Loading...
HomeMy WebLinkAbout12-849 Resolution Approving Analysis of Impediments to Fair Housing Choice ReportCITY OF MERIDIAN RESOLUTION NO. / BY THE CITY COUNCIL: BIRD, HOAGLUN, ROUNTREE, ZAREMBA A RESOLUTION ADOPTING THE ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE REPORT AND THE FAIR HOUSING ACTION PLAN; AND PROVIDING AN EFFECTIVE DATE. WHEREAS, the City, as a recipient of Community Development Block Grant ("CDBG"} funding from the United States Department of Housing and Urban Development ("HUD"), is required to affirmatively further fair housing and as such conduct an analysis of impediments to fair housin choice within the 'urisdiction, and take appropriate actions to overcome the effects of g J any impediments identified through that analysis, and maintain records reflecting that analysis and actions in this regard; and WHEREAS, the City held a public hearing on the Analysis of Impediments to Fair Housing Choice Report and the associated Fair Housing Action Plan on March 7, 2012, and held a public comment period on the report and plan from March 7, 2012 to April 17, 2012. NOW THEREFORE, BE IT RESOLVED BY THE MAYOR AND CITY COUNCIL OF THE CITY OF MERIDIAN CITY, IDAHO: Section 1. That the Analysis of Impediments to Fair Housing Choice Report and Fair Housing Action Plan, copies of which are attached hereto as EXHIBIT A and incorporated herein by reference, and the same hereby are, approved as to both form and content. Section 2. That this Resolution shall be in full force and effect immediately upon its adoption and approval. 4-G~- ' of Meridian Idaho this 2 da of ADOPTED by the City Council of City y 2012. APPROVED by the Mayor of the City of Meridian, Idaho, this , O D A UC~S~t c°`~ '~~ APPROVED: ~ ~ City of E IDIAN~- tpAHO ¢ '~ ti ~ ~~ ti ATTEST: ~r~~. g~~~y E r~~~ By: ycee olman, ity Clerk Z`~a of i ~~ Mayor m y de Weerd RESOLUTION APPROVING ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE REPORT AND FAIR HOUSING ACTION PLAN Page l OF 1 FINAL REPORT Analysis of Impediments to Fair Housing Choice ~~Q/~E IDIAN:-- City of Meridian, Idaho 9 i .,--- ~, - . ' ~ ~ ~,~ \Y~ l ~~" ~`~ flt ~ ~ -ly fc-.` ~ v rSil~.. . ;~ft +r u ~~ ~ - ~ ~ c ~~ l~ > ~ ~ ~~ ~ _ ,fit t1 ; ~~ ~~~ ~ t" )' r w. h ~ 4 fi FINAL REPORT April 18, 2012 Analysis of Impediments to Fair Housing Choice Prepared for City of Meridian 33 E. Broadway Ave. Meridian, Idaho 83642 Prepared by BBC Research St Consulting 1999 Broadway, Suite 2200 Denver, Colorado 80202 303.321.2547 fax 303.399.0448 www.bbcresearch.com bbc@bbcresearch.com s r® RE:SLAKCI ~ Coi\rsu>.~rit~c Table of Contents I. Demographic and Housing Market Analysis Population and Household Composition ..................................................................................... I-1 Economic Characteristics ........................................................................................................... I-10 Housing Market Analysis ........................................................................................................... I-12 Foreclosure Analysis .................................................................................................................. I-18 Transportation ........................................................................................................................... I-19 II. Public Policies and Practices Public Housing Authority ............................................................................................................ II-1 Assisted Housing Units ............................................................................................................... II-5 Land Use Policy Review .............................................................................................................. II-5 Other Public Sector Programs and Services ................................................................................. II-9 III. Fair Lending and Complaints Fair Housing Complaints ........................................................................................................... III-1 Legal Cases ................................................................................................................................ III-4 Fair Lending Analysis ................................................................................................................. III-8 IV. Public Input and Participation Resident Survey .........................................................................................................................IV-1 Stakeholder Survey and Focus Group ...................................................................................... IV-10 V. Fair Housing Impediments and Action Plan Summary of Needs .....................................................................................................................V-1 Fair Housing in Meridian ............................................................................................................ V-3 Fair Housing Impediments and Action Plan ................................................................................ V-4 BBC RESEARCH bT CONSULTING SECTION I. Demographic and Housing Market Analysis SECTION 1. Demographic and Housing Market Analysis This section provides a community and housing profile for the City of Meridian. It includes the racial, ethnic and income concentration maps required by the Department of Housing and Urban Development (HUD) for Analyses of Impediments to Fair Housing Choice (AIs). The primary data sources for the demographic and housing profile include the following: the Census (2010}, American Community Survey (ACS) 1-year (2010), 3-year (2008-2010) and 5-year (2005- 2009) estimates, Claritas (2010), COMPASS, and the Bureau of Labor Statistics (BLS}. Population and Household Composition Population growth. The current population in Meridian i 75,092. Meridian is a fast growing community that has more than doubled its population in the last 10 years. In fact, Meridian accounted for 44 percent of Ada County's growth in the last 10 years. Figure 1-1. Population of Cities within Ada County, 2000 and 2010 Source: 2000 and 2010 U.S. Census. 11.-~..~ .~ - ~ . I I '~ ~, . (~dil. ~; ~ i J ~'t1UL~ I.~! , :~~?~,. Meridian 34,919 75,092 115% 12% Boise 185,787 205,671 11% 1% Eagle 11,085 19,908 80% 840 Garden City 10,624 10,972 34'0 0°.5 Kuna 5, 382 15,210 18345 18% Star 1,795 5,793 223% 22% Ada County Total 300,904 392,365 30% 3% Age. Lilcc many communities in the U.S., Meridian's population is aging. The ciry's population contains a larger proportion of Baby Boomers and seniors now than 10 years ago. Figure I-2. ! Age Distribution, ,___ _~TaXaXo) ~ ~ City of Meridian, Glual_'r~ L' • • 2000 and 2070 Infants and Toddlers (Age 0 to 4) 3,973 11 °r5 G,981 9% School Aged Children (Age 5 to 19) 8,493 24% 19,685 26% Source: zooo and zolo us. census. College Aged Adults (Age 20 to 24) 1,717 5% 3,296 445 Young Adults (Age 25 to 44) 12,964 37% 22,875 30°r5 Baby Boomers (Age 45 to 64) 5,521 16% 15,542 21% Seniors (Age 65 and older) 2,251 6% 6,713 9°.5 Senior residents currently comprise 9 percent of the city's population. As demonstrated in Figure I-3, there are three bloclt groups within the city that contain a relatively large proportion of seniors. One of the block groups (tract 103.22, block group 2) encompasses the core of the downtown business district. BBC RESEARCH Si CONSULTING SECTION I, PAGE 1 Figure 1-3. Percent Seniors of Total Population by Block Group, City of Meridian, 2010 Source: 2010 U.S. Census. Race and ethnicity. The Ciry of Meridian is largely racially White (92%) and ethnically non- Hispanic (93%). The ciry's Hispanic population has peen the fastest growing racial or ethnic group in the last 10 years, and now comprises 7 percent of the city's population, compared with just 3 percent in 2000. Figure 1-4. Race and Ethnicity, City of Meridian, 2010 American Indian and Alaska Native 117 0.3% 375 0.5% 0.2% Asian 516 1.5% 1,345 1.8% 0.3% Black or African American 43 0.1% 573 0.8°r6 0.6% Native Hawaiian and Other Pacific Islander 66 0.2% 106 O.1Ro 0.0% White 32,776 94.0% 69,071 42.0% -2.0% Some other race 479 1.4% 1,449 1.9% 0.6°~ Two or more races 861 2.5% 2,173 2.9% 0.4% Hispanic/Latino 1,128 3.2% 5,111 6.8% 3.6% Non-Hispanic/Latino 33,730 96.8% b9,981 93.2% -3.6% Source: 2000 and 2010 U.S. Census BBC RESEARCH ST CONSULTING SECTION I, RAGE 2 Racial and ethnic concentration. One of the key components of a fair housing analysis is an examination of the concentration of different races and ethnicities within a jurisdiction to detect evidence of segregation. In some cases, racial and ethnic concentrations arc a reflection of preferences-e.g., people of different races and ethnicities may choose to live where they have access to grocery stores or restaurants that cater to them. In other cases, different race/ethnic populations arc intentionally steered away or discouraged from living in certain areas. Housing prices can also heavily influence where minorities live. This report uses HUD's definition of "disproportionate need" to define racial, ethnic and income concentrations. Using this definition, concentrations occur when the percentage of residents of a particular group is 10 percentage points higher than the community-wide average. For example, if 20 percent of residents in a particular Census block group arc Hispanic and Hispanics comprise 10 percent of a comnutniry's population overall, that Census block group contains a concentration of Latino residents. The following maps show the proportions of Non-White and Hispanic residents by Census block group for the City of Meridian. The concentration thresholds used for the concentration maps are: ^ Non-White. In 2010, 8 percent oFresidents in the city reported their race as something other than White. Census block groups that have 18 percent and more non-White residents are concentrated by the disproportionate need definition. ^ Hispanic concentrations. In 2010, 7 percent of residents in the city reported their ethnicity as Hispanic. Census blocks that have 17 percent and more Hispanic residents are concentrated by the disproportionate need definition. The maps also report areas that HUD terms "minority areas" or "racially/ethnically-impacted areas" which are block groups in which minority populations are 20 percentage points higher than the City of Meridian overall. As demonstrated in Figures I-5 and I-6, there arc no areas of concentration or any impact at•eas in the city. The Census block group with the largest proportion of non-White residents (14%) is block group 2 of Census tract 103.22, which encompasses the city's downtown business district. The Census block group with the largest proportion of Hispanic residents (14%) is block group 2 of tract 103.21. This block group lies adjacent to the city's main downtown area. BBC RESEARCH bt CONSULTING SECTION I, PAGE 3 Figure I-S. Concentration of Non-White Residents, City of Meridian, 2010 Source: 2D70 U.S. Censuz. Figure I-6. Concentration of Hispanic/Latino Residents, City of Meridian, 2010 Source: 2010 U.S. Census. BBC RESEARCH & CONSULTING SECTION I, PAGE 4 Type of households. Seventy-nine percent of the city's households arc family households, including 64 percent husband and wife families. By comparison, family households comprise a much larger proportion of Meridian's household composition than neighboring Boise. Family households oily account for 59 percent of Boise's households, and 44 percent of Boise's households are husband and wife families. Figure 1-7. Household Composition, City of Meridian, 2070 Family Households 19,916 79% Source: 2otoU.S.census. Husband-wife family 16,173 64% with children 8,859 35% without children 7,314 29% Male Householder - no wife 1,117 4% with children 777 3% without children 340 1 Female Householder - no husband 2,626 10% with children 1,761 7% without children 865 3% NonfamilyHouseholds 5,386 21% Total Households 25,302 100% Familial status is protected under the Fair Housing Act. In Meridian, 11 percent of fair housing complaints filed in Meridian since 2005 were based on familial status. Similar to race and ethnicity, it is important to note the place of residence of female households with children to determine whether discrimination is preventing them from moving into certain portions of the city. Seven percent of Meridian's households are single female households with children. Families comprised of a single female householder and children are far more likely to live in poverty, and may require some form of public assistance to afford housing and other basic needs. This is certainly the casein Meridian. For example, 5 percent of all Meridian families live in poverty compared with 13 percent of all single female headed households and 45 percent of female households with children under the age of 5 years old. As demonstrated in Figure I-8, female-headed households arc most lilccly to reside in the city's downtown area. BBC RESEARCH LET CONSULTING SECTION I, RAGE 5 Figure 1-8. Geographic Distribution of Single Female Households with Children, City of Meridian, 2010 Source: 2070 U. S. Census. Income and poverty. The American Community Survey (ACS) estimated the city's 2010 median household income at $60,230. Meridian's households earn more than state and national residents; the median household income is $43,490 in Idaho and $50,046 for the U.S. overall. Figure I-9 displays Meridian's household income distribution. About half of Meridian's households earn between $25,000 and $75,000 per year. An additional 1 G percent of the city's households earn less than $25,000 per year. Figure I-9. Household L~eome Distribution, City of ~ t {9'"~~""`°~`°~' 1otp1~lY""' Meridian, 2070 Less than $10,000 1,012 4% $10,000 to $24,999 3,140 12% Source: 2010 American Community survey. $25,000to$49,999 6,563 25% $50,000 to $74,999 6,370 24% $75,000 to $99,999 3,473 13% $100,000 to $149,999 2,911 11% $150,000 or more 2,563 10% BBC RESEARCH SS CONSULTING SECTION I, PAGE 6 Figw•e I-] 0 displays the geographic distribution of the city's lowest income households by Census block group. Two block groups contain more than 26 percent low income households. By HUD's definition of disproportionate need, these two block groups contain a concentration of low income households in the city. Both block groups are located in downtown Meridian. Figure 1-10. Geographic Distribution of Low Income Households, City of Meridian, 2010 Note: Households earning less than $25,000 per year used as a proxy for low income. Source: 2010 Claritas. Median Family Income (MFI) is used by HUD and state and local policy makers to qualify households for various housing programs. According to HUD, the MFI for the Boise-Nampa MSA in 2011 was $62,100. The following classifications utilize MFI to define income levels according to HUD's categorization: ^ Extremely low-30 percent and less of MFI ($18,630 and less); ^ Vcry low-31 to 50 percent oEMFI ($18,631 to $31,050); ^ Low and moderate-51 to 80 percent ($31,051 to $49,680); ^ Above low and moderate-80 percent and above of MFI (more than $49,680); BBC RESEARCH & CONSULTING SECTION I, PAGE 7 Figure 1-11. Distribution of Low Income Households by HUD Income Classification Categories, City of Meridian, 2070 3096 of MFI (10.8°,U) '-~-~~, 5096 of ~%~ MFI (11.696) Y.~ji- Above 80°,6 ~_ `^ ~~ 1- - _ MFI (59.196) ~~ `~ ,~8096of MFI (18.596) ~~ Source: 2010 American Community Survey. Figure I-l 1 shows the percentage of Meridian households within eadi MFI category. The largest proportion of households in Meridian (59%) were considered "above law and moderate income," earning more than $4),680. These households would likely not qualify for HUD-funded programs. Eleven percent of Meridian's households earn less than 30 percent of the local MFI and would be considered by HUD's standards "very low income." Meridian's 6 percent poverty rate is relatively low compared to the poverty rate in Idaho (16%) and the U.S. (15%). Moreover, Meridian's child poverty rate of 7 percent is much lower than the national child poverty rate of 21 percent. i Figure I-12 displays poverty rates by age group for Meridian residents. The city's college age students have the highest poverty rate at 14 percent, which is not surprising given that many of these individuals are likely enrolled in college or are just beginning careers. Moreover, this segment of the population has been heavily impacted by the recent economic downtown. Surprisingly, only 1 percent of the city's seniors arc living in poverty. Given that this segment of the population often lives on a fixed income, poverty rates among seniors are typically higher than l percent. Figure I-72. IF.~'¢:11 Ia Ir;Cl~t4 I t ld~f?111i'! Poverty Status by Age, I ~l ull-t9tan il,~lsrrt-lriny . F-~<<=ia~n ft City of Meridian, 2070 ______- __ ____ __ __ __ , , Infants and Toddlers (Age 0 to 4) 520 10.9% 8.3% source: School Aged Children (Age 5 to 17) 1,175 24.5% 6.2% 2°10 American Community Survey. College Aged Adults (Age 18 to 24) 551 11.5% 13.8% Young Adults (Age 25 to 44) 1,71 S 35.8% 7.4°/a Baby Boomers (Age 45 to 64) 763 15.9% 4.5% Seniors (Age 65 and alder) 65 1.4% 1.1 Total 4,789 100% rate includes all children under the ar:e of IR. Data source is the 20]0 U.S. Census. BBC RESEARCH & CONSULTING SECTION I, PAGE 8 Disability status. Disability status is an important component of fair housing analysis, particularly in Meridian and the Boise region. Disability status has been the basis for a number of fair housing related lawsuits. And, according to HUD, 61 percent of the 18 fair housing complaints filed in Meridian between 2005 and 2011 were on the basis of disability. Nearly 7 percent of all residents in Meridian report having a disability. The city's seniors have the highest rate of disability at 24 percent. Figure I-13 Disability Status by Age, : " City of Meridian, 2010 __ - _ _._ i1o ~~~~?~~.:> M1,l I. I°lkra i(lt~ / /~ I ~ci Under 5 years of age 6,284 - 0.0% source: 5 to 17 years of age 19,030 372 2.0% 2010 American Community Survey. 18 to 34 years old 14,389 594 4.1 35 to 64 years old 29,846 2,615 8.8% 65 years and older 5,697 1,347 23.6% Total 75,246 4,928 6.5% Ambulatory or physical disabilities are the most commonly cited type of disability among Meridian's residents. Forty-six percent of persons with a disability aged 18 to 64 report having an ambulatory disability, as do 18 percent of disabled seniors. Figure I-14 maps the location of the city's residents with disabilities by Census tract. Tracts located in the central portion of the city do contain concentrations (according to HUll's definition of disproportionate need) of persons with disabilities. This is partially impacted by the city's disabled senior population. Figure I-14. Percent of Population with a Disability by Census Tract, City of Meridian, 2017 Source: 2005-2010 ACS S-year estimate. BBC RESEARCH St CONSULTING SECTION I, PAGE 9 Economic Characteristics Unemployment. In the midst of the recent economic recession, the Boise region and the City of Meridian have not been immune to increases in unemployment. The city and the region experienced substantial job loss between 2007 and 2009, which resulted in unemployment rates in Meridian growing from 2.5 percent to 7.9 percent between 2007 and 2(109. Meridian's unemployment rates have historically trended below the MSA, the state and the U.S., and it remains that way in October 2011. Figure I-17. Unemployment Rate, Boise MSA, Idaho, U.S, 2000 to 2071 ~ Meridian ~ - ~ Boise-Nampa MSA - - State of Idaho U.S. 10.0 y-' ` ,..., 8.0 ~ i I 7.0 6.0 5.0 ~ ~~... '~~' _- -~~ ,_ .