1 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE QUESTIONNAIRE Ohio Department of Development Office of Housing and Community Partnerships ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING Jurisdiction: Fairfield County, Ohio _______________________________________________ Prepared by: Fairfield County Regional Planning Commission and Lancaster-Fairfield Community Action ________________________________________________ Date Completed: 2011 _________________________________________________
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ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE
QUESTIONNAIRE
Ohio Department of Development Office of Housing and Community Partnerships
ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING
Jurisdiction: Fairfield County, Ohio _______________________________________________ Prepared by: Fairfield County Regional Planning Commission and Lancaster-Fairfield Community Action ________________________________________________ Date Completed: 2011 _________________________________________________
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Prepared by the Fairfield County Regional Planning Commission and the Lancaster-
Fairfield Community Action Agency – 2011
Methodology Used: For the 2011 Analysis of Impediments to Fair Housing, the Fairfield County Regional Planning Commission (RPC) and the Lancaster-Fairfield Community Action Agency (Community Action) have utilized the 2004 Fairfield County Analysis of Impediments of Fair Housing as a template to develop this new five-year plan. As in the previous plan, we convened a group of individuals (listed below) and asked them to complete a similar survey as completed for the previous five-year plan. This survey is included in the appendix of this document. The intent of this survey was to help determine if there have been any changes in the perception of Fair Housing in Fairfield County. We also conducted one-on-one interviews with some of the agencies to obtain a better understanding of their specific views on fair-housing choice. In addition to the agency survey, the RPC and Community Action also created a citizen survey that we distributed online via Survey Monkey. We also provided hard copies of the survey at Community Action’s offices, Fairfield County Jobs and Family Services, Fairf ield Metropolitan Housing Authority, and the Fairfield County Information and Referral Office (211). A copy of this survey is also included in the appendix of this document. The purpose of this survey was to better understand the perception of Fair Housing from a citizen’s point of view. Impediments to Fair Housing Advisory Committee: Holly R. Mattei, Fairfield County Regional Planning
Alice Saunders, Black Interest Group, Chairperson Dan Bates, Fairfield National Bank, Vice President
Tony Caito, Real Estate Broker, President, Lancaster Board of Realtors
Bruce Burns, Fairfield County Metropolitan Housing Authority, Executive Director
Tonya Leeatoa, Housing Assistant Director, Columbus Urban League
Eddie Rapp, Director, Fairhaven Transitional Living
Don Borah, Realtor, Bartlett-Benner Real Estate Company
Brooke Taley, Lancaster-Fairfield Community Action Agency
Pam Patula, Executive Director, Southeastern Ohio Center for Independent Living (SOCIL)
Dr. Ed Payne, Director, Fairfield County Center for Disabilities
John Pekar, Fairfield County Board of Development Disabilities, Director
Patti Morrow, Information and Referral – 211, Director
Anna Marie Qualls, First Bremen Bank
Carrie Woody, Lancaster Public Transit – Director
Shane Farnsworth, Fairfield County Economic Development, Director
Janet Galligan-Dent, Veterans Association Chillicothe
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Paul Carbol, Appraiser
Mike Kiger, County Commissioner
Judy Shupe, County Commissioner
Steve Davis, County Commissioner
Mary-Jo Smith, Ex-Officio
Jurisdictional Background Data
For this 2011 Analysis, we have reviewed the county’s current CHIS. We continued to utilize a majority of the data within this housing study, along with supplemental information as noted below. Demographic Data and Income Characteristics As stated above, this information is contained within the Fairfield County Community Housing Improvement Strategy (CHIS). In addition to this study, we have included a Table of Persons by Race for both the townships and villages/cities within the county based upon the recently published 2010 Census Data. Employment and Transportation Profile Employment and Transportation Data are provided within the Ohio County Profile within Appendix A of this analysis. A list of major employers with the number of employees prepared by the Fairfield County Economic Development Department in March 2011 is included in Appendix A. Housing Profile
This information is contained within the Fairfield County Community Housing Improvement
Strategy. Maps 1. Maps within Appendix B of the Fairfield County Community Housing Improvement Strategy
include: a. Low and Moderate Income Population Concentrations b. Areas of Minority Concentration c. Percent Elderly Below Poverty Level d. Percent of Persons with Disabilities, 16-64 Years of Age e. Percent of Persons with Disabilities, 65 Years of Age or More f. Percent Owner – Occupied Units g. Percent Renter – Occupied Units h. Percent Owner Units Built Prior to 1950 i. Percent Renter Units Built Prior to 1950
2. The following maps located within Appendix A of this Analysis:
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a. Percentage of Persons Non-White (Source: 2010 Census Data) b. 2009 Median Value of Owner Occupied Homes (Source: Census) c. 2009 Median Gross Rent (Source: Census) d. Percent of Vacant Housing Units (Source: 2010 Census Data)
Identification of Impediments to Fair Housing Choice
(in each area identified in the 24 CFR 904(c)) Demographic Information Has all demographic information been collected which could be helpful, up-to-date as possible? YES __X___ NO _____ Is there any meaningful demographic data which is not available but should be obtained by local surveys or other sources? YES _____ NO __X____ Comments: A limited amount of 2010 Census data, which includes population and demographic data by place, has been recently released. We believe this new data will illustrate the growth that Fairfield County has experienced over the last 10 years. Is there any meaningful demographic data that is not available specifically for the jurisdiction but statewide or area data (averages) could be used to suggest “typical characteristics?” YES NO ___X___ Comments: The new 2010 Census data better reflects areas of population growth and areas with increased minority populations. Is there reason to believe that certain portions of the demographic information collected does not accurately portray the true characteristics and trends of the populations in the jurisdiction? YES NO __X____ Comments:
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In 2004, the county did not believe the 2000 Census data was accurately reflected the increasing minority populations in the northwest quadrant of the county. The new 2010 Census data better reflects areas of population growth and areas with increased minority populations. Do the trends in the demographics of the past 10 or 20 years suggest any important changes that are going on in the area? YES __X___ NO ______ If yes, what causes or other factors can be attributed to these changes? There is now a higher minority population in the northern area of Fairfield County. In general, Fairfield County is becoming a more suburban community with characteristics matching more closely with other Central Ohio suburban communities. According to the new 2010 Census data, there is an increasing minority population in the northwest corner of the county. The percentage of population by race in this area of the county is as follows:
Do the demographics and trends of nearby areas suggest any future trends for the local jurisdiction? YES __X___ NO ______ Comments: With continued growth and suburbanization we will expect to see more growth in the minority population within Fairfield County, and the overall demographics of the county will trend to match more closely with those of the balance of the Columbus Metropolitan Statistical Area, specifically in Violet Township. While this area holds the greatest ethnicity in the county, Violet Township also has the highest income demographic. Are there noticeable patterns of the distribution of protected groups? YES __X___ NO ______ If yes, what causes or other factors can be attributed to these patterns?
We see more growth in minority populations in the northwestern quadrant of Fairfield County. Again, this is attributable to the suburbanization of the area that borders the Columbus Metropolitan area. Has the jurisdiction provided more than the numbers and offered an analysis for the cause of segregation and a plan to desegregate neighborhoods? YES _____ NO __X____ Comments: Our strategy has been education and we believe there is a need for more subsidized housing in Fairfield County. This is a suggestion which may help. This is also an issue which could better be addressed through the Fair Housing Sub Committee of Fairf ield County Housing Coalition to determine the best strategy for this area that is uniquely diverse both in terms of ethnicity and household incomes. Has the jurisdiction reviewed the historical information, policies, ordinances, etc. that helped establish and maintain racial and ethnic segregation? YES __X___ NO ______ Comments: Enlarging housing unit size requirements may have a discriminatory effect. Does the local jurisdiction lack racial or ethnic diversity? YES __X___ NO ______ If yes, what causes or other factors can be attributed to this lack of diversity in the jurisdiction? Compared to state trends, there is a lack of racial and ethnic diversity in Fairfield County. As previously mentioned, the minority population is growing in the northwestern area of the county. However, this is not true for the remainder of the county. Only 4% of the population for the remainder of the county includes minority races. This factor may be positively affected through more education and awareness programs in schools and other community areas. Also, the population is trending toward more diversity as suburbanization continues to take place. Has there been evidence of resistance to diversity or integration in the jurisdiction? YES NO X
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Are there noticeable patterns of segregation within the jurisdiction? YES NO X There is a general lack of diversity in Fairfield County, but as previously stated this is changing as suburbanization is taking place. Does the local jurisdiction lack housing that meets the needs of individuals with disabilities? YES X NO If yes what causes or factors can be attributed to the lack of affordable accessible housing for individuals with disabilities? Once people acquire the affordable accessible housing they hold onto into reducing turnover and limiting availability. Fairfield County has a high percentage of older housing stock that was designed and constructed long before the development of industry trends and ADA requirements for accessibility. Additionally, reliable data about accessible housing needs has been difficult to find. However, we continue to find a method to quantify the need so that the community can find the necessary resources to increase its stock of accessible and affordable housing. Is the housing that is available for individuals with disabilities segregated or limited to individuals with a defined disability or minimum age such as 202 & 811 programs? YES NO X Are mainstream assessable housing units, especially larger units designed for families with a member with a disability, available in public and/or assisted housing? YES X NO If the local jurisdiction has a homeownership program, are accessible units available? YES X NO Habitat for Humanity of Fairfield County is building accessibility and visitability into its new homes. At the present time, HFH is the only organization providing homeownership opportunities linked to new construction. Through the homeownership activities of the Fairfield County CHIP, assisted units are rehabbed with accessibility features when needed by customers. Has there been evidence of resistance to group homes or housing designed for persons with disabilities within the jurisdiction? YES NO X Are larger families with children living in overcrowded conditions?
