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2 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE  Fair Housing Act: Prohibits discrimination in housing based on race, sex,color, religion, national origin, disability, or familial status. Referred to as “protected classes.”  City of Missoula adds sexual orientation and gender identity or expression as protected classes  HUD required certification to affirmatively further fair housing: Identify impediments; take actions; and keep records  HUD defines impediments as any actions, omissions, or decisions : 1. taken because of protected class membership and which restrict housing choices or the availability of housing choices 2. which have the effect of restricting housing choices or the availability of housing choices on the basis of protected class membership


4 ANALYSIS OF IMPEDIMENTS SUMMARY AI SectionHighlights Citizen Participation Process Input from City departments, fair housing agencies, the Missoula Housing Authority, housing providers, and the HUD Field Office. 132 online surveys completed by residents, realtors, and housing providers. Consultation through public meetings, key person interviews, and focus groups. Housing Profile In 2010, Missoula had 45.7% owner-occupied and 48.9% renter-occupied units. 2.4% point decrease in the rate of homeownership from the 2000 Census. The median value of an owner-occupied housing unit in 2000 was $132,500, compared to the 2010 median value of $232,600, a 76% increase. The 2012 ACS 10.4% of Missoula’s civilian non-institutionalized population reported a disability. CHAS data : 3,905 low- and moderate income disabled member households had housing problems. In 2010, there were 7,115 elderly persons living in Missoula (10.4% of the population). Between 2000 and 2010, highest increase in the age group Fair Housing Law and Public Policies The City’s affordable housing objectives (Consolidated Plan) include increasing and preserving the supply of affordable rental units and homeownership for low- and moderate income households, including special needs persons.

5 ANALYSIS OF IMPEDIMENTS SUMMARY Survey Responses Limited minority responses – 94.1% White, 2.9% Native American 28 persons reported either discrimination against themselves or someone they knew 79% involving rental properties. Basis: Disability (32.1%); Familial status (25%); Other bases(similar with 10-14%) 43% felt affordable housing choices limited to certain area due to price, transportation, hostility to new development. Concentration in Northside, Russell Corridor, Canyon Creek, Council Groves. Respondents better informed about fair housing (65%) than other communities Realtors strong response (52) – most knowledgeable about fair housing Written policies re fair housing and diversity in marketing materials. However, large majority do not publish ads in minority or multilingual publications or employ multi-lingual staff. Public Comments Lack of reasonable accommodations and housing choices for persons with disabilities Families with children especially at risk due to poor credit history and low income Poor housing conditions and risk of retribution and loss of housing if complaints made Housing discrimination among Native Americans highest for minority population Legal Cases & Complaints 16 housing discrimination cases reported to HUD in 6years. 3 withdrew, 4 no cause and 6 settled Montana Fair Housing received 89 complaints in 3 years. Six legal cases filed in Basis of discrimination is mainly disability especially mental disabilities, and familial status. 18 hate crimes reported over Based on sexual orientation (8), race (3), and religion (3).

6 IMPEDIMENTS AND RECOMMENDATIONS Public Policy Impediments Zoning restrictions creates a concentration of affordable housing options in certain areas and limits new affordable housing development. Zoning regulations and practices limit housing for individuals with disabilities. The distinction between the residential living and group living use categories may limit the availability of adult living facilities. Land use designations and building codes may limit the availability of affordable housing choices; and focus multifamily housing to certain neighborhoods. Real Estate Impediments Lack of accessible housing units. Lack of incentives and increased regulations limits affordable housing units for families with children. Possible fair housing violations in real estate advertising. Substandard rental housing units available to low income members of the protected classes. Banking and Lending Impediments Credit Issues that limit the ability of members of the protected class to qualify for homeownership or rental. Fair Housing Education & Awareness Impediments Need for more Fair Housing Awareness; and Lack of a Fair Housing Officer

