Choice Vouchers to eligible homeless families. How do these needs compare to the housing needs of the population at large Although Housing Choice Vouchers are available to low-income households, the voucher program is unable to accommodate all low- income households. As discussed in MA-15, there is a gap of 11,445 units for households earning between 0 to 30 percent AMI and a gap of 2,750 units for households earning between 30 to 50 percent AMI. Moderate- and above moderate-income categories are more able to secure affordable housing in the City. 3 Cornell University. Disability Statistics. ACS 2017 1-Year Estimate. http://www.disabilitystatistics.org/reports/acs.cfm Draft 2020 - 2025 Consolidated Plan │ 45 Discussion Please see discussions above. Draft 2020 - 2025 Consolidated Plan │ 46 NA-40 Homeless Needs Assessment – 91.205(c) Introduction: In the most current County Point-in-Time Count, in 2019, the County identified a total of 2,607 homeless individuals. Of these individuals, 687 are sheltered and 1,920 are unsheltered. There are an estimated 890 persons experiencing homelessness in the City of San Bernardino. Population Estimate the # of persons experiencing homelessness on a given night Estimate the # experiencing homelessness each year Estimate the # becoming homeless each year Estimate the # exiting homelessness each year Estimate the # of days persons experience homelessness Sheltered Unsheltered Persons in Households with Adult(s) and Child(ren) Waiting on this information Persons in Households with Only Children Persons in Households with Only Adults Chronically Homeless Individuals 54 703 Chronically Homeless Families 5 34 Veterans 32 175 Unaccompanied Youth 5 Persons with HIV 6 41 If data is not available for the categories "number of persons becoming and exiting homelessness each year," and "number of days that persons experience homelessness," describe these categories for each homeless population type (including chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth): City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 47 Nature and Extent of Homelessness: (Optional) Jurisdiction Unsheltered Sheltered Total ’18-’19 % Change 2018 2019 2018 2019 2018 2019 County of San Bernardino 1,443 1,920 675 687 2,118 2,607 23% City of San Bernardino 333 639 313 251 646 890 37% Estimate the number and type of families in need of housing assistance for families with children and the families of veterans. The 2019 County Point-in-Time count identified 34 homeless families in San Bernardino County. The count identified four individuals with veteran status within the families surveyed. There were 28 homeless individuals with veteran status residing in the City of San Bernardino. Describe the Nature and Extent of Homelessness by Racial and Ethnic Group. Race: Waiting on this information Sheltered: Unsheltered (optional) Ethnicity: Sheltered: Unsheltered (optional) Out of the 348 survey respondents residing in the City, 165 (47.4 percent) were white, 81 (23.3 percent) were black, 72 (20.7 percent) were multiple races or other, and 13 (3.7 percent) were American Indian or Alaskan Native. Describe the Nature and Extent of Unsheltered and Sheltered Homelessness. There are approximately 639 unsheltered homeless individuals and 251 sheltered homeless individuals living in the City. According to the Point-in-Time county survey, 17 percent of unsheltered homeless individuals residing in the City had been homeless for less than a year; 59 percent were homeless between one and five years; 12 percent were homeless between six and ten years; and 11 percent were homeless for more than ten years. Seventy-one percent of respondents stated that they lived in the City of San Bernardino before becoming homeless. Discussion: As discussed above, there are approximately 890 homeless individuals residing in the City; however, as identified in MA-30, there are not enough emergency shelter, transitional, rapid rehousing, or permanent supportive housing beds to accommodate them. The CoC’s service capacities have increased within the previous five years; however, there is still a severe need for beds and additional supportive services. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 48 NA-45 Non-Homeless Special Needs Assessment - 91.205 (b,d) Introduction: The following section describes the special needs of the following populations:  Elderly households (defined as 62 years and older)  Persons with mental, physical, and/or developmental disabilities  Large households  Female-headed households  Persons living with HIV/AIDS and their families Describe the characteristics of special needs populations in your community: Elderly Households Many seniors live on fixed incomes, making housing affordability a key issue. Access to properly sized units, transit, and healthcare are also important concerns of elderly households. Elderly households may also require residential care from time to time. Approximately 11 percent of City residents (23,827) are 62 years of age or older.4 Persons with mental, physical, and/or developmental disabilities Persons with disabilities may require special housing accommodations, such as wheelchair accessibility and other modifications to live independently. Access to transit is also a high priority for this population. According to the ACS 2014-2018 5-Year Estimates, 26,221 residents (12.5 percent) are living with a disability. Of those 65 years and older, 46.5 percent are living with a disability. Large households Large households may live in overcrowded conditions. Large households, defined as households with five or more persons, comprise 24 percent of all households in the City. Number Percent 1 Person 11,511 19.7% 2 Persons 13,060 22.4% 3 Persons 9,742 16.7% 4 Persons 9,740 16.6% 5 or More Persons 14,332 24.5% Total Households 58,385 100% Table 26 – Household Size 4 ACS 2014-2018 5-Year Estimates City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 49 Data Source: ACS 2014-2018 5-Year Estimates Female-headed households Female-headed households may have special needs related to accessing childcare and other supportive services as well as an increased risk of poverty.5 Female-headed households comprise 35 percent of households with children. Number Percent Female-Head of Household 22,603 35.2% Total Households (of households with children under 18 years) 64,054 100% Table 27 – Female-headed Households Data Source: ACS 2013-2017 5-Year Estimates (B09005) What are the housing and supportive service needs of these populations and how are these needs determined? Elderly, disabled, large, and female-headed households are a significant portion of the City’s population and they have special housing needs that require diverse types of affordable housing. When surveyed during the community engagement process, residents selected “create additional affordable housing available to lower income residents” as the overall highest priority need in the community. When asked what type of housing assistance would be most helpful, the highest ranked was “increase affordable rental housing inventory.” Moreover, during stakeholder interviews, participants said that the community is experiencing an increasing number of individuals with untreated mental/behavioral health issues, increasing number of domestic violence victims, lack of services for new immigrants, fewer employment opportunities for special needs populations, language barriers, lack of elderly services, increasing number of youth at risk of homelessness, and inaccessible housing stock. Discuss the size and characteristics of the population with HIV/AIDS and their families within the Eligible Metropolitan Statistical Area: HIV/AIDS Those living with HIV/AIDS and their families require stable and affordable housing in order to consistently access medical care and avoid hospitalizations. On the county level, there are approximately 4,401 people living with HIV (PLWH).6 Approximately 3,120 PLWH are currently in care and 2,278 are virally suppressed. Statewide, 5 Household Composition and Poverty among Female‐Headed Households with Children: Differences by Race and Residence. https://doi.org/10.1526/003601106781262007 City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 50 male-to-male sexual contact is the most common transmission mode at 71.4 percent of all new cases in 2017. Black/African American individuals make up 35.2 percent of all new transmissions, followed by Hispanic/Latinx individuals at 14.3 percent, American Indian/Alaskan Native at 10.8 percent, Native Hawaiian/other Pacific Islander at 9.1 percent, white at 8.2 percent, and Asian at 6.7 percent. Discussion: The County provides rapid HIV testing, counseling, prevention education, AIDS Drug Assistance Program (ADAP), and HIV clinic services for clients who do not qualify for any other medical resources. People living with HIV/AIDs require affordable housing to maintain consistent access to medical care, adhere to medical plans, and avoid hospitalizations. They require affordable housing that will suit their needs, which include proximity to health care centers. 6 California HIV Surveillance Report 2017. https://www.cdph.ca.gov/Programs/CID/DOA/CDPH%20Document%20Library/California%20HIV%20Surveillance% 20Report%20-%202017.pdf City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 51 NA-50 Non-Housing Community Development Needs – 91.215 (f) Describe the jurisdiction’s need for Public Facilities: Community meetings identified the need for facilities for at -risk youth, pedestrian improvements, and traffic-calming measures. Once community engagement is completed the results will be added. How were these needs determined? The needs were consulted through extensive community engagement efforts including a survey, stakeholder interviews, community meetings, and pop-up events. The survey and pop-up events sought to solicit feedback from City residents, while stakeholder interviews focused on community development practitioners and experts. The survey was made available in four languages and online. In total, 1,011 survey responses were received and approximately 12 stakeholder organizations participated in the process. Several residents provided feedback at community meetings and pop-up events. Describe the jurisdiction’s need for Public Improvements: Once community engagement is completed the results will be added. How were these needs determined? See the description of community engagement above. Describe the jurisdiction’s need for Public Services: Stakeholders identified the need for the following public services:  Crime reduction;  Domestic violence services;  Family self-sufficiency programs;  Mental health services;  Tech literacy education;  Vocational training for those with criminal backgrounds; and  Youth life skill education. Feedback at community meetings identified the need for:  Services for at-risk youth  Neighborhood revitalization Once community engagement is completed the results will be added. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 52 How were these needs determined? See the description of community engagement above. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 54 MARKET ANALYSIS MA-05 Overview Housing Market Analysis Overview: This overview summarizes the key points of each section of the market analysis and sets a basis for some of the funding priorities listed in the Strategic Plan. The Market Anal ysis identifies the City’s housing market, which includes the housing stock, the cost of housing in the City, housing needs for low-income and special needs populations, and barriers to the development of new housing, especially affordable housing. As with many suburban cities, the City of San Bernardino is made up mostly of one-unit detached structures. Multiunit structures make up the second highest portion of housing stock. Multifamily units have increased more rapidly than single-family development, but only by approximately two percentage points. The cost of home purchase is more affordable in the City of San Bernardino compared to other cities in California. However, like the rest of the state, San Bernardino has followed the same trend of steadily increasing costs for both homeownership and renting. Housing stock is aging; nearly 70 percent of residential units were built prior to 1980. There are many housing resources in the City and County for low-income, special needs, and homeless households. The Housing Authority of the County of San Bernardino (HACSB) is the largest provider of affordable housing in the County. The HACSB owns and/or manages more than 10,000 housing units and serves approximately 30,000 individuals throughout the County. For special needs, in the City of San Bernardino alone, there are 39 adult residential facilities providing capacity to accommodate 835 persons; there are 24 residential elder care facilities in the City that accommodate 505 persons. Finally, the City utilizes the Emergency Solutions Grant (ESG) program to support services that include emergency shelter, rapid rehousing, homelessness prevention, street outreach, and HMIS costs. There continue to be barriers to the provision of affordable housing. But through many initiatives and supportive services funded by local and federal resources, efforts are continuously being made to increase affordable housing units, provide supportive services and job training, and offer other tools to build the workforce for a strong community. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 55 MA-10 Number of Housing Units – 91.210(a)&(b)(2) Introduction The City is made up mostly of one-unit detached structures, at 61 percent of residential properties. Multiunit structures make up the second highest percentage at 19 percent of the housing stock. From 2000 to the present, the development of housing stock has only increased by three to five percentage points, with multifamily units increasing more rapidly than single - family detached by approximately two percentage points. Vacant land is available for immediate residential development in the City. Opportunities for development are identified in maps in the City’s Housing Element. City policies and goals make evident that the City is committed to both redevelopment and new development. Areas of opportunity include infill housing and new development in the Downtown Core as well as along major corridors.7 A healthy vacancy rate is associated with choice and mobility. A healthy vacancy rate for owner - occupied housing is 2-3 percent and 5-6 percent for rental units. In 2010, the vacancy rate for owner-occupied housing was 3.7 percent; in 2017 it was 1.3 percent, 0.7 percent below the range considered healthy. In 2010, the renter-occupied rate was 6.9 percent, above the healthy range by 0.9 percent. By 2017, the rental vacancy rate returned to the healthy range at 6 percent. Residential mobility is influenced by tenure. Ownership housing is associated with a much lower turnover rate than rental housing. Tenure preferences are primarily related to household income, composition, and age of the householder. Between 2010 and 2017, the number of occupied units decreased, and tenure shifted from majority owner-occupied units to majority renter-occupied units. All residential properties by number of units Property Type Number % 1-unit detached structure 37,940 61% 1-unit, attached structure 2,825 5% 2-4 units 5,660 9% 5-19 units 6,460 10% 20 or more units 5,755 9% Mobile Home, boat, RV, van, etc 4,045 6% Total 62,685 100% Table 28 – Residential Properties by Unit Number Data Source: 2011-2015 ACS 7 City of San Bernardino, 2013-2021 Housing Element, January 2014. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 56 Unit Size by Tenure Owners Renters Number % Number % No bedroom 215 1% 1,135 4% 1 bedroom 675 3% 7,460 24% 2 bedrooms 5,620 21% 12,530 41% 3 or more bedrooms 20,520 76% 9,424 31% Total 27,030 101% 30,549 100% Table 29 – Unit Size by Tenure Data Source: 2011-2015 ACS Describe the number and targeting (income level/type of family served) of units assisted with federal, state, and local programs. The City has a total of 25 assisted multifamily housing projects that provide 3,034 affordable housing units. Fourteen projects (San Bernardino Senior Housing, Sierra Vista, Monte Vista, Buena Vista, Hacienda, AHEPA 302 Apartments, Arrowhead Vista, The Magnolia, Casa Bernadine, Casa Ramona, Jeffrey Court, Laurel Place, Light’s Rancho Linda, and The Plaza) are designated as affordable senior communities and have a combined total of 1,329 units. Most of the City’s affordable housing was funded by HUD, including Section 202, Section 108, PRAC, HOME, or HFDA. Many projects were also financed through Low Income Housing Tax Credits (LIHTC). Affordable housing units also received funding through the former redevelopment agency or bonds. The HACSB also assisted with the development of the Medical Center Apartments (287 affordable units). The City falls within the jurisdiction of the HACSB. The HACSB administers the Housing Choice Voucher program, which provides rental assistance to income-eligible residents of San Bernardino by providing monthly rental assistance to participants who rent from a private landlord but pay only 30 percent of the monthly rental payment, with the rest paid to the landlord by HUD. In 2018, the HACSB provided 10,120 housing choice vouchers throughout San Bernardino County and 2,669 vouchers were issued to San Bernardino City residents. Provide an assessment of units expected to be lost from the affordable housing inventory for any reason, such as expiration of Section 8 contracts. Assisted units convert to market rate when affordable housing contracts expire. In addition, many of the City’s affordable housing projects were assisted with project-based Section 8 contracts and a significant number of these units are considered at risk of converting to market - rate housing due to expiration of subsidy contracts. A total of 15 projects, with a combined total of 1,627 affordable units, are at risk of losing their affordability status before 2020. HACSB does not anticipate losing affordable housing units due to expiration of contracts in the next five years. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 57 Does the availability of housing units meet the needs of the population? Findings in the data show that there is not enough adequate housing affordable to LMI households, especially for extremely low- and very low-income households. Affordable units accommodate only half the number of households in the 0-30 percent and 30-50 percent HAMFI categories, creating an insufficient amount of housing for households at these income levels. There is a surplus of affordable units for households in the 50-80 percent and the 80-100 percent HAMFI categories. Describe the need for specific types of housing: According to data gathered through community outreach, there is a lack of single-family and other quality housing development. Existing housing stock is also in need of rehabilitation. The primary housing problem is affordability; households in the middle and lower-income categories have difficulty affording homeownership. A need for affordable rental housing is a top need but owner-occupied housing is considered one of the more critical housing needs in the community. The community outreach process also revealed a need for housing for persons with mental and physical disabilities. The needs identified through community outreach are substantiated in the CHAS 2011-2015 data. As shown in Table 29, Unit Size by Tenure, renters in the City outnumber homeowners by 13 percent. Renters also tend to reside in smaller units: 3-bedroom units are occupied by owners by 2.18 times that of renters, whereas most no-bedroom, 1-bedroom, and 2-bedroom units are occupied by renters (69 percent). Discussion See discussion above. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 58 MA-15 Housing Market Analysis: Cost of Housing - 91.210(a) Introduction Housing costs have the potential to cause housing problems in a community. If housing costs are high relative to household income, there will be a higher rate of cost burden and overcrowding. According to HUD, families who pay more than 30 percent of their income toward housing costs are considered cost burdened and may have difficulty affording necessities such as food, clothing, transportation and medical care. This section analyzes the cost of housing in the City of San Bernardino. That the purchase price of homes is significantly higher statewide than in the City is not an indication of affordability, but rather what may motivate homebuyers to move into the area and increase the overall demand for housing. Like the rest of the state, San Bernardino has followed the same trend of steadily increasing costs for both homeownership and renting. Base Year: 2009 Most Recent Year: 2015 % Change Median Home Value 270,200 159,800 (41%) Median Contract Rent 780 813 4% Table 30 – Cost of Housing Data Source: 2005-2009 ACS (Base Year), 2011-2015 ACS (Most Recent Year) Rent Paid Number % Less than $500 4,200 13.8% $500-999 17,740 58.1% $1,000-1,499 7,279 23.8% $1,500-1,999 1,155 3.8% $2,000 or more 180 0.6% Total 30,554 100.0% Table 31 – Rent Paid Data Source: 2011-2015 ACS Housing Affordability % Units affordable to Households earning Renter Owner 30% HAMFI 1,890 No Data 50% HAMFI 4,130 2,915 80% HAMFI 18,415 7,975 100% HAMFI No Data 11,994 Total 24,435 22,884 Table 32 – Housing Affordability Data Source: 2011-2015 CHAS City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 59 Monthly Rent Monthly Rent ($) Efficiency (no bedroom) 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom Fair Market Rent 826 986 1232 1717 2132 High HOME Rent 800 859 1033 1184 1301 Low HOME Rent 628 673 808 933 1041 Table 33 – Monthly Rent Data Source: HUD FMR and HOME Rents, 2019. Is there sufficient housing for households at all income levels? Findings in the data show that there is not enough adequate housing affordable to LMI households, especially for extremely low- and very low-income households. Overall, affordable units accommodate only half the number of households in the 0-30 percent and 30-50 percent HAMFI categories, creating an insufficient amount of housing for households at these income levels. According to the CHAS 2011-2015 data, approximately 13,335 households are at 0-30 percent AMI, yet there are only 1,890 rental units available that are affordable to these households (no data is available on homeowner units). For the approximately 9,795 households in the City that are at 30-50 percent AMI, 4,130 rental units are affordable and 2,915 units are affordable for ownership. There is a surplus of affordable units for some of the 10,630 households in the 50-80 percent HAMFI bracket: there are approximately 18,415 rental units and 7,975 ownership units affordable to these households. The same is true of the 6,275 households in the City that are in the 80-100 percent HAMFI bracket: there are 11,994 units that are affordable to households earning 100 percent HAMFI, again, creating a surplus of affordable units for households in this range. Households earning Renter Affordable Units Owner Affordable Units Households Units Needed 30% HAMFI 1,890 No Data 0-30% HAMFI - 13,335 11,445 50% HAMFI 4,130 2,915 >30-50% HAMFI - 9,795 2,750 80% HAMFI 18,415 7,975 >50-80% HAMFI - 10,630 (15,760) 100% HAMFI No Data 11,994 >80-100% HAMFI - 6,275 (5,719) City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 60 How is affordability of housing likely to change considering changes to home values and/or rents? As illustrated in the table below, home prices in the City of San Bernardino are low compared to those of the state. However, the median single-family home price has increased by 25 percent since 2016. According to the ACS 2015-2018 5-Year Estimates, the majority of renters have consistently spent between $500 and $1,499 between 2015 and 2018; renters spending between $1,500 to $1,999 doubled during the same time period. Overall, San Bernardino is experiencing an increase in rental housing costs. Between 2015 and 2018, the median rent increased from $976 to $1,068. As shown in the table below, both the lowest cost categories (up to $999) and the highest cost categories ($2,000-$2,999) decreased as a percentage of the rental market. Based upon market data for home prices and rental units, it can be expected that costs will increase, by small percentages. Source: California Association of Realtors Rental Housing Cost, 2015 through 2018 2015 2016 2017 2018 Less than $500 7.60% 8.50% 8.20% 7.60% $500 to $999 45.70% 45.20% 38.40% 35.70% $1,000 to $1,499 35.00% 31.70% 35.60% 38.30% $1,500 to $1,999 8.40% 12.20% 15.00% 16.30% $2,000 to $2,499 3.00% 2.40% 2.00% 1.80% $2,500 to $2,999 0.30% 0.00% 0.80% 0.40% Median 976 971 1,038 1,068 Median Home Purchase Price for State of California and City of San Bernardino, 2015 through 2019 2016 2017 2018 2019 State City State City State City State City Jan $467,160 $234,460 $491,840 $245,440 $527,780 $277,000 $537,120 $290,000 Feb $444,780 $226,870 $480,270 $265,000 $522,440 $278,000 $534,140 $298,250 Mar $484,120 $237,350 $518,600 $260,000 $564,830 $280,000 $565,880 $309,950 Apr $509,240 $236,850 $537,950 $255,500 $584,460 $289,900 $602,920 $305,000 May $519,930 $245,080 $550,239 $272,500 $600,860 $285,000 $611,190 $315,000 Jun $518,980 $245,220 $555,410 $270,000 $602,770 $293,250 $610,720 $310,000 Jul $511,420 $248,000 $549,460 $266,250 $591,230 $292,000 $607,990 $312,000 Aug $527,490 $240,500 $565,330 $269,950 $596,410 $290,000 $617,410 $315,000 Sep $516,450 $251,750 $555,410 $279,000 $578,850 $300,000 $605,680 $315,000 Oct $513,520 $245,000 $546,430 $274,450 $572,000 $289,000 Nov $502,490 $250,000 $546,820 $280,000 $554,760 $299,450 Dec $510,560 $255,000 $546,550 $278,000 $557,600 $295,000 City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 61 Rental Housing Cost, 2015 through 2018 2015 2016 2017 2018 No Rent Paid 924 788 1,001 509 Occupied units paying rent 30,703 31,350 29,844 30,969 Source: 2015, 2016, 2017, 2018 ACS 1-Year Estimates. How do HOME rents / Fair Market Rent compare to Area Median Rent? How might this impact your strategy to produce or preserve affordable housing? The median gross rent for San Bernardino, according to the ACS 2018 1-Year Estimate, was $1,068; however, the HUD fair market rent for a three-bedroom is higher at $1,717. According to the number of units available, there is a need to develop affordable units for extremely low- to very low-income households. HUD defines cost burden as 30 percent or more of family’s household income spent on housing costs, including utilities.8 Affordable housing cost then would be 30 percent or less of a household’s income. The HAMFI for the Riverside- San Bernardino-Ontario, CA MSA is $69,700. Affordable rent for a family of four, earning 80 percent of the area median family income, or $55,760, would be $1,436; for a family earning a very low income of 35,900, $894; and for a family earning extremely low income of 25,750, $644. A strategy to address affordable housing needs would be to put HOME and CDBG dollars toward affordable housing construction for extremely low- and very low-income households. Discussion See discussion above. 8 U.S. Department of Housing and Urban Development, “Affordable Housing,” under “Community Planning and Development,” https://www.hud.gov/program_offices/comm_planning/affordablehousing/ [accessed February 5, 2020]. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 62 MA-20 Housing Market Analysis: Condition of Housing – 91.210(a) Introduction This section of the ConPlan discusses existing housing supply, age and condition of housing, the number of vacant and abandoned units, and the risk posed by lead-based paint. As discussed in MA-10, 61 percent of the housing stock in the City of San Bernardino is single- family detached. Multiunit structures make up the second highest percentage at 19 percent of housing stock. As is common in many cities in the nation, most residential development in the City occurred between 1950 and 1979. The following section describes the conditions of the housing stock in the City. HUD defines housing “conditions” similarly to the definition of housing problems discussed in the Needs Assessment. These conditions are: 1. More than one person per room; 2. Cost burden greater than 30 percent; 3. Lack of complete plumbing; and 4. Lack of complete kitchen facilities. Definitions In the City of San Bernardino, substandard housing conditions may consist of the following: structural hazards, poor construction, inadequate maintenance, faulty wiring, plumbing, fire hazards, and inadequate sanitation. Substandard units suitable for rehabilitation are those units where the total rehabilitation costs do not exceed 25 percent of the after-rehabilitation value. Condition of Units Condition of Units Owner-Occupied Renter-Occupied Number % Number % With one selected Condition 10,325 38% 16,544 54% With two selected Conditions 1,080 4% 4,305 14% With three selected Conditions 10 0% 160 1% With four selected Conditions 0 0% 20 0% No selected Conditions 15,620 58% 9,515 31% Total 27,035 100% 30,544 100% Table 34 – Condition of Units Data Source: 2011-2015 ACS City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 63 Year Unit Built Year Unit Built Owner-Occupied Renter-Occupied Number % Number % 2000 or later 2,265 8% 1,530 5% 1980-1999 6,644 25% 8,275 27% 1950-1979 12,720 47% 15,580 51% Before 1950 5,405 20% 5,155 17% Total 27,034 100% 30,540 100% Table 35 – Year Unit Built Data Source: 2011-2015 CHAS Risk of Lead-Based Paint Hazard Risk of Lead-Based Paint Hazard Owner-Occupied Renter-Occupied Number % Number % Total Number of Units Built Before 1980 18,125 67% 20,735 68% Housing Units built before 1980 with children present 4,650 17% 1,905 6% Table 36 – Risk of Lead-Based Paint Data Source: 2011-2015 ACS (Total Units), 2011-2015 CHAS (Units with Children present) Vacant Units Suitable for Rehabilitation Not Suitable for Rehabilitation Total Vacant Units 3,570 0 0 Abandoned Vacant Units 0 0 0 REO Properties 193 0 193 Abandoned REO Properties 0 0 0 Table 37 - Vacant Units Data Source: Vacant Units, 2017 ACS 1-Year Estimates; San Bernardino, CA REO, Realtytrac.com, January 27, 2020. Need for Owner and Rental Rehabilitation Most occupied units were built before 1980. Sixty-eight percent of renter-occupied units and 67 percent of owner-occupied units were built prior to 1980. For units built between 1950 and 1979, renters outnumber owners by nearly 25 percent. The disproportionate share of renters that occupy older units could indicate a more urgent need for the rehabilitation of rental units in the City. The high percentage of older units, both owned-occupied and renter-occupied, indicates the potential need for rehabilitation for both. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 64 Estimated Number of Housing Units Occupied by Low or Moderate Income Families with LBP Hazards To estimate the number of housing units in the City with lead-based paint (LBP) hazards that are occupied by LMI families, the building age of each unit is evaluated. The use of LBP on residential units was prohibited after 1978, but for the sake of this plan, the number of units built before 1980 will be used to determine how many LMI households are at risk of LBP hazards. The 2011-2015 ACS data in Table 36 shows that approximately 38,860 units in San Bernardino were built before 1980 and could be at risk of LBP. Based upon the 2012-2016 CHAS data, approximately 31,062 residential units built prior to 1980 are occupied by LMI families and are at risk of exposure to LBP hazards. Discussion The City will continue to develop policies to rehabilitate older and abandoned housing in the City in an effort to fulfill its Regional Housing Need Allocation (RHNA) obligation and provide housing to LMI households. The City will continue efforts to reduce LBP hazards in housing constructed prior to 1978 and assisted through the Owner Occupied Residential Rehabilitation Program by testing for LBP. If LBP is found, safe work practices or abatement procedures will be included in the scope of work for the rehabilitation. All City procedures for the prevention of LBP poisoning when working on residential structures will comply with 24 CFR Part 35. The City still has several abandoned homes that have been foreclosed, have deteriorated, and have been vandalized. In Ward 1, there is a focus on the City’s Single-Family Unit Acquisition and Rehabilitation program, but foreclosed homes citywide are eligible properties. The City has identified providers, including Housing Partners 1, Inc. and Neighborhood Housing Service of the Inland Empire, to rehabilitate, manage, market, and close the sale of foreclosed homes.9 9 City of San Bernardino, 2013-2021 Housing Element, January 2014. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 65 MA-25 Public and Assisted Housing – 91.210(b) Introduction The HACSB is the largest provider of affordable housing in the County. The HACSB owns and/or manages more than 10,000 housing units and serves approximately 30,000 individuals throughout the County. Currently, the HACSB does not anticipate awarding new project-based vouchers.10 Totals Number of Units Program Type Certificate Mod- Rehab Public Housing Vouchers Total Project -based Tenant -based Special Purpose Voucher Veterans Affairs Supportive Housing Family Unification Program Disabled* # of units vouchers available 0 0 1,321 8,678 552 8,126 352 1,109 834 # of accessible units - - - - - - - - - Table 38 – Total Number of Units by Program Type *includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Data Source: PIC (PIH Information Center) Describe the supply of public housing developments: Under the FY12 HUD appropriations act, the Rental Assistance Demonstration (RAD) program allows public housing agencies (PHAs) to convert their public housing units from their original sources of HUD financing to project-based Section 8 contracts. Similar to the Section 8 Housing Choice Voucher (HCV) program, income eligible tenants pay 30 percent of their income and the project-based rental assistance makes up the difference between what an extremely low-, low-, or very low-income household can afford and the approved rent for the unit. Tenants would have the option of applying to renew the Section 8 contract. As of FY 2020, all public housing units under the HACSB will be converted to project-based vouchers, commonly referred to as Section 8 units. Planned existing project-based voucher properties include:  Family Community, New Development – 333 units  Family Community, Existing Development – 434 units  RAD Conversion, Existing Public Housing Community – 1,003 units  Senior Community, Existing Development – 349 units  Family & Senior Community, New Development – 11 units 10 2020 Moving to Work Annual Plan, Housing Authority of the County of San Bernardino. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 66  Veterans’ Housing, New Development – 37  Permanent Supportive Housing for Chronically Homeless – 69  Veterans’ Housing, Scattered Sites – 12 In June 2018, the City of San Bernardino received $20 million from the state’s Strategic Growth Council through the California Affordable Housing and Sustainable Communities program. The funding has been prioritized to revitalize the Arrowhead Grove neighborhood, formerly the Waterman Gardens Public Housing site, and the adjacent corridor. The project will include 147 affordable housing units and 36 market-rate units, along with pedestrian and transit improvements that will benefit the community at large. The National Community Renaissance (National CORE), an affordable housing developer, has partnered with the HACSB for the project. Describe the number and physical condition of public housing units in the jurisdiction, including those that are participating in an approved Public Housing Agency Plan: As mentioned above, all units under the HACSB will be converted to project-based vouchers, commonly referred to as Section 8 units. The primary benefit of RAD is that properties that convert under this process are no longer restricted from securing private sources of capital financing, and the owners are therefore able to address deferred maintenance issues that have caused public housing and other HUD rental stock to deteriorate nationwide. HACSB refers to housing projects as Asset Management Projects (AMPs). The initial phase of the RAD conversion included rehabilitation at the following sites:  97 scattered site units in AMP 120  330 units in AMP 130 (Maplewood Homes)  75 units in AMP 150 (Brockton site 19-05)  50 units in AMP 160 (Monte Vista site 19-06) In September 2018, the second phase of the RAD conversion of public housing units closed and rehabilitation work identified under the RAD physical needs assessments commenced. The second phase of the conversion included the following sites:  12 scattered site units in AMP 150 (E. 9th Street)  125 units in AMP 160 (Colton sites 19-04 & 19-10)  217 units in AMP 170 (Barstow sites 19-07, 19-12, 19-13 and Deseret) Public Housing Condition Public Housing Development Average Inspection Score WATERMAN GARDENS 64 Table 39 – Public Housing Condition City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 67 Describe the restoration and revitalization needs of public housing units in the jurisdiction: The HACSB has received approval under HUD’s RAD program to convert its entire public housing portfolio. As of FY 2020, all units have been or will be converted to project-based vouchers, commonly referred to as Section 8 units. Describe the public housing agency's strategy for improving the living environment of low - and moderate-income families residing in public housing: The HACSB works to facilitate opportunities for families and individuals to become self -sufficient and financially independent so that they can transition from dependency on housing subsidy through the following strategies:  Develop and maintain policies, programs, and services that foster accountability, responsibility, and economic independence.  Partner with external organizations to support clients in acquiring life skills, education, and training.  Strengthening tenants’ personal accountability and in transitioning to home ownership/market rentals. In addition to implementing non-MTW activities to address the goal of self-sufficiency, the HACSB has implemented nine MTW activities that address this goal: Local Policies for Portability, Elimination of Earned Income Disallowance, Minimum Rent, Pilot Work Requirement, Local Income Inclusion, implementation of a local Family Self Sufficiency program, Term-Limited Lease Assistance Program, No Child Left Unsheltered, and Transition for Over-Income Families.11 Discussion: See discussion above. 11 City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 68 MA-30 Homeless Facilities and Services – 91.210(c) Introduction The City of San Bernardino assists homeless populations through funding supportive service providers in the community. The Ci ty has traditionally provided funding through the ESG program to support services that include emergency shelter, rapid rehousing, homelessness prevention, street outreach, and HMIS costs. Facilities and Housing Targeted to Homeless Households Emergency Shelter Beds Transitional Housing Beds Permanent Supportive Housing Beds Year Round Beds (Current & New) Voucher / Seasonal / Overflow Beds Current & New Current & New Under Development Households with Adult(s) and Child(ren) 252 17 145 695 0 Households with Only Adults 176 0 101 833 0 Chronically Homeless Households N/A 0 N/A 652 0 Veterans 29 0 5 712 0 Unaccompanied Youth 5 0 0 3 0 Table 40 – Facilities and Housing Targeted to Homeless Households City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 69 Describe mainstream services, such as health, mental health, and employment services to the extent those services are used to complement services targeted to homeless persons Many organizations in San Bernardino, including businesses, civic groups, corporations, educational institutions, faith-based organizations, local government, and nonprofit agencies, provide financial assistance, food, health care, clothing, legal assistance, public assistance, rental assistance, and utility assistance at little or no cost. Mainstream benefit programs such as CalFresh, Medicaid/Medi-Cal, Social Security Disability Income (SSDI), Supplemental Security Income (SSI), and Veteran’s Benefits are available to homeless persons in the City. Additionally, the Homeless Provider Network (HPN) acts as an advocate for homeless populations and those at risk of becoming homeless. The HPN facilitates the collaboration between the public and private sectors to coordinate services to assist and prevent homelessness. Member organizations of the HPN meet monthly. List and describe services and facilities that meet the need s of homeless persons, particularly chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth. If the services and facilities are listed on screen SP-40 Institutional Delivery Structure or screen MA-35 Special Needs Facilities and Services, describe how these facilities and services specifically address the needs of these populations. The City works with various agencies and provides referrals for services to homeless populations and those at risk of homelessness:  Community Action Partnership of San Bernardino County (CAPS) – provides homeless persons and those at risk of homelessness with temporary rental assistance, financial literacy education, and linkages to other support services;   Family Service Association of Redlands (FSA) – provides emergency shelter (motel vouchers), wraparound services, and case management to prevent homelessness;  Lutheran Social Services (LSSSC) – provides emergency shelter as a "bridge" to permanent housing, and wraparound services to help homeless men 18 years and older to achieve self-sufficiency;  Step Up on Second – provides supportive services which begin with engagement and street outreach activities; and  The Salvation Army Hospitality House – provides emergency shelter, referrals to permanent housing services, and meals to families and single females and experiencing homelessness. Other agencies in the County providing services to address homelessness include:  Catholic Charities San Bernardino   High Desert Homeless Services, Inc. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 70  Victor Valley Family Resource Center Time for Change Foundation provides emergency shelter services to women and children as well as permanent housing. Helping Hands Pantry, a food bank serves the communities of the County of San Bernardino. Programs of the Helping Hands Pantry include a mobile food pantry and the College Student Food Assistance Program for students who do not have the resources to buy enough food. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 71 MA-35 Special Needs Facilities and Services – 91.210(d) Introduction There are 39 adult residential facilities in the City of San Bernardino. Such facilities provide safe and secure places for the elderly and disabled to stay while their primary caretakers work or run errands. In January 2020, there were 60 licensed adult residential facilities in the City with the capacity to accommodate a total of 835 persons. Residential care facilities for the elderly are family homes, group care facilities, or other similar facilities in which non-medical care is provided 24 hours per day to support daily activities and ensure personal security of the elderly. There are 24 residential elder care facilities in the City that accommodate 505 persons. Including the elderly, frail elderly, persons with disabilities (mental, physical, developmental), persons with alcohol or other drug addictions, persons with HIV/AIDS and their families, public housing residents and any other categories the jurisdiction may specify, and describe their supportive housing needs Seniors Seniors may have special housing needs primarily due to income, health care costs, and physical or mental disabilities, particularly those that tend to increase with age. As a result, seniors may face difficulty in finding housing and may become victims of housing discrimination or fraud. According to the 2011-2015 ACS, approximately 15,302 persons 62 years and older reside in the City, representing seven percent of the total population. The senior population is growing at a faster pace than the overall population. According to the ACS, between 2010 and 2017, the total number of seniors in San Bernardino increased by more than 12 percent while the City’s total population increased by only 2.5 percent. Persons with Disabilities Disabled persons frequently have special housing needs, often related to a potentially limited ability to earn enough income, a lack of accessible and affordable housing, and higher health costs associated with a disability. Persons with self-care and mobility limitations may also require housing design features such as wheelchair ramps, grab bars, special bathroom designs, and/or wider doorway openings. According to the ACS 2014-2018 5-Year Estimates, 12.5 percent of San Bernardino residents reported a disability, a decrease from the 2009-2013 estimates, which estimated that 13.2 percent of the population had one or more disabilities. Approximately 16.5 percent of those between the ages of 35 to 64 reported having a disability. Approximately 38.5 percent of those between the ages of 65 to 74 reported having a disability, which is approximately 8 percent higher than the County level. For those 75 years and older, 60.9 percent of the population reported having a disability, which is approximately 5 percent higher than the County level. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 72 A major challenge facing the City is the availability of housing stock with accessible features that meet the needs of disabled residents and their families. The ACS 2014-2018 5-Year estimates showed that 14.2 percent, or 2,586, residents above the age of 65 were living below the poverty level. Living below the poverty level further limits resources and puts an additional constraint on the already limited housing options available to seniors with a disability. Community outreach also revealed a need for housing programs with mental health services for people with mental and physical disabilities. Drugs/Alcohol The County of San Bernardino provides alcohol and drug services through the Substance Use Disorder and Recovery Services (SUDRS) program. Services are available to all County residents. Additionally, Supervised Treatment After Release (STAR) is the treatment component of the Mental Health Court System of Care. Individuals are generally referred while incarcerated in the West Valley Detention Center. STAR arranges for:  Day treatment  Intensive case management  Residential placement  Drug and alcohol treatment  Periodic court reviews HIV/AIDS The National Commission on AIDS states that up to half of all Americans with HIV or AIDS are either homeless or at imminent risk of becoming homeless because of their illness, lack of income or other resources, and having a weak support network. Persons with HIV/AIDS may also require a broad range of services, including counseling, medical care, in-home care, transportation assistance, and food provision. Describe programs for ensuring that persons returning from mental and physical health institutions receive appropriate supportive housing The City has worked with St. Bernadine Hospital to transition homeless individuals who are being discharged from the hospital into bridge housing and ultimately transition into permanent housing. The City will continue to support the regional Continuum of Care’s efforts to implement the San Bernardino County 10-Year Strategy for Ending Homelessness. This plan includes a recommendation to focus on discharge planning to prevent people from becoming homeless when they are discharged from correctional, foster care, health care, or mental health care systems. The McKinney-Vento Act requires that state and local governments have policies and protocols in place to ensure that persons being discharged from a publicly funded institution or system of care are not discharged immediately into homelessness. To meet HUD’s requirements, the 10-Year Strategy has established a Discharge Planning Committee to focus City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 73 on improving coordination between discharge planning agencies, local government, and homeless service providers in order to implement a “zero tolerance” plan that will prevent persons from being discharged into homelessness. The City has provided ESG funding to Step Up On Second to provide essential service referrals and housing placement services to homeless and near-homeless persons. They also provide daily street outreach to the most service-resistant homeless population in San Bernardino. Specify the activities that the jurisdiction plans to undertake during the next year to address the housing and supportive services needs identified in accordance with 91.215(e) with respect to persons w ho are not homeless but have other special needs. Link to one-year goals. 91.315(e) Through CDBG, ESG, and other available resources, the City traditionally funds organizations that provide services to residents in need. Such funding support includes ADA accessibility for public spaces and service organizations providing assistance and referrals to low-income persons in need of various supportive services. For entitlement/consortia grantees: Specify the activities that the jurisdiction plans to undertake during the next year to address the housing and supportive services needs identified in accordance with 91.215(e) with respect to persons who are not homeless but have other special needs. Link to one-year goals. (91.220(2)) See above. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 74 MA-40 Barriers to Affordable Housing – 91.210(e) Negative Effects of Public Policies on Affordable Housing and Residential Investment The City recognizes that barriers to affordable housing exist and continues to employ strategies to overcome them. Policies can create barriers to the production of affordable housing and residential investment because such factors increase costs. The high cost of affordable housing and residential investment can be contributed to the following: Lack of Affordable Housing Funds: Funding for affordable housing usually comes from the government at the local, state, or federal levels or from nonprofit organizations specializing in the construction of affordable housing. Before 2012, redevelopment had the ability to borrow against future property tax revenue in order to finance capital projects and address blight; 20 percent of redevelopment money was required to be allocated toward affordable housing. Due to state budgetary problems, redevelopment agencies were dissolved. Now the City relies on private resources, federal grant programs, state resources, and philanthropy to fund affordable housing projects. Environmental Review: Environmental review can be a long process and is expensive if extensive environmental review is required under the California Environmental Quality Act (CEQA) or the National Environmental Policy Act. Additionally, if a developer is applying to rezone an area or parcel, an amendment to the General Plan or Zoning Ordinance is required, which is a project under CEQA. Such an amendment requires environmental review, which can become a long and even political process that can slow or even stop the development of projects. Site Improvements: Many parts of the City of San Bernardino are undeveloped and lack adequate pedestrian and automobile infrastructure to support new residential subdivisions. All new residential development is required to provide sidewalk with curbs and gutters and must be served by appropriate roadways consistent with the General Plan Circulation Element and adopted road development standards. The cost of these improvements increases the cost of development but is necessary to facilitate pedestrian and vehicular access and movement in the City. Planning and Development Fees: Planning and development impact fees, such as for transportation, water, and sewer infrastructure improvements, often add to the overall cost of development. The City’s fees reflect the fair share of the costs of providing permitting, infrastructure, and services for new residences. Infrastructure and Impact Fees: Impact fees are charged to housing developers to pay for City infrastructure that will support the project, or pay for parks or other City services that protect the welfare of residents. A primary financial deterrent for developers is the high cost of impact fees. Construction costs, permitting fees, and impact fees are passed on to the consumer, driving up the cost of housing at all income levels. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 75 State and Federal Davis-Bacon Prevailing Wages: The state Department of Industrial Relations (DIR) expanded the kinds of projects that require the payment of prevailing wages. Prevailing wage adds to the overall cost of development. A prevailing wage must also be paid to laborers when federal funds are used to pay labor costs for any project over $2,000 or on any multifamily project over eight units. Based on discussions with developers, various prevailing wage requirements typically inflate the development costs by 35 percent. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 76 MA-45 Non-Housing Community Development Assets – 91.215 (f) Introduction The City of San Bernardino is located in the Inland Empire, which is part of a populous area west of Los Angeles in Southern California. Top employers in the City include California State University, San Bernardino, Caltrans, and the Community Hospital of San Bernardino. There are 57,889 jobs in the City with a labor force of approximately 88,000. The City has strong millennial growth with an average age of 32, younger than both the state (36) and the nation (37). Additionally, the Co unty is the second-fastest growing county in the state, likely due to lower home prices and commercial vacancy rates, making the area ideal for investment.12 Economic Development Market Analysis Business Activity Business by Sector Number of Workers Number of Jobs Share of Workers % Share of Jobs % Jobs less workers % Agriculture, Mining, Oil & Gas Extraction 771 229 1 0 -1 Arts, Entertainment, Accommodations 7,079 7,320 11 11 -1 Construction 4,002 2,357 6 3 -3 Education and Health Care Services 11,756 14,338 19 21 2 Finance, Insurance, and Real Estate 2,248 3,649 4 5 2 Information 752 350 1 1 -1 Manufacturing 5,683 3,438 9 5 -4 Other Services 2,023 2,422 3 4 0 Professional, Scientific, Management Services 3,168 4,139 5 6 1 Public Administration 0 0 0 0 0 Retail Trade 8,041 8,264 13 12 -1 Transportation and Warehousing 5,321 7,872 9 12 3 Wholesale Trade 4,046 3,511 7 5 -1 Total 54,890 57,889 -- -- -- Table 41 – Business Activity Data Source: 2011-2015 ACS (Workers), 2015 Longitudinal Employer-Household Dynamics (Jobs) 12 County Remains Southern California’s Retail Leader, San Bernardino, News Release, Economic Development, March 7, 2019, https://sanbern- prod.s3.amazonaws.com/uploads/SBCounty-Leads-in-RetailFinal-003.pdf . City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 77 Labor Force Total Population in the Civilian Labor Force 88,507 Civilian Employed Population 16 years and over 73,795 Unemployment Rate 16.60 Unemployment Rate for Ages 16-24 34.05 Unemployment Rate for Ages 25-65 9.00 Table 42 - Labor Force Data Source: 2011-2015 ACS Occupations by Sector Number of People Management, business and financial 9,155 Farming, fisheries and forestry occupations 4,155 Service 10,555 Sales and office 18,790 Construction, extraction, maintenance and repair 7,535 Production, transportation and material moving 5,500 Table 43 – Occupations by Sector Data Source: 2011-2015 ACS Travel Time Travel Time Number Percentage < 30 Minutes 45,150 66% 30-59 Minutes 15,889 23% 60 or More Minutes 7,445 11% Total 68,484 100% Table 44 - Travel Time Data Source: 2011-2015 ACS Education Educational Attainment by Employment Status (Population 16 and Older) Educational Attainment In Labor Force Civilian Employed Unemployed Not in Labor Force Less than high school graduate 14,685 3,539 14,005 High school graduate (includes equivalency) 16,405 2,535 10,015 Some college or Associate degree 19,900 2,590 7,675 Bachelor's degree or higher 8,335 615 2,630 Table 45 - Educational Attainment by Employment Status Data Source: 2011-2015 ACS City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 78 Educational Attainment by Age Age 18–24 yrs 25–34 yrs 35–44 yrs 45–65 yrs 65+ yrs Less than 9th grade 535 2,144 3,713 7,580 3,660 9th to 12th grade, no diploma 5,399 5,765 5,350 7,669 2,500 High school graduate, GED, or alternative 9,005 9,785 7,140 12,035 4,600 Some college, no degree 10,905 8,939 5,085 9,830 3,385 Associate degree 1,004 2,258 1,405 2,665 1,224 Bachelor's degree 1,179 2,595 1,775 3,705 1,394 Graduate or professional degree 15 754 850 1,894 918 Table 45 – Educational Attainment by Age Data Source: 2011-2015 ACS Educational Attainment – Median Earnings in the Past 12 Months Educational Attainment Median Earnings in the Past 12 Months Less than high school graduate 33,509 High school graduate (includes equivalency) 65,568 Some college or Associate degree 88,789 Bachelor's degree 57,200 Graduate or professional degree 109,150 Table 46 – Median Earnings in the Past 12 Months Data Source: 2011-2015 ACS Based on the Business Activity table above, what are the major employment sectors within your jurisdiction? Education and health care services is the top employment sector with the highest percentage of local workers within the sector in San Bernardino, followed by retail trade, arts/entertainment/accommodations, transportation and warehousing, and manufacturing. The sectors with the highest percentage of jobs within the sector are education and healthcare services, retail, transportation and warehousing, and arts, entertainment and accommodations. Manufacturing has the most oversupply of labor (more workers than jobs). Education/health care services and finance/insurance/real estate both have the most undersupply of labor (more jobs than workers). Describe the workforce and infrastructure needs of the business community: The City has a civilian labor force of 88,507. However, the unemployment rate is unusually high at 16.6 percent overall, and 9 percent for those in the 25-65 age cohort; the national rate is 3.7 percent and for comparably sized cities, 5.5 percent. Though education and health care services is the top business sector, the most occupations are in sales and office. As discussed above, there is a need for workers in the finance, insurance, and real estate sector. Additionally, because of the City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 79 finding that there are more workers than jobs in manufacturing, it could be beneficial to incentivize manufacturing companies to locate in the City. The public outreach process for the 2020-2025 ConPlan also expressed the need for job training for residents. Describe any major changes that may have an economic impact, such as planned local or regional public or private sector investments or initiatives that have affecte d or may affect job and business growth opportunities during the planning period. Describe any needs for workforce development, business support or infrastructure these changes may create. The City of San Bernardino has developed the San Bernardino Downtown Vision & Action Plan, which includes the development of the 48.2-acre Carousel District. A goal of the plan is to capitalize on the Carousel District’s ability to attract visitors to its arts and entertainment amenities by further developing the area. Projects being considered for this mixed-use development include residential market-rate housing and retail redevelopment with future phases of office, educational, and/or additional housing. In addition to development, the InTech Center in Fontana is part of an initiative designed to provide hands-on training that manufacturing employers are looking for. Manufacturing sectors are growing in the County and include advanced manufacturing, food, plastics, and metal manufacturing. The center provides individual certificate programs as well as comprehensive career skill development, such as in industrial maintenance, pre-engineering, robotics, and IT.13 Tens of thousands of new residential units are anticipated. As such, the County also has resources in place to attract retail by assisting investors with site selection, business planning, obtaining permits to operate retail, workforce assistance, and demographic and market reports. How do the skills and education of the current workforce correspond to employment opportunities in the jurisdiction? As discussed above, there is a need for workers in the finance, insurance and real estate sector, possibly indicating a need for related job training and educational opportunities. Additionally, because of the finding that there are more workers than jobs in manufacturing, it could be beneficial to incentivize manufacturing companies to locate in the City. As mentioned above, job training is a need in the community. Describe any current workforce training initiatives, including those supported by Workforce Investment Boards, community colleges and other organizations. Describe how these efforts will support the jurisdiction's Consolidated Plan. The San Bernardino Community & Economic Development Department will continue consulting with County Workforce Development, County Department of Behavioral Health, and County Office on Aging and Adult Services, all of which are involved in the delivery of housing, supportive services and economic development to low- and moderate- income San Bernardino residents. 13 San Bernardino County, Economic Development Agency under “Initiatives”, https://www.selectsbcounty.com/major-initiatives/manufacturing, [January 29, 2020]. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 80 Workforce Development provides job placement services for persons in the County and paid on - the-job training and any equipment that an employee may require to carry their new job. In the realm of economic development, the City recently established a partnership with the Mexican Consulate’s Emprendedores program. The program partners with the Small Business Administration and the City’s Micro Enterprise program to provide Spanish language training for persons interested in launching a small business or expanding an existing small business. Through the City’s partnership with the Emprendedores program, the City will cross promote the services available through Workforce Development. Does your jurisdiction participate in a Comprehensive Economic Development Strategy (CEDS)? No. If so, what economic development initiatives are you undertaking that may be coordinated with the Consolidated Plan? If not, describe other local/regional plans or initiatives that impact economic growth. Not applicable. Discussion See discussion above. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 81 MA-50 Needs and Market Analysis Discussion Are there areas where households with multiple housing problems are concentrated? (include a definition of "concentration") As discussed below, there are racial and ethnic concentrations and LMI concentrations within the City. The definition of “concentration” is provided below. Are there any areas in the jurisdiction where racial or ethnic minorities or low - income families are concentrated? (include a definition of "concentration") A minority concentration is defined as census tracts where the percentage of individuals of racial or ethnic minority groups is at least 20 percent higher than the City average. An LMI concentration is defined as a census tract in which the median household income is less than or equal to 80 percent of the statewide median family income, in which the median family income is less than or equal to 80 percent of the metropolitan area’s median family income, or in which the federal poverty rate is 20 percent or greater. As discussed in NA-30, five census tracts have a Hispanic minority concentration. Map 2 below displays census tracts which meet the LMI concentration standard. Most of the City is considered an LMI area. What are the characteristics of the market in these areas/neighborhoods? According to the ACS 2014-2018 5-Year Estimates, the median household income for the City is $43,136, which is less than the County’s median household income of $60,164. As of January 24, 2020, there are approximately 185 houses in various states of foreclosure throughout the City.14 Housing units in foreclosure generally overlap with LMI neighborhoods displayed in Map 2. Are there any community assets in these areas/neighborhoods? The County operates an Employment Resource Center in downtown San Bernardino near City Hall in an LMI neighborhood. California State University, San Bernardino is also located in an LMI neighborhood. Are there other strategic opportunities in any of these areas? The City has several economic advantages, including modern industrial buildings, convenient freeway access, and generally lower labor costs. Additionally, the City continues to encourage economic development and will continue to fund nonprofits that develop the capacity of residents through job and small business development training. 14 Zillow. For Sale, Foreclosure. January 24, 2020 City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 82 Map 2 – Areas of Low- and Moderate-Income Concentration City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 83 MA-60 Broadband Needs of Housing occupied by Low - and Moderate-Income Households - 91.210(a)(4), 91.310(a)(2) Describe the need for broadband wiring and connections for households, including low - and moderate-income households and neighborhoods. According to the California Interactive Broadband Map, most of the City is served by fixed -service broadband.15 Most unserved areas are nonresidential; however, approximately 150 mobile homes are unserved in the City. Stakeholders also identified a need for internet access among homeless individuals and housing program participants. Describe the need for increased competition by having more than one broadband Internet service provider serve the jurisdiction. Charter Communications (Spectrum) and Frontier Communications are the primary fixed-service internet service providers (ISPs) operating within the City. Charter and Frontier generally cover the entire City, save for the unserved pockets discussed above. Frontier provides DSL and fiber internet, whereas Charter provides broadband with small pockets of fiber service. The table below displays the monthly price of internet (excluding equipment rental fees) by ISP as of January 24, 2020. ISP Tier 1 (Mbps/$) Tier 2 (Mbps/$) Tier 3 (Mbps/$) Frontier (DSL) 6Mbps/$27.99 25Mbps/$34.99 45Mbps/$44.99 Frontier (Fiber) 50Mbps/$29.99 500Mbps/39.99 1000Mbps/$74.99 Charter (Broadband/Fiber) 200Mbps/$49.99 400Mbps/$69.99 940Mbps/$109.99 For households that are recipients of the National School Lunch Program (NSLP), the Community Eligibility Provision of the NSLP, or Supplemental Security Income (SSI; 65 years and older), Charter offers broadband internet access (up to 30Mbps) for $14.99 per month with no equipment rental fees. Frontier also provides low-cost internet access (1.61Mbps to 12Mbps) for $19.99 per month for recipients of CalFresh, SSI, Medi-Cal, and Bureau of Indian Affairs programs. This offer also comes with a Chromebook provided by funding from the California Emerging Technology Fund. LMI households who are participants of these programs would be able to access the internet at a low cost. LMI households who are not participants of these specific programs or cannot afford the reduced price would be unable to access the internet. Increasing competition amongst these ISPs would likely result in reduced costs, increased speeds, and/or better quality of customer service and infrastructure within the market area. It is likely that more households would be able to afford internet access as a result. 15 California Interactive Broadband Map. http://www.broadbandmap.ca.gov/ City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 84 MA-65 Hazard Mitigation - 91.210(a)(5), 91.310(a)(3) Describe the jurisdiction’s increased natural hazard risks associated with climate change. Climate change is a phenomenon where greenhouse gases (GHGs) produced by natural and man- made sources trap heat in the atmosphere, causing an increase in the global average air and ocean temperatures and the melting of snow and ice, which consequently causes sea level rise. Depending on the level of emissions, by 2099, the average temperature of San Bernardino County is projected to rise between 3.8 and 6.7 degrees Fahrenheit.16 Increased temperatures could manifest as heat waves, which would lead to increased incidents of heat stress and heat stroke and exacerbate existing health conditions. Furthermore, the lack of moisture in the air, when compounded by long-term drought, may also increase the risk of wildfires, resulting in more deaths, destroyed property, and increased air pollution. Climate change may also cause increased occurrences of extreme weather events, such as storms and flooding. This would increase fatal and nonfatal injuries, ruin housing, and may result in permanent displacement. Describe the vulnerability to these risks of housing occupied by low - and moderate- income households based on an analysis of data, findings, and methods. LMI households and those with special needs without the means to evacuate would be more vulnerable during natural disasters caused by climate change. It would be difficult for households to acquire transportation and housing accommodations during an emergency. Additionally, housing destroyed by natural disasters would be difficult to replace in the already constrained housing market. Furthermore, households without adequate air conditioning systems would also be at increased risk of heat stress and heat stroke. Stakeholders identified homeless individuals as having the greatest risk from emergencies and natural disasters. Extreme heat events require cooling centers; however, resources may not be available to accommodate all homeless persons. Additionally, it was identified that households at risk of fire hazard may not have the resources to find replacement housing, and resources may not be available to provide emergency shelter. 