___- ` 6 2.0 1.0 0.0 z e v E b 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 (October) No[e: Data are not seasonally adjusted annual averages. Source: Bureau of Labor Statistics, Jobs and wages. As demonstrated in Figure I-18, Ada County's employment base is largely associated with service jobs (85%) that pay an average annual wages of $37,000 per year. Manufacturing jobs pay the highest wages in the county; however, they only comprise 9 percent of the county's total employment. Overall, the county's private sector employment opportunities pay an average of $40,000 per year. Figure 1-78. Employment and Wages, Ada County, 7 Q207 7 Note: Employment data only available by county. Source: Bureau of Labor Statistics. ~,f~USfnt-L'j3 -- /~~i~ •zr ~ a x ~ t t. rrd t~1; kids?titif( 1'stt - Goods Producing 23,252 14.6% $58,344 Natural Resources and Mining 722 0.5°,6 $32,084 Construction 8,118 5.146 $39,156 Manufacturing 14,412 9.Oo~ $70,512 Servicing Producing 136,317 85.4% `537,024 Trade, Transportation, and Utilities 36,306 22.896 $36,036 Information 3,514 2.246 $46,072 Financial Activities 10,661 6.796 $51,688 Professional and Business Services 32,785 20.5°,6 $43,680 Education and Health Services 30,241 19.0°.6 $39,936 Leisure and Hospitality 17,649 11.196 $14,664 Other Services 5,143 3.296 $24,024 Unclassified 18 0.096 $50,908 Total Private Employment 159,568 540,092 BBC RESEARCH & CONSULTING SECTION I, PAGE 10 Largest employers. Figure I-19 displays the largest cmploycrs in the Boise-Nampa MSA. Many of the region's largest employers have multiple locations, some of which are in Meridian (e.g., St. Luke's Regional Medical System, Wal-Mart). The Meridian School District is the fifth largest employer in the region with 4,000 employees. The school district is very large, and does extend outside the city's boundaries. Most of the region's largest private sector cmploycrs included in Figure I-17 are located in Boise. Meridian's employment base is primarily comprised of smaller firms involved in retail and services. Figure I-19. Major Employers, Boise City-Nampa MSA, 207 7 State of Idaho St. Luke's Regional Medical System Micron Technology, Inc. WalMart Meridian Joint School District tl2 Boise State University St. Alphonsus Regional Medical System Hewlett-Packard Company Albertson's/A Supervalu Company Ada and Canyon County Boise School District IDACorp. (Idaho Power) J. R. Simplot Nampa School District City of Boise DirecTV Citi Darmody Enterprises (McDonald's) Veteran's Affairs/Medical Center Fred Meyer WDS Global Services EDS Teleperformance USA Vallivue School District (1139 URS Source: Boise Valley Economic Partnership. 8,489 Government 7,677 Healthcare Services 5,000 Semi Conductor Mfg. 4,235 Retail/Grocery 4,000 Education 3,952 Education 3,407 Healthcare Services 4,000 Laser Printing Div 2,500 Grocery/Retail 2,308 Government 2,200 Education 1,961 Utility 1,800 HQ/Food Production 1,700 Education 1,600 Government 1,400 Customer Service 1,250 Inbound -Credit Card Sales/Service 1,250 Retail Food 1,250 Healthcare Services 1,200 Retail/Grocery 1,100 Customer Service Call Center 1,000 Inbound - 3rd Party (military) 950 Inbound Customer Service 950 Education 900 Construction/Engineering Services (Gov't, Mininq & Power industries) BBC RESEARCH SF CONSULTING SECTION I, PAGE 11 Housing Market Analysis Development trends. Figure I-20 displays the number oEresidential building permits issued in Meridian. As is the case in many communities, residential permitting pealeed in the middle portion of the last decade and drastically declined starting in 2007. Figure 1-20. Residential Permits, 2001 City of Meridian, 2002 2001 to 2010 2003 Source: COMPASS. 2004 2005 2006 2007 2008 2009 2010 Figw•e I-21 examines the number of permits issued in Meridian byproduct type. According to permit data, single family units comprised much of the city's development in the last 10 years. Assuming permits resulted in built units, die largest proportion of multifamily units was constructed in 2008 when 26 percent of all permits were issued for multifamily development. Figure I-21. Percent of Regional Permits by Product Type, City of Meridian, 2001 to 2010 BBC RESEARCH St CONSULTING SECTION I, PAGE 12 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 Number of Residential Permits 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Note: Percentages based on estimates with imputations. Source: U.S. Census Building Permit Estimates. Housing supply. There are currently 26,674 housing units in the City of Meridian. The vacancy rate reported in the 2010 Census was 5.1 percent, indicating that 1,372 of the city's housing units were vacant at the time of the Census. Most units were vacant because they were either for sale (612) or for rent (293). The city's housing marltet has experienced remarkable growth in the last 20 years. The city had approximately 3,700 housing units in 1990 and 12,300 in 2000. The 600 percent increase in the size of the city's housing inventory since 1990 has resulted in the city's evolution from a small farm community to the 3`d largest community in Idaho. Tenure. Between 1990 and 2000, the proportion of homeowners in the city grew from 71 percent to 84 percent. However, the percentage of homeowners decreased in the last 10 years and currently stands at 77 percent, which indicates that 23 percent of the city's households currently rent their home. Figure 1-23. Housing Tenure, City of Meridian, 1990, 2000 and 2070 Source: 1940, 2000 and 2010 O.S. Census. 1990 zooo 2010 Type. Despite the extensive growth in the local housing market, the distribution by type of housing unit has changed very little in the last few years. This means that housing construction in the last 10 years reflected the city's existing housing stock in 2000. The city has lost some of its existing mobile home stock, which has resulted in a larger proportion of single family detached units. Figure 1-25. Distribution by Type of Housing Unit, City of Meridian, 2000 and 2070 Source: 2000 U.S. Census and 2008-2010 American Community Survey. Detached Single Family Attached 2 to 4 Units 5 to 50 Units 50 or more units Mobile Homes SS.Z9G 88.296 2.696 i ~ 2000 2.946 6.096 4.796 1.496 ! i 0.8°,6 0.3°,6 ~ 2010 1.796 4.546 1.896 0°,6 2046 4046 6046 80°.6 1004U BBC RESEARCH ~ CONSULTING SECTION I, PAGE 13 1OD46 8046 6046 40°,5 20°,6 045 Renter 0°,6 20°,6 40?G 60°.6 80°.6 100°.6 Flomeowner Age. Given the city's rapid growth in the last 20 years, it's no surprise that nearly 90 percent of the city's housing units were constructed after 1)90. However, there are homes in Meridian constructed in the 1970s, indicating that 6 percent of the city's homes are approaching 40 years of age. Figure I- 26 displays the age distribution of the city's housing stock. Figure I-26. Age Distribution of Housing Built 2005 or later Stock, City of Meridian, 2010 Built 2000 to 2004 Built 1990 to 1999 Source: Built 1980 to 1489 2010Ameri<an Community Survey. Built 1970 to 1979 Built 1960 to 1969 Built 1950 to 1959 Built 1940 to 1949 Built 1939 or earlier Housing demand and cost. This section discusses the cost of housing for both rental and homeownership housing. It then discusses demand and gaps in provision of housing to determine the greatest housing needs in Meridian. Rental costs. The gross median rent in the City of Meridian in 2010 was $9G5, which was an increase of 53 percent from the 2000 median rent of $629. The city's median gross rent is significantly higher than the median gross rent for Ada County overall ($751), as well as neighboring Boise $718. 2 Figure I-27 displays the distribution of gross rental rates within the City of Meridian in 2000 and 2010. In the last 10 years, the city's rental rates have become increasingly more expensive. In 2000, residents would be challenged to find a unit requiring a rent of $1,000 or more; currently, half the city's rental units have rents of $1,000 or snore. z The Census Bureau defines gross rent as "the amount of the contract rent plus the estimated average moutlily cost of utilities (electricity, gas, water and sewer) and fuels (oil, coal, kerosene, wood, etc.) if these are paid fnr by the renter (vr paid for the renter by someone else). BBC RESEARCH & CONSULTING SECTION I, PAGE 14 U~/o lU"/o LU`Yo 3U% 4UK'o IUl)% Figure I-27. Gross Rental Rate Less than $250 Distribution, City of Meridian, 2000 and 2070 $250 to $499 source: $500 to $749 2000 and 2010 Census. $750 to $999 $1,000 to $1,249 $1,250 to $1,499 $1,500 or more Renter incomes have increased in the last 10 years to account for increased rental rates. The median household income of a renter household in 2000 was $27,148; it was $38,494 in 2010. While the city's median renter household income did not grow as quicldy rental rates in Meridian, the median household income of renters is enough to afford the city's median gross rental rate. Despite increases in renter's income, the city's median yenta( rates now require a larger proportion of renters' household income. Median gross rent as a percentage of renter household income in 2000 was 26 percent; the 2010 ACS reported that the percentage had increased to 33 percent. HUD's generally accepted definition of affordability is for "a household to pay no more than 30 percent of its annual income on housing."' On average, Meridian's renter households slightly exceed HUD's affordability standard. Rental gaps. To understand more specifically where the rental market in Meridian fails to meet residents' needs, we performed an exercise called a "gaps analysis." The gaps exercise compares the supply of rental housing at various price points to the number of households who can afford such housing. If there are more rental units than households, the marlcct is "over-supplying" rental housing at that price range. Conversely, if there arc too few units, the market is "under-supplying" housing. Figure I-28 displays the results of the rental market gaps analysis. htt~//~s~sw.hud.gov/offices/cpd/affordablehousin~/ BBC RESEARCH St CONSULTING SECTION I, PAGE 15 0°.6 1036 20°.6 30.6 40°.6 50;6 100°,6 Figure I-28. Mismatch in Rental Market by Household Income, City of Meridian, 2010 f:\rtC i_i_ir ii_~~~ ~1~r;I v I rfaali5r!Iii~ fPrad h r%it rr%~ Srs"?!a; ~fi! IhP~HFt=lit•fl~i _ I;t_-1i C?.-1~~ ~ Lait.7~4k111_~I;tait~ V(t~11ir~: 9Etirri~n['~lif~r!rit[~9) L'3~~ii5t11 ~ nitd,~i~~c~I;i-rK~~~; ,~~r»~;rrr:,. r~r~~.,re!~,,::~ ~rr;rai~~ti,t_~rrrrrr,~-~~i r.vrrr~r;.~~ iii=~~_~:~;ttr.r~~ _ ~~~~ Less than $10,OD0 682 12°.6 $ 250 229 4°.v (453) $10,000 to $14,999 442 8°h $ 375 197 345 (245) $15,000to$19,999 336 6°.6 $ 500 74 1°~6 (262) $20,OOD to $24,999 270 546 $ 625 153 2°.6 (11 7) $25,000 to $34,999 703 1346 $ 875 1,768 2945 1,065 $35,000 to $49,999 1,037 18°h $ 1,250 2,804 4646 1,767 $50,000 to $74,999 1,371 24°.6 $ 1,875 775 13°.6 (596) $75,000 to $99,999 357 6°,6 $ 2,500 147 245 (210) $100,000 to $749,999 288 596 $ 3,750 0 0°,6 (288) $150,000 or more 123 2°~ $ 3,751 D D96 (123) Total 5,609 100°rb 6,147 Source: BBC Research & Consulting. As shown in Figure I-28, there are 682 renters earning less than $10,000 per year living in Meridian-but just 229 units to serve them. This leaves a shortage of 453 units for the city's lowest income households. These renters have such low incomes that they can only afford to pay $250 per month in rent. Altogether, the City's rental gap is 1,077 for renters earning less than $25,000 per year. Renters earning more than this can find an adequate supply of units. In particular, renters earning between $25,000 and $50,000 have an abundance of units affordable to them. The City's highest income renters could pay more in rent than what the market has available to serve them; however, these renters likely pay less than their maximum affordable rent to save for a down payment for a home purchase. Owner costs. The median value of an owner-occupied home in the Ciry of Meridian is $190,400 according to the 2010 Census. By comparison the median home value in Boise is $188,900. In 2000, the Census estimated Meridian's median borne value to be at $1 19,800. Based on these estimates, the median has increased by $70,600 (59%), or by an average of $7,060 per year. BBC RESEARCH ~I CONSULTING SECTION I, RAGE 16 Figure I-29 demonstrates how the city's owner-occupied housing market has changed in the last 10 years. More than half the ciry's homes were valued between $100,000 and $150,000 in 2000. Many of those homes likely appreciated between 2000 and 2010, and are now valued higher than $150,000. Additional changes to the distribution of the ciry's housing market are likely attributed to new construction that occurred in the last 10 years. New construction likely favored homes valued at $200,000 or more. Figure 1-29. Owner-Occupied Home Less than $50,00( Value Distribution, City of Meridian, 2000 and gso,ooo to $99,995 2010 $100,000 to $149,995 Source: $150,000 to $199,995 2000 and 2010 Census. $200,000 to $299,995 $300,000 to $499,999 $500,000 to $999,999 $1,000,000 or more The housing market downturn impacted Meridian profoundly both in sales activity and sales prices. In the last four years, the average sales price has declined by 37 percent, And, 2010 produced the lowest number of annual sales of the last five years. Figure I-30. Frequency and Average Sales Price of MLS Sales, City of Meridian, 2006 to 2070 Source: COMPASS and Intermountain MLS . •~=1~cCi IF~i((~t~ ~i ,. ~ 2006 3,271 $ 269,515 2007 1,864 $ 167,924 2008 1,464 $ 234,706 2009 1,614 $ 187,171 2010 1,426 $ 168,547 BBC RESEARCH St CONSULTING SECTION I, PAGE 1 ~ 0°,5 10°.6 20°,6 306 40°,6 5045 605 100°h Figure I-3l maps the 2010 median sales price by Census tract. There was no portion of the city that did not experience a decline in home prices in the last five years. Average sales prices declined by 35 to ~U percent in every Census tract in the city but one (103.31). Figure 1-31. Average MLS Sales Price by Census Tract, City of Meridian, 2010 Source: COMPASS and Intermountain MLS . Foreclosure Analysis According to RealtyTrac, there were 324 new foreclosure filings in Ada County in November 2011. This foreclosure rate indicates that one in every 485 homes in the county received a foreclosure filing in November 2011. This was a higher foreclosure rate than the State of Idaho (one in every 77(1 housing units) and the U.S. overall (one in every 579 housing units). Meridian's housing stock represents 17 percent of the county's housing stock. Assuming foreclosures in Meridian occur in proportion with the city's contribution to the county's housing stock (17%), Meridian may have had 55 foreclosure filings just in November 201 l . BBC RESEARCH SI CONSULTING SECTION I, PAGE 18 Figure II-40 maps the percentage of bank owned properties of total home sales in 2010 by block group. Since foreclosures are not identified in the MLS, bank owned properties arc used as a proxy for foreclosures. Bank owned properties accounted for 30 to 50 percent of all home sales in 2010 in most of the ciry's block groups. The proportion of banked owned properties of total safes exceeded 50 percent in two of the city's block groups. Both block groups were located in central Meridian. Figure I-32. Percent Bank Owned Properties, of Total Sales by Block Group, 2070 Source: COMPASS and 66C Research & Consulting. Transportation Like many western communities, residents in Meridian and the Boise region are primarily dependent on cars for transportation. Nearly 80 percent of Meridians residents drove alone to work each day. And, less than 1 percent of the city's workers relied on public transportation for their work commute. The Boise region is served by Valley Regional Transit (VRT), which provides public transit For both Ada and Canyon counties. Figure I-33 displays VRT's inter-county bus lines. The purpose of the inter-county bus line is largely to connect Boise with the City of Nampa; however, Meridian is served along Interstate 84, Stakeholders and residents engaged during the public input process both noted that public transportation opponunities are very limited in Meridian, Means of transportation to work statis[ics from the 20 ] 0 American Community Survey 1-year estimate. BBC RESEARCH ST CONSULTING SECTION I, PAGE 19 Figure 1-33. Valley Regional Transit Bus Lines, City of Boise, 2017 ,~ _ ~~ ~P ~~~IC~WCI~ ~c~C~~C ~; s ~ ti e' c \~~.~ ~~. College oF'i r_arrn lda ~. _~ V ~~~ Franklin Rd. y` • K:~rh rf ~!I •~ /i~ @ //'~~ ~ry ° +t ~~... v {sJ C?rcrland f -! ..--~ ~ 3 rt AS t,p7 ~ ~ S td~trr L~r~.~~~r !+ I anli•:•n . f- a ~n,~ a hide: ~~ ~~ :,. r..