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YES __X___ NO ____ Comments: Due to the high costs of rents in the area, larger families have a diff icult time identifying and accessing safe, affordable housing suitable for larger numbers of family members. Many agencies have indicated that they have seen an increase in overcrowded housing conditions over the past couple of years due to the poor economy. The advisory committee also noted that there are relatively few homeless shelter units for families to utilize, thus contributing to these overcrowded living conditions when households are “doubled-up.” The family shelter at Lancaster-Fairfield Community Action Agency is now under rehabilitation and expansion. Acquiring adequate funding for construction of family shelter units is a challenge. This particular project was made possible through a combination of local private funds, LFCAA funds and grant funds from the Ohio Department of Development. Funds to operate a family shelter are also extremely limited. LFCAA has been able to operate the family shelter by layering resources and by receiving donations from the community. Have all geographic areas been examined and meaningful access to program information given to Limited English Proficiency (LEP) speaking populations within the local jurisdiction? YES X(Somewhat) NO As noted below, the advisory group has identified a need for better translation services and also recommended cards be created to help citizens identify their primary language to fair housing officials so that appropriate translators can be obtained. Overall, Fairf ield County has a very low percentage of Limited English Proficiency households. We are in the process of gathering and analyzing recent census data to see if there are any newly emerging trends that would be relevant in this area. Does the jurisdiction have a LEP Implementation Plan to ensure that eligible LEP populations benefit from and are included as program participants? YES NO X Fairfield Metropolitan Housing Authority has an LEP plan and has noted the need to translate their housing forms into Spanish. Fairfield County as a whole does not have a formal plan, but as noted below, we have identified several areas where we can make improvements to better include LEP populations as program participants. Has the jurisdiction translated fair housing materials into languages for LEP persons residing in the jurisdiction? YES _X____ NO ___ ___ Comments:
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This was an impediment that was identified in the 2004 analysis. As a result, the fair housing printed material has been translated into Spanish and is now available to the public in both English and Spanish. The advisory group has recently indicated an increase in the Somali population with many of them speaking different dialects. Due to the number of different dialects, the advisory committee believes that increasing interpretation options for this population would be more beneficial than providing written brochures. The advisory committee also recommends that small cards be developed with various languages. A non-English speaking citizen could then identify his/her primary language on the card to the Fair Housing official then appropriate translators would be called in for further assistance. Are translators available to help people understand their fair housing rights? YES _____ NO ___X___ Comments: As noted above, this is an area we believe we need to improve upon. The advisory committee believes that this could be achieved by partnering with the Fairfield County Literacy Council and local universities. Is there a relationship with service providers for linguistically isolated families and the fair housing office to identify and remedy problems? YES __X___ NO ______ Comments: The committee believes that the relationships recommended above need to be strengthened to address this issue. The Fair Housing Office is actively engaged in the Fairfield County Housing Coalition, which engages service providers throughout the county. Has the jurisdiction applied for and utilized funds to make public places, streets and sidewalks accessible for people with disabilities? YES __X___ NO ______ Comments: Yes, CDBG funds have been effectively utilized to build handicapped accessible ramps, elevators, and sidewalk ramps. Since 2004, CDBG funds have been used to make the following public places accessible for people with disabilities:
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County Courthouse ADA Restroom Improvements Two county buildings (automatic door openers) West Rushville – Sidewalk Improvements Pleasantville – ADA improvements to Village Hall Violet Township, Pickerington, and Bremen ADA ramps for sidewalks Rushcreek – ADA improvements to Township Hall Olivedale Senior Center building entrance and public restrooms Village of Lithopolis Village Hall The advisory committee recognizes the efforts taken, but stresses the need to continue these efforts to become an even more accessible community. Also, the Fairfield County RPC recently formed an Active Transportation Sub Committee which will be looking into forming a Complete Streets Policy. This type of policy could also assist with making our transportation facilities more accessible. Is there are relationship with service providers for people with disabilities and the fair housing office to identify and eliminate barriers to fair housing? YES _X___ NO ______ The Fairfield County fair housing office (RPC) works very closely with the SOCIL, Fairfield County Board of Developmental Disabilities and other agencies that provide services to people with disabilities. Has an analysis been completed that makes recommendations for achieving fair housing for people with disabilities? YES __X___ NO ______ The surveys completed with this 2011 analysis showed that persons with disabilities perceive that they have been discriminated against when trying to obtain housing more than the other protected classes. The advisory group for this analysis has identified this as an impediment to be further addressed as part of this plan. In addition to basic statistics, has the jurisdiction analyzed the patterns, laws, and actions implicated in establishing and maintaining certain demographic patterns? YES _____ NO ___X___ Comments: These tasks could be completed by the Housing Coalition Fair Housing Sub Committee. Has the jurisdiction made recommendations for challenging programs, policies, laws or other activities that violate the fair housing laws? YES __X___ NO ______
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Comments: Regional Planning has recommended against townships placing increased housing size in building codes within the townships as this practice lends itself to increases in housing prices. Regional Planning has also worked with townships to incorporate language into their zoning codes to allow adult family homes, adult group homes, and residential facilities within residential districts, per the requirements of the Ohio Revised Code. Sale of Housing Is there evidence of restrictive covenants, trusts or lease provisions in use in the community that would exclude sale to, or occupancy by, a particular group of potential buyers or renters based on membership in any of the protected classes? YES __X___ NO ______ Comments: During our review, we found a plat restriction that caused concern, which was located within the City of Lancaster. The restriction was referred to the City’s Fair Housing office for investigation, and the City has taken action to resolve this concern. Are covenants that contain such restrictions recorded in deeds on file in the jurisdiction's deed recordation office? YES __X___ NO ______ Comments: The one restriction noted above is located on a plat recorded in the Fairfield County Recorder’s office. This plat has language that indicating that this restriction is invalid because it violates Federal and state laws. Are, or have there recently been, incidents of negative community attitudes resulting from moves by minorities into non-minority, white neighborhoods, or vice versa? Moves by persons with disabilities into, for example, groups homes in certain area? YES _____ NO __X__ Does the jurisdiction collect similar information from lenders, brokers, and subdivision sellers on applicants for mortgage loans, brokerage services, or home purchases? YES _____ NO ___X___ Comments:
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Does the jurisdiction conduct sales audits to measure whether or not homes are made available regardless of the racial composition of the neighborhood or public schools? YES _____ NO ___X___ Comments: Nothing looked at in that manner at this time, not aware of any recorded data on this in Fairfield County. Does the jurisdiction conduct investigations to insure that racial steering is not occurring and that no illegal manipulation of the market place is occurring in any neighborhood? YES _____ NO ___X___ Will real estate companies accept listings regardless of the value of the home? YES __X___ NO ______ Have real estate companies carved out a niche market and refuse to accept listings or show homes outside of that niche market? YES _____ NO ___X___ If yes, does this policy have a discriminatory effect on neighborhoods where the residents are members of protected groups? NA Rentals Do local rental complexes have policies that unduly restrict access for families with children or persons with disabilities such as high security deposits or restricting in which building families or persons with disabilities can reside? YES _____ NO __X____ Are families with children or persons with disabilities restricted to first floor units? YES _____ NO __X____ When families with children reside in the complex, are they limited to the times when children can have access to the pool, community room, etc?
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YES _____ NO ___X___ Is there evidence, from complaints, audits or other sources, that landlords of privately owned rental housing, or their management agents, are limiting occupancy in multifamily housing complexes through use of occupancy quotas based on membership in any of the protected classes? YES _____ NO __X____ Does the jurisdiction have a regular program to collect summary data from landlords and managers of rental housing on the racial, ethnic, gender, and familial and disability status of tenants and applicants for rental housing in the jurisdiction's jurisdiction? YES _____ NO ___X___ Does the jurisdiction use this information in connection with fair housing audits of rental housing, as a part of its fair housing enforcement or education and outreach efforts? YES _____ NO ______ N/A Advertising Do the advertisements for home sales, rental, or access to rehabilitation or remodeling programs include photographs of people from different racial/ethnic backgrounds?