16 Climate Change and Health Profile San Bernardino County. https://www.cdph.ca.gov/Programs/OHE/CDPH%20Document%20Library/CHPRs/CHPR071SanBernardino_County 2-23-17.pdf City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 85 STRATEGIC PLAN SP-05 Overview Strategic Plan Overview The Strategic Plan identifies the five-year goals that the City of San Bernardino expects to achieve during the 2020–2025 ConPlan cycle. These goals are aligned with HUD’s objectives and outcomes and are achieved through the Annual Action Plan, which divides up the five-year goals into annual targets. The City has identified ten need categories through the Needs Analysis, Market Analysis, and Community Outreach portions of the ConPlan. The Strategic Plan then identifies goals that are aligned to address most of those needs. Not every need identified in the plan can be met and sufficiently addressed in the next five years. Some of the needs are not feasible, some require much more funding than the City currently receives, and some are simply too large to be addressed in just five years. The Strategic Plan includes goals to address affordable housing, infrastructure, public services, fair housing, and economic development. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 86 SP-10 Geographic Priorities – 91.215 (a)(1) General Allocation Priorities Describe the basis for allocating investments geographically within the jurisdiction (or within the EMSA for HOPWA): The City will use most of its federal funding to finance projects targeted to low- to moderate- income households throughout the City, including those in special needs categories. Based on 2011-2015 CHAS data, 59 percent of households in the City are low- to moderate-income households. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 87 SP-25 Priority Needs - 91.215(a)(2) Priority Needs 1 Priority Need Name Preserve and Rehabilitate Housing Priority Level High Population Low Income Moderate Income Large Families Families with Children Elderly Frail Elderly Persons with Physical Disabilities Geographic Areas Affected Associated Goals Preserve and Rehabilitate Housing Description The preservation and rehabilitation of single-family owner-occupied units. Basis for Relative Priority As discussed in MA-20, 67 percent of owner-occupied units (18,125) were built prior to 1980. In general, housing begins to require major repairs after 30 or 40 years of age. Many low- to moderate-income households may be unable to afford needed repairs. 2 Priority Need Name Improve Neighborhood Conditions Priority Level High Population Extremely Low Income Low Income Moderate Income Middle Income Geographic Areas Affected Associated Goals Improve Neighborhood Conditions Description Code enforcement for areas in need of revitalization. Basis for Relative Priority Stakeholders identified a need for increased code enforcement due to deteriorating properties and absentee landlords. 3 Priority Need Name Expand Homeownership Opportunities Priority Level High Population Low Income Moderate Income Large Families Families with Children City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 88 Geographic Areas Affected Associated Goals Expand Homeownership Opportunities Description Construction of below market-rate homes. Basis for Relative Priority The median income of the City is approximately $16,000 lower than the national average; however, the cost of living in the County is higher than the national average. Consequently, City residents will likely need assistance to secure their first home without incurring a cost burden. 4 Priority Need Name Provide Assistance to Renter Households Priority Level Low Population Extremely Low Income Low Income Large Families Families with Children Elderly Frail Elderly Persons with Mental Disabilities Persons with Physical Disabilities Persons with Developmental Disabilities Persons with Alcohol or Other Addictions Persons with HIV/AIDS and their Families Victims of Domestic Violence Geographic Areas Affected Associated Goals Provide Assistance to Renter Households Description Support multifamily development for low-income households. Basis for Relative Priority For the Riverside-San Bernardino metro area, the hourly wage needed to afford a one- bedroom apartment is $17.46 (or $36,320 annually).17 Therefore, individuals and families earning minimum wage, which as of January 2020 is $12 to $13 per hour, would be unable to afford rent. 5 Priority Need Name Provide Supportive Services Priority Level High Population Extremely Low Income Low Income Moderate Income Families with Children Elderly Public Housing Residents Chronically Homeless Individuals Chronic Substance Abuse Veterans Victims of Domestic Violence Unaccompanied Youth 17 Rent affordability. http://wp.sbcounty.gov/indicators/housing/rental-market/ City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 89 Frail Elderly Persons with Mental Disabilities Persons with Physical Disabilities Persons with Developmental Disabilities Persons with Alcohol or Other Addictions Persons with HIV/AIDS and their Families Geographic Areas Affected Associated Goals Provide Supportive Services Description Emergency shelters, rapid rehousing, homelessness prevention. Basis for Relative Priority As discussed throughout the Needs Assessment, the need for supportive services is high for low-income households, and households with special needs, elderly, and homeless individuals. 6 Priority Need Name New Affordable Housing Construction Priority Level Low Population Extremely Low Income Low Income Moderate Income Large Families Families with Children Elderly Frail Elderly Persons with Mental Disabilities Persons with Physical Disabilities Geographic Areas Affected Associated Goals New Affordable Housing Construction Description Construct new multifamily rental units. Basis for Relative Priority There is a significant mismatch between housing supply and affordability within the City. As discussed in MA-15, there is a 11,445-unit gap for households earning between 0 and 30 percent AMI and a 2,750-unit gap for households earning between 30 and 50 percent AMI. 7 Priority Need Name Promote Economic Development Priority Level High Population Extremely Low Income Low Income Moderate Income Geographic Areas Affected Associated Goals Promote Economic Development City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 90 Description Create job opportunities. Basis for Relative Priority The unemployment rate of the City is high at 16.6 percent. Additionally, only 10 percent of the labor force has a bachelor’s degree or higher and 21 percent have not graduated high school. 8 Priority Need Name Improve Facilities and Infrastructure Priority Level High Population Extremely Low Income Low Income Moderate Income Families with Children Elderly Public Housing Residents Chronically Homeless Individuals Families with Children Chronic Substance Abuse Veterans Victims of Domestic Violence Unaccompanied Youth Frail Elderly Persons with Mental Disabilities Persons with Physical Disabilities Persons with Developmental Disabilities Persons with Alcohol or Other Addictions Persons with HIV/AIDS and their Families Non-Housing Community Development Geographic Areas Affected Associated Goals Improve Facilities and Infrastructure Description Improve public facilities including parks and accessibility upgrades. Basis for Relative Priority The City of San Bernardino’s 2018-2023 Capital Improvement Plan (CIP) has indicated the need for the replacement of streetlights, pavement rehabilitation, improvement of safe routes to schools, and citywide accessibility improvements. 9 Priority Need Name Fair Housing Priority Level High Population Extremely Low Income Low Income Moderate Income Middle Income Large Families Families with Children Elderly Persons with Mental Disabilities Persons with Physical Disabilities Persons with Developmental Disabilities Geographic Areas Affected City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 91 Associated Goals Fair Housing Description Promote fair housing and support fair housing services. Basis for Relative Priority Between 2015 and 2016, 114 fair housing discrimination cases were forwarded to the Office of Fair Housing and Equal Opportunity; 51.8 percent of these cases were based on disability. 10 Priority Need Name Planning and Administration Priority Level High Population Other Geographic Areas Affected Associated Goals Planning and Administration Description Implement goals of Consolidated Plan. Basis for Relative Priority Compliance with all HUD Consolidated Plan and CDBG, HOME, and ESG program regulations is a requirement for participation in this program. Table 46 – Priority Needs Summary Narrative (Optional) In establishing the above priorities, the City has considered input from community engagement efforts, including the surveys, stakeholder interviews, and engagement meetings, as well as demographic and data analysis. Activities that address the high priority needs will be funded using CDBG, HOME, and ESG funds during the ConPlan period and activities that address low priority needs may be funded by these funds pending availability. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 92 SP-30 Influence of Market Conditions – 91.215 (b) Influence of Market Conditions Affordable Housing Type Market Characteristics that will influence the use of funds available for housing type Tenant Based Rental Assistance (TBRA) As discussed in the Needs Assessment, 48 percent of households (28,092) pay more than 30 percent of their income toward housing costs. TBRA for Non- Homeless Special Needs As discussed in the Needs Assessment, special needs population require affordable housing to meet the various needs pertaining to disabilities, low household incomes, rising healthcare costs, and children. New Unit Production As discussed in the Market Assessment, there is a gap of 11,445 housing units for those earning less than 30 percent AMI and a gap of 2,750 housing units for those earning between 30 and 50 percent AMI. Rehabilitation As discussed in the Market Assessment, approximately 67 percent of owner-occupied housing and 68 percent of renter-occupied housing was built before 1980. Generally, housing begins to require major repairs after 30 or 40 years of age. Acquisition, including preservation The abundance of land within the City may make this option less desirable than new unit production. Table 47 – Influence of Market Conditions City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 93 SP-35 Anticipated Resources - 91.215(a)(4), 91.220(c)(1,2) Introduction Anticipated Resources Program Source of Funds Uses of Funds Expected Amount Available Year 1 Expected Amount Available Remainder of ConPlan $ Narrative Description Annual Allocation: $ Program Income: $ Prior Year Resources: $ Total: $ CDBG Public- Federal Acquisition Admin and planning Economic development Housing Public improvements Public services 3,405,816 13,200,000 The estimated amount of CDBG funds available over the planning period is based on allocations for FY 2019-2020 HOME Public- Federal Acquisition Homebuyer assistance Homeowner rehabilitation Multifamily rental new construction Multifamily rental rehabilitation New construction for ownership TBRA 1,404,784 4,800,000 The estimated amount of HOME funds available over the planning period is based on allocations for FY 2019-2020 City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 94 ESG Public- Federal Conversion and rehab for transitional housing Financial assistance Overnight shelter Rapid re-housing (rental assistance) Rental assistance services Transitional housing 295,000 1,120,000 The estimated amount of ESG funds available over the planning period is based on allocations for FY 2019-2020 Table 48 - Anticipated Resources Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied Entitlement Funds Leverage means to combine funding sources, such as local, state, or other federal financial resources, with HUD funding in or der to increase project efficiencies and benefit from economies of scale. Other Federal Grant Programs Additional federal programs that fund community development and affordable housing activities include:  Section 8 Housing Choice Voucher Program  Section 202  Section 811  Affordable Housing Program through the Federal Home Loan Bank These programs would not be provided to the City but rather to HACSB and affordable housing developers. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 95 If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan According to the City’s 2013-2021 Housing Element update, the City of San Bernardino has enough vacant land and land designated for residential use to satisfy all projected housing needs. Additionally, the City has not identified any constraints on these sites that would prevent development or reuse. The City estimates that 12,918 housing units could be accommodated on this land. Discussion The City has enough available land and residential designations to meet the affordable housing needs of the community. HUD allocations are critical to meeting these needs; however, they are not sufficient to address all the needs of LMI households. Therefore, the City will continue to continue to leverage other funding sources to provide services to populations in need. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 96 SP-40 Institutional Delivery Structure – 91.215(k) Explain the institutional structure through which the jurisdiction will carry out its consolidated plan including private industry, non-profit organizations, and public institutions. Responsible Entity Responsible Entity Type Role Geographic Area Served San Bernardino Government Economic development Homelessness Non-homeless special needs Planning Neighborhood improvements Public facilities Public services Jurisdiction San Bernardino County Housing Authority PHA Public housing Rental Region Table 49 - Institutional Delivery Structure Assess of Strengths and Gaps in the Institutional Delivery System The City has invested significantly in its CDBG, HOME, and ESG programs, specifically for consulting, auditing, and program d esign; however, the City remains financially constrained. The City continues to improve its capacity and effectiveness in using federal funding. Availability of services targeted to homeless persons and persons with HIV and mainstream services Homelessness Prevention Services Available in the Community Targeted to Homeless Targeted to People with HIV Homelessness Prevention Services Counseling/Advocacy X X Legal Assistance X Mortgage Assistance X Rental Assistance X Utilities Assistance Street Outreach Services Law Enforcement Mobile Clinics Other Street Outreach Services X X City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 97 Supportive Services Alcohol & Drug Abuse X X Child Care X X Education Employment and Employment Training X X Healthcare X X X HIV/AIDS X X Life Skills X X Mental Health Counseling X X Transportation X X Other Other Table 50 - Homeless Prevention Services Summary Describe how the service delivery system including, but not limited to, the services listed above meet the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) ESG funding is used to combat homelessness within the City. The City coordinates with emergency shelters and funds nonprofit agencies that operate emergency shelters and transitional housing. These shelters offer basic needs and drop-in services. Transitional housing provides assistance in helping homeless individuals become more stable and continue independent living. Describe the strengths and gaps of the service delivery system for special needs population and persons experiencing homelessness, including, but not limited to, the services listed above Update from CoC Provide a summary of the strategy for overco ming gaps in the institutional structure and service delivery system for carrying out a strategy to address priority needs Update from CoC City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 98 City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 99 SP-45 Goals Summary – 91.215(a)(4) Goals Summary Information Sort Order Goal Name Start Year End Year Category Geographic Area Needs Addressed Funding Goal Outcome Indicator City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 100 1 Preserve and Rehabilitate Housing 2020 2025 Affordable Housing Preserve and Rehabilitate Housing CDBG: HOME: Homeowner housing rehabilitated 2 Improve Neighborhood Conditions 2020 2025 Affordable Housing Improve Neighborhood Conditions CDBG: Housing code enforcement/foreclosed property care 3 Expand Homeownership Opportunities 2020 2025 Affordable Housing Expand Homeownership Opportunities HOME: Homeowner housing added 4 Provide Assistance to Renter Households 2020 2025 Affordable Housing Provide Assistance to Renter Households CDBG: HOME: Rental units rehabilitated Public service activities for low/moderate income housing benefit 5 Provide Supportive Services 2020 2025 Homeless Non-Homeless Special Needs Provide Supportive Services CDBG: Public service activities other than low/moderate income housing benefit 6 New Affordable Housing Construction 2020 2025 Affordable Housing New Affordable Housing Construction HOME: Rental units constructed 7 Promote Economic Development 2020 2025 Non-Housing Community Development Promote Economic Development CDBG: Jobs created/retained 8 Improve Facilities and Infrastructure 2020 2025 Non-Housing Community Development Improve Facilities and Infrastructure CDBG: ESG: Public facility or infrastructure activities other than low/moderate income housing benefit 9 Fair Housing 2020 2025 Affordable Housing Fair Housing CDBG: Public service activities other than low/moderate income housing benefit 10 Planning and Administration 2020 2025 Administration Planning and Administration CDBG: HOME: Table 51 – Goals Summary Goal Descriptions 1 Goal Name Preserve and Rehabilitate Housing Goal Description Provide funding for single-family owner-occupied rehabilitation loans. 2 Goal Name Improve Neighborhood Conditions City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 101 Goal Description Provide funding for code enforcement and neighborhood revitalization. 3 Goal Name Expand Homeownership Opportunities Goal Description Provide funding for the construction of new below market-rate homes. 4 Goal Name Provide Assistance to Renter Households Goal Description Provide funding to housing developments that restrict units to low-income households. 5 Goal Name Provide Supportive Services Goal Description Provide funding to assist homeless individuals and those with special needs with supportive services; includes funding for emergency shelters, rapid rehousing, homelessness prevention, street outreach, and HMIS costs. 6 Goal Name New Affordable Housing Construction Goal Description Provide funding to construct new multifamily rental units. 7 Goal Name Promote Economic Development Goal Description Provide funding to create jobs through physical and economic revitalization, includes funding for micro-enterprise programs and paying Section 108 debt. 8 Goal Name Improve Facilities and Infrastructure Goal Description Provide funding to improve public facilities and infrastructure, including parks, community centers, and sidewalks. 9 Goal Name Fair Housing Goal Description Promote fair housing choice through the following activities: fair housing education, fair housing testing, housing assistanc e hotline, and landlord-tenant mediation. 10 Goal Name Planning and Administration Goal Description Provide funding to implement the goals and objectives of the Consolidated Plan, comply with planning and reporting requiremen ts, and monitor use of the funds. Estimate the number of extremely low -income, low-income, and moderate-income families to whom the jurisdiction will provide affordable housing as defined by HOME 91.315(b)(2) The City estimates that HOME funds will provide affordable housing to approximately 10 households over the ConPlan period. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 102 SP-50 Public Housing Accessibility and Involvement – 91.215(c) Need to Increase the Number of Accessible Units (if Required by a Section 504 Voluntary Compliance Agreement) Households in California with at least one member living with a disability have a median household income of $56,600, approximately $26,000 less than the median household income of all households at $82,000.18 Consequently, the need for accessible affordable units would be high. As discussed in NA-35, the average annual income of all vouchers holders is approximately $14,084, which indicates these voucher holders have limited income to cover basic transportation, medical, food, and personal needs. As indicated in Table 23 in NA-35, 5,277 voucher holders (37 percent) have requested some type of accessible feature, demonstrating a need. Given the number of persons with disabilities across the County, the need for accessible units would be great. Activities to Increase Resident Involvements The HACSB Board of Commissioners has regular meetings twice per month that call for public comment on agenda items. The HACSB also operates a Family Self Sufficiency Program designed so that residents can be involved in the development of self-sufficiency goals, job training, and other services. Is the public housing agency designated as troubled under 24 CFR part 902? No. Plan to remove the ‘troubled’ designation Not applicable. 18 Cornell University. Disability Statistics. http://www.disabilitystatistics.org/reports/acs.cfm City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 103 SP-55 Barriers to affordable housing – 91.215(h) Barriers to Affordable Housing Several factors act as barriers to acquiring and constructing af fordable housing. Lack of funding is the most significant as local, state, and federal funding has been decreasing over the last decade. Local, state, and federal development requirements are the next most significant barrier, and include:  Planning and development fees, such as for transportation, water, and sewer infrastructure, increases the cost of development.  Permit and processing procedures, including application review, can also delay housing development.  Environmental protection policies, including the California Environmental Quality Act and the National Environmental Policy Act, require environmental review for discretionary projects, which increases costs and delays the development process.  Site improvements required by the City for undeveloped land or land that lacks adequate transportation and pedestrian infrastructure increases the cost of housing development. Strategy to Remove or Ameliorate the Barriers to Affordable Housing The City continues to make the development process more efficient for developers through amendments to the Development Code. The City plans to make the following updates to its development code:  General Lot Consolidation Incentive – This incentive would increase development potential by allowing a 15 percent density bonus for projects with a residential component, maintenance plan, and on-site management.  Density Bonus Provisions – The City plans to update the Development Code to reflect the latest amendments to state density bonus law.  Transitional and Supportive Housing – The City plans to update the Development Code to adequately define transitional and permanent supportive housing to eliminate confusion and facilitate the review and approval process for this housing type.  Streamlined Processing – The City plans to analyze potential programs that seek to eliminate land use constraints related to the development of new housing and rehabilitation of existing housing. Additionally, the City is applying for an SB 2 planning grant that will assist with streamlining. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 104 SP-60 Homelessness Strategy – 91.215(d) Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs The City of San Bernardino provides ESG funding to Step Up On Second, which provides essential service referrals and housing placement services to homeless persons and near- homeless persons. Step Up also provides daily mobile outreach to the most service-resistant homeless population in the City. Addressing the emergency and transitional housing needs of homeless persons The City funds nonprofits that operate emergency shelters and transitional housing for homeless individuals. Emergency shelters provide shelter, nutrition, supportive services, counseling, medical treatment, transportation assistance, referrals to mental health and social service agencies, and housing assistance. Transitional housing provides shelter and services such as job training, financial literacy training, drug and alcohol rehabilitation, and counseling to help individuals reestablish independent living. Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again. The City provides funding for supportive services to assist homeless individuals, including funding for emergency shelters, rapid rehousing, homelessness prevention, and street outreach. The City also funds nonprofit agencies that operate emergency shelters, which provides services to help homeless individuals stabilize and live independently. During PY 2019-2020, ESG funds were awarded to agencies that provide homeless prevention, rapid rehousing, and emergency shelter. The City will continue to fund nonprofits that help homeless individuals transition to permanent housing. Help low -income individuals and families avoid becoming homeless, especially extremely low-income individuals and families who are likely to become homeless after being discharged from a publicly funded institution or system of care, or who are receiving assistance from public and private agencies that address housing, health, social services, employment, education or youth needs As discussed above, the City funds a number of nonprofits that provide homeless prevention services to those at risk of homelessness. Additionally, the Coordinated Entry System (CES) is used to quickly identify, assess, refer, and connect clients to housing assistance and services in the event they are hospitalized. The City also collaborates with St. Bernardine’s Hospital and City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 105 Community Hospital in the City of San Bernardino to connect homeless patients with bridge housing. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 106 SP-65 Lead based paint Hazards – 91.215(i) Actions to address LBP hazards and increase access to housing without LBP hazards The City follows all applicable lead-based paint hazard (LBP) regulations, which primarily affect projects funded by the City’s Housing Rehabilitation Program. All applicants are notified about LBP risk and, if they are low-income and have a child under six at home, are then referred to the County’s LBP Abatement Program for free paint inspections, lead testing for children, information about LBP, and abatement. In general, housing built after 1977, zero-bedroom units, and housing for the elderly or disabled persons (unless children are present) are exempt from this rule. How are the actions listed above related to the extent of lead poisoning and hazards? Units built prior to 1980 may contain LBP, to which children under the age of six years are especially vulnerable. As discussed in MA-20, approximately 31,000 housing units were built prior to 1980, of which approximately 6,500 are occupied by children under six years of age. How are the actions listed above integrated into housing policies and procedures? The City, as part of its Housing Rehabilitation Program, requires that all LBP be controlled or abated and disposed of properly to eliminate or reduce the hazard of environmental or human contamination. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 107 SP-70 Anti-Poverty Strategy – 91.215(j) Jurisdiction Goals, Programs and Policies for reducing the number of Poverty- Level Families The City annually allocates federal funds for economic development activities, which includes microloan programs and Section 108 loan repayment. HUD’s Section 108 Loan Guarantee Program provides CDBG recipients with financing for economic development activities. The goal of the program is to provide the public investment needed to catalyze private economic activity in underserved areas. The City utilizes Section 108 financing to acquire properties for the development of commercial centers and in the process creates jobs for City residents. How are the Jurisdiction poverty reducing goals, programs, and policies coordinated with this affordable housing plan The City allocated up to 15 percent of its CDBG funds annually to public and nonprofit service providers to offer a range of supportive services, including those that fight poverty. City of San Bernardino Draft 2020 - 2025 Consolidated Plan │ 108 SP-80 Monitoring – 91.230 Describe the standards and procedures that the jurisdiction will use to monitor activities carried out in furtherance of the plan and will use to ensure long -term compliance with requirements of the programs involved, including minority business outreach and the comprehensive planning requirements The City implements a subrecipient grant monitoring policy. City staff conducts program monitoring and audits of subrecipient records and facilities throughout the program year. As part of this responsibility, the City reviews quarterly compliance reports and annual single audits (as required by 24 CFR Part 44.6). Additionally, the City conducts risk assessments using financial information provided by subrecipients. Monitoring activities are conducted by telephone or on- site. The City’s CDBG, HOME, and ESG monitoring reports include: 1. Background of the agency, program, or project; 2. Review of current findings; 3. Corrective actions necessary (if applicable); 4. Observations about the program operations; and 5. Communication/advisement offered to the agency about their operations. EXHIBIT A(1) 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 2 of 53 Table of Contents Chapter 1: Introduction ........................................................................................................ 4 A. What is an Impediments to Fair Housing Choice? ................................................. 4 B. What is an Analysis of Impediments to Fair Housing Choice? .............................. 4 C. What is the purpose of the Report? .......................................................................... 4 D. Methodology & Organization .................................................................................... 5 E. Legal Framework ......................................................................................................... 7 Chapter 2: Public Participation ......................................................................................... 10 A. Community Survey .................................................................................................... 10 B. Stakeholder Interviews .............................................................................................. 10 C. Pop-Up Events and Focus Group Meetings........................................................... 12 D. Community Meetings ................................................................................................ 12 E. Public Review and Hearings .................................................................................... 13 Chapter 3: Community Profile ........................................................................................... 14 A. Demographic Profile ................................................................................................. 15 B. Race and Ethnicity .................................................................................................... 18 C. Housing Profile ............................................................................................................ 24 D. Employment and Workforce .................................................................................... 38 E. Homeless ..................................................................................................................... 40 F. Public Transit and Train Services .............................................................................. 41 Chapter 4: Lending Practices ............................................................................................ 43 A. Laws Governing Lending .......................................................................................... 43 B. Conventional Loans Versus Government-Backed Loans .................................... 45 C. Home Mortgage Disclosure Act and Data Analysis ............................................ 47 Chapter 5: Public Policies ................................................................................................... 51 A. Housing Element Law and Compliance ................................................................ 51 B. Land Use Element ...................................................................................................... 51 C. Development Code .................................................................................................. 53 Chapter 6: Fair Housing Profile ........................................................................................... 58 A. Fair Housing Practices in the Homeownership Market ........................................ 58 B. Fair Housing Practices in the Rental Housing Market ........................................... 60 C. Fair Housing Services and Statistics ......................................................................... 62 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 3 of 53 Chapter 7: Fair Housing Progress ....................................................................................... 67 G. Impediment: Housing Discrimination ...................................................................... 67 H. Impediment: Public Policies and Programs Affecting Housing Development 67 I. Impediment: Lending Practices .............................................................................. 70 J. Impediment: Demographics ................................................................................... 71 K. Impediment: Housing Market Conditions .............................................................. 72 Chapter 8: Fair Housing Action Plan ................................................................................. 73 A. Data Collection and Engagement Conclusions .................................................. 73 B. Setting Fair Housing Priorities and Goals ................................................................ 73 C. Contributing Factors to Fair Housing Issues ............................................................ 73 D. Priority Goals and Actions ........................................................................................ 