~ is ~~ t -r~ uu~. a u Source: Valley Regional Transi[. Public transportation for special needs population. The VRT's ACCESS program is a paratransit service for regional residents with disabilities who are unable to access Va1lcyRide's traditional bus services. ACCESS is an origin to destination transit service operating Monday through Saturday with the same hours as the fixed-line bus system. ACCESS will travel up to three-fourths of a mile off fixed-line routes for service pickups. If residents live further than three-fourths of a mile from affixed-line service, they must get to a bus stop to receive ACCESS services. The Meridian Senior Center transports homebound seniors from their homes to the Meridian Senior Ccntcr Monday through Friday for lunch. Every Wednesday, the Senior Ccntcr will also take seniors to Albertsons for gt•ocery shopping. BBC RESEARCH & CONSULTING SECTION I, PAGE 20 SECTION I1. Public Policies and Practices SECTION I1. Public Policies and Practices This section reviews city zoning and land use policies, as well as the policies and practices of the Boise City Ada County Housing Authority (BCACHA), For barriers to fair housing choice and violations with the Federal Fait Housing Act. The section also contains the results of an examination of a sample of Homeowners Associations' covenants. It concludes with an overview of city goals and objectives related to housing and community development. Public Housing Authority BCACHA serves as the housing authority for the Ciry of Meridian, as well as Ada County, and provides housing to the city's lowest income households primarily through the Section 8 voucher program and public housing units. Section 8 Voucher Program. The BCACHA administers 1,794 Section 8 vouchers in Ada County. Most BCACHA vouchers are used within the Ciry of Boise (64%). The remaining .3G percent of vouchers are spread throughout the remaining portions of the county, including Meridian. The BCACHA currently administers 185 vouchers to residents of Meridian. Figure II-7. BCACHA Section 8 Waitlist, Household Demographics, City of Meridian, 201 7 Applicants on Active Waitlist Household Characteristics Families with children Elderly families Families with disabilities As of May 2011, there were 5,331 households on the Section 8 waitlist. It is likely that as many as 550 Meridian households are currently waiting for a Section 8 voucher.) The BCHACHA estimates that households on the waitlist will wait four to five years for a voucher. Income Extremely low income Very low income Low income Race/Ethnicity American Indian/Alaskan Native Asian Black/African American Figure lI-1 displays the demographic Native Hawaiian/Pacific Islander characteristics of all households on the white Section 8 waitlist. Waitlisted households Hispanic Non-Hispanic 5,331 100% 2,920 559'0 495 990 2,064 3996 4,449 820 23 83% 1596 096 127 211 394 63 4,237 523 4,053 2% 4% 7% 1% 7996 10% 7696 are largely categorized as extremely low i neome. African American and Hispanic Note: Demographic data is not provided for all applicants. Household characteristic income and race/ethnicity categories will not sum [0 100 percent. residents are disproportionately represented Source: BCACHA. on the Section 8 waitlist; AFi'ican Americans account for less than 2 percent of the city's population, but 7 percent of waitlisted households. r The BCACHA does not differentiate between City of Boise and Ada County applicants on the waitlist Meridian residents account for ] 0 percent of all voucher recipients, and are assumed to account for 10 percent of all waitlisted households. BBC RESEARCH ~F CONSULTING SECTION II, PAGE 1 Section 8 policies. According to BCACHA's website, households can check their status on the waitlist online or by calling or visiting the BCACHA ofFice. Households are notified by mail when a voucher becomes available to them. To stay on the Section 8 and/or public housing waitlist, residents must report changes of address, phone, household members or local preference in writing within 10 working days of the change. Residents must also respond to requests made by the BCACHA. Faihue to abide by these rules may result in the removal of residents from the waitlist.2 This information is presented on the rental assistance application found on the BCACHA's website. The online application is only available in English. The BCACHA closed its Section 8 waitlist on April 29, 2011citing "large demand for rental assistance in the community, a limited amount of funding and federal budget cuts." 3 The BCACHA also recently suspended all Section 8 waitlist preferences, with the exception of the following categories: ^ Applicants with a Family Unification Program referral from the Department of Health and Welfare; ^ Applicants with a Homeless Program rcfcrral from one of the BCACHA recognized referring agencies; ^ Applications with a CATCH program rcfcrral from the City of Boise; ^ A household whose head or co-head (or at least one adult member) is working at least 20 hours per week, with verifiable income or whose head or co-head is participating in a BCACHA recognized job preparedness/self-sufficiency program or a household whose head or co-head is either elderly (62 or older), and/or handicapped and unable to work; and ^ A household whose head or co-head is fleeing their home due to domestic violence. If a household does acquire a Section 8 voucher, the BCACHA provides assistance to recipients in the following ways: ^ The BCACHA provides recipients with information on the location of accessible units in the region; ^ They provide residents with an online checltlist to evaluate apartments. The BCACHA encourages residents to evaluate the condition of the unit and the neighborhood; the cost of utilities; and the home's proximity to public transportation, employment, schools, medical facilities and shopping. ^ The BCACHA encourages residents to find housing outside of high poverty areas in hopes of increasing access to good schools, job opportunities, better quality housing and responsive landlords. Z These policies are presented on the rental assistance applications found here: ht~:/hvww.hcacha.orglrental assist app ] 2- 07-2009.pdf s For more information o» the Section 8 program: httpa/www.BClACHA.org/Rental Assistance/Section_8/section_8.html BBC RESEARCH Si CONSULTING SECTION II, PAGE 2 Public housing. The BCACHA has 230 public housing units located in Boise. There are no public housing units in Meridian. Both facilities serve elderly residents and persons with disabilities. Both facilities contain a mix of studio, one bedroom and two bedroom apartments. The BCACHA also manages five scattered site duplexes in Boise with federal aid from HUD. If a Meridian resident was interested in moving into a public housing unit, they could obtain a public housing application at the BCACHA office or online. Applications must be mailed or hand delivered to the BCACHA office in Boise. The BCACHA website can be interpreted into many languages through the Uoogle Translate tool; however, the public housing application is only available online in English. There arc currently 168 families on the waitlist for public housing units. It is unknown whether any of these families currently reside in Meridian. The average wait time for a public housing unit ranges from three months to two years depending on the unit size requested. Figure II-2 summarizes the demographic characteristics of families on the public housing waitlist. Nearly all households on the waitlist (93%) have a household member with a disability. Figure II-2. BCACHA Public Housing Unit Waitlist, 2011 Note: Demographic data is not provided for all applicants. As such, household characteristics, income and race/ethnicity categories will not sum to 100 percent. Source: BC/AChIA. Applicants on Active Waitlist 168 100% Household Characteristics Families with children - 0°6 Elderly families 34 20°r6 Families with disabilities 1S6 93°.6 Income Extremely law income 7 4°6 Very low income 2 1 °.6 Low income 2 1 °~fi Race/Ethnicity American Indian/Alaskan Native 3 2°.6 Asian 2 1 °6 Black/African American 10 6°.6 Native Hawaiian/Pacific Islander 1 1°h White 138 82°,6 Hispanic 15 9°.6 Non-Hispanic 114 6846 BBC RESEARCH r;I CONSULTING SECTION II, PAGE 3 Limited English Proficiency policy. Title VI of the Civil Rights Act of 1964 is "the federal law that protects individuals from discrimination on the basis of their race, color, or national origin in programs that receive federal financial assistance."4 Compliance with Title VI requires that recipients of federal dollars provide language assistance to individuals with limited English proficiency (LEP). Otherwise, "failure to ensure that persons who are limited English proficient (LEP) can effectively participate in, or benefit from, federally assisted programs may violate Title VI's prohibition against national origin discrimination."5 In 2007, HUD issued guidance to help federal assistance recipients understand their obligations to serving individuals with LEP. HUD suggests federal assistance recipients conduct afour-factor analysis to determine how to best service LEP individuals (explained below); develop a Language Assistance Plan (LAI'); and provide appropriate language assistance to LEP individuals. HUD's four-factor analysis is a "flexible and fact-dependent" approach to helping federal assistance recipients determine which LEP populations to serve and how to best serve these populations. The four-factor analysis includes identifying the following: ^ The number of proportion of LEP pet•sons eligible to be served or likely to be encountered by the program or grantee; ^ The frequency with which LEP persons come in contact with the program; ^ The nature and importance of the program, activity or service provided by the program to peoples' lives; and ^ The resources available to the grantee/recipient and costs. In addition to the four-factor analysis, HUll provides more specific guidance for Title VI compliance. HUD recommends recipients provide written translation of vital documents and oral translation of non-vital documents for LEP languages if the LEP group represents either 5 percent of the total population or 1,000 persons. HUD recommends that federal assistance recipients develop a language assistance plan (LAP) to describe how they intend to serve LEP individuals in their communities. The BCACHA's LAP was last updated in 2004, prior to HUD's 2007 guidance. According to the BCACHA's LAP, the housing authority is committed to quickly connecting LEP individuals to interpreters at no cost to the individual. BCACHA explicitly states that friends or family members of the LEP individual are not valid interpreters. Instead, the BCACHA utilizes bilingual staff members when available and a telephone interpreter service known as the Language Line Services. InFarmation on Title VI and HUD programs can he found here: http://portal.hud.~ovt, /hudportal/HUD?src=/ program offices/fair housine equal opt/vro~ moringFhllep-faq s IBID. c BBC RESEARCH & CONSULTING SECTION II, PAGE 4 The BCACHA's implementation plan dots not specify when written interpretation of vital documents will be provided for residents, which is an important component of HUD's 2007 Title VI guidance. However, the BCACHA's rental assistance application for its Section 8 and public housing programs does aslc residents whether they need assistance with language interpretation. Assisted Housing Units The following summarizes the city's inventory of affordable housing units directly owned and operated by the city or constructed with federal subsidies and tax credits. Assisted units. There are 50 assisted units in Meridian developed from federal subsidies. All units are contained in one building, the James Court Apartments, located in central Meridian. The affordability requirement of this facility is set to expire in 2018. Figure II-3. Units with Subsidized Rent, City of Meridian, 2011 Source: U.S. Department of Housing & Urban Development. Land Use Policy Review The following section reviews important pieces of the city's overall land use policy. This includes a review of how land use decisions are made and approved and the long-range growth vision for the city. Additionally, a HUD checklist was used to conduct a general analysis of the city's zoning code. Planning and Zoning Commission. Meridian's Planning and Zoning Commission is responsible for reviewing all zoning changes and conditional use applications. All five members of the Commission are appointed by the Mayor and confirmed by the City Council. The Planning and Zoning Commission is responsible for upholding the city's land use policies and ensuring that all planning decisions support the city's development goals, objectives, and action items. According to city staff, the commission very rarely recommends denial of housing developments as long as they align with the city's adopted land use policy plan, and public opposition alone is not a reason for the cotntnission to recommend denial of a proposed project or development. Comprehensive Plan. During 2010-2011, the city updated its Comprehensive Plan. The process commenced in early 2010 with a town hall meeting and revised goals, objectives, and action items were adopted by the Planning and Zoning Commission in March 2011. The Ciry Council conducted a public hearing and adopted the updated Comprehensive Plan in April 2011. The updated Comprehensive Plan was based upon the concerns and expressions of the community, as well as the Existing Conditions Report that was adopted concurrently as an addendum to the plan. The Existing Conditions Report includes background information and analysis about the built and natural environment in Meridian in 2010, trends, and a strategic plan for the future. BBC RESEARCH bi CONSULTING SECTION II, ('AGE 5 The ldaho State Code requires that Idaho communities examine a number of community development categories in their Comprehensive Plans including land use; school facilities and transportation; housing; and economic development. The city's Comprehensive Plan examines these elements within the fi•ameworlc of seven key community values: ^ Manage growth to achieve high-quality development; ^ Enhance Meridian's quality of life for all current and future residents; ^ New growth should finance public service expansion; ^ Prevent school overcrowding and enhance education services; ^ Expand commercial and industrial development; ^ Improve transportation; and ^ Protect Meridian's self-identity. The Comprehensive Plan states, "opportunities for housing should be available for all income groups with a mix of housing including modular, ranchettes, townhouses, apartment housing, low-income housing, and mansions. A vibrant community needs a good cross-section of housing and therefore must guard against an abundance of subdivisions in like density and price range. High-density housing must be strategically located to public transportation, COmIIlUIIIry SCIVICCS, and not negatively affect property values."G Related to the goal of offering a diversity of housing types for a great range of choice arc several action items listed in the City's Comprehensive Plan. Those action items are as follows: ^ Adopt land use designations that will allow for housing oppot•nrnities For all income levels. ^ Support a variety of residential categories (low, medium, medium-high, and high-density single- family, multi-family, townhouses, duplexes, apartments, condominiums, etc.} for the purpose of providing the City with a range of affordable housing opportunities. ^ Require an open housing market for all persons, regardless of protected class, ie: race, sex, age, religion, disability, handicap, family status or ethnic background. ^ Ensure that no discriminatory restrictions are imposed by local codes and ordinances. ^ Loolc for incentives to encourage the development of accessible, single-family home designs. ^ Provide for a wide diversity of housing types (single-family, mobile homes and multi-family arrangements} and choices between ownership and rental dwelling units for all income groups in a vat•iery of locations suitable for residential development.' The Comprehensive Plan states, "The City of Meridian, as a recipient of the CDBG federal funds, and its partnering non-profits, are obligated to not discriminate in housing or sewices directly or indirectly on the basis of race, color religion, sex, national origin, age, familial status, or disability."~ G Ciry of Meridian Comprehensive Plan, Adopted April 19, 2011: page 36 ~ Ciry of Meridian Comprehensive Plan, Adopted April 19, 2011, }>age 53-55 s Ciry of Meridian Comprehensive Plan, Adopted April 19, 2011, page 82 BBC RESEARCH Si CONSULTING SECTION II, PAGE 6 Zoning code review. To evaluate potential fair housing concerns within the city's zoning code, a "Review of Public Policies and Practices (Zoning and Planning Codes)" form recently circulated by the Los Angeles fair housing office of HUD was utilized. This section poses the ducstions from this checklist, along with responses about the city's code. Does the code definition of `family"have the effect of discrirrcinating against unrelated individuals zuit/~ disabilities zuho z•eside together in a cangz•egate orgroccp living arrangement? The City's code defines dwelling or dwelling unit as any structure, or portion thereof, providing independent living facilities for one "family" as herein defined, including provisions for living, sleeping, eating, cooking, and sanitation. The City's code defines the term family as A) a person living alone or two or more persons related by blood or marriage; B) A group of not more than ten persons who need not be related by blood or marriage living together in a dwelling unit, C) Eight or fewer unrelated mentally and/or physically handicapped or elderly persons residing in a dwelling under staff supervision, provided that no more than two staff members reside in the dwelling at any one time. Thus, group living for individuals with disabilities is allowed at the same level as individuals without disabilities, and group homes are allowed in all residential districts. The code does not discriminate against unrelated individuals with or without disabilities. The Meridian City Code does not reference Idaho State Code Section G7-G53] which defines a single family dwelling to include "any group residence in which eight (8) or fewer wtrelated persons with disabilities or elderly persons reside and who are supervised at the group residence in connection with their disability or age related infirmity." However, the Meridian code does restrict the number of physically handicapped or elderly persons living together to eight persons when there is a need for supervision, similar to the State code. ZozzingRegulation I»zpedi»zent: Does the Code definr.•tion of family"have the effect ofdiscri»zinating against unrelated individuals with disabilities zuho reside together in a congregate orgr•orap living arrangement? N/A, sec above. Zoning Regaclatio» Izrzpediment.• Does the Code definition of "disability" the sa»ze as the Fair HousingAct? The Zoning Codc does not provide a definition of "disability," "disabled" or "handicap." P~czctice hnpediment: Does the zoning ozdizzance restrict hausi»g opportunities for individuals with disabilities and nzr'scharacterizesueh housing as a Goazzling or rooming house"or `hotel"? No. As discussed above, individuals with disabilities may live together in asingle-family dwelling unit. The Ciry code does not have a definition for boarding or rooming house. Practice Izzzpedinzent.