YES __X___ NO _____ Comments: Both in the Columbus Dispatch and the Lancaster Eagle Gazette, recent real estate advertising include photographs of diverse racial/ethnic identifications. Are advertisements published in newspapers that reach a wide variety of eligible applicants as well as being written in languages other than English when appropriate? YES __X___ NO ______ Are newly constructed rental units advertised as “barrier free?” YES __X___ NO ______ Do local newspapers use the non-discrimination disclaimer in its advertising section? YES __X___ NO ______ Does the local newspapers know the fair housing law requirements for advertising?
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YES __X___ NO ______ Comments: On numerous occasions the local newspaper staff has referred landlords to the Fair Housing Office for fair housing education information. Does the jurisdiction monitor the advertising of newspapers for compliance with the fair housing laws? YES __X___ NO ______ Are affordable housing developments advertised on the Internet? YES X NO Are local affordable housing providers advertising their available units on the Internet on the Ohio Rental Housing Locator? YES X NO Other Notes: The Internet has become an increasingly popular way to advertise rental unit availability. It is also more difficult to monitor these advertisements. Fairfield County should continue to increase its efforts to monitor these Internet advertisements. Insurance Are there age restrictions that prevent the writing of replacement or guaranteed replacement cost policies for older homes? YES _____ NO __X____ Comments: Everything is up to code. Do insurance companies have marketing programs that exclude writing multi-line coverage for the jurisdiction or certain neighborhoods within its jurisdiction? YES _____ NO __X____ Do companies have policies that prohibit the writing of replacement or guaranteed replacement cost coverage for homes with market values that fall significantly below the estimated cost to replace the home? YES _____ NO __X____
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Do residents of some neighborhoods, particularly low-to moderate income residents, experience difficulty in obtaining reasonable insurance coverage for the dwellings? YES NO X We have received no reports of difficulty in obtaining insurance coverage for dwellings. Affirmative Marketing Programs Housing that receives federal and/or state of Ohio funding generally must develop and implement an affirmative marketing plan. The plan should be designed to attract the people least likely to apply for the housing. Have the developers/builders of federal- or state-assisted housing identified and attempted to reach those persons least likely to apply for the housing? YES X NO ______ Comments: Do local assisted housing providers (HOME, LIHTC, Rural Development, Section 8, Public Housing, etc) and Supportive Housing Programs list and market their units through the Ohio Rental Housing Locator? YES X NO Are people with disabilities encouraged to seek housing in the new subdivisions through print and online advertising or direct marketing through agencies that serve people with disabilities? YES _____ NO ___X___ Comments: Does the jurisdiction monitor subsidized housing developments for compliance with affirmative marketing requirements? YES __X___ NO ____ Accessibility for Persons with Disabilities/Design Issues Does the local jurisdiction have a system in place for the review and approval of architectural designs, platting, sidewalks, curb cuts, etc. to ensure compliance with Federal, state and local accessible design requirements? YES __X___ NO ______
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Developments subject to the Fairfield County Subdivision Regulations, which would include those developments that are platted and include sidewalks and curb cuts, are submitted to the Fairfield County Regional Planning Commission. The plans are reviewed by the RPC and the Fairfield County Engineer’s office and inspected by the County Engineer’s office to ensure compliance with ADA requirements. Non-residential buildings must also receive approval from the Fairfield County Building Department who ensures compliance with ADA requirements. Does the local government have a process in place to conduct on-site review during construction projects to ensure compliance with accessibility designs as submitted? YES __X___ NO ______ Is there a mechanism to review and bring into compliance any builder not following the requirements of the Fair Housing Act or other applicable accessibility requirements? YES ___X__ NO ______ What unit of government oversees compliance with the Fair Housing Act for new construction, substantial rehabilitation, remodeling of commercial and multi-family housing, etc.?
The Fairfield County Regional Planning Office and Fairfield County Building Department. Has the local government taken any steps to disestablish segregated and promote integrated housing for individuals with disabilities? YES NO Community Development Corporations (CDC) Are fair housing training and educational materials provided to local CDCs to insure that they affirmatively market and provide housing in a non-discriminatory manner?
YES _____ NO ______ (N/A. We do not know of any CDC’s in Fairfield County per se.) Is staff trained to recognize and report fair lending or insurance problems that the CDC or its clients experience during any phase of the development of the project—acquiring land, zoning/special use issues, etc.? YES _____ NO ______(N/A. We do not know of any CDC’s in Fairfield County per se.) Does the local jurisdiction encourage CDCs and other housing developers to include units to meet the area’s underserved populations including development of affordable, integrated, accessible and/or Universally-designed housing or units for large families with children or multi-generational families?
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YES X NO Although we do not have any CDCs in Fairfield County, in general SOCIL advocates for universally designed housing. CDBG/HOME Funded Programs Is credit scoring used by CDBG or HOME-funded programs to determine eligibility? YES _____ NO ___X___ Have the credit scoring systems been evaluated for possible discriminatory impact against members of the protected groups? YES _____ NO ______ (N/A. We do not use credit scoring for eligibility determination) Do the local CDBG and housing program staff administrators insure that program participants are treated fairly under the requirements of the Fair Housing Act when applying for f inancing or being pre-qualified by the organization for home loans?
YES __X___ NO ______ Is preference for program participation given to residents of the community and, if so, will this have a disparate impact of members of the protected groups? (For example, if a predominately white community restricts applicants for government subsidized/built housing to local residents, this may have a discriminatory impact on people of color wanting to move to the community) YES _____ NO ___X___ Do actual beneficiaries (outcomes) of the local federally funded housing and community development programs represent the characteristics and statistics of the local demographics? YES X NO Housing Programs and Activities Before undertaking a new OHCP-funded housing program or activity, or before renewing funding for an existing program or activity, grantees should review and document the projected or actual impact on fair housing and related aspects of protected equal opportunity based on race, color, ethnicity, national origin, disability status, gender, familial status, and military status. Does the housing project promote or discourage integrated housing and neighborhoods; and will it include and enhance housing opportunity, mobility, and affirmative fair housing measures, as required under existing law?
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YES X NO Does the housing project include measures to ensure that the populations with the greatest barriers to upward mobility (under 200% of the federal poverty level) have access to more quality housing? YES X NO Will displacement due to the project, if any, disproportionately burden members of particular demographic groups? YES NO X Will displacement due to the project create segregation or integration effects for members of particular demographic groups? YES NO X To what extent will any new housing units be equally accessible to individuals and families across the covered characteristics?
YES X NO Fair Housing Implementation plans are developed and implemented for all assisted housing projects and activities.
Housing Brokerage Services Have the brokerage firms in the jurisdiction carefully examined their business relationships with mortgage lending institutions to assure that these institutions do not restrict their lending activities to certain areas of the community? YES _X____ NO ______ Comments: Standard practice is to talk about multiple lenders and hand out fair housing brochures. Do the formal training and licensing requirements for real estate brokers that are applicable in the jurisdiction and surrounding jurisdictions include a requirement for training in and demonstrated knowledge of all applicable fair housing laws?
YES __X___ NO ______
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Is there any evidence that minority brokers are excluded from participation in multiple listing services in the jurisdiction or surrounding areas? YES _____ NO __X____ Is there any evidence that minority, persons with disabilities, or woman participants in real estate brokers associations are excluded or restricted? YES _____ NO __X____ Is there evidence that real estate brokerage services are assigning brokers based on the race or ethnicity of the brokers and the racial or ethnic composition of neighborhoods in which brokers operate?
YES _____ NO __X____ Are the opportunities for minority persons and persons with disabilities to become brokers as available as opportunities for non-minority white and non-disabled persons?
YES __X___ NO ______ Are there specific programs to attract minority and disabled persons to careers as brokers and to provide training and other assistance for this purpose?
YES _____ NO __X____ Are the boards of real estate brokers in the jurisdiction and nearby jurisdictions signatory to a voluntary affirmative marketing agreement (VAMA) with HUD? YES __X___ NO ______ (Not sure if all enter such agreements, but we are aware of brokers that do.) Financing Assistance for Dwellings Have lenders, appraisers and private mortgage insurers operating in the jurisdiction carefully examined their policies, procedures and practices to determine where differential treatment based on race and ethnicity occurs?
YES __X___ NO ______ Comments: Bankers report that they work hard in Fairfield County to make sure this does not happen. Local banks report that they conduct annual training.
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Are loan officers, other lending personnel, appraisers and private insurer staff fully trained in how to apply the new policies and standards and aware of the reasons they have been developed?
YES __X___ NO ______ Comments: Each year training on Fair Housing is required of all lenders, and all bank personnel who are involved are required to be in attendance. Where lenders, appraisers or private mortgage insurers have removed old policies, standards and procedures because of their association with discriminatory antecedents, have they adopted new policies, procedures and standards for:
• Loan origination • Loan processing • Assessing borrower credit worthiness • Appraising the value of the collateral and selecting appraisers • Underwriting decisions • Providing private mortgage insurance and selecting a private mortgage insurer
YES __X___ NO ______ Comments: As lenders, local bankers report they are always watching to make sure they are current on all policies. Do lenders, mortgage bankers, appraisers and private mortgage insurers in the area regularly monitor the application of these new policies and standards to determine if they are followed as intended?