76 Goal 1 ................................................................................................................................ 77 Goal 2 ................................................................................................................................ 77 Goal 3 ................................................................................................................................ 78 Goal 4 ................................................................................................................................ 78 Goal 5 ................................................................................................................................ 79 E. Regional Collaboration ............................................................................................ 80 APPENDIX A: Community Engagement Summary ......................................................... 81 A Introduction ................................................................................................................ 81 B Community Meetings ................................................................................................ 81 C Stakeholder Interview Summary .............................................................................. 84 D Pop Up Events ............................................................................................................ 87 E Housing Summit .......................................................................................................... 90 F Community Needs Survey ........................................................................................ 95 Index of Tables, Figures, Graphs, and Maps .................................................................... 97 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 4 of 53 Chapter 1: Introduction The City of San Bernardino (the City) is a recipient of funds from the U.S. Department of Housing and Urban Development (HUD). As such, the City is required to conduct an Analysis of Impediments to Fair Housing Choice (AI). A. What is an Impediments to Fair Housing Choice? Fair housing is a condition in which people of similar income levels, liv ing in the same housing market, have a similar range of choice regardless of characteristics protected under State and Federal laws. The U.S. Department of Housing and Urban Development defines impediments to fair housing choice as:  Any actions, omissions, or decisions taken because of race, color, ancestry, national origin, religion, sex, disability, marital status, familial status, or any other arbitrary factor which restricts housing choices or the availability of housing choices; or  Any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices based on race, color, ancestry, national origin, religion, sex, disability, marital status, familial status or any other arbitrary factor. B. What is an Analysis of Impediments to Fair Housing Choice? An Analysis of Impediments to Fair Housing Choice (AI) is an assessment of how laws, policies, real estate practices, and local conditions affect the location, availability, and accessibility of housing. The analysis of their impact on housing choice can highlight areas where corrective actions might broaden the housing options of persons protected by fair housing laws. C. What is the purpose of the Report? Through the AI , jurisdictions examine the affordability of housing with an emphasis on affordability for households with annual incomes classified as low income and less. Low income is defined as equal to or less than 80 percent of the adjusted area median family income as most recentl y published by the U.S. Department of Housing and Urban Development (HUD). 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 5 of 53 This AI has three major goals: Goal 1: Provide an overview of the City and current conditions as they impact fair housing choice. Goal 2: Review the City’s policies and practices as they impact fair housing choice and the provision of housing, specifically affordable housing and housing for special needs households. Goal 3: Identify impediments to fair housing choice and actions the City will take to remove those impediments or to mitigate the impact they have on fair housing choice. Fulfilling these goals involves:  A review of the laws, regulations, and administrative policies, procedures, and practices of the City.  An assessment of how those laws affect the location, availability, and accessibility of housing.  An assessment of conditions, both public and private, affecting fair housing choice. D. Methodology & Organization Pursuant to HUD guidance, jurisdictions are not required to collect new data and can use existing data to analyze potential impediments to fair housing choice. For this AI, the City employed the following data sources:  American Community Surveys (2013-2017)  Decennial Census Data (1990-2010)  Home Mortgage Disclosure Act (HMDA) Data (2018)  San Bernardino Consolidated Annual Performance and Evaluation Reports  San Bernardino Consolidated Plan (2020-2024)  San Bernardino General Plan (2005)  San Bernardino Housing Element (2013-2021)  San Bernardino Zoning Ordinance  U.S. Department of Housing and Urban Development 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 6 of 53 Organization of the Report This report is divided into eight chapters, including this introduction, as described below. Chapter 1: Introduction explains the purpose of the AI, describes its methodology and organization, and outlines its legal framework. Chapter 2: Public Participation discusses outreach efforts undertaken for the development of the AI . Outreach results include comments received during the public review draft AI, community engagement and stakeholder meetings . Chapter 3: Community Profile presents demographic information and income characteristics in the City, including the number and percentage of persons by age, ethnicity, familial status, and disability. The housing profile includes the number of housing units by type, cost, overcrowding condition, and housing cost burden. Income characteristics include the distribution of low - and moderate-income population by census tract. Chapter 4: Lending Practices assesses the access to financing for different groups. Predatory and subprime lending issues are also discussed. Chapter 5: Public Policies analyzes public policies and actions that may impede fair housing in the city, such as those contained in the City’s Housing Element, Land Use Element, and Zoning Ordinance. Chapter 6: Fair Housing Profile provides information on the institutional structure of the homeownership and rental markets in the City. It also includes local, state, and federal data on fair housing complaints. Chapter 7: Fair Housing Progress evaluates the progress toward recommendations made in the previous AI’s Action Plan. Chapter 8: Fair Housing Action Plan summarizes the findings regarding fair housing issues in the City and provides recommendations for furthering fair housing practices. Appendix B: Community Engagement Summary describes the community outreach program and summarizes input from residents, agency representatives, and other stakeholders. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 7 of 53 Funding Source Preparation of this report was funded with Community Development Block Grant (CDBG) administration funds. E. Legal Framework Fair housing choice grants provide individuals the opportunity to choose where they wish to live. To ensure that all individuals and families are given equal access to housing, the federal government and the State of California have enacted the following laws listed below to prohibit subtle and overt forms of housing discrimination. HUD’s Office of Fair Housing and Equal Opportunity has played a lead role in enforcing the Act since its adoption in 1968. The Act prohibits discrimination in the sale, rental, and financing of dwellings based on race, color, religion, national origin, sex, familial status (presence of child under the age of 18, and pregnant women), and or disability. Because housing choice is so critical to personal development, fair housing is a goal that government, public officials, and private citizens must embrace if social equality is to become a reality. Federal Laws Federal Fair Housing Act The Act is the protection against discrimination in housing on the federal level. After a lengthy legislative battle, urban riots, and the assassination of Dr. Martin Luther King Jr., the Act was enacted in 1968. It extended the general disclination protec tions included in the 1964 Civil Rights Act into the housing market. The Act prohibits discrimination in housing based on a person’s race, color, religion, gender, disability, familial status, or national origin. In addition, HUD issued a Final Rule on Feb ruary 3, 2012 that prohibits entitlement communities, public housing authorities, and other recipients of federal housing resources from discriminating based on actual or perceived sexual orientation, gender identity, or marital status. Persons who are protected from discrimination by fair housing laws are referred to as members of the protected classes. The Act covers “dwellings” which are defined as structures designed or occupied as residences or land offered for sale where a residence will be built. A “dwelling” is broadly defined and can include a homeless shelter or a summer home. In some circumstances, exemptions to the Act include the following: owner-occupied buildings with no more than four units, single-family housing sold or rented without the use of a broker, and housing operated by organizations and private clubs that limit occupancy to members. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 8 of 53 Equal and unimpeded access to residential housing is a fundamental civil right that enables members of protected classes, as defined in the Act, to pursue personal, educational, employment, or other goals. Because housing choice is so critical to personal development, fair housing is a goal that government, public officials, and private citizens must embrace if social equity is to become a reality. Other federal laws relevant to fair housing are included in Appendix A. Reasonable Accommodations The Fair Housing Amendments Act requires housing providers to make reasonable accommodations if it is necessary for people with disabilities to live in and use the housing. Accommodations may include interior or exterior modifications, such as installation of ramps, or modifications of rules, policies, or practices, such as allowing guide dogs in a building that has a no pet policy. Equal Access to Housing in HUD Programs Regardless of Sexual Orientation or Gender Identity On February 3, 2012, HUD issued a rule to ensure fair and equal access to housing regardless of sexual orientation, gender identity, nonconformance with gender stereotypes, or marital status. The rule requires that a determination of eligibility for housing assisted by HUD be made without regard to actual or perceived sexual orientation, gender identity, or marital status. The rule also included a definition for sexual orientation and gender identity and expanded the definition of family in most of HUD's programs. On September 21, 2016, HUD issued the Gender Identity Rule, which ensures that all individuals have equal access to HUD’s shelter programs in accordance with their gender identity and without being subjected to intrusive questioning or being asked to provide documentation. California Laws Fair Employment and Housing Act The California Fair Employment and Housing Act is a California statute that prohibits employment and housing discrimination based on ancestry and national origin, race and color, religion and creed, age, mental and physical disability, sex and gender, sexual orientation, source of income, gender identity and expression, medical condition and genetic information, marital status, and military and veteran status. Unruh Civil Rights Act The Unruh Civil Rights Act prohibits discrimination by all business establishments, including housing accommodations, based on race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, primary language, or immigration status. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 9 of 53 Ralph Civil Rights Act The Ralph Civil Rights Act prohibits violence or threats of violence based on race, color, religion, ancestry, age, disability, sex, sexual orientation, political affiliation, or position in a labor dispute. Bane Civil Rights Act The Bane Civil Rights Act prohibits interference or attempted interference with someone’s state or federal statutory or constitutional rights, including equal access to housing. Senate Bill 329 Mostly recently, Governor Gavin Newsom signed Senate Bill 329. The bill expands the definition of “source of income” to include income paid to a housing owner or landlord on behalf of a tenant, including federal, state, or local public assistance or subsidies. Therefore, SB 329 expands fair housing protections to recipients of Section 8 vouchers. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 10 of 53 Chapter 2: Public Participation The public participation process for the AI sought input from community members and stakeholders. Methods included on-line and paper surveys for community members, stakeholder interviews, community meetings, and pop-up events. The AI development engagement process took place in November, December, and January. The process concluded with a 30-day public review period and a public hearing. A. Community Survey The City prepared a Community Needs Survey in both English and Spanish and provided online links and paper copies for distribution. The survey was promoted at scheduled project community meetings, Housing Summit, and pop-up events. The survey link was posted on the City’s website, stakeholder newsletters, social media posts and on flyers distributed at community events. The survey period was from December 9, 2019 to February 28, 2020. The City received approximately 1,011 responses. Of which 88 percent were residents, 55 percent were homeowners. The survey sought community input on the City’s most pressing needs in the areas of housing, community facilities, infrastructure, homelessness, community services, and economic development. Survey summaries of the English and Spanish versions is included in Appendix B –Community Engagement Summary. B. Stakeholder Interviews The City also conducted interviews and an on- line stakeholder survey to gather input from stakeholders. They represent housing, health, education, employment, faith-based, service delivery, and professional service organizations. The interviews and survey posed questions about community facilities, community services, infrastructure, residents with special needs, neighborhood services, business and job services, housing services, and housing facilities. KEY TAKEWAY: Most Important Community Needs:  Job readiness, creation of new and job-generating businesses, college readiness  Homeless services, homeless emergency/ overnight shelters and permanent supportive housing, rent assistance  New affordable housing, first- time homebuyer program, renter-occupied rehabilitation and accessibility improvements  Community and youth centers, parks, and healthcare  Infrastructure improvements (streets and sidewalk repairs), lighting, safe routes to school  Social programs; at-risk youth, children’s after school/summer, and youth activities Figure 1: Key Takeaways Community Survey 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 11 of 53 Stakeholder interviews included representatives from the following organizations:  California State University – San Bernardino  Catholic Charities of San Bernardino and Riverside Counties  Dignity Health  Hope through Housing  Salvation Army  Omni Trans  Continuum of Care – San Bernardino County  Center for Employment Opportunities  Inland Congregations United for Change  Inland Fair Housing and Mediation Board  Mental Health Systems  National Core Renaissance  Neighborhood Partnership Housing Services, Inc.  San Bernardino County Department of Behavioral Health A list of stakeholder interviews and the stakeholder survey are included in Appendix B –Community Engagement Summary. KEY TAKEWAY: Critical Needs Identified by Stakeholders  Increase in housing inventory – an increased supply will help all, including the Latino and African American population  Improve perceptions of San Bernardino (negative perception deters private investment)  Address discrimination, particularly race or ethnicity discrimination  Raise awareness about homelessness using humanistic stories that go beyond the data  Support a growing population of homeless seniors  Decrease dependency on government and draw foundations and corporations into the solutions  Create pathways to employment Figure 2: Key Takeaways Critical Needs 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 12 of 53 C. Pop-Up Events and Focus Group Meetings Four Pop-Up events were attended including a local football game, San Bernardino Fest 2019 Airshow, Housing Authority County of San Bernardino, and City of San Bernardino Winter Wonderland. Common themes derived from the events include: o Most critical economic development need. Job creation/job generating businesses o Most important areas of need. Affordable housing and services for the homeless o Most critical homelessness needs. Transitional housing and emergency shelters o Most critical community services. Youth activities and children after school/summer programs o Most critical infrastructure needs. Repaving of streets, street lighting o Most critical housing needs. First-time homebuyer’s assistance, construction of new affordable units and housing for larger families D. Community Meetings Community meetings were attended by representatives of Neighborhood Partnership Housing Services, Inc., Executive Director of Akoma Unity Center, National CORE, Dignity Health, Accelerating Investment for Healthy Communities (AIHC), Housing Authority County of San Bernardino, Hope Through Housing Foundation, and Executive Director of Community Engagement for the San Bernardino City Unified School District. Six community engagement meetings were held at the following locations:  Rezek Center – St. Bernardine Medical Center, 2101 N. Waterman Ave, San Bernardino, Tuesday, January 21, 2020, 11 AM – 1 PM  Akoma Unity Center 1367 N California St, San Bernardino, Saturday, January 18, 2020 9:30 AM (Set-Up) – 11:30AM  Maplewood Homes 906 Wilson St, San Bernardino, Wednesday, January 22, 2020 4PM – 5PM  Olive Meadows 610 East Olive Street, San Bernardino, Thursday, January 23, 2020 4PM – 5PM  Valencia Vista 950 N Valencia Ave, San Bernardino, Thursday, January 23, 2020 5PM – 6:30PM  San Bernardino Valley College 701 S Mt Vernon Ave, San Bernardino, Friday, January 24, 2020 9AM – 10:30AM 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 13 of 53 There were eight re-occurring themes including: 1. Affordable housing 2. Target areas for redevelopment and safety 3. Community services needed 4. Homeless/homeless prevention services 5. Infrastructure needs 6. City communications 7. Jobs and employment 8. Crime safety. A summary of the input received during popup engagement and focus groups is included in Appendix B –Community Engagement Summary. E. Public Review and Hearings The AI was completed concurrently with the City’s 2020-2025 Consolidated Plan. Two public hearings were held, March 18, 2020 and April 15, 2020. A public review draft and comment of the AI and the Consolidated Plan was available for a 15-day review period from February 27, 2020 through March 18, 2020. A public review draft of the AI and the Consolidated Plan was available for a 30-day public review period from March 12, 2020 through April 15, 2020. Public Hearings were advertised in the San Bernardino Sun and El Chicano. The AI was also made available on the City’s website, City of San Bernardino Public Information Center, Community and Economic Development Department, and Feldheym Central Library. All written comments received relative to impediments to fair housing will be documented and reviewed by the City. City Council is responsible for holding a public hearing to discuss and adopt the final AI report. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 14 of 53 Chapter 3: Community Profile Various characteristics affect housing choice for people and households with similar income levels, in the same housing market. Therefore, understanding the social, racial, economic, and other population characteristics and how they change over time is crucial to evaluating current and future housing needs and housing choice among characteristically different populations and households. The City of San Bernardino is the most populous city in the County of San Bernardino and one of the oldest communities in the State of California. Throughout the years, the City has experienced economic vitality, built on agriculture, railroads, and distribution. In the latter half of the 1900s, with changing market conditions, high rates of population growth, and overall development patterns, and other social , economic, and cultural change throughout the Inland Empire, the City experienced significant change. The changes have had a more acute impact on vulnerable populations. This Community Profile compiles information about population change, incomes, household characteristics, and housing costs, which influence housing choice. KEY TAKEWAY: Vulnerable Residents The City’s most vulnerable residents tend to include those who are:  Disabled and elderly  Living in poverty,  Members of the Latino and/or African American communities,  Homeless. For the City, particularly for residents who do/may experience discrimination and live in areas of concentrated poverty, critical needs include good, accessible jobs and housing options. Workforce Development Living Wages & Job- Generating Businesses A Larger, More Diverse Housing Stock Figure 3: Key Takeaways Vulnerable Residents 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 15 of 53 A. Demographic Profile Information in this section is primarily based on the 2013-2017 American Community Survey (ACS). I n some cases, data from the 2006-2010 ACS estimates and the 2010 U.S. Census have been used to detect trends. Population Growth City population growth has slowed since 2010. Between 2000 and 2010, the City grew by 12.8% percent. In the following decade, growth slowed to about 3 percent between 2010 and 2017. According to the 2013-2017 ACS estimates, the City’s population was 215,252, which is much lower than the growth forecast in the Southern California Association of Government’s (SCAG) 2012 Regional Transportation Plan. Based on projections prepared by SCAG, the City was projected to reach 231,200 people by 2020. To reach that projection, the City would need to achieve a 7 percent increase between 2017 and 2020, which is unlikely when compared to the prior growth rate of 3 percent and the comparably low growth rates in the County of San Bernardino and the State of California. The population increase over time is shown in Table 1 along with a comparison to the County of San Bernardino and the State of California. Population Increase 2000 2010 2017 Percentage Change 2010- 2017 San Bernardino 185,401 209,174 215,252 3% County of San Bernardino 1,709,434 2,005,287 2,121,220 5% State of California 33,871,648 37,253,956 38,982,847 4% Table 1: Population Increase Source: 2000, 2010, 2013-2017 ACS 5-Year Estimates Population growth is significantly lower than regional 2020 projection. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 16 of 53 Age Characteristics Age is an important factor when evaluating housing needs. As people age, they pass through different stages associated with changing family types and sizes, education and training that influence earning capacity , physical abilities, mental faculties, and overall independence. Together, these and cultural norms correspond to different housing needs over time. The ability to fill those needs depends on available housing options in both the rental and ownership markets. According to the 2013-2017 ACS estimates, and as shown in Figure 4, San Bernardino has a higher percentage of young people than the County in every category from birth to 39 years old. Within that age range, those between 20 and 24 years of age make up the largest segment of the total population at 9.4 percent. The second and third largest age groups are children under 5 years old and 5 to 9 years old at 8.5 percent and 8.8 percent, respectively. Largest Age Groups in Order  20-24 years old (9.4%)  5-9 years old (8.8%)  Under 5 years old (8.5%) Figure 4: Age Distribution 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 17 of 53 0%1%2%3%4%5%6%7%8%9%10% Under 5 years 5 to 9 years 10 to 14 years 15 to 19 years 20 to 24 years 25 to 29 years 30 to 34 years 35 to 39 years 40 to 44 years 45 to 49 years 50 to 54 years 55 to 59 years 60 to 64 years 65 to 69 years 70 to 74 years 75 to 79 years 80 to 84 years 85 years and over City County Age Distribution in San Bernardino City and County Source: 2013-2017 ACS 5-Year Estimate Graph 1: Age Distribution in San Bernardino City 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 18 of 53 B. Race and Ethnicity Race and ethnicity can have implications for housing choice as a result of discrimination or economic variables that may correlate with race. According to the 2013-2017 ACS estimates and as shown in Table 2, Hispanic populations of any race and White Alone populations were the two largest race/ethnic groups in the City, representing 64.3 percent and 57.4 percent of the total population, respectively. Black or African American populations represent just over 14 percent of the total population. Compared with the 2006-2010 ACS estimates, the Hispanic and White populations have increased however, the black or African American population has decreased. Residential Segregation Residential segregation refers to the degree to which groups live separately from one another. Segregation is complex, difficult to generalize, and influenced by many factors. Individual choices can certainly be a cause of segregation, when residents choose to live among people of their own race/ethnic group. This does not mean that they prefer ethnically homogeneous neighborhoods, but that they feel more comfortable where members of their group are commonly found. However, individual choices may also be constrained by factors outside an individual’s control. A large factor in residential segregation is related to housing market dynamics. Availability of affordable housing and discrimination can also affect residential segregation. Race and Ethnicity 2006-2010 2013-2017 # % # % White alone 97,283 46.5% 123,583 57.4% Black or African American alone 33,684 16.1% 30344 14.1% American Indian and Alaska Native alone 1,606 0.8% 1593 0.7% Asian alone 8,916 4.3% 9,602 4.5% Native Hawaiian and Other Pacific Islander alone 534 0.3% 433 18.5% Some other race alone 59,271 28.3% 39,759 18.5% Two or more races 7,880 3.8% 9,933 4.6% Total 209,174 100% 215,252 100% Hispanic or Latino (of any race) 121,583 58.1% 138,349 64.3% Not Hispanic or Latino 87,591 41.9% 76,903 35.7% Table 2: Race and Ethnicity Source: 2006-2010 ACS 5-Year Estimates, 2013-2017 ACS 5-Year Estimates 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 19 of 53 Language Spoken Housing may not be refused based on a resident’s birthplace or ancestry, nor can housing providers take advantage of a person’s inability to read, write, speak, or understand English to deny access. Those with limited English proficiency (LEP) can face unique challenges in meeting their housing needs, so recipients of federal financial assistance are required to provide access to programs to LEP citizens. This condition applies to HUD funds that are allocated to the City. While housing needs do not vary with language spoken, language is an important population characteristic because it may influence discriminatory practices and should be considered when establishing goals and actions to further fair housing. Of the City’s total population, 48.7 percent speak only English, 46.5 percent speak Spanish, 3.4 percent speak Asian and Pacific Islander languages, and less than 2 percent speak other Indo-European languages or other non-specified languages. Language Spoken at Home Number % Population 5 years and over 196,983 100.0 -English only 95,891 48.7 -Language other than English 101,092 51.3 Speak English less than "very well" 41,044 20.8 -Spanish 91,525 46.5 Speak English less than "very well" 36,438 18.5 -Other Indio-European languages 1,531 0.8 Speak English less than “very well” 520 0.3 -Asian and Pacific Island languages 6,618 3.4 Speak English less than "very well" 3,426 1.7 -Other languages 1,418 0.7 Speak English less than "very well" 663 0.3 Table 3: Languages Spoken at Home Source: 2013-2017 ACS 5-Year Estimates The dissimilarity index is the most used measure of segregation between two groups, reflecting their relative distributions across neighborhoods (as defined by census tracts). The index represents the percentage of the minority group that would have to move to new neighborhoods to achieve integration of that group. An index score 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 20 of 53 can range in value from 0 percent, indicating complete integration, to 100 percent, indicating complete segregation. An index number above 60 is considered high similarity and segregated. An index number of 31 to 60 is considered moderate segregation and values of 30 or below are considered low levels of segregation. Table 4 represents dissimilarity indices for the City. In 2010, segregation was highest between Asians and Hispanics at an index of 40.4, followed by white and Hispanic populations, with an index of 39.4. The lowest segregation was between black and Hispanic residents with an index of 24.6. Overall San Bernardino has become more integrated, having a healthier mix of ethnicities. Index of Dissimilarity 1980 1990 2000 2010 White - Black 65.1 49.8 37.4 33.1 White - Hispanic 53.4 49.7 43.1 39.4 White - Asian 26.6 32.2 38.4 36.6 Black - Hispanic 41.7 31.2 25.1 24.6 Black - Asian 59.5 36.3 35.2 32.8 Hispanic - Asian 49.5 38.1 38.6 40.4 Table 4: Index of Dissimilarity Source: Diversity and Disparities, American Communities Project 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 21 of 53 Minority Concentration and Concentrated Areas of Poverty HUD requires jurisdictions to identify areas of minority concentrations. Minority population is defined as the total population less those who responded “White alone” to the U.S. Census. Concentrations are classified through census tract block groups whose populations of a race or ethnic group are greater than the citywide proportion. Block group areas where the percentage of total minority population exceeds the group’s citywide total percentage are areas of “minority concentration.” Areas that have a minority population at least two times the citywide total percentage are areas of “high minority concentration.” Using this criteria and data from HUD’s data tool for affirmative fair housing, the following census tracts had a high minority concentration. The Minority Concentration map (Figure 2) shows the predominant race/ethnicity per census tract. Census tracts in the City have a concentration of minority citizens. The Hispanic population is distributed widely across the City. A few census blocks have predominantly white populations, which are located in the northern half of the city. Two census blocks on the southern edge are primarily populated by Asian households. Census tracts with a household poverty rate of 40 percent or above and a majority/minority population are referred to as Racially/Ethnically Concentrated Areas of Poverty (R/ECAP). Figure 3 displays R/ECAP census tracts in green. Most R/ECAPs are in the center of the City. Poverty has an adverse impact on housing choice. The limitation to affordable housing can compromise health, safety, and services that households needs to live. American Indian and Alaska Native groups have the highest percentage of poverty across all racial and ethnic groups with 38.6 percent. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 22 of 53 Minority Concentration in and Near City of San Bernardino Map 1: Minority Concentration 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 23 of 53 Racially or Ethnically Concentrated Areas of Poverty Map 2: Racially or Ethnically Concentrated Areas of Poverty 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 24 of 53 C. Housing Profile The household profile, which outlines characteristics of San Bernardino’s househ olds, aids in understanding housing needs. Households with different characteristics face different impediments in the housing market. Various household characteristics may affect equal access to housing, including household type, size, and income level. A household, as defined by the U.S. Census Bureau, includes all the persons who occupy a housing unit, which may include a single family, one person living alone, two or more families living together, or any other group of related or unrelated persons who share living arrangements. Household Size The number of San Bernardino households increased between 2015 and 2017, from 57,580 to 58,046 households. As shown in Table 5, the majority of the City’s households are families (75 percent). Approximately 3.5 percent of households are female-headed single-parent households living with their own children. In 2010, the average household size in the City was 3.42 persons per household, and in 2017 it was 3.52. About 23 percent of San Bernardino households included at least one or more elderly persons. Table 5: Housing Types Source: 2006-2010, 2013-2017 ACS 5-Year Estimates Household Type Total Households Number # Percent % Family households 43,624 75.2% With own children under 18 yrs 22,881 39.4% Married couple with family 23,799 41.0% With own children under 18 yrs 11,981 20.6% Female householder, no husband present 14,218 24.5% With own children under 18 yrs 8,242 14.2% Nonfamily households 14,422 24.8% Householder living alone 11,144 19.2% Householder 65 years and over 4,205 7.2% Households with individuals under 18 years 27,423 47.2% Households with individuals over 65 years 13,450 23.2% Average household size 3.52 Average family size 4.02 Source: 2013-2017 ACS 5-Year Estimates 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 25 of 53 Table 6: Housing Tenure Source: 2006-2010, 2013-2017 ACS 5-Year Estimates Special Needs Populations Certain groups may have difficulty finding housing in the City and may require specialized services, assistance, and accommodations. Due to challenges that accompany special needs, these people may be more likely to earn extremely low to low incomes. Special needs groups include the elderly, disabled persons (mental, physical, and/or developmental), veterans, persons with HIV/AIDS, single-parent households (male and female), large households, and homeless persons. Seniors Persons age 65 years and older may have special housing needs primarily due to income, health care costs, and physical or mental disabilities, particularly those that tend to increase with age. As a result, s eniors may face difficulty in finding housing and may become victims of housing discrimination or fraud. According to the 2013- 2017 ACS estimates, approximately 18,597 seniors resided in the City, representing 8.6 percent of the total population. The senior population is growing at a faster pace than the overall population. Between 2010 and 2017, the total number of seniors in San Bernardino increased by more than 12 percent, while the City’s total population between those two years increased by only 2.5 percent. Seniors are distributed among 23 percent of households in San Bernardino wherein at least one or more persons are 65 or older. Persons with Disabilities Physical, mental, and/or developmental disabilities may prevent a person from working, restrict one’s mobility, or make self-care difficulty. Disabled persons frequently have special housing needs, often related to a potentially limited ability to earn enough income, a lack of accessible and affordable housing, and higher health costs associated with a disability. In addition, persons with self-care and mobility limitations may require special housing design features such as wheelchair ramps, grab bars, special bathroom designs, wider doorway openings, and other features. Housing Tenure (Occupied Units) Tenure 2010 2017 Units % Units % Owner-Occupied 31,662 52.0% 27,137 46.8% Renter-Occupied 29,294 48.0% 30,909 53.2% Total Occupied Housing Units 60,956 100% 58,046 100% 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 26 of 53 According to the 2013-2017 ACS estimates, 12.8 percent of San Bernardino residents reported a disability. This is an increase from the 2008-2012 ACS estimates, which estimated 12 percent of the population had one or more disabilities. About 18 percent of the black or African American population reported a disability, which means that black or African Americans reported a disability at a higher rate. Disability is also categorized by age. Approximately 16.5 percent of those between the ages of 35 to 64 reported having a disability. Approximately 38.5 percent of those between the ages of 65 to 74 reported having a disability, which is approximately 8 percent higher than the County level. For those 75 years and older, 60.9 percent of the population reported having a disability, which is approximately 5 percent higher than the County level. Persons with Disabilities Subject Estimate Total With a disability Percent with a disability Total civilian noninstitutionalized population 209,082 26,794 12.8% SEX Male 105,780 13,240 13.1% Female 109,472 13,554 12.6% RACE AND HISPANIC OR LATINO ORIGIN White alone 123,583 15,013 12.4% Black or African American alone 30,344 5,165 18.0% American Indian and Alaska Native alone 1,598 264 17.7% Asian alone 9,602 1,178 12.4% Native Hawaiian and Other Pacific Islander alone 433 43 10.1% Some other race alone 39,759 4,176 10.8% Two or more races 9,933 955 9.9% White alone, not Hispanic or Latino 32,877 7,139 23.1% Hispanic or Latino (of any race) 138,349 12,892 9.5% AGE Under 5 years 18,269 69 0.4% 5 to 17 years 46,196 2,390 5.2% 18 to 34 years 60,139 4,497 7.8% 35 to 64 years 72,051 11,378 16.5% 65 to 74 years 14,283 4,228 38.5% 75 years and over 7,314 4,232 60.9% Table 7: Persons with Disabilities Source: 2013-2017 ACS 5-Year A major challenge facing the City is the availability of housing stock with accessible features that meet the needs of disabled residents and their families. As discussed 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 27 of 53 above, the rate of disability tends to increase with age; as the City’s population ages, the need for accessible senior housing is expected to increase. The 2013-2017 ACS estimates showed that 14.8 percent or 2,659 residents above the age of 65 were living below the poverty level. Living below the poverty level further limits resources and puts an additional constraint on the already limited housing options available to seniors with a disability. Large Households and Families with Children The size and composition of large households vary from family to family and home to home. Large households often are families with three or more children or households with extended families including in-laws or grandparents. They are considered a special needs group because of the limited availability of adequately sized, affordable housing units. To afford shelter in addition to food, clothing, and medical care, very low- and low-income large households may live in overcrowded conditions. Families with children may face discrimination or differential treatment in the housing market. Some landlords may charge large households a higher rent or security deposit, limit the number of children in a complex, limit the time children can play outdoors, or choose to not rent to families with children. According to the 2013-2017 ACS estimates, there were approximately 58,046 total households in the City, of which 43,624 were families. Within the count of families, there were 17,188 families with their own children under 18 years old (or 29.6 percent of the total household population). Table 8 shows the number of large households residing the City in the years 2000 (6,555), 2010 (8,022), and 2017 (14,267). In 2010, there were 8,022 large households and in 2017, there were 14,267 large households representing an increase of 77.8%. Large Households 2000 2010 2017 # % # % # % 5 persons 3,206 10.9% 5 persons 3,577 11.9% 5 persons 6,795 11.7% 6 persons 1,815 6.1% 6 persons 2,059 6.9% 6 persons 4,144 7.1% 7+ person 1,534 6.2% 7+ person 2,386 8.0% 7+ person 3,328 5.7% Table 8: Large Households Source: 2000, 2010, 2013-2017 ACS 5-Year Estimates Single-Parent Households Single-parent families, particularly female-headed families, often require special consideration and assistance due to more limited resources in having a one person - heading up the household versus two. There is a greater need for affordable housing and accessible daycare, healthcare, and other supportive services. Because of 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 28 of 53 more limited resources, and relatively lower income and higher burden of living expenses, female-headed families have more limited opportunities to find affordable, healthy, and safe housing. Female-headed families may also be discriminated against in the rental housing market because some landlords are concerned about the ability of these households to make regular rent payments. Consequently, landlords may require more stringent credit checks for women, which would be a violation of fair housing law. Single Parent Households City County Total Households 58,042 623,642 # of Single Parent Households 10,900 77,378 % of Single Parent Households 18.8% 12.4% Table 9: Single-Parent Households Source: 2013-2017 ACS 5-Year Estimate Data from the 2013-2017 ACS estimates is limited on the breakdown of single male - or female-headed household families with children. Male householders with no wife present totaled 23,799 households and female householders with no husband present totaled 14,218 households. According to the 2010 Census, there were a total of 59,283 households in the City and 24,979 households with children. Households with a male householder (no wife present) with their own children were 2,819 (or 4.8 percent of the household population) and households with a female householder (no husband present) with their own children were 7,930 (or 13.3 percent of the household population). Married couple families with children under 18 years old had a poverty rate of 22.1 percent, whereas the rate was 54.1 percent for female householder-headed families with children under 18 years old with no husband present (2013-2017 ACS estimates). Therefore, households with a female householder (no husband present) with children under 18 years old have higher rates of poverty. Furthermore, per 2013-2017 ACS estimates, families with two people had a poverty rate (as defined by HUD standards of family income -- $16,240 or less for family of two1) of 7.5 percent and families with five people had a poverty rate of 22.4 percent ($28,780 or less). Larger families faced a significantly higher rate of poverty. The 2013 - 2017 ACS estimates identified 36.2 percent of families in San Bernardino as families 1 The bottom quintile households receive on average $45,000 in government transfers, (such as food stamps, Medicare, Medicaid etc.) which the Census Bureau does not count as income, thus understating household’s resources and overstating poverty status. (Source: Phil Gramm and Joh F. Early The Truth About Income Inequality WSJ 11/4/19). 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 29 of 53 with children living below the poverty level. According to the 2018 Census estimate, the overall poverty rate for the City was 11.8 percent. Family households with children are therefore more likely to be living below the poverty level. Persons with HIV/AIDS For persons living with HIV/AIDs, access to safe, affordable housing, along with quality healthcare, are the primary contributing factors to their overall well -being. The National Commission on AIDS states that up to half of all Americans with AIDS are either homeless or at imminent risk of becoming homeless because of their illness, lack of income or other resources, and having a weak support network. Biases such as stigmatism associated with their illness and perceived sexual orientation can add to the difficulty of obtaining and maintaining housing. Persons with HIV/AIDS may also require a broad range of services, including counseling, medical care, in-home care, transportation assistance, and food provision. Today, compared to decades ago, persons with HIV/AIDS live longer and require longer provision of services and housing. The most current information available from the California Department of Public Health, Office of AIDS indicates that the number of new diagnoses increased by 0.8 percent between 2013 and 2017. However, the rate of new diagnoses per 100,000 people declined by 2.4 during the same time period. The number of newly diagnosed people in the County was 189 people in 2013 and 248 in 2017. According to the same source, between 2013 and 2017, diagnoses and rate (number per 100,000 people) increased from 3,261 at a rate of 2.6 to 4,401 at a rate of 3.3, which is an increase of 0.7 percent. In 2014, 3,380 people were diagnosed and living with HIV in San Bernardino County at a rate of 2.7. In 2015, that number was 3,575 at a rate of 2.8. In 2017, the number of people living and diagnosed w ith HIV in the County was 4,401 at a rate of 3.3. Overall, in 2017, there were 4,401 people living and diagnosed with HIV of which 3,120 were in care and 2,278 were virally suppressed. To address fair housing issues of a community, the existing housing ma rket must be analyzed to distinguish local and current conditions. The following sections provide an overview of the characteristics of the local and regional housing market. Housing Conditions Age is an indication of the quality of the housing stock. Hou sing over 30 years old is likely to require rehabilitation such as plumbing, roof, or foundation repairs. In addition, older homes tend to be less energy efficient, which increases utility costs. Graph 2 displays the age of San Bernardino’s housing stock according to the 2013- 2017 ACS estimates. Of all housing units in San Bernardino, 14.7 percent are less than 30 years old. In contrast, 52 percent are more than 50 years old. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 30 of 53 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 1939 or earlier 1940 to 1949 1950 to 1959 1960 to 1969 1970 to 1979 1980 to 1989 1990 to 1999 2000 to 2009 2010 to 2013 2014 or laterNumber of Units Year Built Graph 2: Housing Stock by Year Built Housing Stock by Year Built Source: 2013-2017 ACS 5-Year Estimates Vacancy Rate Residential mobility is influenced by tenure. Ownership housing is associated with a much lower turnover rate than rental housing. Tenure preferences are primarily related to household income, composition, and age of the householder. Table 10 demonstrates the City’s vacancy rates in 2010 and 2017 based on ACS data. A healthy vacancy rate is associated with choice and mobility. Generally, a healthy vacancy rate for owner-occupied housing is 2-3 percent vacancy. For rental units, a healthy rate is 5-6 percent. In 2010, the vacancy rate for owner-occupied housing was 0.7 percent above range, or 3.7%, and in 2017 it was lower by 0.7 percent, or 1.3%. In 2010, the renter- occupied rate was above the healthy range by 0.9 percent, at 6.9%. By 2017, the rental vacancy rate returned to the healthy range at 6.0 percent. Vacant Units and Vacancy Rates Tenure 2010 2017 Homeowner Vacancy Rate 3.7% 1.3% Renter Vacancy Rate 6.9% 6.0% Table 10: Vacant Units and Vacancy Rates Source: 2006-2010, 2013-2017 ACS 5-Year Estimates 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 31 of 53 Housing Costs and Affordability The cost of housing relative to income is one of the most important factors in evaluating a community’s housing market. If housing costs are relatively high in comparison to household income, housing cost burden and overcrowding tends to occur. However, housing affordability alone is not necessarily a fair housing issue. Such concern arises when housing affordability is coupled with factors protected under fair housing laws, such as household type, composition, and race/ethnicity. Affordability Rent and Mortgage Combined 1 Person 2 Persons 3 Persons 4 Persons Extremely Low (0%-30%) Annual Income $15,100 $17,250 $21,330 $25,750 Monthly Income $1,258 $1,438 $1,778 $2,146 Affordable Purchase Price* $62,000 $70,000 $87,000 $105,000 Affordable Monthly Rent $377 $431 $533 $644 Very Low (30%-50%) Annual Income $25,150 $28,750 $32,350 $35,900 Monthly Income $2,096 $2,396 $2,696 $2,992 Affordable Purchase Price* $102,000 $125,000 $132,000 $146,000 Affordable Monthly Rent** $629 $719 $809 $898 Table 11: Affordability Rent and Mortgage Combined Source: 2006-2010, 2013-2017 ACS 5-Year Estimates Table 12: Affordability Rent and Mortgage Combined Source: 2019 HUD Income Limits for San Bernardino County *Note: Affordable Purchase Price assumes a minimum down payment (3.5%), a mortgage payment that will not result in a cost burden, and good credit. Pricing from https://smartasset.com/mortgage/how-much-house-can-i-afford#PCGmA6nHyA **Note: Affordable Monthly Rent assumes a monthly payment that will not result in a cost burden (less than 30% of monthly income) Affordability Rent and Mortgage Combined (continued) 1 Person 2 Persons 3 Persons 4 Persons Low (50%-80%) Annual Income $40,250 $46,000 $51,750 $57,450 Monthly Income $3,354 $3,833 $4,313 $4,788 Affordable Purchase Price* $164,000 $187,000 $211,000 $234,000 Affordable Monthly Rent $1,006 $1,150 $1,294 $1,436 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 32 of 53 Housing & Ownership Costs Table 13 shows median home purchase prices in the City compared to statewide. While the purchase price of homes is significantly higher statewide than it is in the City, this is not an indication of affordability. Instead, the difference is an indication of what may motivate homebuyers to move into the area and increase the overall demand for housing. This migration of homebuyers into the City from other parts of the state is a concern expressed during stakeholder interviews. Like the rest of the state, San Bernardino has followed the same trend of steadily increasing housing prices. Table 13: Median Home Purchase Price Source: California Association of Realtors Median Home Purchase Price for State of California and City of San Bernardino, 2015 through 2019 2016 2017 2018 2019 State City State City State City State City Jan $467,160 $234,460 $491,840 $245,440 $527,780 $277,000 $537,120 $290,000 Feb $444,780 $226,870 $480,270 $265,000 $522,440 $278,000 $534,140 $298,250 Mar $484,120 $237,350 $518,600 $260,000 $564,830 $280,000 $565,880 $309,950 Apr $509,240 $236,850 $537,950 $255,500 $584,460 $289,900 $602,920 $305,000 May $519,930 $245,080 $550,239 $272,500 $600,860 $285,000 $611,190 $315,000 Jun $518,980 $245,220 $555,410 $270,000 $602,770 $293,250 $610,720 $310,000 Jul $511,420 $248,000 $549,460 $266,250 $591,230 $292,000 $607,990 $312,000 Aug $527,490 $240,500 $565,330 $269,950 $596,410 $290,000 $617,410 $315,000 Sep $516,450 $251,750 $555,410 $279,000 $578,850 $300,000 $605,680 $315,000 Oct $513,520 $245,000 $546,430 $274,450 $572,000 $289,000 - - Nov $502,490 $250,000 $546,820 $280,000 $554,760 $299,450 - - Dec $510,560 $255,000 $546,550 $278,000 $557,600 $295,000 - - 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 33 of 53 Rental Housing Cost Overall, the median rental cost in San Bernardino increased between 2015 and 2018. During these years, the median rent increased from $976 to $1,068 for a percent increase of 9.4%, which is lower than State (+13.9%) and National (10.2%) rates . As shown in Table 14, both the lowest cost categories (up to $999) and the highest cost categories ($2,000-2,999) decreased as a percentage of the rental market. Rental Housing Cost, 2015 through 2018 2015 2016 2017 2018 Less than $500 7.60% 8.50% 8.20% 7.60% $500 to $999 45.70% 45.20% 38.40% 35.70% $1,000 to $1,499 35.00% 31.70% 35.60% 38.30% $1,500 to $1,999 8.40% 12.20% 15.00% 16.30% $2,000 to $2,499 3.00% 2.40% 2.00% 1.80% $2,500 to $2,999 0.30% 0.00% 0.80% 0.40% Median 976 971 1,038 1,068 No Rent Paid 924 788 1,001 509 Occupied units paying rent 30,703 31,350 29,844 30,969 Table 14: Rental Housing Cost Source: 2015, 2016, 2017, 2018 ACS 1-Year Estimates Another way to look at cost is to incorporate utilities. HUD annually publishes fair market rents (FMR), which represent an affordable cost and include an estimated utility cost for different size units in the County. As shown in Table 15, FMR increased for all unit sizes between 2018 and 2019. San Bernardino County Fair Market Rents by Unit Bedrooms, 2018 and 2019 Year Efficiency One- Bedroom Two- Bedroom Three- Bedroom Four- Bedroom FY 2018 FMR $768 $926 $1,156 $1,618 $2,004 Table 15: County Fair Market Rents Source: HUD FY 2018 and 2019 Fair Market Rent Documentation System, Riverside-San Bernardino- Ontario, CA Housing Cost Burden According to the federal government, households that spend more than 30 percent of income on housing is considered cost burdened. A cost burden of 30 to 50 percent is considered moderate; payment in excess of 50 percent of income is considered a severe cost burden. Cost burden is an important housing issue because paying too much for housing leaves less money available for basics such as food and living expenses as well as for emergency expenditures. Upper-income households generally can pay a larger proportion of income for housing. Therefore, estimates of housing cost burden generally focus on low - and 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 34 of 53 moderate-income households. Primarily, the City households in low-income brackets are renters, as shown in Table 16. Table 16: Income Distribution Overview Source: 2012-2016 Comprehensive Housing Affordability Strategy Most low-income households in the City experience cost burden. Table 17 shows two overlapping categories of cost burden. The categories represent those who spend more than 30 percent of their income on housing costs and a subset of that group that spends more than 50 percent of their income on housing costs. The latter group is severely cost burdened. The rate of severe cost burden is highest among the extremely low-income group. Housing Cost Burden Overview (Owners and Renters) Household Income Cost Burden > 30% Cost Burden > 50% # % # % Extremely Low Income (0% - 30%) 10,785 78.92% 9,415 68.90% Very Low Income (30%-50%) 7,415 77.85% 3,755 39.42% Low Income (50%-80%) 5,925 52.64% 1,070 9.51% Table 17: Housing Cost Burden Overview Source: 2012-2016 Comprehensive Housing Affordability Strategy Income and Workforce Household income does not directly affect fair housing options. However, perceptions about income as it relates to household type and size, race/ethnicity, and other characteristics can result in biases that trigger fair housing concerns. The workforce profile included here is important to help set goals and priorities for workforce development to increase access to jobs and economic mobility. Median Income Limits In 2017, the median household income (MHI) for the City of San Bernardino was $41,027, County of San Bernardino was $57,156, and the State of California was $67,169. MHI was 39.1 percent less than the County and 63.72 percent less than California. Table 18 shows the breakdown of MHI by race and ethnicity. When compared to other racial and ethnic groups, Asian and white households have the highest MHI in the City. Black households have the lowest MHI of any groups in the City. Income Distribution Overview Owner Rental Total # % # % Extremely Low Income (0%-30%) 2,805 20.53% 10,860 79.47% 13,665 Very Low Income (30%-50%) 3,260 34.23% 6,265 65.77% 9,525 Low Income (50%-80%) 5,210 46.29% 6,045 53.71% 11,255 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 35 of 53 Median Household Income by Race 2006-2010 2013-2017 Median Income Median Income White $44,304 $44,701 Black $32,590 $29,311 Indian $47,500 $36,071 Asian $37,045 $45,154 Native Hawaiian $73,098 Some other race $37,492 $40,081 2 or more races $46,367 $33,910 Hispanic $37,737 $41,325 Median in San Bernardino $39,895 $41,027 Table 18: Median Household Income by Race Source: 2013-2017 ACS 5-Year Estimates, 2006-2010 ACS 5-Year Estimates As established by HUD, low-moderate income (LMI) households refer to those whose incomes do not exceed 80 percent of the area median income (AMI). A low -income area is defined as a census tract or block group made up of at least 51 percent of households in the low- and moderate- income ranges. LMI is set by HUD and adjusted for the total number of persons in the household. There are three income levels for LMI households:  Extremely low income: Households earning 30% or less than the AMI  Very low income: Households earning between 30% to 50% of the AMI  Low income: Households earning between 50% to 80% of the AMI 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 36 of 53 HUD Median Income Limits for City of San Bernardino, 2019 Median Family Income FY Income Limit Category Number of Persons in Household 1 Person 2 Person 3 Person 4 Person 5 Person 6 Person 7 Person $69,700 Extremely Low (0- 30%) $15,100 $17,250 $21,330 $25,750 $30,170 $34,590 $39,010 Very Low (30%-50%) $25,150 $28,750 $32,350 $35,900 $38,800 $41,650 $44,550 Low (50%-80%) $40,250 $46,000 $51,750 $57,450 $62,050 $66,650 $71,250 Table 19: HUD Median Income Limits Source: HUD 2019 Income Limits Summary, Riverside-San Bernardino-Ontario, CA 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 37 of 53 Areas of Low- and Moderate-Income Concentration Map 3: Areas of Low- and Moderate-Income 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 38 of 53 D. Employment and Workforce Employment status appears in Table 20 The total number of people employed was 78,721 or about 49.9 percent of the total population. The number of unemployed was 11,584 or 7.3 percent. The number of people not in the labor force was 67,504 or 24.7 percent of the population. In comparison, the unemployment rate for the County was 5.9 percent for the same time period. In 2020 the City will open an employment center focused on homeless employment needs. Table 20: Employment Status Source: 2013-2017 ACS 5-Year Estimates Table 21 summarizes the City’s workforce by industry. Three industries comprise nearly 45 percent of the workforce. They are a) educational services, health care and social assistance, b) retail trade, and c) transportation, warehousing and utilities. Public administration has the highest median earning of $39,638. The lowest earning industry includes those who work in the arts, entertainment, recreati on, accommodations and food services. Workforce by Industry # of Total Industry % Share Median Earnings Educational services, and health care and social assistance 16,489 20.90% $28,826 Retail trade 9,987 12.70% $17,284 Transportation and warehousing, and utilities 8,299 10.50% $28,288 Professional, scientific, and management, and administrative and waste management services 7,493 9.50% $21,771 Arts, entertainment, and recreation, and accommodation and food services 7,384 9.40% $14,657 Employment Status # % Employed 78,721 49.9% Unemployed 11,584 7.3% Not in labor force 67,504 42.7% 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 39 of 53 Manufacturing 7,217 9.20% $28,514 Construction 5,921 7.50% $29,232 Other services, except public administration 4,800 6.10% $20,300 Public administration 3,760 4.80% $39,638 Finance and insurance, and real estate and rental and leasing 3,312 4.20% $31,350 Wholesale trade 2,762 3.50% $27,965 Agriculture, forestry, fishing and hunting, and mining 708 0.90% $23,050 Information 589 0.70% $31,027 Table 21: Workforce by Industry Source: 2013-2017 ACS 5-Year Estimates 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 40 of 53 E. Homeless Homelessness is attributable to challenges resulting from the loss of employment, difficulty finding jobs, the need to develop or redevelop marketable skills, the cost of housing, chronic health problems, physical disabilities, mental health disabilities, drug and alcohol addiction, and/or a host of other factors. Individuals or families that are homeless have a variety of special needs, including emergency shelter, counseling, job training, transitional housing, and permanent supportive housing. The San Bernardino County Point in Time Count and Subpopulation Survey for 2019 documented 890 homeless individuals in the City of San Bernardino. Based on the County’s 2018 survey, the homeless population in the City increased by 37.8 percent. Table 22 summarizes the information available for 2019. 2019 Homeless Count Sheltered Unsheltered Living in Transitional Housing Total 123 639 128 890 Table 22: Homeless Count Source: 2019 San Bernardino County Point in Time Count and Subpopulation Survey The San Bernardino County Homeless Survey provides more detail about the County’s homeless population. Although the information does not break out information for the City, those who live in the City are included in the County’s total numbers. When unsheltered homeless persons were asked how long they have been homeless, 59 percent responded “1 to 5 years.” Most homeless persons were male (71 percent). Veterans were 8 percent of those surveyed. Approximately 20 percent surveyed self-reported life-threatening chronic health conditions, such as heart, lung, liver, kidney, or cancerous disease. HUD reports on homeless household types in the County of San Bernardino in its 2018 Continuum of Care Homeless Assistance Program’s Homeless Populations and Subpopulations data. Nearly 10 percent of homeless households in the County include children. Among those households with children, most take shelter in emergency facilities or transitional housing. Table 23 summarizes this data. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 41 of 53 Homeless Populations by Type Reported in the County and City of San Bernardino Emergency Shelter Transitional Housing Unsheltered Total Households without children 109 127 1,336 1,572 Households with at least one adult and one child 65 59 29 153 Households with only children 3 0 4 7 Total Homeless Households 177 186 1,369 1,732 Table 23: Homeless Populations Source: HUD 2018 Continuum of Care Homeless Assistance Program Homeless Populations and Subpopulations F. Public Transit and Train Services The City and surrounding County are served by the San Bernardino County Transportation Authority (SBCTA). SBCTA distributes many of the funds for public transit service in the area and is responsible for oversight of all transit service throughout the County. The County is currently served by seven operators for public transit, and SBCTA funds all these operators except for the Foothill Transit Authority. The SBCTA funds various bus operators in the area, as well as rail and rideshare services. The SBCTA funds five bus operators, with the largest being Omnitrans, which provides about 13 million passenger trips per year on local and express routes, SBX rapid transit services, and paratransit services. Omnitrans serves 15 cities and seven unincorporated areas of the County. In addition, SBCTA also funds Morongo Basin Transit Authority, Mountain Transit, Victor Valley Transit Authority, and Needles Area Transit to help bolster bus services for the region. The City and surrounding County has rail services which are partly funded by SBCTA and provided by Metrolink, which provides rail service to transportation commissions in the counties of Los Angeles, Orange, Riverside, Ventura, and San Bernardino. Metrolink is governed by the Southern California Regional Rail Authority (SCRRA). These rail services operate on seven routes on a 536-mile network which also touches parts of San Diego County. In addition to the City’s services through Metrolink, the Redlands Regional Rail Project is currently in the construction phase and will bring more options to the City. It is a 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 42 of 53 new, 9-mile advances regional rail project that will connect residents, business, and visitors to many destinations in the area, and will also work to integrate itself into surrounding systems of other modes including auto, bus, and bicycle. Along with the funded bus services and rail services, the SBCTA also funds a newly devised rideshare/vanpool program for the City. This program is in partnership with the Riverside County Transportation Commission (RCTC), and offers residents incentives, rewards, and free rideshare program support to employers in order to encourage reduced single occupancy vehicle trips and help reduce traffic for the area. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 43 of 53 Chapter 4: Lending Practices Lending practices are a contributing factor to fair housing choice. An important element of fair housing choice is equity in money lending from financial service organizations. Such organizations include credit unions, banks, credit card companies, and insurance companies. Lending is often required for the access to credit financing for mortgages, home equity, and home repair loans. Access to information regarding financial services is also a concern involving equality. Gaps in financial services can make residents vulnerable to these types of predatory lending practices, and lack of access to quality banking and financial services may jeopardize an individual’s credit and the overall sustainability of homeownership and wealth accumulation. This chapter reviews lending practices of financial institutions and financing allowed to all households but with an emphasis on lending to minority and low -income households. However, a jurisdiction’s control over lending is limited due to federal laws and regulations. A. Laws Governing Lending Historically, lending practices of financial institutions prevented minority groups from equal access to credit. Such practices included credit market distortions and redlining. These barriers contributed to segregated neighborhoods that persist in cities today. This section reviews the lending practices of financial institutions and the access to financing for all households and neighborhoods. Fair Housing Act The passage of the FHA in 1968 sought to end discrimination against protected classes in all aspects of residential real estate-related transactions, including mortgage lending. Under the FHA, a lender may not discriminate against a protected class in any aspect of mortgage lending, such as failure to provide information or services, selectively encouraging or discouraging applicants, varying the terms of credit offered, as well as refusing to extend credit. Further, the FHA requires lenders to make reasonable accommodations for persons with disabilities when such accommodations are necessary to offer equal opportunities to apply for credit. Equal Credit Opportunity Act The Equal Credit Opportunity Act passed in 1974 makes it unlawful for any creditor to discriminate against any applicant, with respect to any aspect of a credit transaction, on the basis of race, color, religion, national origin, sex, marital status, age, or the applicant’s receipt of income derived from any public assistan ce program. The law applies to any person who, in the ordinary course of business, 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 44 of 53 regularly participates in a credit decision, including banks, retailers, bankcard companies, finance companies, and credit unions. Community Reinvestment Act The passage of the Community Reinvestment Ac t (CRA) in 1977 was designed to improve access to credit for all members of the community, including very low - and low-income persons and neighborhoods. In particular, the CRA counteracted redlining, or the historical practice by which banks and other financial institutions would not provide loans to lower-income neighborhoods. Under the CRA, federal regulators assess banks’ and other financial institutions’ performances in addressing the needs of all community members and neighborhoods. Banks and financial institutions are given a score of Outstanding, Satisfactory, Needs Improvement, or Substantially Noncompliant, which are published publicly. Subsequently, Congress enacted the Home Mortgage Disclosure Act (discussed in further detail below) in 1975 to require financial institutions to make annual public disclosures of their home mortgage lending activity, including the disposition of loan applicants by income, gender, and race. Banking Regulators for the CRA Three federal banking agencies, or regulators, are responsible for the CRA. Banks that have CRA obligations are supervised by one of these three regulators. Each regulator has a dedicated CRA site that provides information about the banks they oversee and those banks' CRA ratings and Performance Evaluations. Regulators are as follows:  Federal Deposit Insurance Corporation (FDIC)  Federal Reserve Board (FRB)  Office of the Comptroller of the Currency (OCC) Federal Reserve’s Role The Federal Reserve supervises state member banks or state-chartered banks that have applied for and been accepted to be part of the Federal Reserve System--for CRA compliance. To carry out its role, the Federal Reserve must:  Examine state member banks to evaluate and rate their performance under the CRA;  Consider banks' CRA performance in context with other supervisory information when analyzing applications for mergers, acquisitions, and branch openings; and  Share information about community development techniques with bankers and the public. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 45 of 53 Financial Stability Act The Financial Stability Act of 2009 established the Making Home Affordable Program, which assists eligible homeowners who can no longer afford their home with mortgage loan modifications and other options, including short sale or deed-in-lieu of foreclosure. The program is targeted toward homeowners facing foreclosure and homeowners who are unemployed or “underwater” (i.e., homeowners who owe more on their mortgage than their home is worth). Helping Families Save Their Homes Act The Helping Families Save Their Homes Act was passed by Congress in May 2009 and expands the Making Home Affordable Program. This act includes provisions to make mortgage-assistance and foreclosure-prevention services more accessible to homeowners and increases protections for renters living in foreclosed homes. It also establishes the right of a homeowner to know who owns their mortgage and provides more than two billion dollars in funds to address homelessness. Under this bill, tenants also have the right to stay in their homes after foreclosure for 90 days or through the term of their lease. B. Conventional Loans Versus Government-Backed Loans Conventional financing is market-rate-priced loans provided by private lending institutions such as banks, mortgage companies, and savings and loans. To assist households that may have difficulty in obtaining home mortgage financing in the private market due to income and equity issues, several government agenc ies offer loan products that have below-market interest rates and are insured (or underwritten) by the agencies. Sources of government-backed financing include loans insured or underwritten by the Federal Housing Administration (FHA-insured), the Department of Veterans Affairs (VA-guaranteed), and the Farm Service Agency or Rural Housing Services (FHS/RHS). Often, these types of loans are offered to the consumer through private lending institutions and make the difference in qualifying or not qualifying for a mortgage. Table 24 summarizes the disposition of home loan applications submitted to financial institutions in 2008, 2013, and 2018 for purchase in the City. Despite a dip in applications in 2013, the total number of applicants rose from 5,068 in 2008 to 6,335 in 2018. The increase in applicants is mainly attributable to a jump in the number of people applying for government-backed loans. Government-backed loans generally have more lenient credit score requirements, lower down payment requirements, and are available to those with recent bankruptcies. However, these loans may also carry higher interest rates and require most homebuyers to purchase mortgage insurance. Furthermore, government- 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 46 of 53 backed loans have strict limits on the amount the homebuyer can borrow for the purchase of the home. Federal Housing Administration Loans from the Federal Housing Administration (FHA) loans have helped people become homeowners since 1934. The Federal Housing Administration (FHA) - which is part of HUD - insures the loan so that lenders can offer borrowers a better deal. Advantages of FHA include:  Low down payments  Low closing costs  Easy credit qualifying Veterans Administration (VA) Home Loans VA loans help current and former service members, veterans, and eli gible surviving spouses become homeowners. As part of their mission they provide a home loan guaranty benefit and other housing-related programs to help buy, build, repair, retain, or adapt a home for personal occupancy. VA Home Loans are provided by private lenders, such as banks and mortgage companies. VA guarantees a portion of the loan, enabling the lender to provide more favorable terms. Rural Housing Services/Farm Service Agency (RHA/FSA) FSA/RHS-guaranteed USDA’s Rural Housing Service offers a variety of programs to build or improve housing and essential community facilities in rural areas. They provide loans, grants and loan guarantees for single- and multi-family housing, childcare centers, fire and police stations, hospitals, libraries, nursing homes, schools, first responder vehicles and equipment, housing for farm laborers. The RHS/FSA also provides technical assistance, loans and grants in partnership with non-profit organizations, Indian tribes, state and federal government agencies, and local communities. Conventional Loan A conventional loan is a mortgage that is not sponsored by government but is available through a private lender. Conventional loans comprise most mortgages issued. Some conventional loans must meet the requirements of Fannie Mae and Freddie Mac, the two largest buyers of mortgage loans in the United States. Studies of conventional loans in HMDA data have shown that commercial banks and thrift institutions lend less to areas (or tracts) that are low -income and predominantly minority concentrated. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 47 of 53 Over 75% of the community is Hispanic, as are most of the home purchase loans and a large majority of loans in the City are conventional bank loans. Studies have also shown that a substantial portion of home purchase loans extended in predominantly minority middle-income areas are government-backed, while a similar pattern does not hold for white neighborhoods with similar incomes. Such practices have the potential to constitute discrimination and are known as redlining. The practice of redlining is a barrier to fair housing. However, in the case of the City, over 75% of the community is Hispanic, as are most of the home purchase loans and a large majority of loans in the City are conventional bank loans. Disposition of Home Loans (2008, 2013, and 2018) Loan Type Total Applicants Percentage of Total 2008 2013 2018 2008 2013 2018 Government- Backed Loans (FHA, VA, FSA/RHS) 1,909 1,995 3,174 37.6% 57% 49.9% Conventional 3,159 1,504 3,161 62.4% 43% 50.1% Total 5,068 3,499 6,335 100% 100% 100% Table 24: Disposition of Home Loans Source: www.lendingpattern.com, 2008, 2013, and 2018 C. Home Mortgage Disclosure Act and Data Analysis The Home Mortgage Disclosure Act (HMDA) was enacted by Congress in 1975 and is implemented by the Consumer Financial Protection Bureau under Regulation C (12 CFR Section 1003). This regulation provides the public loan data that can be used to assist:  In determining whether financial institutions are serving the housing needs of their communities;  Public officials in distributing public-sector investments to attract private investment to areas where it is needed;  In identifying possible discrimination lending patterns. Under the HMDA, lenders are required to disclose information on the disposition of home loan applications and on race, national origin, gender, and annual income of loan applicants. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 48 of 53 As described above, the FHA prohibits discrimination in mortgage lending based on race, color, national origin, religion, sex, familial status , or disability. It is, therefore, important to look not just at overall approval and denial rates for a jurisdiction, but also whether these rates vary by other factors, such as race/ethnicity. Table 25 presents data provided via the Home Mortgage Disclosure Act by race and ethnicity. In 2018, there were 6,335 applications in the City and 67.9 percent were approved. The following action rates are notable.  Hispanic applicants submitted the most applications, which corresponds to their percentage of the overall population  Black or African American applicants experienced the highest rate of other actions, meaning that Black or African American applicants either withdrew, submitted incomplete applications, or had loans purchased  Native Hawaiian or Other Pacific Islander applicants had the highest denial rate Mortgage Approvals by Race/Ethnicity, 2018 Total Number of Applications Percent of Total Applications Action Type Approved (a) Denied (b) Other (c) Non-Hispanic American Indian 7 0.1% 71.4% 14.3% 14.3% Asian 201 3.2% 64.8% 10.8% 24.3% Black or African American 398 6.3% 62.1% 10.7% 27.2% Native Hawaiian or Other Pacific Islander 23 0.4% 63.6% 27.3% 9.1% White 1,076 17.0% 71.5% 9.6% 18.9% Multi-Race 47 0.7% 64.2% 11.9% 23.8% Information Not Provided 1,292 20.4% 65.1% 11.1% 23.9% Hispanic 3,291 51.9% 68.2% 10.4% 21.4% Total 6,335 67.9% 9.1% 29.1% Table 25: Mortgage Approvals by Race/Ethnicity Source: www.lendingpattern.com, 2018 Notes: (a) includes loans originated, applications approved but not accepted, and preapproval requests approved but not accepted; (b) includes application denied by financial insti tution and preapproval request denied by financial institution; and (c) includes applications withdrawn by applicant, incomplete applications, and loans purchased by institution. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 49 of 53 While this analysis provides a more in-depth look at lending patterns, it does not conclusively explain any of the discrepancies observed. Aside from income, many other factors can contribute to the availability of financing, including credit history, the availability and amount of a down payment, and knowledge of the home buying process. HMDA data does not provide insight into these other factors. Table 26: Loan Type by Race Source: FFIEC Home Mortgage Disclosure Act Denials Total Applications (2018) Total # of Denials Overall Denial Rate 4,710 490 10.40% Table 27: Denials Source: 2018 National HMDA-LAR via the Federal Financial Institutions Examination Council Loan Type by Race Los Angeles-Long Beach-Glendale Area Applicant Race Conventional FHA-Insured VA- Guaranteed Total Applications # of applications # of applications # of applications # of applications American Indian or Alaska Native 1,472 368 228 2,068 Asian 16,324 1,238 760 18,322 Black or African American 6,920 3,037 2,490 12,447 Native Hawaiian or other Pacific Islander 1,001 208 181 1,390 White 101,697 27,624 11,760 141,081 Race not provided 40,165 15,359 7,042 62,566 Totals 167,579 47,834 22,461 237,874 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 50 of 53 Top Lenders Lender Name Total Approved Denied Withdrawn/ Closed # Market Share # % of Total # % of Total # % of Total Lakeview Loan Servicing, LLC 441 7.0% 1 0.2% - 0.0% 1 0.2% Mountain West Financial, Inc. 277 4.4% 182 65.7% 25 9.0% 70 25.3% Eagle Home Mortgage of California 264 4.2% 190 72.0% 23 8.7% 51 19.3% United Shore Financial Services, LLC 264 4.2% 200 75.8% 27 10.2% 37 14.0% Broker Solutions, Inc. 238 3.8% 157 66.0% 14 5.9% 67 28.2% Wells Fargo Bank, National Association 233 3.7% 48 20.6% 10 4.3% 7 3.0% Paramount Residential Mortgage Group, Inc. 192 3.0% 162 84.4% 15 7.8% 15 7.8% Golden Empire Mortgage, Inc. 161 2.5% 123 76.4% - 0.0% 38 23.6% PennyMac Loan Services, LLC 154 2.4% 2 1.3% 3 1.9% 2 1.3% Caliber Home Loans, Inc. 151 2.4% 77 51.0% 8 5.3% 26 17.2% Other Lenders (247) 3,960 62.5% 2,060 52.0% 365 9.2% 704 17.8% TOTAL 6,335 100% 3,202 50.5% 490 7.7% 1,018 16.1% Table 28: Top Lenders Source: Data from HMDA-LAR, published by individual lenders and or the Federal Financial Institutions Examination Council 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 51 of 53 Chapter 5: Public Policies Public policies, along with other factors, affect the development of housing. In turn, they impact the range and location of housing options available to residents. Fair housing laws, as described in Chapter 1, are intended to encourage an inclusive living environment and active community participation. An assessment of public policies and related practices help identify potential impediments to fair housing opportunity. This chapter provides an overview of public policies, regulations, standards, and practices including housing element law and compliance, land use, and the zoning ordinance. A. Housing Element Law and Compliance California housing element law requires that local governments adequately plan to meet the existing and projected housing needs of all economic segments of the community. For the private market to adequately address housing needs and demand, local governments must adopt land-use plans and regulatory systems that provide opportunities for and do not unduly constrain housing development. California housing element law requires each jurisdiction to:  Identify adequate sites which will be made available throug h appropriate zoning and development standards and with the services and facilities needed to facilitate and encourage the development of a variety of types of housing for all income levels in order to meet the city’s regional housing needs;  Assist in the development of adequate housing to meet the needs of extremely low-, very low-, low-, and moderate-income households;  Address and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing;  Conserve and improve the condition of the existing affordable housing stock ;  Promote housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability. The City’s current Housing Element was adopted on February 10, 2014 and was certified as compliant with State Law by the California Department of Housing and Community Development (HCD) on March 28, 2014. B. Land Use Element The Land Use Element of the City’s General Plan designates the general distribution, location, and extent of residential, commercial, industrial, public/quasi-public, and open space uses. Regarding housing, the Land Use Element establishes a range of nine residential land-use designations, specifies densities, and suggests the types of housing appropriate in a community. The Land Use Element is implemented through the Development Code, which establishes zones where residential uses are 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 52 of 53 permitted. Development density ranges from one unit per acre in single-family designations to 54 dwelling units per acre in the CR-2 zone. Table 29: Land Use and Zoning Source: City of San Bernardino General Plan, 2014 Residential Land Use Designations and Zoning Districts General Plan Land Use Designation Zoning District Primary Residential Type(s) Du/Ac Residential Estate RE Single-family detached in an estate setting 1 Residential Low RL Single-family detached in low-density setting 3.5 Residential Suburban RS Single-family detached in high quality suburban setting 4.5 Residential Urban RU Single/multi-family attached and detached residences 8 Residential Medium RU Multi-family dwellings, all types 12 Residential Medium High RMH Multi-family dwellings including apartments and condominiums 24 Residential High RMH Multi-family dwellings including apartments and condominiums 31 Commercial Regional CR-2 Vertical residential, retail, and office mixed use 47 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 53 of 53 C. Development Code The City’s existing Development Code regulates the type, location, density, and scale of residential development and exists to protect and promote the health, safety, and general welfare of residents. In addition, the Development Code serves to preserve the character and integrity of existing neighborhoods. Zoning & Provisions for Diversity Housing Types Residential uses are allowed in residential and some commercial districts. The City’s zoning permits a range of housing types, which is essential to providing a full range of housing choice. Table 30 lists all the unit types per property, exhibiting the di versity of housing available in the City of San Bernardino. Table 31 lists housing types allowable with approval of a Development Permit or Conditional Use Permit, permitted by -right, or prohibited. Table 30: Units Per Property Source: 2013-2017 ACS 5-Year Estimate Housing Types by Zone Housing Types RE RL RS RU RM RMH RH RSH CO CG- 2 CR- 2 Single-Family D D D D D D D X X X X Multi-Family X X X D1 D D D X X C C Condominium or Townhouse D D D D D D D X X X X Manufactured Housing D D D D D D D X X X X Mobile Home Park D D D D D D D X X X X Units Per Property Total Occupied Owners Renters Property Type Number % Number % Number % 1-unit detached structure 36,223 62.4% 23,395 86.2% 12,828 41.5 1-unit, attached structure 2,538 4.4% 501 1.8% 2,037 6.6 2 apartments 916 1.6% 41 0.2% 875 2.8 3 or 4 apartments 3,618 6.2% 233 0.9% 3,385 11.0 5 to 9 apartments 3,159 5.4% 52 0.2% 3,107 10.1 10 or more apartments 7,933 13.7% 85 0.3% 7,848 25.4 Mobile home or other type of housing 3,659 6.3% 2,830 10.4% 829 2.7 Total 58,046 100.0% 27,137 100.0% 30,909 100.0 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 54 of 53 or Subdivisions Second Unit P P P P P P P X X X X Senior Housing/ Congregate Care X X X D D D D X C C C Community Care Facility (≤ 6 persons) P P P P P P P X C C C Emergency Shelters2 X X X X C C C X X X C Transitional/Supporti ve Housing3 D D D D D D D X X C C Single Room Occupancy X X X X X X X X X C C Mixed Used X X X X X X X X X C C 1. Multi-Family units that legally existed in the RU zones prior to June 3, 1991 may remain as a permitted use without a Development Permit. 2. An Emergency Shelter overlay zone permits emergency shelters serving 60 or fewer persons nightly without discretionary review within designated areas of the Industrial Light (IL0), Commercial Heavy (CH), or Office Industrial Park (OIP) zones. 3. Transitional and permanent supportive housing will be permitted based on unit type like any other residential use. P = Permitted D = Development Permit C = Conditional Use Permit X = Prohibited Table 31:Housing Types by Zone Source: City of San Bernardino Development Code, 2014 Density Bonus In accordance with State Government Section 65915, Subsection D.2., to promote the development of affordable housing, the City provides for a housing density bonus of 25 percent for zones RU, RM, RMH, RH, CO-1 and 2, and CG-2. Parking The cost of parking can negatively impact construction of housing, particularly multi - family affordable housing. When land available is limited, parking structures are necessary for larger projects. As the number of required parking spaces increases, the development costs increase as well. The City recognizes these challenges and offers incentives, such as reduced parking standards within areas served by transit, to alleviate potential constraints to development. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 55 of 53 Parking Requirements Residential use Parking Spaces Required Mobile Homes 2 garage spaces per unit, tandem is permitted. 1 uncovered guest space per unit Residential Day Care 2 spaces in addition to those required by primary residence Senior Apartments 1 covered space for each unit and 1 uncovered guest space for every 5 units Senior Congregate Care 0.75 covered space per unit Single-family Dwelling 2 garage spaces per unit Second Unit 1 covered space per bedroom, may be in the side yard setback Student Housing 1 off-street parking space for each bedroom (65% covered) plus 3 uncovered off-street guest-parking spaces for 100 rooms Planned Residential Redevelopment Single- family dwellings and condominiums 2 garage spaces per unit. 1 uncovered guest space per unit, 1 uncovered guest space per 5 units Multi-Family Residential Studio 1 space per unit One Bedroom 1.5 covered spaces per units and 1 uncovered guest space per 5 units Two Bedrooms 2 covered spaces per unit and 1 uncovered guest space per 5 units Three or more Bedrooms 2.5 covered spaces per unit and 1 uncovered guest space per 5 units Senior Citizen Apartments 1 covered space per unit and 1 uncovered guest space per 5 units Table 32: Parking Requirements Source: City of San Bernardino Development Code, 2014 Definitions Local zoning definitions that should be consistent with Fair Housing Act include family, group home, assisted care facility, boarding homes, single-room occupancy, homeless shelters, second dwelling occupancy unit, and reasonable occupancy. California court cases have ruled that a definition of “family” that: 1) limits the number of persons in a family; 2) specifies how members of the family are related (i.e. by blood, marriage or adoption, etc.), or 3) a group of not more than a certain number of unrelated persons as a single housekeeping unit, is invalid. Court rulings stated that defining a family does not serve any legitimate or useful objective or purpose recognized under the zoning and land planning powers of the jurisdiction, 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 56 of 53 and therefore violates rights of privacy under the California Constitution. A Zoning Ordinance also cannot regulate residency by discrimination between biologically related and unrelated persons. Furthermore, a zoning provision cannot regulate or enforce the number of persons constituting a family. The City’s definition does not serve to impede housing choice. The City’s current “Family” definition is not overly restrictive. This definition was amended or “cured” of any discriminatory language in 2011. The current definition is as follows: “Family” means one or more persons living together in a dwelling unit, with common access to, and common use of all living, kitchen and eating areas within the dwelling unit. Currently the current zoning ordinance does not provide for group homes except when it refers to senior living homes or congregate care housing. The current zoning ordinance does not include group homes, boarding homes or single room occupancy uses. Affordable housing comes in many forms, the City should revise its zoning to include such uses in accordance with the Fair Housing Act as amended. Shelters are permitted within the Emergency Shelter Overlay District which is located across industrial districts. These districts do not provide any services needed for homeless populations including mental and physical health care facilities, transitional housing, childcare, public housing, substance abuse clinics, schools, and grocery and pharmacy stores. Hoarding and other Intellectual Disabilities. The City does regulate reasonable accommodations through, Chapter 19.63 Reasonable Accommodations which establishes a procedure for an individual with a disability seeking equal access to housing to request reasona ble accommodation as provided by the Federal Fair Housing Amendments Act of 1988 and the California Fair Employment and Housing act. Fair Housing laws may protect people with disabilities who unintendedly violate nuisance laws, such as those pertaining to garbage and rubbish. For example, mental health professionals have identified Compulsive Hoarding Syndrome as a disorder that involves the accumulation of belongings to such an extent that the resulting clutter renders parts of the living space unusable. Symptoms include:  The acquisition and failure to discard a large number of items/possession that are considered by most to be of little or no value  These possessions clutter the living space, rendering the space unable to be used in the way it was intended  The hoarding behavior causes marked distress or interferes with one’s daily functioning 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 57 of 53 An individual who engages in hoarding might run afoul of the measures regarding garbage and rubbish disposal and will be subject to Chapter 15.24 Property Maintenance Requirements. Conditions constituting property nuisances someone with Compulsive Hoarding Syndrome may need a reasonable accommodation (i.e. additional time to comply with the order to abate the nuisance or information regarding community resources to assist with the cleanup) to meet City standards. Additionally, persons with physical disabilities who cannot sustain long periods of strenuous activity might need additional time to comply. While the right to a reasonable accommodation is available to persons with disabilities under existing fair housing laws, it would be helpful to explicitly state within this code section that persons with disabilities may request an accommodation as needed which will be evaluated by the appropriate agency. Such accommodation should include relief from any penalties assessed pursuant to a finding of a nuisance or other violation. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 58 of 53 Chapter 6: Fair Housing Profile This section provides information on the institutional structure of the homeownership and rental markets in the City of San Bernardino. It also includes local, state, and federal data on fair housing complaints. A. Fair Housing Practices in the Homeownership Market This section analyzes potential impediments to fair housing in homeownership. Advertising Advertising is usually the first consideration for potential buyers. Often times, advertisements for homes for sale include discriminatory language. This includes advertising amenities not included in the home itself such as proximity to schools, type of residents nearby, and location of churches and other institutions. L anguage like this may indicate a preference for certain types of people, such as families or people of a certain religion, and can be discriminatory. Potentially Discriminatory Language in Listings of For-Sale Homes Discrimination Type Number of Listings Potentially Discriminatory Language No Discriminatory Language 25 There was no discriminatory language Income Related 0 Household Size/ Family Related 0 Disability Related 0 Table 33: Discriminatory Language in For-Sale Homes Listings Source: www.trulia.com, www.zillow.com, www.realtor.com, www.craigslist.com, accessed February 10, 2020 Lending Lending institutions determine if a potential buyer will qualify for a loan. As part of the lending process, applicants are asked to provide information such as gender, race, and income, which is then used for reporting required by the Home Mortgage Disclosure Act and the Community Reinvestment Act. However, this information may be used to discriminate during the application process. Credit Scores Credit histories are significant factors in lending institutions approvin g home loans. Applicants with higher scores are more likely to be given conventional loans while applicants with lower scores are more likely to receive FHA or government-backed loans and pay higher interest rates. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 59 of 53 Real Estate Agents Real estate agents may unintentionally discriminate by directing potential buyers to certain neighborhoods, known as steering, or by being selective in who they represent. In California, a broker or salesperson must be licensed by the California Bureau of Real Estate (CalBRE) in order to conduct business in the field of real estate. The CalBRE also enforces violations of California real estate law. In San Bernardino, housing discrimination or other fair housing violations related to the sale of real property are reported to the CalBRE for investigation. The real estate industry in California is highly professionalized. Almost all real estate brokers and salespersons are affiliated with a real estate trade association. The two largest are the California Association of Realtors (CAR), associated with the National Association of Realtors (NAR), and the California Association of Real Estate Brokers (CAREB), associated with the National Association of Real Estate Brokers (NAREB). The use of the term “Realtor” is restricted by NAR as a registered trademark. Members of NAREB are licensed to use the professional designation “Realtor.” NAR has a professional code of conduct that specifically prohibits unequal treatment in professional services or employment practices on the basis of “race, color, religion, sex, handicap, familial status, or national origin” (Article 10, NAR Code of Ethics). Both prohibit members from promulgating deed restrictions or covenants based on race. Article 10 of the NAR Code of Ethics provides that “Realtors shall not deny equal professional services to any person for reasons of race, color, religion, sex, handicap, familial status, or national origin. Realtors shall not be a party to any plan or agreement to discriminate against any person or persons on the basis of race, color, religion, sex, handicap, familial status, or national origin.” A Realtor pledges to conduct business in keeping with the spirit and letter of the Code of Ethics. Article 10 imposes obligations upon Realtors and is also a firm statement of support for equal opportunity in housing. A Realtor who suspects discrimination is instructed to call the local Board of Realtors. Local Boards of Realtors will accept complaints alleging violations of the Code of Ethics filed by a home seeker who alleges discriminatory treatment in the availability, purchase, or rental of housing. Local Boards of Realtors have a responsibility to enforce the Code of Ethics through professional standards, procedures, and corrective action in cases where a violation of the Code of Ethics is proven to have occurred. The California Association of Realtors (CAR) has many local associations throughout the state. San Bernardino is served by the Inland Valley Association of Realtors. It is the mission of the Inland Valley Association of Realtors to provide members with 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 60 of 53 education and resources that will enable them to conduct business successfully, to promote and enforce professional and ethical standards, and to strengthen the Realtor image by improving the quality of life in the communities they serve, promoting equal housing opportunity, and protecting and preserving private property rights. CAR offers continuous online courses dealing with fair housing requirements and issues. Part of the license renewal requirements for all sales agents and brokers is continuous education on fair housing laws and regulations. According to the course description, the course will provide an overview of the federal fair housing laws and an in-depth discussion of the individual laws and their application to the practice of real estate. The course also provides CAR members with a study of the State of California fair housing laws and regulations. The course emphasizes anti- discriminatory conduct that all licensees should practice and concludes by discussing the voluntary affirmative action marketing program and why promoting fair housing laws is a positive force at work in California and throughout the nation. NAREB follows a strict code of ethics stating that “any Realtor shall not discriminate against any person because of Race, Color, Religion, Sex, National Origin, Disability, Familial Status or Sexual Orientation” (Part I, Section 2, NAREB Code of Ethics):  In the sale or rental of real property;  In advertising the sale or rental of real property;  In the financing of real property;  In the provision of professional services. Part I, Section 2 of the NAREB Code of Ethics continues, stating that any “Realtor shall not be instrumental in establishing, reinforcing or extending any agreement or provision that restricts or limits the use or occupancy of real property to any person or group of persons on the basis of race, color, religion, sex, national origin, disability, familial status, or sexual orientation.” NAREB’s California Chapter offers statewide conferences to educate its members. The most recent conference was held in October 2019: Democracy in Housing. NAREB’s local chapter called Inland Empire Association of Realtors serves the San Bernardino area. B. Fair Housing Practices in the Rental Housing Market This section analyzes potential impediments to fair housing in renting. Advertising Advertising is also the first consideration for a potential renter. Discriminatory language includes listings expressing a preference for families, students, or single individuals and references to the allowance of pets. Language like this may indicate 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 61 of 53 a preference for certain types of people while also excluding people who may need a guide dog or emotional -support animal. Potential renters may also face discrimination when responding to ads or viewing a unit based on their perceived race and social class. Potentially Discriminatory Language in Rental Listings Discrimination Type Number of Listings Potentially Discriminatory Language No Discriminatory Language 18 Income Related 3 “Must make 3x the monthly rent, pass criminal background check, no bankruptcies or lease breaks” “For the quickest response, have a 650 FICO or higher” “Need to make 2 and a half times the rent, proof of income, no evictions, no felonies” Disability Related 4 “No pets allowed” “Sorry, no pets” “No pets” (x2) Household Size/ Family Related 0 Table 34: Discriminatory Language in Rental Listings Source: www.trulia.com, www.zillow.com, www.realtor.com, www.craigslist.com, accessed February 10, 2020 California Apartment Association The California Apartment Association (CAA) is the country’s largest statewide trade association for rental property owners and managers. CAA was incorporated in 1941 to serve rental property owners and managers throughout California. CAA represents rental housing owners and professionals who together manage more than 1.5 million rental units. CAA has a local association called CAA-Greater Inland Empire that services the counties of Imperial, Riverside, and San Bernardino. CAA supports the spirit and intent of all local, state, and federal fair housing laws for all residents without regard to color, race, religion, sex, marital status, mental or physical disability, age, familial status, sexual orientation, or national origin. Members of the California Apartment Association agree to abide by the following provisions of their Code for Equal Housing Opportunity:  We agree that in the rental, lease, sale, purchase, or exchange of real property, owners and their employees have the responsibility to offer housing accommodations to all persons on an equal basis; 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 62 of 53  We agree to set and implement fair and reasonable rental housing rules and guidelines and will provide equal and consistent services throughout our resident’s tenancy;  We agree that we have no right or responsibility to volunteer information regarding the racial, creed, or ethnic composition of any neighborhood, and we do not engage in any behavior or action that would result in steering; and  We agree not to print, display, or circulate any statement or advertisement that indicates any preference, limitations, or discrimination in the rental or sale of housing. CAA provides members with tenant screening services, application forms, and other types of landlord-tenant forms, which if used by CAA members provide legal procedures for processing rental applications and resolving tenant issues. Further, should landlords stay within these guidelines, they will likely avoid committing housing violations. CAA offers a landlord helpline where landlords can call and speak to an attorney about their responsibilities. Lastly, all members receive a fair housing flyer to post at their properties stating that it is illegal to discriminate based on the protected classes. When CAA receives complaints about potential fair housing violations, the association provides tenants with information on their rights and then refers them to the California Department of Fair Employment and Housing to file a claim. CAA offers a certificate in residential management, which requires a course on fair housing law. In addition, the CAA website provides links to the Fair Housing Institute and Fair Housing Network. Members receive CAA Issue Insight, an online publication that provides in-depth discussion of fair housing or landlord-tenant issues. CAA offers training opportunities across the state and in the Inland Empire. CAA has a landlord helpline open Monday through Friday where landlords can ask questions about landlord-tenant issues and property management. Questions can be submitted online or over the phone. CAA also provides free forms online to its members, such as rental applications and lease agreements. CAA provides fair housing information to renters at outreach events. C. Fair Housing Services and Statistics Patterns of complaints and enforcement are useful when assessing the nature and level of potentially unfair or discriminatory housing practices in the private sector. Several public and private agencies may receive complaints about unfair housi ng practices or housing discrimination. At the federal level, the Office of Fair Housing and Equal Opportunity (FHEO) of the U.S. Department of Housing and Urban Development receives complaints of housing discrimination. FHEO will attempt to resolve matters informally. FHEO may act on 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 63 of 53 those complaints if they represent a violation of federal law and FHEO finds that there is “reasonable cause” to pursue administrative action in federal court. At the state level, the Department of Fair Employment and Housi ng (DFEH) has a similar role to FHEO. DFEH also receives, investigates, attempts to settle, and can take administrative action to prosecute violations of the law. FHEO and DFEH have some overlap in jurisdiction and depending on the nature of the case, may refer cases to one another. DFEH is a HUD Fair Housing Assistance Program (FHAP) grantee, meaning that it receives funding from HUD to enforce federal fair housing law in the state. U.S. Department of Housing and Urban Development, Office of Fair Housing, and Equal Opportunity (HUD) From 2015 to 2016, 114 fair housing discrimination cases in the County of San Bernardino were forwarded to the Office of Fair Housing and Equal Opportunity. The table below presents the bases for the cases forwarded. Disability was included as a basis for complaint in 51.8 percent of cases. Race followed at 22 percent. HUD Basis for Complaint # Percent Race 25 22% Black or African American 21 18.4% Native American 2 1.8% White 1 0.9% Color 1 0.9% National Origin 12 10.5% Hispanic Origin 11 9.6% Disability 59 51.8% Religion 3 2.6% Sex 10 8.8% Retaliation 15 13.2% Familial Status 17 14.9% Table 35: HUD Fair Housing Complaints Source: 2019 HUD Note: Complaints may be made on multiple bases. Therefore, the percentages do not total 100 percent. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 64 of 53 California Department of Fair Employment and Housing (DFEH) From 2015 to 2019, 16 fair housing discrimination cases in the City of San Bernardino were forwarded to the California Department of Fair Employment and Housing. The table below presents the bases for the cases forwarded. DFEH Basis for Complaint # Percent Race 3 18.8% National Origin 3 18.8% Disability 4 25.0% Religion 1 6.3% Familial Status 1 6.3% Marital Status 1 6.3% Source of Income 1 6.3% Sexual Orientation 2 12.5% Table 36: DFEH Basis for Complaint Source: 2019 California Department of Fair Employment and Housing Inland Fair Housing and Mediation Board The Inland Fair Housing and Mediation Board (IFHMB) is a nonprofit, public benefit corporation that has served San Bernardino County and parts of Riverside and Imperial Counties in Southern California since 1980. IFHMB’s services are provided to the community free of charge and are funded through the U.S. Department of Housing and Urban Development’s Community Development Block Grant (CDBG) program provided by the City of San Bernardino and the County of San Bernardino. The purpose of IFHMB is to ensure that all members of the community have equal access to safe, affordable housing and to eliminate discrimination in housing. IFHMB headquarters is in Ontario and has satellite offices in San Bernardino, Victorville, Indio, and El Centro. IFHMB provides numerous services including:  Information, investigation, education, and conciliation and/or referrals of housing discrimination complaints  Fair housing workshops to educate housing providers, tenants, homeowners, and financial and lending institutions  Information to tenants, landlords, mobile home park owners, and mobile home residents on their rights and responsibilities  Mediation as an alternative to resolve housing issues for tenants, property management, and owners. From 2018 to 2019 the number of clients served in San Bernardino are broken into two cl assifications: 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 65 of 53  Fair Housing clients – 143 households and 394 persons assisted  Landlord/Tenant clients – 758 Households and 2,363 persons assisted A large majority of the clients were Latino (1,119 persons and 304 households) and African American (757 persons and 273 households). Most discrimination complaints were because of disability followed by race. Eviction , housing repair needs, and tenant rights were the most common housing issues. In 2018-2019 IFHMB prepared fair housing literature (7,448 brochures distributed), conducted several fair housing workshops (330 persons attended14 regional workshops), and paid for cable television promotion (23 cable releases). Persons Served 2018-2019 Discrimination Cases Extremely Low Income Very Low Income Low Income Moderate Income TOTAL Fair Housing 262 70 57 5 394 Landlord/Tennant 1380 506 388 89 2,363 Persons with Disabilities Discrimination Cases Female-Headed households Seniors Persons with disabilities Persons w/disabilities (households & Persons) 341 305 535 Table 37: IFHMB Persons Served 2018-2019 Source: Inland Fair Housing and Mediation Board, 2018-2019 San Bernardino annual report Hate Crimes Hate crimes are committed based on a bias against gender, mental disability, physical disability, race, religion, or sexual orientation. The table below shows that there were 35 hate crimes reported within the City in the past five years. Twenty-four (68.6 percent) hate crimes were motivated by race or ethnicity and 1 1 (31.4 percent) were motivated by sexual orientation. Reported hate crimes represent less than 1% of all crimes over this 5-year period. Hate Crimes Reported Gender Mental Disability Physical Disability Racial Religion Sexual Orientation 2015 0 0 0 3 0 1 2016 0 0 0 7 0 1 2017 0 0 0 6 0 5 2018 0 0 0 4 0 0 2019 0 0 0 4 0 4 Total 0 0 0 24 0 11 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 66 of 53 Since 2015, overall crime has decreased by 8.6 percent. Table 38: Hate Crimes Reported Source: San Bernardino Police Department, 2015-2019 Overall, crime has decreased in the City since 2015, with some small yearly increases in- between. Since 2015, overall crime has decreased by 8.6 percent. There were 13,087 crimes reported by the San Bernardino Police Department in 2015 and just 11,955 reported in 2019. The decrease in overall crime is mostly due to a decrease in property crime (-12.6 percent), however, violent crime has increased by 6.6 percent since 2015. Crime Year Violent Crime Property Crime Total Crime Percent Change from Previous Year 2019 2,874 9,081 11,955 0.20% 2018 2,906 9,014 11,931 6.34% 2017 2,806 8,403 11,209 (7.03%) 2016 2,878 9,178 12,056 (7.88%) 2015 2,697 10,390 13,087 N/A Table 39: Crime in the City of San Bernardino Source: San Bernardino Police Department, 2015-2019 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 67 of 53 Chapter 7: Fair Housing Progress G. Impediment: Housing Discrimination The previous AI identified that discriminatory practices by landlords continue within the City and that discrimination against persons with disabilities increased. Action Item 1.1: The City should continue its outreach efforts through its fair housing service provider to educate landlords and tenants regarding fair housing rights and responsibilities. Random audits should be conducted periodically to identify problem properties and implement reconciliation efforts. Efforts: The City continues to fund the IFHMB to provide landlord/tenant and mobile home mediation/housing counseling, alternative dispute resolution, and senior services to City residents. IFHMB also refers housing discrimination complaints to the City. During FY 2018-2019, 2,757 City residents were served. Additionally, IFHMB provides local housing provider groups, rental property owners, community agencies, and the public with education and outreach on housing rights and responsibilities. Under the FY 2020-21 contract with IFHMB the City will contract for:  Landlord workshops, specifically around the new rent cap law, but also to highlight fair housing practices. H. Impediment: Public Policies and Programs Affecting Housing Development The previous AI identified that a lack of affordable housing disproportionately affected minority households; there was a need for diversity training for City staff who interacted with the public; housing discrimination was more prevalent for renter households; elderly households may be less able to make critical improvements to their housing; large households found it difficult to find adequately sized , affordable housing; persons with disabilities faced a greater amount of housing discrimination; the City does not define supportive housing development; and that San Bernardino Development code did not comply with State density bonus law. Action Item 2.1: The City should continue to encourage the development of affordable housing through: (1) streamlined permit processing; (2) flexibility in applying design and development standards; (3) density bonuses; (4) other general plan, administrative and zoning efforts; and (5) public-private partnerships with developers of affordable housing. The City should continue to offe r housing rehabilitation assistance to HOME and CDBG eligible households and ensure affirmative marketing efforts are extended to minority households to encourage participation in City programs. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 68 of 53 Efforts: In FY 2018-2019, the City sold three newly built homes for households at 80 percent AMI. The City is developing a general lot consolidation incentive that offers a 15 percent density bonus for projects with a residential component, maintenance plan, and on-site management The City also developed a streamlined process for certain projects subject to a Conditional Use Permit through what is called a Minor Use Permit, which requires less staff time and has lower fees. In FY 2018-2019, the City improved its Notice of Funding Availability application and held public meetings to explain the application process. Action Item 2.2: The City should require that staff members in each department, specifically those who interact with the public, attend cultural diversity training periodically but at a minimum at time of employment. Efforts: The City offers two cultural diversity training sessions per year that are open to all City staff. Cultural diversity training is not currently required for any staff and the City does not track which staff members attend the training sessions. Action Item 2.3: Homeownership is particularly important as a vehicle for providing decent housing for working families. In cooperation with lending institutions, local associations of realtors, and fair housing providers, the City should provide outreach to inform lower-income households of special local, state, and federal homebuyer assistance programs. Efforts: The City partners with IFHMB and Neighborhood Partnerships Housing Services Inc. to provide first-time homebuyer workshops as well as default/foreclosure prevention counseling, reverse mortgage counseling, and financial education workshops. Action Item 2.4: The City should continue its efforts to expand the variety of available housing types and sizes. In addition to persons with disabilities, senior households can also benefit from a wider range of housing options. To allow seniors to age in place, small one-story homes, townhomes, or condominiums may be needed. Efforts: In FY 2018-2019, the City partnered with the County of San Bernardino and National Community Renaissance to redevelop the Waterman Gardens public housing project and construct a $79 million mixed-income affordable housing community of 184 units. The project received $20 million in Affordable Housing and Sustainable Communities (AHSC) funds and the City of San Bernardino contributed $2.5 million in HOME, CDBG and NSP1 to the project. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 69 of 53 In FY 2015-2016, the City partnered with National Community Renaissance to fund the construction Valencia Vista, a 76 unit affordable housing development that is part of the redevelopment of the Waterman Gardens public housing project. The City contribu ted $1.5 million in HOME funds to the development. Households served ranged in income from 30%, 50% and 80%. In FY 2016-17 The City again partnered with National Community Renaissance to fund the construction of Olive Meadow, a 62 -unit affordable housing development, which is also part of the redevelopment of the Waterman Gardens public housing project. The City contributed $734,000 in HOME funds. Households served range in income from 30%, 50% and 80%. Action Item 2.5: The City should continue its efforts to expand the variety of available housing types and sizes. Rental housing units of adequate size for large households should be encouraged as a large portion of the City’s large renter-households experience housing problems. Efforts: In FY 2018-2019, the City partnered with the County of San Bernardino and National Community Renaissance redevelop the Waterman Gardens public housing project and construct a $79 million mixed -income affordable housing community of 184 units. The project received $20 million in Affordable Housing and Sustainable Communities (AHSC) funds and the City of San Bernardino contributed $2.5 million in HOME, CDBG and NSP1 to the project. In FY 2016-2017, the City again partnered with National Community Renaissance to fund the construction of Olive Meadow, a 62 -unit affordable housing development, which is also part of the redevelopment of the Waterman Gardens public housing project. The City contributed $734,000 in HOME funds. Households served range in income from 30%, 50% and 80%. Action Item 2.6: The City should consider incentivizing or requiring universal design features in new construction or substantial rehabilitation of housing, especially projects that receive financial assistance from the City. Efforts: The City did not pursue this action item. Action Item 2.7: The City plans to amend its Development Code to define and permit transitional and supportive housing based on the unit type rather than the potential occupants. Efforts: The City is currently working on amending the Development Code to define transitional and permanent supportive housing in order to facilitate review and approval process of this housing type. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 70 of 53 Action Item 2.8: According to the City’s 2013-2021 Housing Element, the City commits to amending their density bonus provisions to comply with State law. Efforts: The City is currently working on amending the Development Code to comply with the amended State density bonus law. I. Impediment: Lending Practices The previous AI identified that the racial and ethnic composition of conventional home loans did not reflect the racial and ethnic composition of the City. It was also identified that white and Asian home loan applicants had the highest rate of approvals while black applicants had the lowest. Action Item 3.1: The City should expand outreach efforts to minority households, especially black households, to raise awareness of and education about homeownership opportunities. Efforts: The City partners with IFHMB and Neighborhood Partnerships Housing Services, Inc. to provide first-time homebuyer workshops as well as default/foreclosure prevention counseling, reverse mortgage counseling, and financial education workshops. As a requirement of HOME, rental projects consisting of five or more units must include and adhere to affirmative marketing procedures and requirements. The requirements include:  The City will continue to contract with IFHMB to inform the public, owner and tenants of fair housing laws;  In its monitoring/inspections of HOME assisted units, City staff reviews all marketing plans and a sample of tenant files to ensure that fair marketing practices are being followed. Owners and leasing agents will place advertisements to market HOME-assisted units through local sources, public agencies and social service organizations;  Description of outreach efforts to people not likely to apply for housing without special outreach is included in all City and County assisted housing developments;  Maintenance of records to document actions taken to affirmatively market HOME-assisted units and to assess marketing effectiveness; and  Description of actions that will be taken if requirements are not met. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 71 of 53 J. Impediment: Demographics The previous AI identified that the City had moderate levels of segregation between racial groups. It also found that a higher percent of renters (58 percent) were affected by cost burden when compared to all households (50 percent). Action Item 4.1: The City should continue to offer a range of housing options to allow the greatest residential mobility among its residents. The City should ensure developers and housing providers using local, state, and federal funds adhere to the Affirmative Fair Marketing Plan as required. Efforts: As a requirement of HOME, rental projects consisting of five or more units must include and adhere to affirmative marketing procedures and requirements. The requirements include:  List of methods to inform the public, owners and potential tenants about fair housing laws and the City’s marketing policy;  Description of the efforts that will be made to conduct affirmative market housing units assisted with HOME funds.  Owners and leasing agents will place advertisements to market HOME- assisted units through local sources, public agencies and social service organizations;  Description of outreach efforts to people not likely to apply for housing without special outreach. These efforts will include the distribution of marketing materials to organizations that likely have contact with these populations;  Maintenance of records to document actions taken to affirmatively market HOME-assisted units and to assess marketing effectiveness; and  Description of actions that will be taken if requirements are not met.” Action Item 4.2: The City should continue to promote economic development and expand its housing stock to accommodate a range of housing options and income levels. Efforts: The City has implemented an Infill Housing Program that constructs units on City-owned parcels to sell to low-income buyers. In FY 2018-2019, the City sold three newly built homes for households at 50 percent to 80 percent AMI. The City partners with Inland Empire Small Business Development Center, which holds eight-week intensive courses for new businesses and also for existing businesses I the City of San Bernardino. The City, as a requirement of federal funding, participates in outreach events for disadvantaged business enterprises (DBEs) and posts bid documents on the 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 72 of 53 City’s website. The City also encourages DBEs to bid on CDBG, HOME, and ESG construction contracts. The City partnered with the County of San Bernardino and National Community Renaissance to leverage $79 million for the construction of 184 mixed income units as part of the larger redevelopment of the Waterman Gardens public housing project. The City in partnership with National Community Renaissance has developed and approved the Waterman Gardens specific plan for the neighborhood around the Waterman Gardens public housing project. K. Impediment: Housing Market Conditions The previous AI identified that most of the City’s housing stock (67 percent) was more than 30 years old and may need rehabilitation, especially housing owned by seniors. Action Item 5.1: San Bernardino should continue operating their housing rehabilitation programs and increase efforts to promote the housing rehabilitation programs. Efforts: In FY 2018-2019, the City assisted in the acquisition and rehabilitation of a 38-unit apartment complex (Golden Apartments) for use as permanent supportive housing for homeless households. Golden Apartments opened for occupancy in December 2019. In the same year, the City rehabilitated seven homes through the Owner-Occupied Rehabilitation Loan Program (OORP). The City also maintains lead-poisoning and abatement procedures in all rehabilitation activities, where appropriate. Additionally, it provides education to owner occupants participating in City-funded rehabilitation programs and sends housing and subrecipient staff to Lead Safe. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 73 of 53 Chapter 8: Fair Housing Action Plan A. Data Collection and Engagement Conclusions Through input collected from community members and stakeholders, combined with quantitative data and analysis included in the previous chapters, the following key issues have been identified for the City of San Bernardino.  Housing Discrimination  Lending Practices  Age and size of housing stock  Resources for mobility (job preparedness and access to jobs)  Increasing numbers of homeless seniors B. Setting Fair Housing Priorities and Goals Following the period of public engagement conducted for the Fair Housing Assessment, program partners held meetings to analyze and interpret community comments alongside of HUD and local data in order to create regional fair housing goals. Goals have been set specific to the issues that must be addressed. Area program partners and stakeholders worked with the City to help determine fair housing goals and priorities. HUD provides a list of potential contributing factors in each section, accompanied by descriptions of those potential factors. The City used the HUD-provided list of potential fair housing contributing factors, along with the explanation of each factor, to determine whether any factor listed creates, contributes to, perpetuates, or increases the severity of one or more fair housing issues. Other factors were included if they create, contribute to, perpetuate, or increase the severity of one or more fair housing issues. In addition to the analysis using HUD- provided data, local data, and local knowledge in each section of the AI, the community participation process may be of assistance to program participants in helping to identify and prioritize the contributing factors that should be the focus of the AI. As part of the engagement process, input from housing and social service participants was emphasized. C. Contributing Factors to Fair Housing Issues City staff, stakeholders, and the community at-large identified and prioritized fair housing issues and contributing factors to fair housing. The following contributing factors to fair housing issues have been identifies as “medium” or “high” based on community engagement and data compiled from either HUD or other local sources. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 74 of 53 Contributing Factors to Fair Housing Issues Fair Housing Issues Contributing Factors Priorities Low Medium High Disparities in Access to Opportunity: Affordable Housing  Low volume of affordable housing  Poor housing conditions and blight  Poor outside perception. Developers do not want to build in the City.  Lack of funding for new housing, housing rehab and or maintenance  More housing assistance funding is needed  Tenant background checks stop families from receiving housing  Lack of advocacy for affordable housing. Not-My-Backyard attitudes create a tough land development process for new affordable housing plans  Lack of private company investment  Low number of accessible units for a growing elderly and/or disabled population Disparities in Access to Opportunity: Income & Employment  Cannot find housing in preferably located neighborhoods. Long commute time (average: 26 minutes) (one of the 10 worst commutes in the U.S.)  Lack of convenient transit routes and stops  Lack of jobs  Lack of skilled workers and training opportunities Disparities in Access to Opportunity: Education  Lack of educated workforce  Daycare before or after school  Access to the internet  Work schedule does not permit  Lack of time or finances for higher 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 75 of 53 education  Families do not prioritize higher education Disparities in Access to Opportunity: Racially Concentrated Areas  Available housing in racially concentrated areas is scarce  Lack of homeowners in racially concentrated areas Disparities in Access to Opportunity: Homeless and homelessness services and prevention  Homeless services are at capacity  Lack of/or acceptance of “Housing First” programs  Natural disasters are financially devastating to low income families  Homeless shelter space is at capacity Disparities in Access to Opportunity: Economic development  Struggling downtown  Lack of mixed-use development in the downtown  Lack of economic development incentives and business recruitment/retention  High crime rates  Local politics is affecting economic development Other Impediments: Income  Citywide there is a problem with poverty (particularly African American ethnicity)  High unemployment and poverty rates  Low- and moderate-income populations cannot afford to purchase a home  Lack of programs that link people with available jobs Table 40: Contributing Factors to Fair Housing Issues Source: Community Survey results; Stakeholder interviews; 2020 Housing Summit 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 76 of 53 D. Priority Goals and Actions The highest priority Contributing Factors to Fair Housing listed on Table 39 are based on community engagement activities and data analysis. They are:  Affordable Housing o Low volume of affordable housing o Poor housing conditions and blight o Tenant background checks stop families from receiving housing o Lack of advocacy for affordable housing. Not-My-Backyard attitudes create a tough land development process for new affordable housing plans o Low number of accessible units for a growing elderly and/or disabled population  Income & Employment o Lack of convenient transit routes and stops to get to work o Lack of jobs o Lack of skilled workers and training opportunities o High unemployment and poverty rates is impacting earning capacity o Low- and moderate-income populations cannot afford to purchase a home  Education o Access to the internet is needed for secondary and higher education o Work schedule does not permit families to seek higher education  Racially Concentrated Areas o Lack of homeowners in racially concentrated areas  Homelessness Services and Prevention o Low number of accessible units for a growing LMI elderly and/disabled population o Homeless shelter space is at capacity  Economic Development o Struggling downtown o Lack of mixed-use development in the downtown o Local politics is affecting economic development The following goals and action steps were developed as a result of specific data capture, partner agency consultation, existing programs and policies, community engagement, outreach activities, and issue prioritization. Through the AI process, the following six goals have been developed with associated action steps as shown in Table 40: Goal 1: Provide housing solutions and incentives for special needs populations. Goal 2: Increase affordable housing opportunities. Goal 3: Increase homeownership opportunities for all ethnicities and income groups. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 77 of 53 Goal 4: Create public awareness of fair housing laws and affordable housing advocacy. Goal 5: Increase earning capacity of low- and moderate-income residents. The following table describes and lays out the top issues, priority goals , and action steps that will further fair housing. Several high priority action steps have been highlighted to provide clearer direction for Council, City staff, and partnering agencies. Goals & Action Steps Top Issue Goals Action Steps Goal 1 Provide housing solutions and incentives for special needs populations. 1. Work with agencies that assist with the housing needs particularly the elderly, those with disabilities, and homeless. (Single parent households’ makeup almost 19 percent of the total households. Thirteen percent of the population are reported to have disabilities. Twenty three percent of the total homes contain at least one or more elderly person) 2. Work with housing developers to create affordable housing options for special needs populations. Goal 2 Increase affordable housing opportunities. 1. Support integrated housing approaches near designated employment areas/ centers and transit. 2. Promote building new units containing 2 or 3 bedrooms for larger families. 3. Encourage innovative low-cost housing materials such as modular construction. 4. Identify funding for transitional and permanent supportive housing development. Priority should be given to homeless and special needs households or persons. 5. Understand the specific redevelopment obstacles related to construction on the local level that can be changed. 6. Explore more ways to work with developers to promote housing construction training opportunities homeless. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 78 of 53 Goal 3 Increase homeownershi p opportunities for all ethnicities. 1. Work with local banks (particularly Wells Fargo) in expanding down payment assistance programs for first-time home buyers. Partner with lenders to encourage lending to low-income first- time homebuyers. 2. Incorporate: home ownership education, budgeting, and home maintenance education and skills into housing programs. 3. Retain existing homeowners by promoting and enhanced funding to the City’s existing Owner-Occupied Housing Rehabilitation Program. As well as tap into other future housing reinvestment programs and resources that may exist in the region. Goal 4 Create public awareness of fair housing laws and affordable housing advocacy. 1. Coordinate with the IFHMB to enhance local outreach about the positive impacts of affordable housing. 2. Work with IFHMB, as part of its Fair Housing contract, to annually review and report on apartment rental advertisements released by private housing companies. 2018-2019 IFHMB report for the City noted numerous discrimination cases. 3. Enhance local land use and zoning laws. a. Identify priority goals and target areas for new housing and or housing rehab where employment and transit opportunities exist. 4. Create regulations conducive to affordable housing needs. Introduce appropriate building envelope sizes for each zoning district and be inclusive with regards to unit size building height, reduced parking, transit and pedestrian connectivity. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 79 of 53 Goal 5 Increase earning capacity of low- and moderate- income residents. 1. Work with major employers to develop incentives for new housing near their work. 2. Improve education and provide skills training for education, healthcare, manufacturing and construction jobs. a. Create partnerships with California’s Employment Development Department, Workforce Development Board, Workforce Development Aging & Community Services, California Building Industry Association, Southern California Building Association, San Bernardino Valley College, Riverside Vocational College, Concorde Career College, and the Career Technical Education. b. Strive to collaborate with education and vocational institutions to provide workforce readiness programs. 3. Work with higher education systems to create college-readiness programs, financing solutions and family preservation programs for first generation students. 4. Increase opportunities that target “Second Chance”, persons with disabilities, at-risk homeless individuals, and job retraining program. Agencies such as the Center for Employment Opportunities, Technical Employment Training, Inc, Department of Workforce Development Board, America’s Job Centers of California, and San Bernardino County Workforce Investment Board. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 80 of 53 E. Regional Collaboration Many issues, such as homelessness, affordable housing, jobs-housing balance, housing discrimination and access to services are issues that require the collaboration between cities, the County, and nonprofit agencies throughout the San Bernardino region. I n recent years, the City has undertaken multiple initiatives that address housing-related issues including: owner-occupied housing rehabilitation program, first-time homebuyers programs in coordination with Wells Fargo, Microenterprise Program working with small business owners, and Infill Housing Program to provide housing for LMI families. The City annually collaborates with Community Action Partnership of San Bernardino, Family Service Association of Redlands, Lutheran Social Services, The Salvation Army Hospitality House and Step Up on Second for street outreach, emergency shelter, rapid-rehousing, case management and homeless prevention services. In addition, the City works with the St. Bernadine’s Hospital and Community Hospital, and Dignity Health in San Bernardino to provide homeless patients with appropriate healthcare and bridge housing and case management services. The City collaborates annually with the IFHMB to conduct and react to any complaints surrounding housing discrimination and fair housing education and promotion. Continuing these planning efforts and implementation would bridge the gap of disparities among neighborhoods. Most of the Action Steps noted in Table 40 require collaboration. The Public Engagement planning process for the AI and 5-Year Consolidated Plan was based upon positive community -wide and agency support and participation. The City has created a solid foundation to continue work with its area partners to create a path that initiates and completes the Plan’s action steps . The City is collaborating with the Center for Community Investment and Dignity Health in its Accelerating Investment for Healthy Communities initiative. The AIHC initiative in partnership with the City and Dignity Health has as its goal to create a minimum 800 units of affordable housing during the Con Plan planning period. The City is also collaborating with the SB School District in its Uplift San Bernardino initiative. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 81 of 53 APPENDIX A: Community Engagement Summary A Introduction The public participation process for the AI sought input from community members and stakeholders. Methods included on-line and paper surveys for community members, stakeholder interviews, community meetings, pop-up events and focus group meetings. The AI development engagement process took place in November, December, and January. The process will conclude with a 30-day public review period and a public hearing. B Community Meetings Community meetings were attended by representatives of Neighborhood Partnership Housing Services, Inc., Executive Director of Akoma Unity Center, National CORE, Dignity Health, Accelerating Investment for Healthy Communities (AIHC), Housing Authority County of San Bernardino, Hope Through Housing, and Executive Director of Community Engagement for the San Bernardino City Unified School District. Six community engagement meetings were held:  January 21, 2020, 11 AM – 1 PM @ Rezek Center, St. Bernardine Medical Center, 2101 N. Waterman Ave, San Bernardino  January 18, 2020 9:30 AM -11:30 AM @ Akoma Unity Center, 1367 N California St, San Bernardino  January 22, 2020 4PM – 5PM @ Maplewood Homes, 906 Wilson St, San Bernardino  January 23 4PM – 5PM @ Olive Meadows, 610 East Olive Street, San Bernardino  January 23, 2020 5PM – 6:30PM @ Valencia Vista, 950 N Valencia Ave, San Bernardino  January 24, 2020 9AM – 10:30PM @ San Bernardino Valley College, 701 S Mt Vernon Ave, San Bernardino REOCCURRING THEMES: There were eight re-occurring themes including: Affordable housing, target areas for redevelopment and safety, community services needed, homeless/homeless prevention services, infrastructure needs, City communications, jobs and employment and crime safety. Housing Needs:  Affordable housing Target Areas for Redevelopment and Safety: 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 82 of 53  9th Street and Baseline St (problems include drunk behavior, human trafficking, cars are drag racing, traffic calming measures, poor site distance at intersections, unsafe area for pedestrians and families.  Valencia Vista Area - homes deteriorating.  Olive Street and Valencia Ave - A stop sign or traffic calming is needed.  Southern San Bernardino. Safety concerns for young children.  Auto-shop across from Valencia homes. Shootings and drug-related activity exist.  Base Line Street and Sierra Way. Safety concerns Sierra Way (Liquor store area) and Base Line Street. Shootings are prevalent. Facade improvements are needed on Baseline Street Community Services Needed:  Youth services for at-risk youth (YMCA).  Create more low cost children’s programming such as sports.  Housing programs for special needs people particularly those with disabilities and mental health services. AIHC ties in Housing and Health. Put an emphasis on affordable housing, homelessness, and health because they are all interconnected.  Veteran’s homeless assistance programs.  Work with valuable service entities including: COPE: Congregation of Prophetic Engagement, UPLIFT, catholic groups, the County, Dept. of Public Health, First Five, senior advocacy groups, and neighborhood associations. Homeless & Homeless Prevention Services:  Create jobs for homeless. Create job programing that eases them into job responsibilities.  Create promotion and advocacy for homeless awareness  Collaborate with other communities.  Increase and expand emergency low barrier shelters.  Update and increase public housing. Infrastructure Needs:  School safety. Hire more cross guards for schools. Increase lighting around schools and routes to schools.  Increase streetlights and sidewalk safety. Expand the City’s sidewalk network.  Update facilities and infrastructure to be accessible. City Communications:  Increase City communications with regards to spending and future Consolidated Plan projects. Particularly with community groups. I.e. Communicate via water bills. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 83 of 53 Jobs & Employment:  Increase jobs, the number of businesses, and career opportunities.  Revitalize and rehabilitate the City’s Downtown Rehabilitation.  Create more social and community events.  Encouragement for small business opportunities.  Expand access to transportation– i.e. additional bus routes and stops, and longer run times. Include service animal accessibility. Crime & Safety:  Reduce criminal activity. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 84 of 53 C Stakeholder Interview Summary Throughout the City fourteen stakeholder interviews were held with the following entities:  Catholic Charities of San Bernardino and Riverside Counties  Continuum of Care – San Bernardino County  California State University – San Bernardino  Inland Fair Housing and Mediation Board  Hope through Housing  Inland Congregations United for Change  Omni Trans  Center for Employment Opportunities  Dignity Health  National Core Renaissance  Salvation Army  Mental Health Systems  Neighborhood Partnership Housing Services, Inc.  San Bernardino Department of Behavioral Health The following priority issues and needs were established throughout the interview process: Issues Needs Affordable Housing Location of housing Need Affordable housing near transit lines Occupy vacant City lots Stock More affordable housing Security Safe affordable housing Alleviate Poverty Need housing for those in poverty, who include people of color and single women. Barriers High cost of land, construction. Lead to higher priced housing. Zoning regulations Not in my backyard mentality Lack of funding Crime/bad reputation for City Housing Choicer Voucher Long wait times Application process Need housing navigation Accessibility Units are not accessible Conditions Poorly managed properties Address absentee landlord issue Existing units Rehabilitation of existing housing stock Need more code enforcement 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 85 of 53 Vital Services & Homelessness Prevention Connect homeless people to services Provide outreach to those residing in bus shelters Need Housing First/Low Barrier Informed care Shelters Shelters are full Domestic Violence Need to reduce domestic violence Homeless housing Being created, need more Need to involve partners to be creative in finding solutions (e.g. Amazon, Stater bros, Weingart, Union Pacific Foundation) Education People don’t understand homeless issues. Need to humanize homeless persons Youth Increase in homeless youth Need life skills Institution -> Housing Need assistance from institutions to permanent housing Communication Government to Government communication is needed Basic needs Need resource centers for homeless individuals Police Need for education of Police Department to approach Homeless in a productive way Increase Family Income Self Sufficiency Need more programs to improve self sufficiency Need to raise family incomes Families & Individuals in Transition Drugs/Alcohol Rehabilitation Need for sober housing Special Needs or Target Populations Housing Need Housing for mentally ill Discharge from Hospitals Those discharged from hospitals need support for follow ups/find housing (Care coordination) Medi-Cal does not pay very well for hospice care, which is a big cost to hospitals Hotel for discharge patients is ideal Veterans need housing when homeless St. Bernardines, through donations, provides discharges clients new clothes, shoes Emergency/Natural Disaster Effect Vulnerable Populations Transit Summer/Winter conditions, heavy rains affect riders waiting for transit Heat Hospitals used as cooling centers; people can stay inside if they “say the right things” Energy People with disabilities (home dialysis) Warming shelters shut off Homelessness Homeless persons are at risk during natural disaster 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 86 of 53 Those living by the Wash most susceptible Winter Winter increases the number of vulnerable homeless persons Need low barrier shelters during this time Fires Not enough shelter for those whose houses burn, will likely make people homeless Crime Low/Mod families vulnerable to crime, a lot in SB One-car households are vulnerable, especially if one family member is at work while an emergency happens. Employment and Workforce Development Homeless Employment training for homeless individuals. A new temporary employment agency will be opening in the City with a focus on employment for homeless persons) talk to Jennifer Kawar with the NPFF. Low wages make it difficult for people to move up No vocational funding for those with criminal backgrounds Fair Housing Education Need education on fair housing rights for tenants and landlords Discrimination Discrimination on basis of familial status, voucher status, disability, race Criminal background checks can cause people to think they’ve been denied Landlords may deny those with criminal background reentering Target Areas Arrowhead Grove Community Waterman and Baseline (Crime is happening in this area) Future CDBG Expenditures Homeless Interventions Using abandoned Motels/hotels for affordable housing Focus on specific homeless subpopulations Housing Asset mapping Gap analysis Rehabilitation Social services Invest in coordination between agencies Funding to rehabilitate homeless individuals who are discharged from hospitals (Dignity Health) (ESG funding) Homeless resource centers (one-stop) (ESG funding) 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 87 of 53 Broadband Access to housing applications HACSB has application online, people should be able to access internet Workforce People need internet to apply for jobs Homeless Services/Welfare Access People don’t have access to broadband Need tech literacy/digital equity Libraries have computer but limited hours Need computer labs for those that don’t have internet at home/no home Homeless persons need tech help/literacy D Pop Up Events Four Pop-Up events were attended including a local football game, San Bernardino Fest 2019 Airshow, Housing Authority County of San Bernardino, and City of San Bernardino Winter Wonderland. Common themes derived from the events include: o What are the most critical economic development initiatives needed? o Job creation o Job generating businesses o What are the most important areas of need? o Affordable housing for the homeless o Services for the homeless o What is the most critical homelessness needed? o Transitional housing o Emergency shelters o What are the most critical community services? o Youth activities and children after school o Youth summer programs o What is the most critical infrastructure needed? o Repaving of streets o Street lighting o What is the most critical housing needed? o First-time homebuyer’s assistance o Construction of new affordable units and housing for larger families 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 88 of 53 0 20 40 60 80 Job creation/job generating… Job readiness programs College readiness programs Grants/loans to small… Counseling/training for… Other 0 20 40 60 80 100 Services for the homeless Affordable housing Economic development Youth issues Infrastructure E.g) sidewalks… Senior issues HIV/AIDs housing Other 0 10 20 30 40 50 Youth centers Parks and recreational facilities Libraries Community centers Childcare centers Healthcare facilities Firestations and equipment Senior centers Other 0 10 20 30 40 50 60 Transitional housing Emergency/overnight shelters Permanent supportive housing with social services One-time rent/utility payments Other What is the most critical economic development need in San Bernardino? What are areas of need most important to you? What is the most critical community facility needs? What are the most critical homelessness needs? 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 89 of 53 0 10 20 30 40 50 60 70 Youth amenities (activities?) Children after school/summer… Programs for at-risk youth Childcare services Senior activites Other 0 20 40 60 80 100 Street/alley… Street lighting Tree planting and urban… Safe routes to school Accessibility improvements… Graffiti removal Water/sewage improvements Broadband internet access Electric vehicle charging station Other 0 20 40 60 80 First-time homebuyer stance Constructon of new affordable… Housing for large families Accessibility improvements Housing for those with… Renter-occupied housing… Senior housing Owner-occupied housing… Other What are the most critical community services needed? What are the most critical community infrastructure needs? What are the most critical housing needs? 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 90 of 53 E Housing Summit The City hosted a Housing Summit on Thursday, February 6th, 2020 at the Arrowhead Country Club located at 3433 Parkside Drive in San Bernardino from 8:00 AM to 12:00 PM. A Housing Summary Package was prepared and is attached to this Appendix and includes the event’s promotional flyer, agenda, sign-in, and speaker presentation. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 91 of 53 Housing Summit Notes: General Questions/Comments/Concerns:  How can you entice affordable housing? o Clemente Mojica: For single-fam development lower, it means to lower impact fees and streamline the development process  Think about all the overlays, NIMBYYS, subsidies, tax credits – it will help to lower impact fees and streamline approval process o Greg Bradbard: Agrees. Also, National Core Renaissance are a mission driven. Its about making the numbers work. We want affordable housing, but is there land and additional dollars with that?  Developer-side: could be more incentives, higher density, encourages density and affordable units  Melia Lopez (president of neighborhood associations) o To Tina Roseberry: organization during the survey and organization outreach  Need to include Neighborhood Associations on the slide  Important to be at the table because there’s a big disconnect b/w policy makers, organizations, agencies  We strongly encourage to be included, they are an investor as well and live in San Bernardino o To panel: If you are having coalition to anything, the neighborhood associations need to be involved on the table and beyond Commission  Need to be creative and get the community involved Purpose Inform area agencies on current priority issues and solutions to housing and homeless 1. Homeless prevention 2. Fair housing law and discrimination 3. Planning for affordable housing 4. Workforce development Keynote Speakers 1. Michael Huntley, City of San Bernardino 2. Eddie Estrada, Inland Empire Housing First Program 3. Clemente Arturo Mojica, NPHS, Inc. 4. Sarah Glenn-Leistikow, Center for Employment Opportunities 5. Sandra Espadas, Hope Through Housing 6. Kathleen McDonnel, Dignity Health 7. Greg Bradbard, Hope Through Housing Foundation 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 92 of 53  These things impact them o Kristine Gaa responded: They provide wealth and feedback especially in the Consolidated Plan. The City cares what they have to say. If anyone has questions, please reach out.  Community Education Partnership - Comment to throw on the table: geared to add ideas to the ConPlan o Want to look at what is happening around the entire world. San Bernardino has the chance to be a model. Governor came down to talk about homeless, addition to the plan to turn hotels to affordable housing, opportunity zones are important to look at San Bernardino is an opportunity zone  Wells Fargo o Lot about community living spaces: WeWork  Using it as community living and spaces – smaller dwellings in max square footage  Development cost: have people looked into it? Does it seem attractive? Will it help with affordability?  Clemente Mojica: working on strategic corporations. Smaller homes and are shared, an area that we need to look at, getting those products off the ground in cities where approval process is counter intuitive so it is difficult and may be difficult. So collaborative with Sandra + Kathleen, when you pipeline a project you identify the choke points. Gaps in policies and financing and community engagement. Need to do a better job with engaging the community and make sure you’re building what the community wants. Community = shareholders  Gloria Maya: To Core Housing o How do you account for constant and repetitive actions for resident harassment to their residents?  Greg Bradbard: Firstly, we should have a conversation offline. But in general, that does not align with their mission and values. They do have 25,000 residents so we do have times when residents don’t agree, and they do manage properties. Those issues do come up. I want to know.  Question: Federal Government involvement with local leaders o Lots of opposition b/w local leaders and government  “Housing First”  Eddie Estrada – “Housing First” is a big paradigm shift from what social service providers used to provide, not only to the city but to the county. We believe it works and there are challenges. There 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 93 of 53 are lot of homeless people with a lot of barriers that they need to reduce. o What do they see the resistance is? Is it negative or beneficial?  Eddie Estrada – Explains “Housing First” model. There is something with HUD to put restrictions with “Housing First”. They tend not to allow service providers to receive HUD money. To be able to put some restrictions to address the pipeline. o To Dignity Health: Most vulnerable population to disease and epidemics, especially now, that could eventually affect the general public  Kathleen McDonnel – we serve everyone who comes in. They are treated. o What does Dignity Health plan to do to help?  Hospital does not sweep out encampments. There are colleagues that do ministries where they go to the streets and tend to those who live there. But Dignity Health does not do that.  Council Member answers – disconnect b/w local decision making and local community members. Heard several comments. We need more homeownership and don’t want apartments. Heard about discussion about increase density. That strikes fear into homeowners and decision makers. Decision makers are elected officials. We need to have multi family dwellings. There needs to be good location for it and not just in a single-family home area. There’s an appropriate place for it – if there are no apartments, then you lose most families.  Elected Leader (second ward) and works for non-profit that encourage housing: talking about waiving city fees when it comes to development, how does waiving these fees benefit the community? It benefits the developer but how does it benefit the community?  Clemente Mojica: As an affordable housing developer, we are mission driven. We are not making a lot of money. It’s not market based. When we build affordable housing as a non-profit, how much can we recoup while still offering a home that is very affordable to low-income families? Factor built housing costs less. 20-25% less development construction cycle. The community will benefit. Families were at 80% AMI, got her into the home. None of the fees were waived. Appraises just like a site-built home.  Eddie Estrada: as a homeless service provider. Think about how it helps the individual get into housing. Think of how much it costs as a city for emergency services, police cars, and ambulances. This is a hidden cost when you don’t think see that. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 94 of 53  Sandra Glenn-Leistikow: part of the work is understanding the return of investment to see. People react to numbers. How does that stabilization bring to the community? AIHC that is what they’re aiming for.  Ayako: affordable housing is built, either owner or renter is paying no 1/3 of gross monthly income, they have more disposable income. Pay these sales taxes. Encourage the City to talk about why affordable housing and more density is important? Rather than get votes. You need density. Don’t have a car but that means to build higher density. Need lower site setbacks, need lower square footage, lower minimums as well as apartments. Utilities are expensive. Building and safety need to take this into consideration that heightens the cost of construction.  Because cost of construction is so high, what can you do to get the cost of construction down? Too risky for smaller developers to use smaller housing costs, what can we do to accelerate adopting technologies?  Greg Brand Bard: making sure there aren’t regulation that don’t prohibit us with traditional funding streams. They don’t necessarily align. Dormitory type style housing could produce more housing but that doesn’t align with tax-credit funding. [Maria Gallegos] closing remarks 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 95 of 53 F Community Needs Survey The City prepared a Community Needs Survey in both English and Spanish and provided online links and paper copies for distribution. The survey was promoted at scheduled project community meetings, Housing Summit, and pop-up events. The survey link was posted on the City’s website, stakeholder newsletters, social media posts and on flyers distributed at community events. The survey period was from December 9, 2019 to February 29, 2020. The City received approximately 1,011 responses. Included in this summary are the survey informational flyer and online survey summary. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 96 of 53 Key Findings of the Survey 1,011 Online and Paper responses to online survey. Response information:  91% English  88% residents  55% homeowners  40 percent renters  58% 10 or more years living in the City  18% less than 10 years Identified needs in priority order: 1) Housing Most critical housing needs: 1. First time homebuyer program 2. Construct more affordable rental housing 3. Renter-occupied housing rehabilitation 4. Accessibility improvements 2) Homeless Most critical homelessness needs: 1. Permanent supportive housing 2. Emergency overnight shelters 3. One-time rent/utility payment assistance 4. Transitional housing 3) Community services Most critical community services needs: 1. Programs for at-risk youth 2. Children’s after school/summer care 3. Youth activities 4) Economic development Most critical economic development needs: 1. Job creation 2. College readiness programs 3. Job readiness programs 4. Grants and loans to small businesses Complete survey summaries are provided below in both English and Spanish. 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 97 of 53 Index of Tables, Figures, Graphs, and Maps Table 1: Population Increase ............................................................................................................. 15 Table 2: Race and Ethnicity ............................................................................................................... 18 Table 3: Languages Spoken at Home .............................................................................................. 19 Table 4: Index of Dissimilarity .............................................................................................................. 20 Table 5: Housing Types ........................................................................................................................ 24 Table 6: Housing Tenure ...................................................................................................................... 25 Table 7: Persons with Disabilities ........................................................................................................ 26 Table 8: Large Households ................................................................................................................. 27 Table 9: Single-Parent Households .................................................................................................... 28 Table 10: Vacant Units and Vacancy Rates .................................................................................... 30 Table 11: Affordability Rent and Mortgage Combined ................................................................. 31 Table 12: Affordability Rent and Mortgage Combined ................................................................. 31 Table 13: Median Home Purchase Price .......................................................................................... 32 Table 14: Rental Housing Cost ........................................................................................................... 33 Table 15: County Fair Market Rents ................................................................................................... 33 Table 16: Income Distribution Overview ........................................................................................... 34 Table 17: Housing Cost Burden Overview ........................................................................................ 34 Table 18: Median Household Income by Race .............................................................................. 35 Table 19: HUD Median Income Limits ............................................................................................... 36 Table 20: Employment Status ............................................................................................................. 38 Table 21: Workforce by Industry ........................................................................................................ 39 Table 22: Homeless Count .................................................................................................................. 40 Table 23: Homeless Populations ........................................................................................................ 41 Table 24: Disposition of Home Loans ................................................................................................. 47 Table 25: Mortgage Approvals by Race/Ethnicity.......................................................................... 48 Table 26: Loan Type by Race ............................................................................................................ 49 Table 27: Denials .................................................................................................................................. 49 Table 28: Top Lenders.......................................................................................................................... 50 Table 29: Land Use and Zoning ......................................................................................................... 52 Table 30: Units Per Property ................................................................................................................ 53 Table 31:Housing Types by Zone ........................................................................................................ 54 Table 32: Parking Requirements ........................................................................................................ 55 Table 33: Discriminatory Language in For-Sale Homes Listings ..................................................... 58 Table 34: Discriminatory Language in Rental Listings ..................................................................... 61 Table 35: HUD Fair Housing Complaints ............................................................................................ 63 Table 36: DFEH Basis for Complaint ................................................................................................... 64 Table 37: IFHMB Persons Served 2018-2019 ...................................................................................... 65 Table 38: Hate Crimes Reported ....................................................................................................... 66 Table 39: Crime in the City of San Bernardino ................................................................................. 66 Table 40: Contributing Factors to Fair Housing Issues ..................................................................... 75 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 98 of 53 Figure 1: Key Takeaways Community Survey .......................................................................................... 10 Figure 2: Key Takeaways Critical Needs ................................................................................................... 11 Figure 3: Key Takeaways Vulnerable Residents ...................................................................................... 14 Figure 4: Age Distribution .............................................................................................................................. 16 Graph 1: Age Distribution in San Bernardino City .................................................................................. 17 Graph 2: Housing Stock by Year Built ........................................................................................................ 30 Map 1: Minority Concentration ................................................................................................................... 22 Map 2: Racially or Ethnically Concentrated Areas of Poverty ........................................................... 23 Map 3: Areas of Low- and Moderate-Income ....................................................................................... 37 2020 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 99 of 53 Activity CDBG Requested ESG HOME NSP1 2020 Grant Fund Allocation 3,405,816$ 295,799$ 1,404,784$ 300,000$ Program Income and Reprogrammed Funds 817,368$ 1,965,694$ -$ Available Funds 4,223,184$ 295,799$ 3,370,478$ -$ Administration (maximum available)681,163$ 22,185$ 140,478$ 60,000$ Section 108 Repayment 763,021$ Micro-enterprise 35,000$ Fair Housing (IFHMB)73,000$ Citywide Concrete Repairs 500,000$ Hanes Project 500,000$ -$ Infill Housing 700,000$ -$ Seccombe Park Housing Project 2,000,000$ -$ Mary Erickson Community Housing (MECH)300,000$ First Time Homeownership - CHDO 15% Set-Aside1 210,718$ -$ Public Facilities Projects Meadowbrook Park 253,000$ Nicholson Park 1,000,000$ Anne Shirrel Park 253,000$ Encanto Community Center - Phase I 665,000$ Public Facilities Projects Total 2,171,000$ -$ -$ -$ Lutheran Social Services (LSS)70,000$ Community Action Partnership (CAPS)54,446$ -$ -$ Family Services Association (FSA)63,000$ Step Up on Second 86,168$ The Salvation Army -$ Total Requested 4,223,184$ 295,799$ 3,551,196$ 360,000$ 1Community Housing Development Organization (CHDO) set-aside as required by HOME regulations. EXHIBIT B FISCAL YEAR 2020-2021 DRAFT ACTION PLAN ACTIVITY RECOMMENDATIONS 1 2020-2025 Consolidated Plan Process City of San Bernardino 2 Overview Statistics Source: 2013-2017 American Community Survey Estimates POPULATION 215,252 0.313% GROWTH MEDIAN AGE 29.4 MEDIAN HOUSEHOLD INCOME $41,027 6.69% GROWTH POVERTY RATE 30.6% NUMBER OF EMPLOYEES 78,721 2.6% GROWTH MEDIAN PROPERTY VALUE $202,100 14.3% GROWTH CITY OF SAN BERNARDINO 3 Entitlement Grants Grants received by the City of San Bernardino •Community Development Block Grant (CDBG) Program - $3,405,816 •HOME - $1,404,784 •ESG - $295,799 To receive these funds, the City must complete and submit to HUD a Consolidated Plan Document (CPD) 4 What is a Consolidated Plan? •The CPD covers a five-year period. •The Consolidated Plan (ConPlan) is designed to aid the City in assessing affordable housing and community development needs •The ConPlan determines how funds from the U.S. Department of Housing and Urban Development (HUD) are used •Priorities are determined through data analysis as well as a communitywide outreach program. Ensures the programs are data-driven and place-based Analysis of housing and economic market conditions Addresses the priority needs and County’s goals Allocates funds to priority projects and needs in Con Plan Outreach, Stakeholder meetings, Data- gathering Analysis of Impediments ConPlan Annual Action Plan 5 Engagement Activities Housing Summit Community survey Stakeholder meetings    Pop-Up Events  Engagement & Outreach Activities: •Identify priorities •Creates a dialogue 6 Community Survey The best tool for providing: •Local data •Housing needs •Community needs •Anonymous input – allows for honest feedback The survey was distributed via paper and online and was open from November 2019 to February 2020 We received 1,011 response 7 Housing Summit February 6, 2020 – Conducted a Housing Summit Arrowhead Country Club 41 attendees We had 7 speakers, and invited a diverse group of community leaders, agency representatives, service providers, planning professionals, land developers, business owners, and more to learn and collaborate about the current state of housing, jobs, and development opportunities. This summit will help the City identify: •Real and perceived public safety concerns, •The need for diverse housing options (both emergency and long-term) •Developing new and improving existing housing stock •Expanding opportunities to advance workforce and build community wealth •Community health including physical, mental, and emotional well -being The presentations and activities: •Give information about City’s Consolidated Plan •Addressed the City's most immediate needs, and •Curate information and ideas for use in long-range planning and development efforts 8 Stakeholders / Focus Groups •Children & Youth Services •Senior Services •Health Services •Employment and Job Training Services •Education Services •Affordable Housing (Developers and Providers) •Homeless Services •Lenders, Brokers, First-Time Home Buyers Programs •Disability Service Providers •Domestic Violence Services •Government Agencies •Business (Chambers of Commerce, Associations, and Real Estate Professionals) •Legal Services •Faith-Based and Cultural Organizations •Publicly Funded Institutions / System of Care •Community / Family Services and Organizations •Environmental Sustainability •Immigrant Services •Neighborhood Associations Reaching out to various providers, organizations and firms for input 9 Pop-Up Events •Temporary events in unique spaces •Venue for public outreach and information distribution •The City of San Bernardino has conducted 3 pop-up events •Have successfully distributed information about the Consolidated Plan process and engaged community members about attending meetings and participating in the survey 10 Data/Outreach Collection Pop-Up Events, Community Meetings Focus Group Meetings Surveys These identified needs are then used to prepare the Consolidated Plan’s Strategic Plan which informs and guides the future projects and programs Helps the City identify high-priority needs for the Consolidated Plan The results of the: 11 Goals Identified Affordable Housing o Low volume of affordable housing o Poor housing conditions and blight o Tenant background checks stop families from receiving housing o Lack of advocacy for affordable housing. Not-My-Backyard attitudes create a tough land development process for new affordable housing plans o Low number of accessible units for a growing elderly and/or disabled population Income & Employment o Lack of convenient transit routes and stops to get to work o Lack of jobs o Lack of skilled workers and training opportunities o High unemployment and poverty rates is impacting earning capacity o Low and moderate income populations cannot afford to purchase a home Education o Access to the internet is needed for secondary and higher education o Work schedule does not permit families to seek higher education Racially Concentrated Areas o Lack of homeowners in racially concentrated areas Homelessness Services and Prevention o Low number of accessible units for a growing LMI elderly and/disabled population o Homeless shelter space is at capacity Economic Development o Struggling downtown o Lack of mixed use development in the downtown o Local politics is affecting economic development 12 12 Thank You