7 IMPEDIMENTS AND RECOMMENDATIONS Public Policy Recommendations Balance affordable housing and provide a variety of options including larger units and single-family homes. Encourage affordable housing development by means such as inclusionary zoning and density bonuses and offering other incentives such as development fee waivers or reductions; prioritization of affordable housing approval. Accommodate group homes throughout the community under the same standards as any other residential uses. Educate residents about the Fair Housing Act and the rights of all individuals. Involve social service agencies and City staff to work with the community to address concerns such as NIMBYism. Remove occupancy standards for community residential facilities that limit the number of persons that may share a dwelling unit. Encourage new multi-family residential developments to increase the supply, variety, and affordability of housing. Adopt a definition for disability that is consistent with the FHA and collect and update demographic information for persons with disabilities living within the City. Consider universal design features to expand housing choice and ensure minimum accessibility standards Review and enhance its existing programs to improve accessibility in existing units. Adopt a policy and procedures for reasonable accommodations that allows certain deviations from development standards to accommodate accessibility improvements in existing units. Evaluate the policy for accessory dwelling units (ADU) to address requirements that limit opportunities for this type of development and restrict the use of ADUs for persons protected by the FHA. Research and conduct feasibility assessments on the use of incentives such as expedited permitting and reduced regulations for affordable housing needs of families with children. IMPEDIMENTS AND RECOMMENDATIONS

8 Real Estate Recommendations Work with the Realtors Association to encourage the placement of diverse images and human models that promote Missoula as a community that welcomes diversity. Increase education on landlord tenant responsibilities and code violations and reporting. Combine the Voluntary Inspection Program with a Rental Registration Program with an annual required inspection and the mandatory requirement for out of state landlords to have a local representative. Leveraging other County and State funds for a Renter-Occupied Housing Rehabilitation Loan Program Banking and Lending Recommendations Expand its work with housing providers and advocates to provide homeownership counseling, down- payment assistance programs and credit repair. Fair Housing Education and Awareness Recommendations Designate a Fair Housing Officer to address fair housing issues, monitor the City’s fair housing compliance, coordinate the AI action plan, and participate with fair housing networks and service providers. Increase its collaboration with the existing institutional structure for fair housing information, training, and fair housing complaint referrals with agencies such as Montana Fair Housing. Expand fair housing activities during Fair Housing Month annually to increase awareness and education. Use existing institutional structure to annually survey agencies and organizations for status of fair housing complaints and issues and assess for follow-up. Capitalize on all media outlets and include fair housing links on the City’s website for complaints. IMPEDIMENTS AND RECOMMENDATIONS

9 IMPLEMENTATION PLAN AND RESPONSIBLE PARTIES  Based on recommendations, Fair Housing Pan to be developed  Recommendations include a 1-2 years, 3-5 years, and ongoing timeframes for delivery  The Grants and Community Programs Department is responsible for the oversight and tracking of the implementation of the fair housing action plan.  Other parties such as the City Council, Development Services Department and the private sector will be responsible for specific activities.  The Department will track the progress of the actions to address impediments to fair housing choice.  The purpose of the implementation tracking is to analyze the impact of the actions taken and demonstrate that the City has met its obligation to affirmatively further fair housing.

10 TRACKING, RECORDKEEPING & MID-PERIOD ASSESSMENT  Ongoing Self-Assessment – Determine progress in addressing the identified impediments and recommendations in relation to timelines in the fair housing action plan  CAPER – Annually identifies the actions taken during the year; provides a summary of impediments to fair housing choice in the AI; and identifies actions taken to overcome effects of impediments identified in the AI.  Mid-period assessment - a comprehensive look at the community in light of the changes that have been made due to the implementation of the fair housing actions/activities and in relation to changes in population, demographics, economy, legislation, or any other factors that may impact fair housing choice.  Recordkeeping – File should contain:  A copy of the AI; and  Records that show the City has taken actions to overcome the effects of impediments identified in the AI



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