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HomeMy WebLinkAbout2023 Analysis of Impediments to Fair Housing Choice City of Palm Desert CDBG CITY OF PALM DESERT 2023 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE Draft 2023 1 | Page CITY OF PALM DESERT 2023 - 2028 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE Contents I. Introduction ................................................................................................................................................................ 7 i. What Is An Impediment to Fair Housing Choice? ........................................................................................... 7 ii. Community Participation ............................................................................................................................... 7 iii. The City’s History .......................................................................................................................................... 7 A. Fair Housing Defined ............................................................................................................................................. 7 B. Analysis of Impediments to Fair Housing Choice ................................................................................................... 8 C. Purpose of the Analysis of Impediments ............................................................................................................... 8 D. Legal Background .................................................................................................................................................. 9 i. Federal Laws ................................................................................................................................................... 9 ii. California Laws ............................................................................................................................................. 10 E. Organization of the Report .................................................................................................................................. 13 F. Data Sources ........................................................................................................................................................ 13 II. Community Participation Process ............................................................................................................................ 15 A. Community Outreach Survey .............................................................................................................................. 15 i. Survey Results ............................................................................................................................................... 15 ii. Community Needs........................................................................................................................................ 15 iii. Housing Discrimination ............................................................................................................................... 15 iv. Housing Needs ............................................................................................................................................ 16 v. Homeless Needs ........................................................................................................................................... 16 B. Public Meeting and Hearing ................................................................................................................................ 16 C. Consultation with Stakeholders ........................................................................................................................... 17 D. Evaluation of Community Participation Efforts ................................................................................................... 17 E. Reaching Underrepresented Populations ............................................................................................................ 17 i. Limited English Proficient ............................................................................................................................. 17 ii. R/ECAPs ........................................................................................................................................................ 17 iii. Persons with Disabilities or Special Needs .................................................................................................. 17 III. Community Data ..................................................................................................................................................... 18 A. Demographic Summary ....................................................................................................................................... 18 B. Population Characteristics ................................................................................................................................... 19 C. Population Age .................................................................................................................................................... 19 D. Race and Ethnicity ............................................................................................................................................... 20 2 | Page E. Limited English Proficiency .................................................................................................................................. 24 F. Dissimilarity Index ................................................................................................................................................ 25 G. Household Characteristics ................................................................................................................................... 26 i. Household Type and Size .............................................................................................................................. 26 H. Special Needs Populations .................................................................................................................................. 27 i. Senior Population and Characteristics .......................................................................................................... 27 I. Disabled Population .............................................................................................................................................. 28 J. Population Living with HIV/AIDS .......................................................................................................................... 28 K. Families with Children ......................................................................................................................................... 28 L. Large Households ................................................................................................................................................. 29 M. Homeless Population .......................................................................................................................................... 31 N. Income Profile ..................................................................................................................................................... 32 i. Median Income ............................................................................................................................................. 32 O. Low to Moderate Target Areas ........................................................................................................................... 33 P. Income by Household Characteristic ................................................................................................................... 34 i. Income by Race/Ethnicity ............................................................................................................................. 34 Q. Racially or Ethnically Concentrated Areas of Poverty ......................................................................................... 34 R. Housing Profile .................................................................................................................................................... 35 i. Housing Growth ............................................................................................................................................ 35 S. Housing Unit Type ................................................................................................................................................ 35 T. Condition of Housing Units .................................................................................................................................. 36 U. Lead-Based Paint Hazard ..................................................................................................................................... 37 V. Housing Tenure- Own Versus Rent and Vacant Units ......................................................................................... 37 W. Housing Tenure- Own Versus Rent and Vacant Units ........................................................................................ 38 X. Housing Problems ................................................................................................................................................ 41 i. Cost Burden .................................................................................................................................................. 41 ii. Overcrowding ............................................................................................................................................... 42 iii. Substandard Housing .................................................................................................................................. 43 Y. Public Housing & Housing vouchers .................................................................................................................... 43 i. Assisted Housing ........................................................................................................................................... 44 Z. Access to Opportunities ....................................................................................................................................... 46 i. Public Transit................................................................................................................................................. 46 AA. Major Employers ............................................................................................................................................... 47 BB. Public Schools .................................................................................................................................................... 