• Does the zozzirag ordinazzce dezzy housing opportunities for disability individuals with ozz sr.'te hozrsingsupportiragservices?The definition of family that addresses individuals with disabilities recognizes the need for supervisors, which is linked to on-site support services. However, Meridian's Code does not go beyond that definition to address support services for individuals with disabilities living together in a single family dwelling unit. Does the jurisdiction policy allow azzy number of unrelated pe~sa»s to reside togethez; bzzt restrict szzch occupancy, if the residents are disabled? No. The City code restriction on the number of unrelated persons who may reside together is the same for all residents, regardless of ability. BBC RESEARCH ~i CONSULTING SECTION II, PAGE 7 Does the jurisdiction policy not allow disabled persons to make reasonable modifications or provide reasonable accommodation for disabled people who live in municipal-supplied or managed residential battling?There are currently no municipal supplied or managed residential housing units in Meridian. Does the jurisdiction re~rtire a public hearing to obtain public input for specific exceptions to zoning and land-ttse rules for disabled applicants and is the hearing only for disabled applicants rather than for all applicants? No. Public hearings arc required to obtain a conditional use permit or zoning variance, but the hearing is not specific to persons with disabilities. Does the zoning ordinance address mixed rases? Hoau are the residential land arses discussed? What standards apply?Yes. The Meridian City Code does encourage mixed use, and there are 8 different future land use designations and 3 zoning districts. Depending on the type of mixed use area envisioned, and the zoning district, land uses are discussed/addressed differently. Some of the mixed use land use designations prohibit residential altogether, some have a minimum number of residential required, and some have a maximum. The emphasis in the Ciry of Meridian Design Manual is on promoting aesthetically pleasing mixed-use developments within neighborhoods and building designs that vertically integrate mixed-use structures and/or horizontal mixed-use forms to create compact developments. Does tl~e zoning ordinance describe any areas in this jurisdiction as exclusive? No. Are there exclzasions or discussions of limiting hoaasing to any of the followinggronps: r ~tce, color sex, religion, age, disability, marital stattas or familial status and/nr creed of national origin? No. Are then c any restrictions for Senior Hoaasircg in the zoning ordinance? If yes, do the restrictions comply with Federal late on housing for older persons (i. e., solely occzapied by persons 62 years of age or older or at least one person 55 years of age and has significant facilities or services to meet the physical or social needs of older people)? No. Does the zoning ordinance contain any special provisions for making /~oaasirag accessible to persons with disabilities?No. However, Meridian City Code 7-15-2.A, Fair Hauling, states: With available resources, the City will assist all persons who feel they have been discriminated against because of race, color, religion, sex, national origin, disability, or familial status to seek equity under Federal and State laws by filing a complaint with the U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Compliance Division. Does the zoning ordinance establish occzapancy standards or• maximum occtaparacy limits? Only based on the definition of family which provides for a maximum of 10 unrelated persons in one dwelling unit. No other maximum occupancy for a residential dwelling unit. Does the zoning ordinance inclarde a discrassiorr of fair hoaasing?The zoning ordinance does not include a discussion of fair housing, but City code 1-15-2 contains the City's Fair Housing Ordinance which outlines how the City will assist those who feel they have been discriminated against and how the Ciry will promote and publicize the Federal Fair Housing Law. BBC RESEARCH &F CONSULTING SECTION II, PAGE 8 Descz•ibe the mizzimzznz standards and amenities z•e~uired by the oz~linance for a mzzltiple family project tuith respect to handicap parking. Meridian zoning code requires compliance with ADA accessible parking standards. Does the zoning code distingzcish senior citizeza hozzsirzg from other single family residential and multifamily resr.'derztial zzses by the application of a conditional zzse permit (cup)? No. There is no separate definition for senior citizen housing. Does the zoning code distinguish handicapped hnzzsizzg from other single family residential and multifamily residential zzses by the application of a conditional zzse perrnit (cup)? Na. How are "special grorzp residential hozzsizzg"defined in the jzzrisdictinzz zoning code? There is no definition for special group residential housing or similar term. The term family is used, and sometimes Nursing or Residential Care Facility is used to define/classify a use. A Nursing or Residential Care Facility (NAILS Code 623) is defined as the "use of a site for providing assistance to individuals needed to perform the routines of daily life. The use includes, but is not limited to, children's treatment facility, assisted cat•e, skilled nursing facility, residential care facility and drug and alcohol treatment facility." Does the jzzrisdiction's planning and bzzildizzg codes presently nzalze specific reference to the accessibility re~uirenzerzts contained in the 1988 amendment to the Fair Hozzsing Act? Is there any provision far morzttorizzg compliance?There is no reference to the Fair Housing Act in the zoning code and no provision for monitoring compliance. Meridian City Code Title 1, Chapter 15 discusses Fair Housing discrimination and complaint procedures. The Meridian Building Code (200`) IBC, IRC) does contain accessibility requirements. The code references American National Standards Institute (ANSI) A 117.1 which contains similar language to accessibility requirements contained in the 19$8 amendment to the Fair Housing Act. The city actively enforces its building code to ensure compliance with the Fair Housing Act's construction and design guidelines. Other Public Sector Programs and Services City housing and community development activities. Meridian wotlcs to ensure that residents have adequate and affordable housing by partnering with the Ada County Housing Authority (ACHA) and Neighborhood Housing Services (NHS) to provide down payment and closing casts assistance to low and moderate income homebuyers through the City's Community Development Block Grant program. COMPASS. The Community Planning Association of Southwest Idaho (COMPASS) serves as the metropolitan planning organization (MPO) for the Boise region. Unlike some states, regional planning organizations and jurisdictions in Idaho are not required to establish and monitor regional and local affordable housing development goals. Instead, COMPASS and other regional planning organizations in the state function as traditional MPOs, whose primary objectives include developing a regional transportation plan that adheres with federal regulations, allocating transportation improvement program fw~ding and serving as a conduit of regional demographic, land use, transportation and GIS data and information. BBC RESEARCH ST CONSULTING SECTION II, PAGE 9 COMPASS is an active regional planning organization and many of COMPASS'S past and current studies encourage the coordination of transportation and land use planning to promote higher density development and transportation access. Public service provision in LMI areas. The city has served the defined LMI area in a variety of ways to ensure that municipal services arc equally provided for throughout the community. The city recently used its CDBG fitnds for improvements to Centennial Parlc, located directly south of one of the city's identified LMI Census tracts. The improvements included the installation of a state-of-the- art NEOS 360 electronic play system, a picnic shelter, bike racks and game tables. The city has used CDBG funds to design improvements to sewer and water lines within the LMI area, and those improvements were recently constructed and paid for with city general funds. The main branch of the Meridian Library is located directly north of an identified LMI Census tract, and the Meridian Community Center which offers a wide variety of classes and activities, is located directly south of an identified LMI census tract. The city has used CDBG fitnds for the design of a segment of the Five Mile Crcck Pathway within the LMT Area. CDBG funds will also be used to construct this pathway segment in 20T 2. This pathway segment will provide an important recreational opportunity as well as an alternative transportation corridor. In addition to the location of these municipal services, the city has coordinated a Community Clean- Up Day for the past 7 years. This Clean-Up Day has taken place within the downtown core of the city, at the heart of the identified LMI Area. The city's contracted waste collection company, SSC, is one of the primary partners For this important community event, and all the metal recycling money collected during the day is given to a local charity. Environmental justice. Title VI of the Civil Rights Act of 1964 requires consideration of the environmental and human health condition in minority and low income communities. Consideration of these areas must include an identification of geographic concentrations of minority and low income areas and analysis of benefits or burdens resulting from activities (e.g., transportation planning) that take place in these communities. The figure on the following page identifies COMPASS' "areas of environmental justice consideration" in Meridian and the Boise region. Meridian has one Census tract identified as an area of environmental justice (EJ) consideration. Currently, COMPASS reviews areas of EJ consideration for new projects. COMPASS tries to determine the impacts new projects (e.g., roadway, transit stop) will have on EJ areas, but projects arc not fiutded simply because they fall within an EJ consideration area.' Currently, the Denver Regional Council of Governments (DRCOG) awards points during the scoring process for transportation projects located in EJ consideration areas. BBC RESEARCH & CONSULTING SECTION II, PAGE 10 N O N V 10 a C 0 ~c u N b i 4 C O 'i+ i v .a C .y v a v C C i .~ W ~ wN Q' ~ ~, ~ 'u. V ~ R 8 8~0 i ~ !•/ ~ j1 /fJ E S ab§ C ~ W P E ~ V b ~c '.. r__ i. ' ...... . T ~ ~Se~ ; - ~ l.__ . oa ~ ~ ~ _ , '• ~ L + ~ - ~ ~.~, , ~ - _ i ,,. ~ _ L 1 r , I . _~-, t? ~,- T , - - r r _ ~ ~ .~ _ l' _ • ' ~ J _ , _ I +_~I II . ~ „~ ., f o j' c , 1 ~ IU f ~ 1 + 7 f t t ~ ' ~ ` ~ VJ tq N t 1~ I-tL ( ~ U S ~~r. rT~~~ I-,~ ~ ,~ „j -~ 1~ ~.~ , f _ V .U C yF ~~{ f ~ li ' JI. 4 ~ J frl . ~ - ,. -~ ~ ~ oho ~ r _ .Ir- ,, + ~ j _,., f . ~ ~:+ : a ~ U o - - : i; , L r ~ ~ ~ ~ _ - r. ~.11 ~ ' ~ 1 .. _ J... ~ ~. f ~ ~ ~ ,: + , r w ' ' ~ ~~ ,i ~ r 1 - ~,, _ __: ~ ~ ~ JJ ~...~ t /~ --- - ~~ ,! r J ~ W V x ~ ~ ~ ~ ~ ~ ~ ~ T a t v ~ ° uuau ~ ~ b , E a ~ ~ r r ~ f~ ~ ~ 9~_Ag n ~ u 6 ~ ~ t~ ~ ~ 4 ~ ` ~ R . ~~. , ~~~J[J ~~ ~ r ~~ ~ W V Q z U v Z J z 0 V V w N V m m SECTION III. Fair Lending and Complaints SECTION III. Fair Lending and Complaints This section of the City of Meridian AI is divided into two sections. The first section reviews fair housing complaint data and legal cases related to fair housing violations to highlight the prevalence of and trends in fair housing violations. The second part of this section contains an analysis of mortgage loan and community reinvestment data to detect fair lending concerns. Fair Housing Complaints The Federal Fair Housing Act, passed in 1968 and amended in 1988, prohibits discrimination in housing on the basis of race, color, national origin, religion, gender, familial status and disability. The Fair Housing Act covers most types of housing including rental housing, home sales, mortgage and home improvement lending, and land use and zoning. Excluded from the Act are owner-occupied buildings with no more than four units, single family housing sold or rented without the use of a real estate agent or broker, housing operated by organizations and private clubs that limit occupancy to members, and housing for older persons.' HUD has the primary authority for enforcing the Fair Housing Act. The State of Idaho's fair housing act prohibits discrimination on the basis of race, color, sex, religion, national origin and disability. It does not recognize familial status as a protected class. The law is also different from the Federal Fair Housing Act in that it covers providers with two or more units or properties. The state's fair housing law is enforced through the Idaho Human Rights Commission. The City of Meridian does not have a fair housing ordinance. Contacts for complaints. Meridian residents who feel that they might have experienced a violation of the Fair Housing Act can contact one or more of the following organizations: ^ HUD's ~Ffice of Fair Housing and Opportunity (FHEO); ^ The Idaho Housing and Finance Association (IHFA}; ^ The Intermountain Fair Housing Council (IFHC); ^ Idaho Legal Aid; and ^ The Idaho Human Rights Commission. Legal Aid and the Idaho Human Rights Commission refer residents who call about fair housing complaints directly to HUD. Similarly, IHFA does not enforce fair housing law and refers complaints or questions to the appropriate service provider. The city was a sponsor of the City of Boise's fair housing public awareness campaign in April 2011. The campaign was called Good Neighbors + Fair Hoarsing =Strong CornmrGnities and was intended to increase community awareness and understanding of fair housing rights and responsibilities. Fair This is a very general description of the Fair Housing Act and the actions and properties covered by the Act. For more detailed iuformaiion on the Pair Housing Act, please see the full text, which can be found on the U.S. Deparunent of Justice's website, www.usdoj.gov/crdhausinghide8.hun. BBC RESEARCH Si CONSULTING SECTION III, PAGE 1 housing messages were spread to Treasure Valley residents through radio and television public service announcements, billboards, bus panels, bus benches and community presentations. The initiative was supported through the financial contributions of 15 partners, inchtding Idaho Housing and Finance Association (IHFA), the Idaho Department of Health and Welfare, local banks, Valley Regional Transit and local broadcasting companies. HUD complaint investigation process. Housing discrimination complaints filed with HUD may be done online at (httpa/www.hud.gov/complaints/housediscrim.cfin), toll free at 1-800-669-9777, ar by contacting the Office of Fair Housing and Equal Opportunity in Washington D.C. or Idaho's Fair Housing Hub located in Seattle, Washington. When HUD receives a complaint, HUD will notify the person who filed the complaint and will normally notify the alleged violator and allow that person to submit a response. The complaint will be investigated to determine whether there has been a violation of the Fair Housing Act. A complaint may be resolved in a number of ways. First, HUD will ny to reach an agreement between the two parties involved. A conciliation agreement must protect the filer of the complaint and public interest. if an agreement is signed, HUD will take no further action unless the agreement has been breached. HUD will then recommend that the Attorney General file suit. IFHUD has determined that a state or local agency has the same housing powers ("substantial equivalency") as HUD, they will refer the complaint to that agency and will notify the complainant of the referral. The agenry must begin work on the complaint within 30 days or HUD may take it back. If, during the investigation, review, and legal process, HUD finds that discrimination has occurred, the case will be heard in an administrative hearing within 120 days, unless either parry prefers the case to be heard in Federal district court. The State of Idaho and Meridian do not currently have substantial equivalency nor are they seeking such. HUD complaint trends. IiBC obtained data from HUD's Seattle Regional Office of Fair Housing and Equal Opportunity (I~HEO) on the number of housing discrimination complaints filed in Meridian from 2005 through 201 1. Figure III-1 presents complaints by year. During the six year period, M complaints were filed in Meridian. The largest number of annual complaints was five in 2011. Figure III-1. Number of Fair Housing Complaints Filed zoos with HUD, City of Meridian, 2005 to 2010 2ooE Source: zoos HUD. 2008 2009 2010 2011 BBC RESEARCH Ei CONSULTING SECTION III, PAGE 2 0 1 2 3 4 5 6 Number of Complaints Most complaints filed in Meridian were on the basis of disability status (61%). The remaining complaints were filed on the basis of race (17%), family status (11%) and national origin (6%).2 Two-thirds of all complaints filed in Meridian were filed by Meridian residents. Six of the 18 complaints filed in Meridian between 2005 and 2011 were filed by individuals from other communities looking for housing in Meridian, including Boise. The most common violation tired in complaints was failure to make reasonable accommodations (25%).3 An additional 18 percent of complaints were filed because of discrimination in the terms, conditions and privileges relating to a rental property. Figure III-2. Discrimination in terms/ ca n dltio n s/privileges Issues Cited in Complaints, Failure to make reasonaf7le relating to rental (17.996) City of Meridian, 2~~5 t0 2~~ 0 accommodation (25.096) Dis<riminatiorl in the _- selling of residential __.._ r _. _... --, real property (3-6°,b) Source: I Discriminator refusal HUD. Discriminatory terms, to rent (3.696) conditions, privileges ~ ~ - /~~Dis<riminatory acts undE or services and ~~Sec[ion 818 (10.796) facilities (14.345) ~~ ~,,. •® ~ ~ 1 DiscrirnLratory refusal ~~ ~ ~ ~ Discriminatory advertising, to sell (3.696) statements and notices (7.196) Dixrirninatory refusal Discriminatory refusal to rent (3.696) to rent and negotiate for rental (70.796) Of the 18 cases filed in Meridian, 11 cases were closed. Seven cases are still open. These cases were all filed in 2010 and 20l 1. The largest proportion of cases (64%) closed following a successful conciliation or settlement. The remaining cases (36%) closed after HUD found "no reasonable cause to believe that housing discrimination occurred."4 IFH~ complaint process. The Intermountain Fair Housing Council (IHFC) "is a nonprofit organization that promotes fair housing practice for housing consumet•s and housing providers throughout Idaho.s5 The IHFC is involved in fair housing education, compliance monitoring, enforcement activities (e.g., complaint investigation, testing, complaint filing) and mediation. When IFHC receives a complaint, they collect all information from the complainant that supports the complaint (e.g. doctor note) and determine whether the complaint meets four important factors to determine whether a complaint is valid: ^ The complaint occurred within the last year; ^ The action seemed to occur because the person fell within a protected lass; ^ The individual that committed the potential violation is subject to Fair Housing Act; and ^ The complaint appears to be a prohibitive activity. 2 One case was filed by a relief agency. No basis for discrimination was provided. 3 Complainants are allowed to cite more than one reason for discrimination when filing a complaint. For example, a complainant may cite discriminatory teens, conditions, privileges of services and f<~cilities, as well as discrimination in terms/conditions/privileges relating to rental. 