YES __X___ NO ______ If lenders and mortgage bankers hire fee appraisers, or refer customers to an approved list of appraisers, do lenders set clear requirements regarding the standards that are acceptable to the bank that appraisers and private mortgage insurers should use? YES __X___ NO ______ Local banks have reported that they have more standards in place at the present time than they have had in the past. Do lenders and mortgage bankers disclose the full appraisal report to the borrower? YES _X____ NO ______
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One agency has indicated that although the full report is provided to the borrower, many individuals do not understand the details of the report. Do lenders and mortgage bankers use a pre-screening process and, if so, do they document the results, place the documentation in the applicant's file and make the document available to the applicant? YES ___X__ NO ______ Local bankers report that this is based on credit scores. Do lenders and mortgage bankers examine their conventional mortgage and home improvement loan profiles to determine whether they are neighborhoods that are under represented or not represented in these profiles?
YES __X___ NO _____ One local bank reports that they use census data and community reinvestment area data to assist with this review. Do lenders and mortgage bankers use the population and housing characteristics data that is available from the federal f inancial regulatory agencies for this purpose and their Home Mortgage Disclosure Act (HMDA) data? YES __X___ NO Do lenders and mortgage bankers compare the home improvement loan profile to the mortgage loan profile to determine if the former, which is usually a short term consumer loan, is made more frequently to minorities in minority neighborhood and to homeowners in mixed neighborhoods than mortgage loans?
YES _X____ NO ______ Does the jurisdiction regularly monitor reports of financial institutions subject to Home Disclosure Act (HMDA) Community Reinvestment Act (CRA)? YES __X___ NO ______ If so, what are the results and does the jurisdiction act upon this information in any specific way? This is also regularly addressed by the bank examiners of the local banks. For example, does the jurisdiction use this information as an incentive by depositing jurisdiction funds in banks with the best performance records? YES _____ NO ___X___
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Comments: Fairfield County goes out for bids for banking. The funds are placed in the local financial institution which provides the county with the most competitive rates, and the lowest banking fees. Do any lending institutions aggressively market the availability of mortgage and home improvement loans in minority neighborhoods and encourage minorities to apply? In. non-minority neighborhoods? In low and moderate-income neighborhood? YES __X___ NO ______
If so, do these institutions provide such loans in all areas of the community, or only in minority neighborhoods? Local banks report that marketing is conducted and loans are made available to the entire community. Are these “prime” lending institutions such as banks or are they “subprime” lending institutions such as mortgage companies? Fairfield County is comprised of mostly prime lending institutions such as national and state regulated banks. There are very few mortgage brokers in operation to date. Is there evidence of mortgage fraud or foreclosure rescue scheme operations within the local jurisdiction? YES NO X If yes, what is being done to educate the public about the various schemes and legitimate alternatives? Locally there is not a company creating scams for foreclosure. However, companies from other areas obtain the courts records and have sent items to all foreclosed residents. The Housing Solutions Program reports that they are not really hearing or seeing mortgage fraud at this time. New rules have made it more diff icult to obtain loans through the secondary market. What specific steps should the jurisdiction take based on an examination of sales and rental practices including real estate broker practices, e.g. adoption and dissemination of anti-redlining or anti-blockbusting policies establishing reporting requirements for housing providers in the jurisdiction's jurisdiction; establishing a stronger public education effort regarding the protection under fair housing laws; other actions? Fairfield County has a strong and active Housing Coalition within which the Fair Housing Sub-Committee operates. This committee is comprised of local government agencies, including the housing authority, shelters, etc. as well as private businesses, such as local banks. This coalition
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serves as a place to discuss these policies and practices and to determine future eduction efforts to reduce housing discrimination. What steps should the jurisdiction take to promote specific efforts to make brokerage services more inclusive and fully consistent with the requirements and objectives of fair housing laws? Again, the Housing Coalition is the venue Fairfield County uses to help promote better fair housing practices at all levels. What steps should the jurisdiction take to promote cooperative efforts with other nearby communities to foster open and fair sale and rental practices and services on a metropolitan or other region-wide basis? Fairfield County has had open discussions in the past with the Columbus Urban League staff. With recent staff turnover, these connections need to be re-established. What specific actions should the jurisdiction take regarding restrictive covenants, leases, or other restrictive provisions that have been recorded in deeds or appear to operate in single-family housing developments, condominiums or rental complexes? Continue to provide education in this area. What steps should the jurisdiction take to educate the public about mortgage schemes and how to avoid them? Fairfield County has a strong Save our Homes Task Force that helps to educate the public regarding foreclosure and other housing problems. The Housing Solutions office within the Fairfield Metropolitan Housing Authority also provides homebuyer education sessions and counseling. These educational efforts should be continued and enhanced to help people avoid mortgage schemes. Appraisal Practices Is there a pool of appraisers familiar with all types of housing and markets throughout the jurisdiction? YES ___X__ NO ______ Do lenders use appraisers familiar with evaluating property in older, urban neighborhoods, if appropriate? YES __X___ NO ______ Does the jurisdiction review the impact of foreclosures on the community and if foreclosures were due to faulty, discriminatory appraisal practices?
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YES __X___ NO ______ What specific actions should the jurisdiction direct to the lending and appraisal industries to promote fair lending and appraisal self-monitoring programs, revisions to lending and appraisal policies, procedures and standards, and training of lending institution officers and staff? One of the local banks in the county has begun to “audit” some of its appraisals, which requires a second appraisal to ensure that the first one is accurate. This bank has noted success with this process. The jurisdiction should promote the use of these review appraisals throughout the lending and appraisal industries. Subprime Lending Issues Has the jurisdiction identified local companies offering subprime loans within the local community? YES _____ NO ___X___
Has the jurisdiction attempted to identify predatory lenders soliciting loans in minority, integrated and low and moderate-income neighborhoods? YES ___X (Somewhat)__ NO ______ This is mostly done through monitoring of advertisements. If a problem is identified, it is discussed at the Housing Coalition meeting to determine what course of action is needed. Has predatory or abusive lending practices resulted in fast foreclosures and vacant, abandoned or boarded up properties that have an adverse affect on home values?
YES __X___ NO ______ Comments: Fairfield County has not been immune to the recent housing crisis. Foreclosures have signif icantly increased over the last several years, which is illustrated in the table below. Abusive lending practices have contributed to the increase in foreclosure rates, but the unemployment rate due to the poor economy has also played a role in this increase. Year Foreclosures
Has the jurisdiction taken action to educate homeowners who are typically the victims of predatory lending – the elderly, women and people of color and persons with disabilities? YES __X___ NO ______ Comments: Home Buyer education programs are provided in a variety of venues throughout the county and throughout the year. The Housing Solutions Program through the Fairf ield Metropolitan Housing Authority has recently received its HUD approval for housing counseling. They provide one-on-one counseling services and also provide homebuyer education courses. The Save our Homes Task Force also provides educational material regarding foreclosure procedures to assist those who may have fallen victim to predatory lending. Literature providing information about predatory lending is available at local social services agencies. What steps has the jurisdiction developed and implemented to foster conventional lending services in under-served neighborhood? When LFCAA works with families to assist with home purchase, staff suggests first seeking financing options from the traditional banks, which are prime lenders. The Housing Solution’s homebuyer education courses also encourage people to shop around prior to committing to a mortgage. Also, Prime Lenders are the only type of lenders permitted to speak at the Housing Solution’s educational courses. What is the distribution of full service branches, offices, or ATMs in the jurisdiction? Good distribution. Are full service branch offices located in low and moderate-income neighborhoods that are racially or ethnically identifiable? YES __X___ NO ______ Have branch offices been closed in the past five years and what impact has this had on access to credit for people residing in the affected neighborhood?
YES __X___ NO ______
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There have been some branches closed within local retail grocery stores, but it is believed that these closures have had little impact on access to credit. Are ATMs, check cashing, payday loan stores being used to provide services in minority and low-moderate income neighborhoods? YES __X (somewhat)___ NO ______ Comments: There are several check cashing/payday loan stores that are located within business districts, but within walking distance of low-moderate income neighborhoods. The Housing Solution’s staff has also indicated that most of their foreclosure clients have visited a check cashing/payday loan store at least once. The advisory committee also noted a substantial increase in the use of these services in the last several years. Public Policies and Actions
Should policies and procedures for selecting persons to serve as members on planning boards be changed in order for an overall membership that is more representative of all segments in the community? YES _____ NO ______(Maybe) If so, who within the jurisdiction’s governing structure is responsible for such selections and what specific steps should be taken to accomplish these changes? The Township Trustees are responsible for making appointments to the planning boards in townships and the Village/City Councils are responsible for making these appoints within a village or city. It appears that several communities advertise vacancies on these boards to ensure that the entire community is provided an opportunity to apply. Other communities make appointments based upon word of mouth. The Fairfield County Regional Planning Commission periodically conducts zoning training sessions for the elected representatives and zoning officials within Fairfield County. As part of this training, the RPC could incorporate best practice procedures for making planning board appointments to help educate communities on the importance of providing an opportunity to all citizens to serve on these boards. Municipal Services, Revitalization, Employment-Housing Linkage Does the jurisdiction have a strategy to revitalize or enhance lower income neighborhoods that looks to all possible resources including private investment strategies, such as those developed by banks and other financial institutions to meet the objectives of the Community Reinvestment Act (CRA)?