49 3 | Page IV. Public Policies ......................................................................................................................................................... 51 A. The Housing Element ........................................................................................................................................... 51 B. Land Use Policies and Practices ........................................................................................................................... 52 C. Zoning for Housing............................................................................................................................................... 52 i. Residential Density ....................................................................................................................................... 52 ii. Residential Care Facilities ............................................................................................................................ 52 iii. Emergency Shelters ..................................................................................................................................... 52 iv. Transitional and Supportive Housing .......................................................................................................... 52 v. Supportive Housing ...................................................................................................................................... 53 vi. Single-Room Occupancy (SRO) .................................................................................................................... 53 vii. Employee Housing ...................................................................................................................................... 54 viii. Reasonable Accommodation .................................................................................................................... 54 ix. Permitting Process ...................................................................................................................................... 54 D. Development Incentives ...................................................................................................................................... 54 E. Regional Housing Needs Allocation (RHNA) ........................................................................................................ 55 F. Equal Housing Opportunity .................................................................................................................................. 56 V. Lending Practices ..................................................................................................................................................... 57 A. Laws Governing Lending ...................................................................................................................................... 57 i. Community Reinvestment Act (CRA) ............................................................................................................ 57 B. Banking Regulators for the CRA ........................................................................................................................... 57 C. Federal Reserve’s Role ......................................................................................................................................... 57 D. Home Mortgage Disclosure Act (HMDA) ............................................................................................................. 58 E. Equal Credit Opportunity Act ............................................................................................................................... 58 F. Types of Loans...................................................................................................................................................... 58 G. Government Backed Loans.................................................................................................................................. 58 i. Federal Housing Administration ................................................................................................................... 59 ii. State of California’s Government Loan Programs ........................................................................................ 59 H. VA Home Loans ................................................................................................................................................... 59 I. Rural Housing Services/Farm Service Agency (RHA/FSA) ..................................................................................... 59 J. Conventional Loans .............................................................................................................................................. 59 K. Lending Findings .................................................................................................................................................. 60 i. Refinancing ................................................................................................................................................... 60 L. Home Improvement ............................................................................................................................................. 61 M. Demographics of Loan Applicants ...................................................................................................................... 62 4 | Page N. Income of Loan Applicants .................................................................................................................................. 62 VI. Fair Housing Profile ................................................................................................................................................ 64 A. Homeownership-Private Sector Practices ........................................................................................................... 64 Home Purchase Process....................................................................................................................................... 64 B. Real Estate Advertisement .................................................................................................................................. 64 C. Home Loans ......................................................................................................................................................... 65 D. Real Estate Agents ............................................................................................................................................... 65 E. Rental Housing Process ........................................................................................................................................ 66 F. Advertisement for Rental Units ........................................................................................................................... 66 G. Fair Housing Complaints and Enforcement ......................................................................................................... 66 Office of Fair Housing and Equal Opportunity (FHEO) ......................................................................................... 66 California Department of Fair Employment and Housing (DFEH)........................................................................ 66 Fair Housing Council of Riverside, Inc. (FHCRC) ................................................................................................... 66 VII. Five Year Progress ................................................................................................................................................. 68 VIII. Actions .................................................................................................................................................................. 72 A. Recommendations for Ongoing Actions .............................................................................................................. 72 i. Lending Practices .......................................................................................................................................... 72 B. Keep Existing Housing Affordable ........................................................................................................................ 72 C. Housing Discrimination ........................................................................................................................................ 73 D. Increase Homeownership ................................................................................................................................... 73 E. Provide Opportunities for Affordable Housing .................................................................................................... 74 F. Recommended Actions for Other Impediments .................................................................................................. 74 i. Land Use Policies and Practices .................................................................................................................... 74 G. Collaborating Regionally...................................................................................................................................... 75 IX. Appendices ............................................................................................................................................................. 76 Appendix A – Federal Fair Housing Laws ................................................................................................................. 78 Appendix B – Community Outreach ........................................................................................................................ 79 List of Tables Table 1: Regional Populations Increase ....................................................................................................................... 19 Table 2: Regional Populations Percent Increase .......................................................................................................... 19 Table 3: Age Characteristics (2020) ............................................................................................................................. 20 Table 4: Current Race & Ethnicity Comparison ........................................................................................................... 20 5 | Page Table 5: Language Spoken At Home ............................................................................................................................ 24 Table 6: Index of Dissimilarity ...................................................................................................................................... 25 Table 7: Household Type and Size ............................................................................................................................... 