4 For a deFmition of no cause determination, please visit: http://port.ll.hud.gov/hudportal/HLJD?srr-Jpro~ram offices/fair housing equal opp/complaint-process 5 FOP lnOl'e lllf°l7nanon On the lntel'mOUntal^ Palr 1-loUSing ~.OUI1CIl, please visit. hrtpa/ifhcidaho.Drg/abour.html. BBC RESEARCH & CONSULTING SECTION III, PAGE 3 If the complaint requires additional facts to prove its validity, IFHC will conduct extra research and investigation (e.g., testing, check property tax records with the Assessor's office, gather additional documentation). Once sufficient information has been gathered, IFHC will advise the client on next steps. Next steps could include calling HUD directly to file a complaint by phone or IFHC staff can help individuals fill out complaint forms to ensure the complaint has strong documentation. IHFC faxes the complaint directly to HUD and also sends the complaint via registered mail. If IFHC has invested sufficient administrative resources into the complaint filing, they co-file a complaint. IFHC believes co-filing demonstrates to FHEO that there is strong merit to the case. Legal Cases As part of the fair housing analysis, legal cases occurring in the past ten years were reviewed to determine significant fair housing issues and trends in Meridian and the Boise region. None of these lawsuits occurred in Meridian; however, it is important to include them in the analysis to understand the types of cases that could occur in Meridian. Cases were found on websites maintained by the Department of Justice, the National Fair Housing Advocate and HUD. In many cases, text was borrowed directly from the Icgal briefs. An analysis of statewide complaints completed by BBC in summer 2011 found that the vast majority of fair housing legal cases in the State of Idaho occurred in Ada County and were related to developers, builders, engineers and/or architects failing to comply with the accessibility requirements of the federal Fair Housing Act and the Americans with Disabilities Act (ADA). Disability. United States v. Canal Street Apartments, et al. In 199$, the IFHC filed a complaint with HUD alleging that the Canal Street Apartments located in Boise, Idaho frustrated the IFHC's mission of eliminating discrimination by failing to construct and design the complex so that the public use and common use portions are readily accessible to and usable by individuals with disabilities and ground floor units contain features of adaptive design.G Upon finding reasonable cause for discrimination based on disability, HUD referred the case to the DOJ. In September 2002, the court filed a consent dect•ee requiring the defendants to retrofit the ground floor units and public and common areas to make them accessible to persons with disabilities; submit to periodic inspections and record-keeping; and pay $3,300 in monetary damages to 1FHC, $5,000 to the Accessibility Improvement program (AII'} of the Idaho Housing and Finance Association to promote handicap accessible housing construction and fair housing in the City of Boise and Ada County area, and a $6,500 civil penalty. The five-year consent order also requires the defendants notify HUD if they again design or construct multifamily dwellings and provide a written statement from any architect involved with the project that the plans include design specifications that comply with the requirements of FHA Accessibility Guidelines. G ltt this case, adaptive design included: (i) doors sufficiently wide to allow passage into and within the unit by persons in wheelchairs; specifically including: doors to the bedroouns; doors to the bathrooms; doors to the walk-in closets; doors to the patio; (ii) threshold at the exterior primary entrance low enough to allow entry by persons in wheelchairs; (iii) bathroom floor space sufficiently clear for an individual in a wheelchair to enter and close the door; (iv) providing reinforcement in the walls at the tub and water closet to permit the later installation of grab bars. BBC RESEARCH br CONSULTING SECTION III, PAGE 4 United States v. Pacific Northwest Electric, Inc., et al. In January, 2001 the United States filed a complaint alleging that the defendants developers Walter T. Sigmont and Wirt Edmonds, Pacific Northwest Electric, Inc., Edmonds Construction Co., Inc., and architects Teal Whitworth Architects, P.A. and Capstone, Inc. located in Boise, Idaho discriminated on the basis of disability by failing to design and construct five Boise apartment complexes in accordance with the FHA's accessibility requirements for new multifamily housing. The five Boise complexes that were the subject of the suit are Grayling Place, Jade Village, Imperial Court, Eagleson Parlc and Harborview Station (formerly known as Lawton Apartments). Specifically, the defendants failed to design the apartment complexes so that the public and common areas arc readily accessible to and usable by individuals with disabilities; all doors within the 72 ground floor units are sufficiently wide to allow passage by persons with disabilities who use wheelchairs; and the 72 ground floor units contain the features of adaptive design. In October, 2003, the court entered a consent decree, which required the defendants to retrofit the complexes by, among other things: removing steps; reconfiguring kitchens and bathrooms to provide added rnancuvering space; widening doorways; leveling sidewalks; and adding accessible parking and curb ramps at an estimated cost of approximately $300,000. In addition, the dcfcndants were required to pay damages in the amount of $29,000 to persons harmed by the lack of accessible features at the complexes, pay $5,000 in damages to the IFHC, and ensure that any new construction complies with the FHA. The consent decree remained in effect for two years. United States v. Thomas Development Co., et al. In February, 2002 the United States filed a complaint alleging that Thompson Development Co. and affiliated companies (defendants) engaged in a pattern or practice of discrimination on the basis of disability by failing to design and construct the ground floor units and public /common use areas in compliance with the accessibility requirements of the FHA. The defendants were alleged to commit these violations at 17 apartment complexes located throughout Southern Idaho in the cities of Boise, Meridian, Nampa, Shelly, Rexburg, Caldwell, Rigby, Lewiston and Jerome. The complaint also alleged that some of the defendants retaliated against a tenant family atone of the complexes by attempting to evict the family after one of the family members requested a reasonable acconunodatian for their disability. In March, 2005, the court entered a consent order, which included injunctive relief and monetary payments totaling $125,000. The consent order remained in effect for three years. Garcia v. Brockway. In May 200,3, Noll Garcia (plaintiff) filed a complaint against the original owner/developer and designer of his apartment building in Boise, Idaho. The complaint alleged a failure to accommodate disabilities as mandated by the FHA. Mr. Garcia is disabled and uses a wheelchair for mobility and filed a complaint because the apartment complex he was lacked curb cuts fi•om the parking lot to the sidewalk, didn't have a ramp to the front entrance door, and the doorways were too narrow to allow clear passage of his wheelchair. Mr. Garcia requested that management make appropriate accessibility improvements, which were ignored, as was his request that management build a ramp to his door or that he be relocated to a more accessible unit. In addition, Mr. Garcia sued the original builder and architect (Brockway and Robert Stewart, respectively), and the current owners and management (the Zavoshy dcfcndants). See footnote 2 For qualifications of "adaptive design. BBC RESEARCH SI CONSULTING SECTION III, RAGE S The defendants (Brockway and Stewart) argued that because they no longer owned the building (which they sold in 1994), their liability was time-barred by the statute of limitations in the FHA. Thus, the plaintiff's complaint would have had to been filed within two years following construction of the apartment building in 1993. The plaintiff countered, arguing that the failure to remodel the apartments constituted a continuing violation and that the statute of limitations take effect upon discovery of the alleged violations. Mr. Garcia also claimed that failure to make modifications constituted new violations. The court ruled that the continuing accessibility issues were an effect of a prior discriminatory act but not a continuing violation. The argument that the two-year statute of limitations should begin at discovery of a violation was deemed unworkable, as a developer would be liable for these violations indefinitely in spite of his or her ownership of the complex. Finally, the original developer was not found to be liable for refusal to make modifications while current management company was at fault. The defendant still had a remedy under the FHA with building owners, but his motion against the developers was dismissed. Claims against the current owners and management were settled out of court. United States v. S-16 Limited Partnership, et al. In April, 2003, the United States filed a complaint alleging that the owners and developers of the 254-unit Village at Columbia apartment complex in Boise, Idaho and the architects and engineering firm involved in its design failed to design and construct the complex in compliance with the accessibility requirements of the FHA. Specifically, the defendants failed to design the apartment complexes so that the public and common areas are readily accessible to and usable by individuals with disabilities; all doors within the 7G ground floor units arc sufficiently wide to allow passage by persons with disabilities who use wheelchairs; and the 76 ground floor units contain the features of adaptive design. In March, 2005, the court entered the consent order requiring the defendants to retrofit the common use areas of the complex and 76 ground-floor apartments. The order also required defendants to pay $2,000 in damages to the IFHC, the original HUD complainant in the case, and to establish a fund of $40,000 to compensate victims of defendants' discriminatory practices. In addition, the order included a general injunction against future discrimination; arequirement that defendants inform HUD of future development and design work in which they become involved and obtain statements that design plans comply with the FHA; a mandate that defendants require all supervisory employees and agents to participate in fair housing u'aining and certify that they have read the order; post signs describing their policy of nondiscrimination in housing; and meet reporting and record-keeping obligations. The consent order remained in effect for three years. Familial status. United States v. Blue Meadows Apartments, et al. In July, 1995 Blue Meadows Limited Partnership, the owner of Blue Meadows Apartments in Boise, Idaho (defendant) stated, adopted, and enforced a policy that imposed a limitation on the use of facilities by persons under the age of 18 years. Specifically, those rules required all occupants under the age of 18 years to be supervised whenever they were outside of their apartments; the rules also prohibited all people under the age of 18 years from using or occupying any of the common areas after 10 p.m., irrespective of adult or parental supervision. Defendants incorporated these rules into an addendum to the lease that tenants $ See footnote 2 for qualifications of "adaptive design. BBC RESEARCH ST CONSULTING SECTION III, PAGE 6 were required to sign. Several residents of Blue Meadows that had children under the age of 18 filed complaints with HUD in 1999 and 2000. Upon finding reason for discrimination based on family status HUD referred the case to the DC?J for resolution, In September, 2002, the court entered a consent decree where the defendants agreed to delete the current restriction on persons under 17 from using the pool unless accompanied by a parent; limit any Future age restrictions governing unaccompanied children using the pool to those under age 13; and refrain from instituting any other rules that restrict the use of common areas at by persons under 18, except those that apply to all persons, regardless of age. Defendants were also required to pay one of the plaintiffs $1,200 in damages. Religion. Intermountain Fair Housing Council v. Boise Rescue Mission Ministries. The Rescue Mission is an Idaho nonprofit funded through charitable donations from businesses, churches and the general public. The Rescue Mission operates two facilities in Boise. Thef•e were recently two cases filed against the Rescue Mission on the basis of religion. Case #7: Plaintiff Richard Chinn was periodically homeless during the years 2005 and 2006 and a guest of the homeless shelter located at the River of Life Facility. During his stays at the shelter, he had no other place to stay and intended to remain in the shelter in excess of several months. Chinn asserts that he was told by shelter staff that he would he required to participate in Christian religious activities such as chapel services in order to reside and eat meals at the shelter. He observed that guests of the shelter who did not attend chapel services were tither required to wait in the dining room a• were not permitted to enter the shelter until chapel services were completed. Chinn found the practices of the shelter to be coercive, unpleasant, embarrassing, and offensive to his religion. He did, however, participate in the religious services out of fear that if he did not participate, he would be denied housing and other services. Case #2: In addition to the homeless shelter, the Rescue Mission also provides a New Life Discipleship/Recovery Program, which is an intensive, one-year Christian-based residential recovery program far individuals with drug or alcohol dependency. In October 2005, Plaintiff Cowles was in jail on drug-related criminal convictions. Cowles contacted the Rescue Mission and requested that she be admitted into the Discipleship Program, stating that she was "focused on changing my life through God and spiritual growth," and that she is "desperately looking to fill this void in my life with spirituality and not drugs." Following admittance to the program, Cowles was required to participate in religious activities Cowles was upset at being forced to adopt the Christian religion. When Cowles requested that she be allowed to change to a non- religious prograrn, she was put on °30-day restriction" during which all her telephone calls with her attorney were monitored by Program staff and she was not allowed to participate in other limited activities that she previously had been allowed. Eventually, Discipleship Program staff wrote a letter to the judge presiding aver Cowles` criminal case and informed the judge that Cowles "struggled with the Christian based program that was offered." Staff recommended to the judge that Cowles be given an oppornuiity to complete anon-faith-based program to allow her to "better focus on her recovery without the confliction of her beliefs." BBC RESEARCH SI CONSULTING SECTION III, RAGE 7 Both cases were resolved recently in appellate court. The court found that since the Boise Rescue Mission is not a "dwelling," it is not subject to the requirements of the Fair Housing Act. The court also concluded that the religious practice requirements arc protected by the Frec Exercise Clause of the First Amendment. Fair Lending Analysis This section analyzes fair lending conditions in the City of Meridian using residential mortgage lending data from 2010 (the latest data available at the tithe this report was prepared). Community Reinvestment Act (CRA} ratings and Home Mortgage Disclosw•e Act (HMDA) data are commonly used in AIs to examine fair lending practices within a jurisdiction. As of 2004, HMDA data contain interest rates of high cost loans, which allows an analysis of high cost (subprime) lending patterns. CRA review. The CRA requires that financial institutions progressively seek to enhance community development within the area they serve. On a regular basis, financial institutions submit information about mortgage loan applications as well as materials documenting their community development activity. The records arc reviewed to determine if the institution satisfied CRA requirements. The assessment includes a review of records as related to the following: ^ Commitment to evaluating and servicing community credit needs; ^ Offering and marketing various credit programs; ^ Record of opening and closing of offices; ^ Discrimination and other illegal credit practices; and ^ Community development initiatives. The data are evaluated and a rating for each institution is determined. Katings for institutions range from substantial noncompliance in meeting credit needs to an outstanding record of meeting community needs. There are 24 banks with headquarters in Idaho; however, none of those banks are located in Meridian,9 The Farmers and Merchants State Bank was located in Meridian, but moved its headquarters to Boise. lts last CKA rating while hcadgttartercd in Meridian was in 2002, and the bank received a "Satisfactory" rating. HMDA data analysis. HMDA data are widely used to detect evidence of discrimination in mortgage lending. In fact, concern about discriminatory lending practices in the 1970s led to the requirement for financial institutions to collect and report HMDA data. The variables contained in the HMDA dataset have expanded over time, allowing for mare comprehensive analyses and better results. However, despite expansions in the data reported, HMDA analyses remain limited because of the information that is not reported. 