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YES __X___ NO ______ Comments: The CAS document identifies infrastructure needs and downtown revitalization has been targeted using CDBG dollars in the villages. In 2010, Fairfield County also took advantage of the CDBG Neighborhood Revitalization Program grant to leverage funds for major community improvements in the Village of Thurston, a village with 78% low-moderate income residents.
Does the jurisdiction's strategy include a program to encourage expanded lending activity in such areas -- for housing, small business enterprise and job development or expansion -- by requiring reports of lending activity, publishing results and offering deposits of jurisdiction funds -as an incentive to increase lender investment? YES _____ NO ___X___ Does the jurisdiction have a formal CRA strategy that rate lender reinvestment activity, select depository of jurisdiction funds based on these ratings and negotiate specific lending agreements for specific neighborhoods? YES _____ NO __X____ Comments: Fairfield County goes out for bids for banking. The funds are placed in the local financial institution which provides the county with the most competitive rates, and the lowest banking fees. If the jurisdiction has undertaken a strategy, what are the results and what additional efforts, if any, should be made? Are there specific groups within the jurisdiction's jurisdiction that have more severe problems obtaining adequate housing that other groups in the same income range because of, for example, language barriers, physical or mental disabilities, or other conditions that might affect one's ability to secure safe, decent housing?
YES __X___ NO ______ Disability: After reviewing the Fairfield County complaints filed with the Ohio Civil Rights Commission since 2004, it appears a majority of those complaints revolved around a disability. Also, in the Citizen survey conducted as part of this analysis, it appeared that individuals who reported a barrier in obtaining adequate housing perceived that their barrier was due to their familial status or a disability.
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What financial resources are available to the community, from outside sources and those within the jurisdiction's jurisdiction, to fund low and moderate-income housing and other facilities to revitalize deteriorating neighborhoods (for profit as well as non-profit resources)?
Housing Tax Credits) • Federal Home Loan Bank down payment assistance • USDA Rural Development Housing Preservation Grant • Homeless Assistance Grant
Although targeted towards 120% of the area median income, the Neighborhood Stabilization Program has been utilized in Fairfield County to help revitalize deteriorating neighborhoods due to the recent housing crisis. Does the local Housing Plan and the Analysis of Impediments substantiate the need for housing for underserved groups such as low-to moderate income families, individuals with disabilities, SRO, transitional and supportive housing, etc.? YES ___X__ NO ___ The Fairfield County Community Housing Improvement Strategy and the Fairfield County Continuum of Care Plan fully document the need for housing for these underserved groups. Units of shelter and transitional housing have been increased in recent years and progress is being made toward the development of supportive housing for homeless and special needs families.
What types of funding mechanisms have been successful and why?
• Tax Credit Housing • CHIP • CDBG Formula • Section 8 Housing • NSP • Ohio Housing Finance Agency financing • Federal Home Loan Bank down payment assistance
• USDA Rural Development Housing Preservation Grant provides home repairs for
owner-occupied, low-income households in the rural areas of the county (50
percent and below of the area median)
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• Ohio Housing Trust Funds (Housing Assistance Grant from ODOD) provide home
repairs for owner-occupied homes where the household income is at or below 30 percent of the area median
• Home Weatherization Assistance Program provides weatherization for households at or below 200 percent of the federal poverty level
• City of Lancaster CDBG, Fairfield County CHIP and Federal Home Loan Bank Welcome Home funds (private funds) provide down payment assistance to low-
and moderate-income first time homebuyers
• HOME, Ohio Housing Trust Funds and private funds have been used in
conjunction with housing tax credits to preserve and create affordable rental units for seniors and families
• Fairfield County CHIP and City of Lancaster CDBG funds provide home rehabilitation for low-income, owner-occupied households (80 percent and below
of the area median income)
• Fairfield County CHIP provides home repairs for low-income households (50
percent and below of the area median income)
What might the jurisdiction learn from efforts in other communities and what sources of information are available? If OHCP has information we do not have, we would appreciate any new ideas on available resources. Lancaster-Fairfield Community Action Agency administers the CHIP and NSP for Fairfield County. In its role as an administrator for the county and as a state-certified community housing development organization, this agency is actively involved with the Coalition on Housing and Homelessness of Ohio, the Ohio CDC Association and the Ohio Corporation for Community Development. The staff attends state meetings and seminars to learn about new resources and solutions that are being used in other communities throughout Ohio to benefit Fairfield County. What efforts have the jurisdiction and other entities in the jurisdiction's community and in surrounding communities made to link job creation initiatives with improved and more broadly distributed housing opportunities for lower income persons; in particular, minorities and persons with disabilities? Since 2004, the county has established an Economic Development office. This office provides work force training and on the job training for people with lower incomes. This office also has job creation requirements it must meet as part of its revolving loan fund.
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There has also been an increased effort from Fairfield County WorkNet to market jobs locally, which the advisory committee believes helps provide access to jobs to people with limited resources. There have also been recent partnerships with Community Action and the Department of Disabilities to help identify employment opportunities for persons with disabilities. What are the results of these efforts? As in most communities, Fairfield County has experienced a substantial increase in the unemployment rate in the last several years, and the unemployed have not necessarily fallen within the low income designation. Efforts continue to help link job creation with broaden housing opportunities for all residents including minorities and persons with disabilities. As a result, Fairfield County’s unemployment rate remains lower than the state average. Land-use (Zoning); S ite Selection Issues Has the jurisdiction reviewed all of its zoning laws, policies and practices to guarantee that they are in compliance with the federal fair housing laws and up-to-date with the legal decisions? YES __X___ NO ______ Has the jurisdiction reviewed criteria for siting of group homes and determined that any restrictions do not conflict with the Fair Housing Act and judicial decisions? YES __X___ NO ______ The Fairfield County Regional Planning Commission has worked with several villages and townships to help bring their code in line state and federal laws regarding group homes. Are there any occupancy ordinances restricting the number of people in a family when buying a home? YES _____ NO ___X___ Does the jurisdiction define family? YES _____ NO ___X___ If yes, does the definition conflict with the Fair Housing Act? Are there ordinances that criminalize homeless persons; thereby making it difficult if not impossible for a homeless person to qualify for subsidized or other housing? YES _____ NO __X____
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What is the impact on lower income housing of the jurisdiction's zoning ordinances and building codes? Though discouraged by Regional Planning, some townships have increased the minimum standards for house size in their zoning codes. The Fairfield County Regional Planning Commission has also worked with several townships to incorporate multi-family zoning districts into their codes. The RPC has also worked with several townships to incorporate flexible zoning districts into their codes to help reduce lot sizes and broaden the housing choices in the county. Could these regulations be changed to provide for more inclusive housing development plans that provide for lower income housing as a part of housing developed for families with incomes above the lower income levels?
YES _____ NO ______ (Potentially) Does your local jurisdiction’s zoning ordinance set minimum building size requirements that exceed the local housing or health code or is otherwise not based upon explicit health standards? YES __X___ NO ______ Regional Planning has discourage community’s from adopted a higher square footage requirement, but some communities still have these standards within their codes. If your jurisdiction has impact or other significant fees, does the jurisdiction provide waiver of these fees for affordable housing? YES _____ NO ___X___ Does your jurisdiction use a recent version (i.e. published within the last 5 years, or the last published version) of one of the nationally recognized model building codes? YES _X____ NO ______ The Residential Rehabilitation Standards issued in 2008 by the Ohio Department of Development, Office of Housing and Community Partnerships provides the quality standard for all Fairf ield County Community Housing Improvement Program and Neighborhood Stabilization Program projects. The townships and villages that have adopted building codes utilize the state building code. Does your jurisdiction’s zoning ordinance or land use regulations permit manufactured (HUD-Code) housing “as of r ight” in all residential districts and zoning classifications in which similar site-built housing is permitted, subject to design, density, building size, foundation requirements, and other similar requirements applicable to other housing that will be deemed realty, irrespective of the method of production? YES __X___ NO ______
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The Fairfield County Regional Planning Commission has worked with several townships to revise their regulations to allow manufactured home on permanent foundations that meet HUD standards to be allowed within zoning districts where single-family dwelling units are permitted. There may be a few townships that still need to make this revision, but a majority of them have adopted this requirement. Does your jurisdiction provide for expedited permitting and approvals for all affordable housing projects in your community? YES _____ NO ___X (Not that we are aware of)__ Does your jurisdiction have an explicit policy that adjusts or waives existing parking requirements for all affordable housing developments? YES _____ NO __X____ Does your jurisdiction require affordable housing projects to undergo public review or special hearings when the project is otherwise in full compliance with the zoning ordinance or other development regulations? YES _____ NO __X____ These projects are subject to the same standards as any other development within the same zoning district. Are there court decisions or settlements which affect the jurisdiction's zoning ordinances, building codes or other policies and regulations relating to the provision of housing for lower income households and persons with disabilities? YES _____ NO __X____ What is the result of these decisions or settlements and have all legal requirements been met? Has the jurisdiction adopted policies and procedures that promote the placement of new or rehabilitated housing for lower income households (including housing for minorities and families with children; and families or individuals in need of housing accessible to persons with physical disabilities or designed for persons with mental impairments) in the full spectrum of neighborhoods that exist in the jurisdiction's community? YES _____ NO ___X___ Are there concentrations of low and moderate income housing in one or more areas of the jurisdiction's jurisdiction?