9 2011 State of Idaho AI completed by BBC Research ~ Consulting. BBC RESEARCH St CONSULTING SECTION III, PAGE 8 As such, studies of lending disparities that use HMllA data carry a similar caveat: HMDA data can be used to determine disparities in loan originations and interest rates among borrowers of different races, cthnicities, genders, and location of the property they hope to own. The data can also be used to explain many of the reasons for any lending disparities (e.g., poor credit history). Yet HMDA data do not contain all of the factors that are evaluated by lending institutions when they decide to make a loan to a borrower. Basically, the data provide ~ lot of information about the lending decision-but not ill of the information. Since 2004, HMDA data include the interest rates on higher-priced mortgage loans. This allows examinations of disparities in high-cost, including subprime, loans among different racial and ethnic groups. It is important to remember that subprime loans are not always predatory or suggest fair lending issues, and that the numerous factors that can make a loan "predatory" arc not adequately represented in available data. Therefore, actual predatory practices cannot be identified through HMDA data analysis. However, the data analysis can be used to identify where additional scrutiny is warranted, and how public education and outreach efforts should be targeted. HMDA data report several types of loans. These include loans used to purchase homes, loans to make home improvements and refinancing of existing mortgage loans, as defined below. Home purchase loan. A home purchase loan is any loan secured by and made for the purpose of purchasing a housing unit. ^ Home improvement loan. A home improvement loan is used, at least in pat•t, for repairing, rehabilitating, remodeling, or improving a housing unit or the real property on which the unit is located. Refinancing. Refinancing is any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower. The purpose for which a loan is refinanced is not relevant for HMDA purposes. The HMDA data are separated into two primary loan categories: conventional loans and govcrnmcnt- guaranteed loans. Government-guaranteed loans are those insured by the Federal Housing Administration and the Veterans Administration. This section uses the analysis of 2010 HMDA data to examine: ^ The geographic areas in Meridian where high-cost lending and loan denials arc concentrated, and the correlation of these areas with concentrations of minority and ]ow income households; and Disparities in high-cost lending and loan denials across different racial and ethnic groups. BBC RESEARCH Si CONSULTING SECTION III, RAGE 9 Methodology notes. There are two important methodological notes to highlight as part of this HMDA analysis: ^ Only loan applications for owner-occupied properties are analyzed. ^ Loan applications arc analyzed at the Census tract level. Aggregating Census tract data to jurisdictional boundaries may result in loan applications outside jurisdictional boundaries being included in community-level analysis. Types of loans, In 2010, there were 6,190 loan applications filed in the City of Meridian.10 Figure III-4 presents the distribution of loan applications by the types of loans applicants applied for in 2010. Most loans in the city were for conventional loans (67%). Figure I11-4. Types of Loan Applications, City of Meridian, 2010 FSA-RHS Farm Service (0.0,6) VA-guaranteed (6.So,6) Note Less than 1 percent of loan applications were for FSA or Rural Housing loans. These loans are not included in this Figure. The percentages in this Figure will not add to 10D percent. Source: Home Mortgage Disclosure Act, 2010. Conventional (67.4°.6) Twenty-six percent of loans in 2010 were for federal Housing Administration (FHA) loans. Meridian residents were slightly more likely to apply for FHA-insured loans in 2010 than Boise (22%) and Ada County residents (23%). t~urpose of loan applications. When Meridian residents applied for mortgage loans in 2010, 60 percent of loan applicants applied for a mortgage refinance and 38 percent of applicants applied for a loan to purchase a home. Figure III-5. Purpose of Loan Applications, City of Meridian, 2010 Source: Home Mortgage Disclosure Act, 2010. "ome Purchase 38.396) improvement (1.896) Refinancing (59.9~h) 10 These loans were filed in Census tracts that overlap with city boundaries. BBC RESEARCH & CONSULTING SECTION III, PAGE 10 The purpose of loan applications by Meridian residents changed between 2009 and 2010. In 2009, 69 percent of all loan applicants sought loans for a mortgage refinance and 29 percent applied for a loan to purchase a home. This change is due to a larger number of Meridian residents applying for refinances in 20(?9 compared to 2010. This could suggest that the Meridian housing market has stabilized a bit, as homeowners are less urgent to restructure existing home loans. Figure I11-6. zao9 ~ 2010 Purpose of Loan Applications, ~,ooo City of Meridian, 2009 and 2070 6,000 58.745 Source: 5,000 Home Mortgage disclosure Act, 2009 and 2010. 4 Mn 59.94'0 29.44b 38.39b T.995 1.845 Home Purchase Home Refinancing Improvement Action taken on loan applications. Sixty-seven percent of loan applications submitted by Meridian residents in 2010 originated, while 14 percent were denied. The city's loan denial rate decreased slightly between 2009 and 2010; subsequently, its loan origination rate increased. Figure III-7. Action Taken on Loan Loan originates Applications, City of Meridian, 2009 and 2010 Application approves by not accepted Source: Application denied b~ Home Mortgage OisclosureAct, 2009 financial institution and 2010. Application withdrawr by applicant File closed for incompleteness Meridian's 2010 denial rate was slightly lower than denial rates experienced by Boise (16%) loan applicants. Ada County residents overall had a 15 percent loan denial rate. BBC RESEARCH Sr CONSULTING SECTION III, PAGE 11 096 20°.6 4096 6096 80:6 100°~ Figure III-8 compares loan outcome by loan type. Meridian residents primarily applied for conventional, FHA-insured and VA-guaranteed loan products. Conventional loan products had the highest denial rate at 15 percent, while VA-guaranteed loans had the lowest denial rate at 9 percent. FHA-insured loans had a denial rate of 12 percent. Figure III-8. Action Taken on Loan Applications by Loan Type, City of Meridian, 2010 . File closed for incompleteness ^ Application withdrawn by applicant 100.095 I ® Application denied by financial institution 65.24b 70.895 71.345 1 Cornentional FHA-Insured VA-guaranteed FSA-RHS Farm Service Source: Home Mortgage disclosure Act, 2010. 1 Application approved ' by not accepted Loan originated Figure III-9 compares loan outcome by loan purpose. Home improvement loans have the highest denial rate at 33 percent. In fact, only one in every two home improvement loan applications submitted by a Meridian resident was approved in 2010. Home refinance loans had a denial rate of 18 percent, and only 7 percent of home purchase loans were denied by the lending institution. Figure III-9. Action Taken on Loan Applications by Loan Purpose, City of Meridian, 2010 1.146 ^ File closed for incompleteness r. ^ Application withdrawn - ;~.,, ~ by applicant ® Application denied by financial institution 78.495 60.345 Application approved so.o95 ~ ~ by not accepted Loan originated Home Home Refinancing Purchase improvement Source: Home Mortgage Dixlosure Act, 2010. BBC RESEARCH SS CONSULTING SECTION III, PAGE 12 Seventy-eight percent of Meridian's home purchase loans were approved in 2010. This is good news for the city's housing market, as it demonstrates that the city has qualified buyers waiting to purchase homes. Meridian had a higher home purchase loan origination rate in 2010 than neighboring Boise (73%) and the county overall (75%). Denial rates by race and ethnicity. When applicants identified their race and ethnicity as part of their mortgage application, they most often identified themselves as racially white (96%) and ethnically non-Hispanic (97%)." Figure III-10 presents loan outcomes by race and ethnicity. Denial rates were highest for applicants who were Blaclc/African American (31 %) and Native Hawaiian (19%). The city's Asian loan applicants had the lowest denial rate in the city (10%). As the last part of Figure II-10 shows, the most extreme disparity in lending occurs between African Americans and Whites: White applicants had loan origination rates that were 26 percentage points higher than African American applicants'. Similarly, African American applicants had denial rates that were 18 percentage points higher than White applicants'. It is acknowledged that African Americans comprised less than 1 percent of all loan applicants in the city in 2010. There is very little lending disparity between the city's Hispanic and non-Hispanic residents. Figure 111-10. Action Taken on Loan Applications by Race and Ethnicity, Gity of Meridian, 2010 I,yiitlltr:tltrit~ /;Sgl:Ilit~ilYli? r:~~iii3~llh'~ l~,YI.1F~~Slirh~ till? (+4~rtafpr lU~ktei rl 1,7:rvxal•L~ fiuFl7t~l:ii rvdliir~Ji`tSVTdi),'/ <1lkt.(:iSfd~ <~1;1t.7.11 Fi (•I~1 (.~hFt{:{~I fir r'r.C2<(q'fix~r21 Ili6iil,liHleru ~:I !1!Ili4aitt ii,tn ]iila~ti-lib American Indian or Alaska Native 0.496 75.096 8.395 8.396 8.396 0.09'0 Asian 2.296 66.996 9.496 10.296 11.896 1.6% 81ack or African American 0.596 42.396 3.846 30.896 19.296 3.89'0 Native Hawaiian or Other 0.596 69.295 7.796 19.296 3.896 0.096 White 96.496 68.696 6.246 13.296 10.096 1.995 - -- i[ta6ll>/ Hispanic or Latino 3.096 - 67.596 2A96 15.496 11.896 3.095 Not Hispanic or Latino 97.096 68.396 6.595 13.296 10.195 1.995 ~i~l:~~~lhlit~i..~ti.itfi'li~~.i,~3.l-tar{Fls.C~s~ .(3_i.iJ+... -- Non-White/White -3.696 2.195 0.696 1.395 -0.495 African American/White -26.396 -2.495 17.645 9.296 2.096 Hispanic/Non-Hispanic -0.996 -4.196 2.296 1.795 1.146 Note: Nine percent of applicants did not identify their race and 9 percent did not identify their ethnicity in their loan application. This analysis only includes applicants that identified their race and ethnicity. Source; Home Mortgage Disclosure Act, 2010. "Nine percent of applicants did not provide their racial or ethnic information. BBC RESEARCH St CONSULTING SECTION III, PAGE 13 Denial rate by race/ethnicity by census tract. A filrthcr examination of loan approvals by race/ethnicity is provided in the maps that follow. Figures III-11 and III-12 overlay Census tracts containing loan denial rates above the city's 14 percent denial rate with the ciry's racial and ethnic concentration maps. While there are no racial or ethnic concentrations in the city, the city does have LMT Census tract. One of those tract-103.22-has a higher denial rate than the city overall (16%), as does the adjacent tract, 103.21 (17%). However, the denial rates are not significantly difEcrent in these tracts than the city's denial rate overall. Figure III-7 7 . Census Tracts with Higher than City-Wide Average Denials by Percent Non- White, City of Meridian 2010 Note: The denial rate for all loans in the city overall was 14 percent. Source: Home Mortgage Disclosure Act (HMDA), 201D and 2010 Census. ,oI arc. ~i .~ i I..f ~. ~~.~ _ ~~ 1. I ~ f i `~ ~1, _ 1 I t ~p° (I ~- . *p . =P?' i _ it ~ .~ _-. 1`.~, ~ ' n I i t - ~ . `7~ ` i ~ _v ` `,t, I I ~ - ~ '_ j~ 'mL. ~ ~ _'i_ , I ry i - legend ~ ~~ Nigher than CRp4Y de Average (la:n) I., ~, ~ i Ia ~~ I_ _ _ __i Len than S.o:ti ~ ~ -~-' ~ ~ .I , s.o~to le.ob ,, j . ji -More that 18.0?8 [_ .. _ ~ _ i, 1~ f ~ `i 5 BBC RESEARCH bT CONSULTING SECTION III, PAGE 14 Figure III-12. Census Tracts with Higher than City-Wide Average Denials by Percent Hispanic, City of Meridian, 2070 Note: The denial rate for all loans in the city overall was 14 percent. Source: Home Mortgage Disclosure Act (HMDA), 2010 and 2010 Census. i -r,~ Legend ~. `Higherlhan City-tied=. gsera~(li%) Lets chap 5.0?b 5.0°u to V.09o Arare Thai V.04o Applications submitted for loans in these two Census tracts comprise less than 10 percent of all loan applications submitted in the city. Loan applications submitted in these two tracts resembled loans for the city overall by purpose; however, loans applicants were more likely to apply for an FHA-insured loan in this portion of the city (35%) compared to the city overall (26%). Loan applicants applying for loans in these two tracts were slightly more likely to be denied loans for both conventional (] 8%) and FHA-insured loans (14%). Subprime analysis. Less than 1 percent (17 af4,154) of Meridian's originated loans were considered Subprime in 2010. There was no racial or ethnic disparity in subpritne lending in 2010, indicating that Subprime loans were not targeted to the city's racial or ethnic minorities. For example, nearly all Subprime loan recipients that idcnti6ed their ethnicity were non-Hispanic.12 Additionally, Subprime loans in Meridian are geographically dispersed, indicating that low income residents in the city's lowest income Census tracts were not targeted for Subprime loans. lz None of the subpritne loan recipients provided racial information. BBC RESEARCH ST CONSULTING SECTION III, PAGE 15 SECTION IV. Public Input and Participation SECTION IV. Public Input and Participation This section discusses input from citizens, stakeholders and service providers regarding the development of the city's AI. Public input was gathered in the following ways: A resident survey was distributed online and on paper between November 16`h and December 15th of 2011-330 residents participants in the survey; ^ An online stakeholder survey was promoted by city staff and BBC in fa11 201 1-1 5 housing, Fair housing and social service professionals responded; and ^ A focus group and in-depth interviews with service providers and housing developers were conducted in the fall and winter of 2011-12-1 I individuals participated. The city also held a public comment period for the AI. No comments were received. The city's AI was completed in conjunction with its 201 Z-2016 Consolidated Plan. All public input components of the Consolidated Plan and the AI included duestions pertinent to both studies. This insured maximum residenC and stakeholder input into both processes. Resident Survey This section presents the results from the resident survey, Distribution strategy. A vari ety of organizations and mediums w ere used to publicize and distribLtte the resident survey. They arc summarized in Figure IV-1. Figure III-1. Additionally, Survey Distribution, City of Merid ian, 2017 the resident survey was ®. . • , publicized in utility bills mailed to Meridian residents. Ada County Boys and Girls Club City of Meridian website Boise City/Ada County Housing Authority City of Meridian electronic newsletter The resident survey was Chief Joseph Elementary School Cit f M idi C C City of Meridian Facebook page C y o er an lerk ity ity of Meridian Twitter page publicly promoted through City of Meridian Planning Department HOA email distribution lists the Clty'S website and public EI Ada Community Action Partnership Press release to local newspapers SC110o15, as wCll aS dlSCrrbuCCd Friends in Action Public school email list through nonprofit Idaho Leagal Aid Services organizations. As such, the Idaho Office for Refugees Intermountain Fair Housing Council Survey is not mean[ t0 bC Linder Elementary School interpreted as a statistically Meridian Community Center valid swvey of all Meridian Meridian Elementary School residents. Rather, the survey Meridian Food Bank reflects the experiences and Meridian High School opinions of residents who Meridian Library Meridian Middle School were interested in responding Meridian Senior Center CO C1UCStionS about their Terry Reilly Health Services hOUSing eXpCtIeRCCS. United Way of Treasure Valley S ource: BBC Research & Consulting and City of Meridi an. BBC RESEARCH i`I CONSULTING SECTION IV, PAGE 7 Demographic profile. The resident survey included several demographic and socioeconomic questions. Where possible, comparisons are made between survey respondent demographics and those for the city overall. Geography. Figure IV-2 displays survey respondents' place of residence in Meridian. The largest proportion of survey respondents live in North Meridian, defined as the area of the city north of Fairview Avenue/Cherry Lane. The remaining 44 percent of respondents were equally split between South Meridian (south of the Interstate 84) and Downtown/Central Meridian. Figure IV-2. Residence of Survey Respondents, City of Meridian, 2077 Note: n=329. Source: Meridian Resident Survey, 2011 and 66C Research & Consulting. +_~' R~ Southern Meridian BBC RESEARCH bt CONSULTING SECTION IV, PAGE 2 Household profile. Figure IV-3 compares the household size of survey respondents to the size of all households in Meridian. On average, survey respondents have larger households than residents in the city overall. The vast majority of survey respondents have a household size of Four (31%}, Figure IV-3. Household Size of Survey Respondent Compared with Household Size for Meridian, 207 7 31.4% 21.6% 16.696 15.8% 17.3% 6.5% Household Size of Survey 31.296 Respondent 18.996 1 person 2 person 3 person 4 person Note: n=292; According to the 2010 ACS, the average household size in Meridian is 2.89. Source: Meridian Resident Survey, 2011 and 2010 U.S. Censuz. 9s% 70.696 ~ Household ® 6.396 Size (Census) 5 person More than 5 person Survey participants were asked to identify the language most commonly spoken in their home. Most respondents speak English (98%) at home.' Race and ethnicity. Figure IV-~ presents the race/ethnicity of survey respondents. Ninety-two percent of survey respondents identified themselves as racially White. Approximately 3 percent of survey respondents identified themselves as Hispanic. Compared to the proportion of Hispanics in the city (7%), a smaller proportion of Hispanics responded to the resident survey. Figure IV-4. Race/Ethnicity of Survey Respondents, City of Meridian, 2011 Note: n=305. Source: Meridian Resident Survey, 2011. Other (1.696) Native Hawaiian or Other Pacific Islander (0.396) Asian (2.396) Hispanic/Latino (2.696) `,, Black or African American (1.046) ,l Caucasian/White (92.196) n=2J9. BBC RESEARCH St CONSULTING SECTION IV, PAGE 3 Income. Figure IV-5 compares the household income distribution of survey participants with the distribution of the city overall. The largest proportion of survey participants earn between $50,000 and $75,000 per year (28%), which is close to the proportion those households represent in the city (24%). Overall, the survey has strong participation from the city's highest earning households. It should be noted that many survey respondents chose not to disclose their household's income. Figure IV-5. Household Income of Survey Respondents Compared with the Overall Household Income for Meridian, 2011 27.7°.6 25.2°.6 24.596 14.7.6 12.1 °.b 8.29b 3.996 3.996 Household Income of Survey Respondents 26.496 19 096 21.O~b . 13.396 Household ® Income (Census) Less than $10,000 to $25,000 [o $50,000 to $75,000 to $100,000 $10,000 $24,000 $49,999 $74,999 $49,999 or more Note: n=231. Source: Meridian Resident Survey, 2011. Age. Figure IV-6 compares the age of survey respondents with the age of the city's householders. The survey had high participation from residents between 35 and 44 years of age. Sixteen percent of the city's householders arc seniors, compared with 9 percent of survey respondents. Exhibit IV-6. Age of Survey Respondent Compared with Age of Householder, City of Meridian, 207 7 18.396 19296 37.9°,6 - Age of Survey Respondent 20.3.5 n 16.396 t 4.596 Age of 10.096I! ~ Householder f.: ? 8'6°5 ,~ (Census) 1.796 3.296 ~,>~~ i I ~ 096 ~ --~--- Less than 25 25 to 3q 35 l0 44 45 to 54 55 to 64 65 years years old years old years old years old years old and older Note: n=301. Source: Meridian Resident Survey, 2011 and 2010 U.S. Census. BBC RESEARCH St CONSULTING SECTION IV, PAGE 4 Disability. Ten percent of survey respondents reported that a member of their household had a mental and/or physical disability. This is a higher rate of disability than that seen citywide (7%).z Most households with a disabled household member live in housing that meets their accessibility needs, as shown in Figure IV-7. Only one survey respondent provided information on their home's accessibility deficiencies. That individual was a senior in need of home modifications to make their home livable for their wheel chair, walker and oxygen machine (e.g., no bathroom on main floor, wider doottivays). Exhibit IV-7. Disability and Housing Accessibility of Survey Respondents, City of Meridian, 2071 Note: n=322 and n=33. Source: Meridian Resident Survey, 2011. Do you or any member of your family have a disability? t7oes your current home meet fhe needs of the disabled members of your current household? Yes (10%) No (60,'0) 1 t ;, ~ Yes (94%) Fair housing knowledge. Sutvey respondents were also asked whether they knew who to contact iF they wanted to report an incidence of discrimination. Seventy-seven percent of survey respondents said they did not ltnow who they would contact. Figure IV-8. Response to Question: "If you ever felt discriminated against and wanted to report it, do you know who you would contact?" Note: n=312. Source: Meridian Resident Survey, 2011. 2010 1-year Atnerirln Community Survey. BBC RESEARCH Si CONSULTING SECTION IV, PAGE S No (90%) Survey respondents were asked what they would do if they or someone they ktlew felt discriminated against when trying to find a place to rent or buy a home. When respondents were provided with a list of potential fair housing resources, 44 percent of all survey respondents said they would contact the Boise City Ada County Housing Authority, Nearly 30 percent of respondents simply didn't ktlow what they would do if they or someone they knew experienced discrimination when looking for a home. Figure IV-9. Action/Recommendation in Response to Housing Discrimination Note: n=323. Survey respondents were not limited in the number of choices they selected. As such, survey responses do not add to 100 percent. Source: Meridian Resident Survey, 2011. Call/see Boise City Ada County Housing Authority I don't know File a complaint Call/see the Better Business Bureau 21.4 Call/see Community Legal Services 18.346 Call/see/get a lawyer 13.0°,6 Call/see ACLU 6.546 Call/see the District Attorney Other Nothing Call/see church/priest/pastor 046 10°.6 2D96 3046 40:6 5046 10096 Three percent of survey respondents responded to the question with "other." Some of the following responses were provided: ^ "It depends on the complaint. I need more information." ^ "HUD." ^ "I think people should be allowed to discriminate. Who am I to say someone else can't choose not to rent me their home for any reason." ^ "Find a different, more tolerant place to live." ^ "Depends on the situation. We have a gay couple in the community that has been targeted since they moved in, which is not OK." ^ "Call TV cable news." BBC RESEARCH Si CONSULTING SECTION IV, PAGE 6 Experience with housing discrimination. Most survey respondents do not believe they've experienced housing discrimination. Five percent of respondents do think they have experienced discrimination. Figure IV-10. Response to Question: "Have you ever experienced housing discrimination?" Note: n=321. Incidence of discrimination may have occurred outside the City of Meridian. Source: Meridian Resident Survey, 2D11. I don't know (3.4°~6) Yes (4.7°,6) ~~.~ No (91.9°.6) As demonstrated in Figure IV-l 1, rnost residents that said they had experienced discrimination or were "not sure" if they had experienced discrimination provided their own reason for the basis of their discrimination, which were mostly related to credit and finances (e.g., self employed, on unemployment, partner's credit history). Figure IV-11. Reasons for Discrimination other Note: I have children 20. n=20. Incidence of discrimination may have occurred outside the city of Meridian. I have bad credit/bankruptcy/debts 20. I'm poor/I couldn't afford it 15.0°,6 Source: Meridian Resident Survey, 2011. My race 10.0% I'm a student 10.0:6' My gender 10.0°.6' My partner/girlfriend/boyfriend 10.0%' and I are not married My sexual orientation 0.0°~6 I have a disability 0.0% am not a U.S. citizen 0.096 My religion 0.0°.6 I'm on Section 8/receive 0 0°6 government assistance for housing 096 1096 20°,6 30°,6 4096 50°~6 100°.6 Most survey respondents that felt they had experienced discrimination or were unsure as to whether they'd experienced discrimination (85%) did nothing about the discrimination. In other words, they did not report it, nor did they file a complaint.3 n=20. BBC RESEARCH ~i CONSULTING SECTION IV, PAGE 7 Fair housing information and resources. Figure IV-12 presents the resources most residents would use for finding information about fair housing rights. Most survey respondents (77%) would rely on a general Internet search to find information about fair housing. The Boise City Ada County Housing Authority was also identified by survey respondents as an important fair housing resource in the community. Figure IV-71. Reasons for Discrimination Internet searct Housing Authority Source: Meridian Resident Survey, 2011. HUD WebSltE Real estate offices or realtor. City of Meridian website Call alawyer/ACES or Legal Ai. Don't know Call City Council or Mayo Library N Other Radio Summary of housing and community development needs. As part of the Consolidated Plan and AI survey, residents were asked to identify the most important needs in the community. Figure IV-12 summarizes the average response ranking For all activities across all seven housing and community development categories. On average, survey respondents considered fair housing services a low to moderate need (.3.9 out of 9.0) in Meridian. BBC RESEARCH & CONSULTING SECTION IV, PAGE 8 0°,6 20°h 40°6 60°.6 80;6 100°~6 Figure III-21. Summary of Housing and Community Development Needs, City of Meridian, 2011 Senior Centers 4.4 Youth Centers 5:8 « Child Care Centers 4.2 m ~ '« Park and Recreational Facilities 5.5 E ~ Health Care Facilities 4.6 e LL Community Centers 5.4 I V Fire Stations and Equipment q.9 '. Libraries 1 q.9 ', E Drainage Improvement ~~ ~-- _ 4.0 ~ 7 Water/Sewer Improvement StreeVAliey Improvement Street Lighting ~ Sidewalk Improvements ~ ADA Improvements Centers/Services for Disabled ,o Accessibility Improvements d v Domestic Violence Services Z Substance Abuse Services A Homeless ShelterslServices m a HIV/AIDS Centers and Services v i N eglected/Abused Children Center and Services Family Self-Sufficiency Servlces Senior Activities w Youth AcWl[ies N ~ Child Care Services E ~ Public Transportation Services c N Anti-CrimePrograms V Health Services Mental Health Services Legal Services '~ Tree Planting i u Trash and Debris Removal Graffiti Removal ~ ~ Code Enforcement ~ vs Parking Facilities y Cleanup of Abandoned Lots and Buildingz Start-Up Business Assistance Small Business Loans y lob Creation/Retention ~ Employment Training m Fa4ade Improvements Commercial/Industrial 0.e h a b i t u a t i o n Accessibility/ADA Improvements Owner-0ccupied Housing Rehabilitation Rental Housing Rehabilitation Homeownership Assistance ~ Affordable Rental Housing '~ Housing (or Disabled =O Senior Housing Housing for Large Families Fair Housing Servlces Lead-Rased Paint Testing/Abatement !4.6 ' '4.6 3.9 4.7 3.9 5.1 5.3 5.2 !6.6 5.6 4.1 4.7 4.7 8 X4.1 Energy ERldent Improvements S.2 it ~ Housing far Foster Youth S.p 0.0 1.0 2.0 3.0 4.0 S.0 6.0 7.0 8.0 Source: Meridian Resident Survey, 2011. 9.0 BBC RESEARCH Si CONSULTING SECTION IV, PAGE 9 Stakeholder Survey and Focus Group Fifteen stakeholders participated in the online stakeholder survey, and an additional 11 stakeholders participated in a stakeholder focus group or key person interview.4 Organizations participating in the public input process represent individuals from a number of protected classes including seniors, immigrants, low income residents, persons with disabilities, persons and families who are homeless, persons with HIV/AIDS, persons with substance abuseladdition, victims of domestic violence, youth refugees, and veterans. Stakeholder survey and focus group results are summarized below. Fair housing discrimination in Meridian. As part of the stakeholder survey, stakeholders were asked to identify the types of discrimination their clients arc most likely to experience. Stakeholder responses primarily fall under the following categories: ^ Problems obtaining housing because of strict credit requirement, unreasonable deposits, and a lack of rental history; ^ Denial of service animal requests; ^ Refusal to rent or steering to other properties away from desired property; ^ Discrimination targeting non-English speakers. Discrimination includes lack of interpretation of important documents, retention of security deposit; and ^ Denial of reasonable accommodation requests or requiring too much information for reasonable accommodation requests. Stakeholders were asked to identify the most common reason for housing discrimination in Meridian (e.g., race, familial status, disability). Stakeholders believe residents arc most likely to be discriminated against because of disability staats.s Stakeholders also believe residents may experience discrimination in Meridian because of familial status (presence of children) and national origin.G As demonstrated in their survey responses, stakeholders feel that the most common activity taking place in Meridian is "housing providers placing certain tenants in the least desirable units in a development,"' followed by "housing providers refitsing to make reasonable accommodations for tenants with disabilities."$ n Stakeholders were allowed to participate in the online survey and participate in the focus group or key person interviews. As such, there maybe some overlap. 5 Five stakeholders identified this is a common discriminatory activity. G Four stakeholders identified this is a common discriminatory activity. ~ Five stakeholders identified this is a common discriminatory activity. $ Fotu• srrlceholders identified this is a conunou discriminatory activity. BBC RESEARCH bi CONSULTING SECTION IV, PAGE 10 Fair housing barriers in Meridian. As part of the stakeholder survey, participants were asked to evaluate possible fair housing barriers as "not a barrier," a "minor barrier," a "modest barrier," or a "serious barrier" to fair housing in Meridian. "Restrictive covenants by homeowner associations or neighborhood organizations" received the most designations as a serious barrier to fair housing in Meridian. To further evaluate fair housing barriers in Meridian, focus group participants were asked to identify what they think are the greatest fair housing barriers in Meridian. Focus group participants identified the following fair housing barriers in Meridian: ^ Economic constraints. Census tracts that comprise downtown Meridian are HUD-designated LMI areas. Stakeholders feel it would be difficult For low and moderate income residents currently residing in the city's LMl area to move to other portions of Meridian. ^ Lack of affordable housing. Stakeholders said a lack of affordable housing is a barrier to fair housing in Meridian. There are few subsidized units in Meridian and the BCACHA has no public housing units in Meridian. Additionally, the city's limited affordable housing stock is primarily located in central Meridian. ^ Lack of public transportation. Stakeholders recognize that a lack of pttblie transportation is a barrier to fair housing choice in Meridian. A lack of public transportation may prevent residents from moving into Met•idian and it may dictate where some residents reside in Meridian. Stakeholders suggested it was not uncommon for low income residents to move to Boise for greater public transit access. ^ NIMBYism. Stakeholders suggested that certain types of residential projects, such as multifamily development, have been met by resident opposition in the past. As such, NIMBYism could impact future affordable and multifamily housing projects that could diversify neighborhoods and provide low income residents with opportunities to into traditionally higher income neighborhoods. Affordable housing development in Meridian. Three regional affordable housing developers were interviewed to determine why affordable housing has not occurred in Meridian and to identify opportunities for the city to help encourage affordable housing development in Meridian. Their input on the city's affordable housing market is summarized in this section. Development barriers. Affordable housing development, particularly For projects relying on Low Income Housing Tax Credits (L1HTC), has slowed down in all portions of the country. As such, there have been Few affordable housing projects completed in the Boise region in recent years. ~ Five stakeholders responded to this question. Three out of five stakeholders identified this as a serious barrier. BBC RESEARCH Si CONSULTING SECTION IV. PAGE 11 Developers are not optimistic about the return of the LIHTC market because of federal budget cuts and the 5 percent local project investment required by IHFA for LIHTC projects. As such, local affordable housing developers are increasing the affordable housing stock in other ways. One developer has partnered with local private lenders to fund single family acquisition and rehabilitation projects in Meridian. Developers suggested that Meridian has a limited supply of affordable and available land for affordable housing development. More specifically, one developer said "land is currently not available where affordable development would make the most sense." Developers suggested that city-owned land in downtown Meridian should be used for affordable housing development. Affordable housing strategy. Developers suggested that the city first focus on preserving existing affordable units in the city by working with current property owners to ensure that existing affordable housing contracts do not expire. Secondly, the city should adopt a variety of tools to help reduce affordable housing development costs. These tools should be implemented soon to encourage affordable housing development when the mat•ket returns. Developers suggested the city should consider adopting the following tools and policies to help encourage affordable housing in Meridian: ^ Land donations, particularly in downtown Meridian where some density currently exists; ^ Pt•operty tax abatements on affordable projects; ^ Relax building code and design guidelines for affordable projects (rehabilitation and new construction); ^ Expedited review and permitting process for affordable housing projects to alleviate additional carrying costs; and ^ Development fee waivers (e.g., building permits, infrastructure costs, utility hook ups). BBC RESEARCH & CONSULTING SECTION IV, PAGE 12 SECTION V. Fair Housing Impediments and Action Plan SECTION V. Fair Housing Impediments and Action Plan This final section of the Meridian AI identifies impediments found during the research process; and concludes with a recommended Fair Housing Action Plan for the Ciry of Meridian. Summary of Needs The following summarizes the major findings from Sections I through IV of this report Demographic and racial and ethnic concentrations analysis. Tlrc last 10 years in Meridian have been defined by rapid population growth. T'he city grew from approximately 35,000 residents to 75,000 residents between 2000 and 2010. Meridian currently accounts for 19 percent of Ada County's total population; however, the city accounted 44 percent of Ada County's growth in the last 10 years. The city's residents are primarily racially White (92%) and ethnically non-Hispanic (93%). Hispanics are the fastest growing minority group in Meridian. In 2000, there were approximately 1,100 Hispanics living in Meridian, compared with more than 5,000 in 2010. Thet•e are no areas of racial or ethnic concentration in the city. The city's original downtown area, which is a HUD LMI area, contains concentrations (based on HUD's definition of disproportionate need) of low income households. This portion of the city also caltains a larger proportion of persons with disabilities. Housing market analysis. Since 2000, the proportion of renter households in Meridian has grown froml6 percent to 23 percent. In other words, more households rent their home now than in 2000. The median rental rate in Meridian is $965, which is higher than the median rent in Ada County ($751) and neighboring Boise ($718). The rental market has primarily been constructed for households earning between $25,000 and $50,000 per year. As such, there is a gap of approximately 1,000 rental units For the 1,700 renter households in Meridian earning less than $25,000 per year. There are no public housing units and 50 subsidized units in Meridian. An estimated 185 Section 8 vouchers administered by the Boise City Ada County Housing Authority arc used in Meridian, and 550 Meridian households arc currently on the Section 8 waitlist. The BCACHA recently closed the Section 8 waitlist, indicating that households needing housing assistance in the near future will not be able to apply for the Section 8 program. Like most communities in the U.S., Meridian has been impacted by foreclosures. According to RealtyTract data, Meridian may have had as many as 55 foreclosure filings just in November 2011. While no portion of Meridian has been immune to foreclosures, the city's downtown area has been particularly impacted. Far example, in 2010, more than half of all sales in one downtown Census block group were for bank owned properties. BBC RESEARCH St CONSULTING SECTION V, PAGE 1 Public transportation and amenities. Lilce many western communities, residents in Meridian and the Boise region arc primarily dependent on cars for transportation. Nearly 80 percent of Meridians residents drove alone to work each day. And, less than 1 percent of the city's workers relied on public transportation for their work commutc.