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YES _____ NO __X____ Are the current policies promoting this pattern, or exerting a neutral effect in the face of such concentrations? YES _____ NO ______ N/A__X__ What specific steps will the jurisdiction take to strengthen the fair housing aspects of community revitalization activities in poorer neighborhoods through equalization of services, revised displacement policies? The Fair Housing Sub-Committee will have to look at these issues and take appropriate actions. What specific changes should be made in the jurisdiction's zoning or building ordinances to foster the inclusion of housing for lower income households in housing developments for households with higher incomes? The Fair Housing Sub-Committee will have to look at these issues and take appropriate actions. What can the grantee do to change the course of local actions that limit the supply of genuinely open housing? As previously stated, Fairfield County has a strong and active Housing Coalition. This is an effective group that continuously strives, advocates, and helps to further fair housing choices in Fairfield County. The grantee should continue to support this coalition. Tenant Selection; Housing Choices for Subsidized Housing Is there a pattern, in one or more assisted housing developments, of concentration of tenants by race or ethnicity? YES _____ NO ___X___ Do the tenant selection policies and procedures of HUD-assisted multi-family housing providers, including the PHA, exclude -- or limit the participation of -- persons with disabilities in one or more types of housing developments they manage?
YES _____ NO ___X___ Comments: Persons with disabilities are not only included but are given priority. If the answer to either of these questions is yes, are the policies and procedures in use consistent with the requirements of federal, State and local law and HUD regulations and guidance?
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YES _____ NO ______ N/A ___X___ What are these policies and procedures and how do they specifically affect the manner in which applications for housing are treated, and applicants are rejected or selected as tenants?
The PHA has the following list of preferences:
1. Veterans 2. Homeless 3. Disabled (If Public Housing, a disabled family receives the working preference) 4. Children aging out of foster care
The preferences are also cumulative. For example, a disabled veteran would score higher than a veteran. The PHA pulls from the waiting list randomly by preference. Did the local PHA complete the HUD-required Analysis of Impediments to Fair Housing Choice? YES ___X__ NO ______ If yes, were the findings consistent with the local jurisdiction’s analysis? Yes, although we have no areas of minority or low income concentrations to encourage voucher holders to move from or not to move to, 18.6% of the population is disabled. The FMHA has as a preference for its Housing Choice Vouchers, households with a disabled member. If any housing provider has been found in noncompliance with one or more civil rights laws or regulations, has the provider initiated appropriate corrective actions? YES _____ NO ______ N/A__X__ Are there any court lawsuits involving the tenant selection and assignment policies and procedures of any of these providers? YES _____ NO __X____ If court order(s) relate to tenanting practices, what is the status of actions to comply with the orders) and what are the results? There was a 2000 court order with regard to tenanting and ownership rights in the old Lancaster Methodist Campgrounds. Church membership and referrals had previously been used as a screening for residents until a court challenge ended in an order to end this practice.
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If there are concentrations of racial or ethic groups in one or more public housing developments, has the PHA undertaken any efforts designed specifically to desegregate these developments (e.g., changes to the PHA's tenant selection and assignment plan; participation in HUD's Public Housing Affirmative Compliance Actions Program)?
YES _____ NO ______ N/A__X_ What is the location pattern of minority and non-minority certificate and voucher holders (by family type) who rent units under the Section 8 Certificate and Voucher Housing Assistance Programs?
No pattern exists. The percentage of minority populations is very small in Fairf ield County. Are minorities located primarily in minority neighborhoods and Whites in predominantly white neighborhoods regardless of family type (e.g., large family, small family, and elderly family)?
YES _____ NO ___X___ If the answer to the previous questions is yes, what specific step does the local PHA take to promote housing choices for certificate and voucher holders? Can certificate and voucher holders use the certificates and vouchers they receive from the local PHA outside the PHA's geographic jurisdiction? YES __X___ NO ______ Does the PHA -assist certificate or voucher holders that have received their certificates or vouchers from other PHA's and who wish to reside in the jurisdiction's jurisdiction? In what ways?
YES __X___ NO ______ Does the PHA help certificate and voucher holders to find suitable housing? YES __X___ NO ______ Does this help include providing up-to-date information, to minority home seekers in particular, about the various facilities and services that are available in all neighborhoods in which housing suitable to the needs of certificate or voucher holders is available? Facilities and services include schools, day care, health and welfare and other social services agencies, employment centers and public transportation.
YES __X___ NO ______ Comments: This information is provided to all population groups.
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Has the Public Housing Agency (PHA) in the jurisdiction's community completed its Section 504 assessment of the need, among households with various types of disabilities, for public housing and developed a plan for providing such housing opportunities, if an unmet need still exists? YES ___X__ NO ______ Comments: The Housing Authority met all of its identified needs in its public housing. The 504 Assessment was completed by SOCIL. Does the PHA encourage certificate and voucher holders to look for housing in neighborhoods that are not traditional residential areas for the holder in question, and in particular minority certificate or voucher holders? YES ___X__ NO ______ Comments: As required, voucher holders are encouraged to seek housing outside of areas of concentrations of low income and minority households. Does the PHA assist the search process in any other ways, such as:
Calling to confirm the availability of units located in non-traditional neighborhoods?
Providing a master list of the name and addresses, number of units, etc. of multifamily developments in a metropolitan or other regional area that make units available to Section 8 participants?
YES _____ NO ______ Other__X___ Comments: The local PHA also presents choices and encourages consumers to make choice based on best proximity to family self-sufficiency considerations such as employment location, schools, and support services needed. What steps does the PHA take to promote the availability of accessible existing housing resources suitable for Section 8 participant families in which one or more persons are mobility impaired?
At least 10% of the units are handicapped/vision/hearing impaired accessible, also under these guidelines all the tax credit projects are in compliance which were either built or rehabbed since 1990. What steps does the PHA take to promote housing choices for certificate or voucher holders with other types of disabilities?
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With the above mentioned supports in place, there are also supports for individuals with mobility, vision, hearing, and mental health handicaps. Strong partnerships within the social services community exist to foster the best possible access to these services and supports for affordable housing for these targeted groups. The PHA also has 2 Shelter + Care grants (5 years) providing Section 8 assistance along with mental health care. Does the local PHA participate in the state’s Home Choice (or Money Follows the Person) Program to move residents back into the community? YES _____ NO ___X___ The PHA applied for a competitive Home Choice Program grant, but funding was not awarded to our jurisdiction. Does the PHA apply for additional housing vouchers especially those allocated for specific groups such as individuals with disabilities, veterans, etc. YES ____X_ NO ______ The PHA applied for and was awarded funding for the Shelter Plus Care program, which provides housing subsidy for 37 households for people with disabilities. Does the PHA provide clear information to all participants concerning their housing rights and the steps they should take, including requesting assistance from the PHA in the housing search, if they believe they have encountered housing discrimination? YES __X___ NO ______ Comments: We cover these issues well, grievance procedures are reviewed frequently and regular weekly meetings are held to help cover any grievance issues as they arise. If there are legal questions we refer to the legal community. If the jurisdiction's analysis of tenanting practices in assisted housing development, should changes or new steps be instituted to promote more inclusive tenancy patterns? YES _____ NO __X____ Comments: The PHA reviews admissions and continued occupancy policies constantly referring to the federal law updates. The PHA board reviews and approves any changes. Should the jurisdiction regularly monitor tenant characteristic data for these developments as an indicator of marketing policies, procedures and practices? YES __X___ NO ______
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Comments: In light of efforts currently made by the PHA, and their results, should other steps be initiated to promote greater housing choice for one or more racial or ethnic group or disabled Section 8 participants? YES _____ NO ___X___ Comments: Although generally there is a lack of enough available affordable housing in Fairfield County for low income families, the PHA reports that the locally determined preferences help to insure that affordable housing opportunities are reserved for the most in need populations. However, additional funding would better enable the county to truly address the needs in a satisfactory manner. Sale of Subsidized Housing and Possible Displacement If the PHA, or other assisted housing providers (such as section 8 housing owners) have sold or plan to sell assisted housing projects, what policies and procedures are in place provide alternative housing to displaced tenant households? N/A. None have been sold. Although none have been sold or are planned to be sold to our knowledge, we are ready to accept displacement vouchers under an Opt-Out Program. FCMHA is also an expert in administering Uniform Relocation Act Regulations. Are steps being taken to assure that such households are provided a varied choice of replacement housing, in particular so that minority displaced households have an opportunity to select housing outside of areas of minority concentration and not just inside areas?