~ Public transportation opportunities ace limited in Meridian. Although Meridian lies along Valley Ride Transit's regional bus line, the purpose of the regional bus system is largely to connect Boise to Nampa. Residents and stakeholders both noted that public transportation opportunities in Meridian are very limited. The city has served the defined LMI area in a variety of ways to ensure that municipal services are provided equally throughout the community. The city recently used its CDBG funds for improvements to Centennial Park, located directly south of one of the city's identified LMI Census tracts. The city has used CDBG funds to design improvements to sewer and water lines within the LMI area, and those improvements were recently constructed and paid for with city general fitnds. The main branch of the Meridian Library is located directly north of an identified LMI census tract, and the Meridian Community Center is located directly south of an identified LMI census tract. The city has used CDBG funds for the design of a segment of the Five Mile Creek Pathway within the LMI Area. CDBG funds will also he used to consu•uct this pathway segment in 2012. This pathway segment will provide an important recreational opportunity as well as an alternative transportation corridor. In addition to the location of these municipal services, the city has coordinated a Community Clean- up Day for the past 7 years. This Clean-Up Day has taken place within the downtown core of the city, at the heart of the identified LMI Area. The city's contracted waste collection company, SSC, is one of the primary partners for this important conununity event, and all the metal recycling money collected during the day is given to a local charity. Complaint, legal and lending analysis. In the last six years, 18 fair housing complaints were Filed for activities taking place in Meridian. Most complaints were filed on the basis of disability status (61 %), followed by race (17%), familial status (11 %) and national origin (6%). Elcvcn of the 18 cases are closed. Most (64%) cases closed following a successful conciliation or settlement; these cases involved discrimination based on disability or familial status. No recent fair housing legal cases have occurred in Meridian. An analysis of statewide complaints completed by BBC in summer 2011 found that the vast majority of fair housing legal cases in the State of Idaho occurred in Ada County and were related to developers, builders, engineers and/or architects failing to comply with the accessibility requirements of the federal Fair Housing Act and the Americans with Disabilities Act (ADA). There is no evidence of lending discrimination occurring in Meridian. In 2010, Hispanics accounted for 7 percent of the city's population and .3 percent of the city's loan applicants. Denial rates among Hispanic loan applicants (15%) were slightly higher than White applicants (13%); however, the difference is not enough to suggest lending discrimination. Denial rates among Blaclc/African American loan applicants were 31 percent, which is much higher than White applicants. While BlacldAfrican American loan applicants experienced much higher denial rates (38%) than White Means of nansporration to work statistics from the 2010 American Community Survey 1-year estimate. BBC RESEARCH St CONSULTING SECTION V, PAGE 2 applicants; however, too few applications were submitted by African Americans to truly analyze lending disparities. There were two Census tracts in Meridian that had higher loan denial rates than the city overall; these areas did not correlate to the city's low income areas. Furthermore, there was no racial or ethnic disparity in subprime lending in 2010, indicating that subpt•ime loans were not targeted to the city's racial oc ethnic minorities. Public input. The public input process for the ciry's Consolidated Plan and AI included a resident survey (330 responses}, a stakeholder survey (15 responses), a stakeholder focus group (seven participants) and ]cey pet•son interviews (six interviews).2 The city's outreach effort involved numerous organizations representing individuals from a number of protected classes including seniors, immigrants, low income residents, persons with disabilities, persons and families who are homeless, persons with HIV/AIDS, persons with substance abuse/addition, victims of domestic violence, youth refugees, and veterans. Five percent of survey respondents definitively reported that they had experienced housing discrimination in Meridian. Many stalceholdets feel that discrimination happens more frequently in Meridian, particularly for persons with disabilities, families with children/pregnant women and pet•sons of a different national origin. Stakeholders identified a number ways discrimination may be occurring in Meridian. These include: ^ Problems obtaining housing because of strict credit requirement, unreasonable deposits, and a lack of rental history; ^ Denial of service animal requests; ^ Refusal to rent or steering to other properties away From desired property; ^ Discrimination targeting non-English speakers. Discrimination includes lack of interpretation of important documents, retention of security deposit; and ^ Denial of reasonable accommodation requests or requiring too much information for reasonable accommodation requests. Stakeholders identified a number of potential fair housing barriers in Meridian. Survey participants noted that "restrictive covenants by homeowner associations or neighborhood organizations" is potentially a serious barrier to fair housing in Meridian. Focus group participants also believe economic constraints, lack of affordable housing, lack of public transportation and NIMBYism may also be barriers to fair housing in Meridian. Fair Housing in Meridian In 2007, one of the housing impediments identified in the city's AT was related to the need for potential renters, buyers, and the general public to understand the requirements of the Fair Housing Act. In response to this impediment, the city added information to its website about the city's Fair Housing Strategy and other housing related resources for members of the community to access. z Some stakeholders participated in more than one outreach effort. BBC RESEARCH ~i CONSULTING SECTION V, PAGE 3 In addition, the City was a sponsor of the City of Boise's fair housing public awareness campaign in April 2011. The campaign was called Good Neigh6ozs + Fair Hozzsing = Stz•ong Comrrzunities and was intended to increase community awarcncss and understanding of fair housing rights and responsibilities. Fair housing messages were spread to Treasure Valley residents through radio and television public service announcements, billboards, bus panels, bus benches and community presentations. The initiative was supported through the financial contributions of 15 partners, including Idaho Housing and Finance Association (IHFA), the Idaho Department of Health and Welfare, local banks, Valley Regional Transit and local broadcasting companies. Fair Housing Impediments and Action Plan The City of Meridian has evolved from a small, isolated farm community to an integral part of the Boise region. The city's convenient proximity to the region's major service centers, Boise and Nampa, has undoubtedly contributed to the city's rapid growth in the last 10 to 20 years. However, the city is more than a bedroom community to its neighbors. The city is now the home of a major regional medical facility (St. Luke's), and Meridian iswell-positioned to attract additional business growth in the future. As the city's role in the region has evolved, so has its population. The city's residents are aging, and its Hispanic population has grown in the last 10 years. The city's changing population makes fair housing awarcncss even more important. As such, the Fair Housing Action Plan (FHAP} is intended to help the city welcome new residents and retain existing residents as it continues to grow and evolve in the region. IMPEDIMENT NO. 1. Lack of affordable housing. The city has a limited inventory of affordable units for its size. Affordable housing development has recently been limited to acquisition and rehabilitation of single family units in the downtown area. As such, low and moderate income residents may have a hard time finding an affordable unit, particularly outside the downtown area. Stakeholders participating in the public outreach efforts all suggested that a lack of affordable housing was a barrier to fair housing in Meridian. Wiry is this zt b~tz•zier?Lack of affordable housing can lead to income, racial and ethnic segregation and may disproportionately restrict housing choices for certain protected classes. This may occur because racial and ethnic minorities have lower incomes or because persons with disabilities require specific housing accommodations and need affordable housing due to limitations on employment. Action item 1.1. -Preserve existing affordable housing units in the city. The city has a limited affordable housing stock. The city should aggressively attempt to preserve existing affordable units in the city by working with current property owners to ensure that existing affordable housing conu•acts do not expire. This would include identifying affordable housing owners in the city and understanding their needs for retaining the affordability component of their property. Action item 1.2. -Convene an affordable housing task force to investigate ways to develop new affordable housing. The city should convene an affordable housing task force to identify ways to encourage affordable housing development in Meridian. The task force should include community development staff, developers, representatives of the finance and banking industry and representatives from the city's economic development organizations. The task Force could also include existing affordable housing property owners. BBC RESEARCH ~ CONSULTING SECTION V, PAGE 4 The primary task of the committee would be to identify tools used by other neighboring and regional communities to encourage affordable housing development, and determine what may work in Meridian. Some of these tools, which were identified by local affordable housing developers during the public input process, include the following: ^ Property tax abatements on affordable projects (this task will require input from Ada County); ^ Relaxed design guidelines for affordable projects (rehabilitation and new construction); ^ Expedited review and permitting process for affordable housing projects to alleviate additional carrying costs; and ^ Development fee waivers (e.g., building permits, infrastructure costs, utility hook ups). The Idaho Housing and Finance Association (IHFA} is responsible for administering the Low Income Housing Tax (LIHTC) program in Idaho. Local communities are required to contribute 5 percent of the cost of the project to be eligible for LIHTCs projects in their community. As such, Meridian should identify ways to generate funds For this local match if a potential affordable project is proposed in their community. The city should investigate the fiscal tools other Idaho communities have implemented to generate this local contribution. IMPEDIMENT NO. 2. Potential resident opposition to affordable housing development. Stakeholders suggested that certain types of projects in Meridian have historically been met with resident opposition. Opposition against certain types of development is often referred to as "Not in My Backyard Syndrome" (NIMBY). Strong resident opposition to affordable projects may result in future projects being declined. Why is this a bars ier? In reviewing AIs, HUD gives consideration to how communities hold themsch~cs out to residents. Do they appear to be welcoming? Warm? Or exclusive? It is thus important in this era of fair housing that communities and residents project a positive image of housing choice and diversity. Action item 2.1. -Continue to participate in the regional fair housing awareness campaign and tailor it to current needs. In 2011, the city participated in the Good Neighbors + F~cis• Housing = Strong Cnnamulaities campaign to raise awareness of fair housing in Meridian. The city should continue this campaign to ensure residents are aware of their responsibilities, as well as the city's responsibilities, in affirmatively furthering fair housing in Meridian. The campaign should be modified to include issues raised as part of this AI. For example, the campaign should discuss the importance of having a variety of housing types in all neighborhoods to ensure all residents arc welcome throughout Meridian. The campaign should also include some outreach to local HOAs to ensure their covenants, conditions and restrictions (GCBs) do not violate the Fair Housing Act. The city should provide HOAs with the contact information For community development and legal staff to review CCRs if necessary. IMPEDIMENT NO. 3. Limited public transportation opportunities. The city has limited public transportation opportunities. This has the effect of disconnecting Meridian from the rest of the region, particularly for residents reliant on public transportation. This has a disproportionate impact on persons with disabilities who often rely on public transportation, as well as low income residents. BBC RESEARCH Si CONSULTING SECTION V, PAGE 5 Why is this a Gamier? Lack of transit opportunities creates a barrier to fair housing choice because it may have the effect of preventing certain types ofresidents-specifically persons with disabilities, seniors and low-income individuals-fi•om living in a community or in certain parts of a community. Action Item 3.1. Continue to stay engaged in regional transportation planning efforts, leverage local resources for local transit opportunities and seek partnerships. Regional tt•ansit is costly, and solutions to solving regional transit issues will not occur overnight. The city must develop a long term strategy to solving public transportation issues in the community. The city's Transportation Task Force should stay intact and should continue working on the city's initial transit plan. This plan is still in its early stages, but is envisioned to eventually provide reliable, fixed-route service throughout the community. Partnerships will be key to getting a public transit system off the ground. Besides VRT, COMPASS, Joint School District #2 and the City Council will all need to play a role. The city should stay engaged in regional planning efforts and identify opportunities for modifying existing bus toutes or adding stops to existing routes. The city should also work with the Idaho Transportation Department to identify grant opportunities for improving public transportation infrastructure if additional bus stops become available (e.g., bus shelters, curb cuts). The city should also identify local partners reliant on public transportation to leverage resources and generate local transportation partnerships. This could include using the senior center transportation service for persons with disabilities or identifying opportunities to partner with the local school district for out of district trips. IMPEDIMENT NO. 4. Lack of understanding by developers and landlords about housing accessibility requirements. A "lack of understanding by developers and landlords about housing accessibility requirements under the ADA" was identified as an impediment in the city's last AI, and continues to be an impediment in the city. Nearly all legal cases that have occurred in the Boise region in recent years have occurred against developers, builders, engineers and/or architects failing to comply with the accessibility requirements of the federal Fair Housing Act and the Americans with Disabilities Act (ADA). Additionally, C1 percent of all fair housing complaints filed in Meridian in the last six years have been on the basis of disability status, primarily for failure to make reasonable accommodations for a disability.] Why is this a barrier? Persons with disabilities are a protected class under the Fair Housing Act. Action Item 4.1. Tailor fair housing outreach campaign to address the needs of persons with disabilities. BBC recommends that the city continue its fair housing outreach campaign (Action Itctn 2.1). As part of that campaign, the city should tailor its message to highlight the needs and rights of the city's disabled population. 3 Twenty-five percent of all complaints filed in Meridian beaveen 2000 and 2011 cited "failure to make a reasonable accommodation." BBC RESEARCH Sr CONSULTING SECTION V, PAGE 6 Action Item 4.2. Expand outreach and education to Meridian's landlords. As part of the city's fair housing outreach campaign, city staff should visit multifamily properties in the city to ensure landlords are aware of fair housing law and requirements for serving persons with disabilities. City staff could also coordinate with a local FHIP to conduct outreach and training to Meridian landlords. Action Item 4.3. Train community development staff on ADA and fair housing design and construction guidelines. The city should ensure that all staff members involved in the building plan review process are aware of the design and construction requirements of the ADA and the Fair Housing Act to ensure all new units arc in compliance with the legislation. PY2012-2016 fair housing goals. The matrix on the following page summarizes the city's FHAl' to minimize impediments. BBC RESEARCH Si CONSULTING SECTION V, ('AGE 7 0 N N 0 N C Cd G O +_~+ V R C C i~ u Q d1 ~ _ O i Z Y. LL "r ~ ? S `' , ~ , , r_ I i `j;ti. I ~~ ~ .. _ f~~ <.~ i i I r : js; - • ~ ;ii •. - ~ ~' ~f_. x _ X X . ~{ X }' ~ _' x x X r ~ i _ '= j~' K. "'' x x x x x x x x x z I ~ x x x x x R7 x x ?=~ ~- i x X X ! ~. x x X ` ' ~ X x X r° t0 c a S .a ~ w ~ ~ p ' ' « ~ U N C y d a ~ G ~ a -i 5 ~:. : ~ V r . O ~ :. .~ C 61 . d N ~ ~r O L O ~ 2~ ~ C r- m „' m w .~ ¢ O~ ~~ o E .D x i .- ~ 2 ~ N rn C ~ -~ ~ v .~ ~ Q :. -r ~ a~ or m v Y LL ~ F A ~. .~ .C y ~`~ C O 9 ~L 4 A _ m N F~ Q N Ol E ~ . d ~ Cn J d W a m ~~ a O a~ rs ~ rs ~ 1. ' ': 3 a d ~~ ~ c c ~ .0 U~ 2 0~ C .~ E rs d v 0 ,: ~ ~ ~ a °~ N G a E m O a' .. .~ Ol ~ aJ a °i ~ v O u E ~ °' ~ o d '^ m ~ rJ~ c _~ v '^ o~ ~ E E a s rs ~ °- ~ v ~ °' v c E p m E~ v a c rs ~~ v g E v o a 3 Q p x ~ ~ ~ 'O v o ?~ - v v 'O a c i c U E ,. i~ .- ~ ,~ E c U o ~ Cl C L H O ~ O rs ~ 'a ;O U C a ~ ." O Y OU ~ C ~ fl_ O U ^ V = . ' J j O =O .O r rs Y q .V N C _o o O :~I T v _ I ~~ ° ~~ O y O ` L ~ w Y C ~ I ~' v w~ 01 p ~ v A ~ U' 1 « ~d.. C ~ ' ' Y a v v « C a LL ~.. ~ N ~ C o a`+ U ~ ~ O .O m a+ ~ v 'O ~ 3 Ti ~ 9 ~ _p '_-' ~ V Y ~'Ll _ ~ N O ~ C ...~~ ~ ~ O 3 aL. ~ ~ C O ~ O .ten ~ m d 3 U ~C a CJ. O L i C I ~ .i ; F .T .3 ~ .3 -~ ,~' O~ ' ~ L' ~ ~ ~ ~ J E O O V ~ 1 ~ CI C ~ ~ o E ~ " O -_° ~ °u ~v 'av o. v° ~ ;:? ~ o .~, ss ~ Est- - ¢ am u u°r ~~ ~;~ 4 ~7 ti I I ~, ~~ m c ' ' ' d t~ ~ 'a :-s I I, f.i ~ c c ro ~ v ~ w v ~ r a ~ ` v r.~ o v r ,l C fu a~ ~ C Q C `~ `~ ~ o ~ o ` 1 }}~ A ~ _i ` ~ v . FF~~'~~i F ~ v ~ a G 5 " Ol ._~ ~ 3 ~~ ~ •- is ~ °' c ~. E ~, c ~ a v ' '. ~ . f v c o yu « ~.f 5 0~ ~f„ .c a ~ E 2 .o ~ i S v I-' v v .a t m~ o a f l ~ C I p ~ ~ v ~~ ~ b ~ d • -i ~ > N C ~ ~ O T m ~ ~ Q a E ~ ~ ~ c «. ~ O 1~7; ~C ~ C O V rs T_•' a G C . 3 ~ a s ;~,~ ~n p O ~ rf' p ` ~ C~ _ ~ m Y f Ji ~ y ~ ~ ~ ; .t a ~ ~ v a , ~ . I-{ C v ? -~ C a ~~ C G C O N C'O G O - t i. f =. f~ r- nj .- ~1 -~ _ N j' M K N V M '7 a~ .N 0 V L v z U m a rs ~` v v >" z O V w to v z J Z U x V K Q w v m c0 Structure for Oversight Responsibilities, Monitoring Si Evaluation The completion of this AI was overseen by the City of Meridian's Department of Community Development. Community Development will be ultimately responsible for carrying out the Fair Housing Action Plan. To ensure that each activity is carried out, Community Development will conduct an evaluation of each activity during each program year and identify additional areas that require study or analysis and how to address the additional areas. As part of the annual Consolidated Annual Performance and Evaluation Report (CAPER), Community Development will include a sLttnmary of the following: ^ Actions taken to affirmatively fitrthcr fair housing: ^ A summary of impediments to fair housing choice in the AI; and ^ Identify actions taken to overcome effects of impediments identified in the AI. Per Section 2.14 in HUD's Fair Housing Planning Guide, Community Development will maintain the following data and information as documentation of the city's Fair Housing Action Plan: ^ A copy of the AI and any updates. ^ A list of actions taken each year as part of the Fair Housing Action Plan to eliminate the itnpeditncnts identified in the AI. At the end of each program year, the city will submit information to HUD about the actions taken to fulfill the Fair Housing Action Plan and an analysis of their impact. BBC RESEARCH Si CONSULTING SECTION V, PAGE 9