YES __X___ NO ______ Does the jurisdiction have a specific policy with respect to such displacement that the jurisdiction requires housing providers owning assisted housing in jurisdiction's jurisdiction to implement when the sale of such housing occurs? YES ___X__ NO ______ In the event of an Opt-Out or other transfer of assisted housing, the PHA would prefer to take ownership of it. If this is not possible, as stated above the PHA is prepared to administer the Opt-Out vouchers and relocate the families in accordance with HUD regulations. What policies and procedures should be adopted or changed by the jurisdiction, PHA or other agencies to assure that current tenants in assisted housing projects will be provided opportunities to select replacement housing in a full range of neighborhoods if one or more such projects are to be sold and the tenants displaced?
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In the event of an Opt-Out or other transfer of assisted housing, the PHA would prefer to take ownership of it. If this is not possible, as stated above the PHA is prepared to administer the Opt-Out vouchers and relocate the families in accordance with HUD regulations. Who within the jurisdictions governing structure is responsible for such selections and what specific steps should be taken to accomplish these changes? All segments of the population are represented on the local PHA board. There is a resident member of the board. Substantial Rehabilitation to Assisted Units If alterations were undertaken in a project of 15 or more units and the cost of the alterations were 75% or more of the replacement cost of the completed facility- The FMHA has not completed any rehabilitation that exceeded 75% of the replacement cost. The FMHA projects all date from the nineties so there hasn’t been a need for substantial rehabilitation. Nonetheless, as required, the FMHA adheres to the Uniform Act rules whenever FMHA conducts any rehab, and as such the FMHA accommodates the disabled households. Was the project designed to be readily accessible to and usable by individuals with disabilities? YES _____ NO ______ N/A Were the minimum of 5% of the total dwelling units or at least one unit, whichever is greater, made accessible for persons with mobility impairments? YES _____ NO ______ N/A Were an additional 2% of the total units made accessible for persons with hearing or vision impairments? YES _____ NO ______N/A Were the special (and often individualized) needs of tenants with disabilities being taken into consideration during major rehabilitation of assisted housing especially when temporary relocation is necessary? YES _____ NO ______N/A Are reasonable changes made to the temporary relocation rules, policies, practices, or services to accommodate the special needs of persons with disabilities? YES _____ NO ______N/A Information Programs
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Has a court determined that housing discrimination has occurred in any aspect of the jurisdiction's community development or housing programs, or the programs administered by the PHA in the jurisdiction's jurisdiction? YES _____ NO ___X___ Has HUD made a finding of violation of Title VII Title VI, or Section 504, or regulations implementing these laws, in any federally funded housing or housing related activities in the jurisdiction's jurisdiction? YES _____ NO __X____ If yes, has the jurisdiction designed and implemented all actions necessary to address the court determination or HUD finding? Has the jurisdiction assured that all appropriate jurisdiction officials and employees, including sub--jurisdiction officials and employees and PHA officials and employees, as applicable, are fully aware of the required actions and their responsibilities? YES __X___ NO ______ Comments: The local PHA has a policy which mandates all off icials of the local program attend fair housing training annually.
What specific types of actions have been undertaken by the jurisdiction, sub-jurisdictions, and other entities in the jurisdiction's jurisdiction, such as human relations commissions, and other fair housing organizations to provide information to the general public regarding fair housing laws and objectives?
The PHA holds landlord seminars and also invites realtors and the general public. Fair Housing information is presented at these seminars on a regular basis. Many local landlords take advantage of this training. Are these activities confined largely to Fair Housing Month (April) or is there a comprehensive set of activities going on throughout the calendar year? YES _____ NO ___X___ Comments: Seminars are held throughout the year. Staff attends training throughout the year, e-mails are carefully reviewed from OHCP Fair Housing staff. How effective is each of these activities? PHA reports very good response to the offering of this training.
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How much does the jurisdiction and other entities interested in and responsible for fair housing initiatives know about creative, effective activities in other communities and who to contact for such information? The PHA attends Ohio Housing Authorities Conferences on a semi-annual basis where Fair Housing is always covered in sessions, attended by our staff, whose speakers are directors of other agencies’ programs. SOCIL often offers such sessions and the director of that non-profit agency is a member of our board. Housing staff members of LFCAA and RPC staff also attend several fair housing workshops each year. Should the jurisdiction undertake specific programs to educate its officials and employees regarding the provisions of a particular court determination or HUD finding and the actions that are or will be underway to address problems found? YES ___X__ NO ______ The PHA does and shall continue to monitor such determinations. Recent determinations have dealt with service animals and reasonable accommodations in parking. How should these programs be planned and implemented? Policies should continually be revised to reflect recent determinations. Should the jurisdiction, in cooperation with fair housing organizations and organizations working to promote housing opportunities for particular segments of the community such as racial or ethnic minority groups or persons with specific types of disabilities, develop new outreach, education or information programs and activities?
YES __X___ NO ______ If so, what should the specific subject or focus of new efforts be? The PHA reports that it believes the current inadequately addresses need is for housing for people who are physically disabled and those having dual diagnoses in mental illness and developmentally disabilities. What resources are available to support these efforts? The PHA reports that there is currently a lack of funding to help support these efforts. Who should design, carry out and monitor these efforts? A collaboration of applicable local agencies including the FMHA. Local Laws and Procedures
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Does the jurisdiction have a local fair housing law that provides the same protections as the federal Fair Housing Act? YES _____ NO __X____ Comments: Fairfield County passed a resolution that refers to federal laws. Has the ordinance or resolution been updated or reviewed for accuracy? At a minimum, does it include the following protected groups: race, color, national origin or ancestry, religion, sex, familial status, disability and military status? Fairfield County passed a resolution that refers to federal laws. Fairf ield County has updated its fair housing materials to include military status as a protected group per the recent amendment to state law. However, the Fairfield County fair housing resolution should be updated to reference this recent amendment. Does the local fair housing law include any additional protected groups? No. We use and refer to state and federal laws. Does the law include local fair housing enforcement? If so, who is responsible to enforce the law? No. We currently take all unresolved fair housing complaints to the Columbus office of the Ohio Civil Rights Commission. Is it the most appropriate structure and process for the jurisdiction and does it conform to HUD requirements and guidelines and other enforcement programs recognized nationally as a model? Is the enforcement program efficient and effective in providing complainants, and respondents, with a fair process for pursuing and settling fair housing complaints?
YES __X___ NO ______ Employment Opportunities The creation of employment opportunities has a direct impact on fostering fair housing opportunities. Local jurisdictions should take into consideration the fair housing implications when creating employment opportunities. Barrier to job opportunities should be analyzed. They include: • Perception: Barriers to people seeking the new job opportunities may include a perception that
they will not be welcomed into the community, perhaps because of a history of members of the community acting in a threatening manner when people of color moved into the neighborhood.
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• Transportation: The jurisdiction may not make transportation available to the job site. Jurisdictions using federal subsidies as loans, grants or to provide infrastructure to a site should insure that low and moderate-income people as well as people of color have equal opportunity to secure employment. The failure to provide transportation or affordable housing to the new site is a barrier to exercising fair housing rights.
• Affordable Housing: Many newer jobs are being created in suburban communities where the cost of housing, both new and rental, is too high for low and moderate-income families. Plans to incorporate affordable housing units into new construction developments, reducing square footage requirements for units or increasing density of units per site can reduce the cost of housing and increase the opportunities for both racial and economic integration in the community.
Transportation Is the jurisdiction using Department of Transportation funds to increase access for low and moderate-income persons, people with disabilities and people of color to locations where jobs are available and affordable housing exists? YES __X___ NO ______ Comments: Lancaster Public Transit recently received funding to allow this on-demand service to expand countywide at an affordable cost to low-income customers. This will allow better access to transportation for our low income or disabled individuals in need of transportation to an employment opportunity. This has been a significant achievement for a county comprised of primarily rural areas. If affordable housing does not exist where job opportunities have been created, does the jurisdiction provide affordable transportation? YES _X____ NO ______ (See above response) Where mass transportation exists, are incentives provided to employers to subsidize transportation costs? YES _____ NO ______ N/A_X___ Comments: There is no mass transportation system available in the county. Does the jurisdiction provide early morning and late night bus transportation to locations with employment opportunities? YES __X (Somewhat)__ NO
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Comments: As stated above, door to door Lancaster Public Transit is now available to all county residents from 6 a.m. to 9 p.m. Monday through Friday and 7 a.m. to 6:30 p.m. on Saturday with no transportation services on Sunday. Some have noted concern with these hours should someone work in the retail industry with most stores closing at 9 p.m. or later. Are bus routes developed and maintained with the needs of families with children and persons with disabilities in mind? YES _____ NO ______ N/A_X___ Lancaster Public Transit is a door to door service.
Fair Housing Complaint Profile The jurisdiction should review the number of fair housing complaints received, processed and resolved annually. Attach a summary that outlines the details of the complaints including- the number of complaints carried over from year to year; type of complaint (rental, sales, lending, insurance, zoning, advertising, racially/ethnically motivated violence, etc.) ; number of complaints processed; remedies secured for the complainant including securing housing, loans, or insurance and the amount of damages recovered. Have any complaints been filed through the Department of Housing and Urban Development (HUD), the Ohio Civil Rights Commission or a substantially equivalent agency? YES ___X__ NO ______ Were there any private lawsuits filed challenging discriminatory practices? YES _____ NO __X____(None of which we are aware) If so, did the allegations involve any departments under the jurisdiction’s control? Did state or federal agencies bring actions against any individual or corporation doing business in the jurisdiction? YES _____ NO _X_____ Does the jurisdiction do business with any corporation alleged to have violated the fair housing laws? YES _____ NO ___X___ Does the jurisdiction have a policy about doing business with entities found to have violated the fair housing laws? YES __X___ NO ______ Evaluation and Recommendations Identify any changes needed to correct or overcome impediments identified in governmental policies, real estate and lending institutions, zoning restrictions, etc. Plan of Action
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The Plan of Action should be specific with a timetable or schedule for the resolution of identified problems or impediments. Jurisdiction should have short-term and long-term goals. See attachments.
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S-3 Fair Housing , Impediments, Strategies and Timelines Community: Fairfield County (excluding the City of Lancaster) 2011 – 2015
Impediment or Issue Strategy Timeline
1. Fair Housing survey indicated that there is a perception that it is difficult to obtain housing due to a disability.
A. Create brochures to provide to landlords to clearly
explain the reasonable accommodation requirements. B. Hold education and training for persons with disabilities
to provide a better understanding of the rights of this protected class.
a. August 2012 b. On-going
2. Fair Housing survey indicated that there is a perception that it is difficult to obtain housing due to familial status.
A. Better define Familial Status on Fair Housing
Information Pamphlets. B. Increase the distribution of Fair Housing Materials to
organizations including: faith based organizations that provide housing assistance, the Southeastern Ohio Center for Independent Living, and Lancaster-Fairfield Community Action Agency.
a. December 30,
2011
b. On-going
3. Continue to acknowledge the correlation between fair housing choice and transportation, especially with Lancaster Public Transit recently expanding its service countywide.
A. Establish a process to track the usage of the Lancaster
Public Transit system by persons with disabilities. B. Track the usage of the Lancaster Public Transit system
to determine if any adjustments are needed to fully maximize the linkage between fair housing choice and transportation.
a. December 2012 b. On-going
4. Foreclosure Intervention
Continue to participate in the Fairfield County Save Our Home Task Force.
On-going
5. Potential need for housing for disabled veterans.
Fairfield Metropolitan Housing Authority to examine the need for housing for disabled veterans.
2011 - 2012
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APPENDIX
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Fairfield County Fair Housing Survey Summary
The Lancaster – Fairfield Community Action Agency and the Fairfield County Regional Planning Commission conducted two surveys to assess the needs and impediments to Fair Housing in Fairf ield County, concerning both owner occupied dwellings and rental units. The first survey was an agency survey that was sent to each of the organizations participating in the advisory group for this plan. The second survey was a citizen survey that was distributed via Survey Monkey. Paper copies of the citizen survey were also distributed at the Jobs and Family Services offices, the Lancaster – Community Action Agency, and the Fairfield Metropolitan Housing Authority. The following paragraphs outline the results on these surveys:
Agency Survey – Completed by the following advisory committee members:
Alice Saunders Black Interest Group of Lancaster Janice Novotni Fairfield Affordable Housing Tony Caito Lancaster Board of Realtors Patti Morrow Fairfield County 211 Susan Secoy Fairfield Metropolitan Housing Authority Paul Carbol Fairfield Appraisal Group Eddie Rapp Lutheran Social Services Shane Farnsworth Fairfield County Economic Development Carrie Woody Lancaster Public Transit Pam Patula Southeastern Ohio Center for Independent Living Fair Housing Perception
Most of the survey respondents have a positive perception of fair housing and believe that this perception has improved over the last 20 years. Several agencies indicated that there has been better coordination between agencies to increase awareness of fair housing laws, with the exception of agency who responded that it was not aware of these laws. Most agencies also indicated that they display a fair housing logo or poster within their offices and attend fair housing training on a regular basis.
Each of the agencies were also asked to explain their perception on the following areas: overcrowded living conditions; housing for the disabled population; housing for the elderly population; housing for the low to moderate income population; housing for the military population; and housing for race and ethnic groups. Finally the agencies were asked to provide recommendations or suggestions for improving fair housing. The following paragraphs outline the answers provided to these questions:
Overcrowded Living Conditions
Most agencies believe there are overcrowded living conditions and agree that there has been an increase in multiple families living together over the past couple of years due to the poor economy.
Availability of Housing for Disabled
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A majority of the responses indicate that there is not enough safe and affordable housing for the disabled. There may be affordable housing, but is it safe? There may be safe housing, but is it affordable? Some agencies indicated that units can be retrofitted, but it is costly to do so. Several agencies also discussed limited income from SSI/SSD makes it difficult for the disabled to obtain affordable housing.
Availability of Housing for Elderly
Most indicate that there is available housing for the elderly, but cost is an issue. Several agencies indicated that lower income senior housing is limited in Fairfield County. One additional barrier noted was the lack of services to allow the elderly to remain in their current residences once their abilities decrease.
Availability of Housing for LMI population
Most of the agencies indicated that there is not enough safe, decent, affordable housing for the LMI population. Two respondents indicated that with the downturn in the economy that it has made houses more affordable, but at least one of these respondents indicated that a lack of lending is making it difficult to get the LMI population into these units.
Availability of Housing for the Military
Most agencies indicate that there has been improvement with providing housing to our military. One agency believes that more efforts should be focused toward increasing housing options for the military population. It was also noted that the military is one of the fasted growing homeless populations.
Availability of Housing for Races/Ethnic Groups
Most agencies do not believe that there are any across the board issues with housing for certain races or ethnic groups. There were two agencies that reported concerns with housing for Hispanics and African Americans. FMHA indicates that the percent of Caucasians, African Americans and Asians on their waiting list corresponds proportionality with the race demographics of the county.
Suggestions for Improving Fair Housing
The following suggestions were provided to help improve fair housing in Fairfield County:
Education
More interaction between tenants/land lords and fair housing agencies
Continue to provide equal housing opportunities and expand housing choices through fair housing compliance
Job creation to help residents afford housing
Increase the number of income based apartments
Increase the availability of rental assistance
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Hold landlords accountable for the conditions of apartments and rent prices
Identify the percentage of income for county residents compared to the cost for renting units in the county
Citizen Survey
As stated above, the citizen survey was available on both the internet and in various community offices. This survey was geared toward a person’s “perception” to a difficulty in obtaining housing. Demographic questions were also asked. There were 145 respondents to this citizen survey and the results are as follows:
Difficulty in Purchasing Home:
Approximately 76 percent of the respondents indicated that they have never experienced a problem with purchasing a home. Out of those who have experienced difficulty, income seemed to be the largest barrier limiting their purchasing power. Excluding income, familial status and disabilities seemed to be the perceived reasons for the difficulty in purchasing a home.
Approximately 14 percent of the respondents had purchased a home in the last five years, with 67 percent of these home buyers indicating that there was adequate housing available in Fairfield County at the time of purchase. However, a majority of these respondents indicated that their monthly mortgage, interest, taxes and insurance exceed 30 percent of their gross monthly income, indicating that affordability remains an issue.
Difficulty in Renting a Home or Apartment:
Approximately 81 percent of the respondents indicated that they have not experienced any problems with renting a home or apartment. As with home purchasing, income seems to be the largest barrier to renting. Excluding income, familial status was the leading “perceived” reason for the difficulty in renting a house or an apartment.
Approximately 40 percent of the respondents have moved into a different rental unit in the last five years, with approximately 58 percent of these renters indicating that there were adequate rental units available at the time of the move. Unfortunately, almost 80 percent of these renters reported that their rent, renters insurance and utility costs exceed 30 percent of their gross monthly income.