26 Table 8: Percent of Elderly Population ........................................................................................................................ 27 Table 9: Persons with Disabilities Profile 2020 ............................................................................................................ 28 Table 10: Families with Children 2018 (no 2020 data for children) ............................................................................. 29 Table 11: Single Parent Households, 2019 .................................................................................................................. 29 Table 12: Household Size - Comparison ...................................................................................................................... 30 Table 13: Homeless Point-In-Time Count .................................................................................................................... 31 Table 14: Homeless Point-In-Time Count Survey Responses ...................................................................................... 31 Table 15: Demographics Summary ............................................................................................................................ 311 Table 16: Median Household Income (2010-2020) ..................................................................................................... 32 Table 17: HUD Median Income Limits ......................................................................................................................... 33 Table 18: Household Income ....................................................................................................................................... 34 Table 19: Median Household Income Per Race ........................................................................................................... 34 Table 20: RCAP/ECAP % Race/Ethnicity Per Block Group-51%or more LMI ................................................................ 35 Table 21: Housing Unit Growth ................................................................................................................................... 35 Table 22: Housing Characteristics ................................................................................................................................ 36 Table 23: Year Unit Built .............................................................................................................................................. 36 Table 24: Year Unit Built- City v. County ...................................................................................................................... 37 Table 25: Household Tenure – Owner v. Renter ......................................................................................................... 38 Table 26: Housing Unit Tenure Comparison ................................................................................................................ 38 Table 27: Unit Size by Tenure ...................................................................................................................................... 38 Table 28: Changes in Value, Rent, and Income ........................................................................................................... 39 Table 29: Housing Sale Prices (2021 and 2022) ........................................................................................................... 39 Table 30: Average Rental Housing Prices.................................................................................................................... 39 Table 31: Housing Affordability (2019) ........................................................................................................................ 39 Table 32: Fair Market Rent- Riverside-San Bernardino-Ontario, CA ........................................................................... 40 Table 33: Affordable Rental Housing Units in Palm Desert ......................................................................................... 40 Table 34: Housing Cost Burden Overview ................................................................................................................... 41 Table 35: Income by Cost Burden (Owners and Renters Combined) .......................................................................... 42 Table 36: Income by Cost Burden - OWNERS .............................................................................................................. 42 Table 37: Income by Cost Burden - RENTERS .............................................................................................................. 42 Table 38: Overcrowding ............................................................................................................................................... 43 6 | Page Table 39: Housing Problems (Households with one of the listed needs) .................................................................... 43 Table 40: Housing Choice Vouchers (Riverside County) .............................................................................................. 44 Table 41: Assisted Housing .......................................................................................................................................... 45 Table 42: Top Employers ............................................................................................................................................. 48 Table 43: Workforce by Industry ................................................................................................................................. 48 Table 44: Processing Times .......................................................................................................................................... 54 Table 45: Units Required to be Affordable .................................................................................................................. 55 Table 46: Residential Development Potential on Underutilized Sites ......................................................................... 55 Table 47: Loan Type ..................................................................................................................................................... 60 Table 48: Purpose of Loan Applied For ........................................................................................................................ 61 Table 49: Action by Lender .......................................................................................................................................... 61 Table 50: Demographics of Loan Applicants ................................................................................................................ 62 Table 51: Applicants by Income Level.......................................................................................................................... 62 Table 52: Lenders with Highest Denial Rates (Among lenders with 175+ applications) ............................................. 63 Table 53: Potentially Discriminatory Language in Listings of For-Sale Homes ............................................................ 65 Table 54: Fair Housing Progress Since 2018 ................................................................................................................ 68 List of Figures Figure 1: The City of Palm Desert Mapped Location ................................................................................................... 18 Figure 2:Predominate Race/Ethnicity by Census Tract ................................................................................................ 22 Figure 3: Minority Population by Census Tract............................................................................................................ 23 Figure 4: Limited English Proficiency ........................................................................................................................... 25 Figure 5: Low to moderate income areas by census block groups. ............................................................................. 33 Figure 6: SunLine Transit Agency service system map, 2023. ..................................................................................... 47 Figure 7: Palm Desert Unified School District boundary map ..................................................................................... 50 Figure 8: CRA Rating for the City of Palm Desert ......................................................................................................... 58 7 | Page I. Introduction As a recipient of funds from the US Department of Housing and Urban Development (HUD), the City of Palm Desert is required to conduct an Analysis of Impediments to Fair Housing Choice (AI) and to periodically review that analysis and update it as necessary. This AI provides a detailed look into the fair housing environment in Palm Desert. More specifically, this document includes an analysis of local factors that may impact fair housing choice, the identification of specific impediments to fair housing choice, and a plan to address those impediments. As part of its ongoing responsibilities as a recipient of HUD funds, the City of Palm Desert must also continuously assure equal access to services and programs it provides or assists in the community. i. What Is An Impediment to Fair Housing Choice? As defined by the US Department of Housing and Urban Development Fair Housing Planning Guide (1996), impediments to fair housing choice are: Any actions, omissions, or decisions taken because of race, color, ancestry, national origin, religion, sex, disability, marital status, familial status, or any other arbitrary factor which restrict housing choices or the availability of housing choices; or Any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices on the basis of race, color, ancestry, national origin, religion, sex, disability, marital status, familial status, or any other arbitrary factor. To affirmatively further fair housing, a community must work to remove impediments to fair housing choice. ii. Community Participation Throughout the preparation of the AI, a number of local agencies and organizations were contacted to obtain feedback on housing discrimination complaints and perceptions. To ensure the report responded to community concerns, the City conducted stakeholder interviews and a survey of several specific groups, including residents, housing professionals, and service providers. iii. The City’s History Palm Desert is a city in Riverside County, California, United States, in the Coachella Valley, approximately 14 miles east of Palm Springs, 121 miles northeast of San Diego, and 122 miles east of Los Angeles. A major center of growth in the Coachella Valley, Palm Desert is a popular retreat for the population from colder climates that swell its population by an estimated 31,000 each winter. Palm Desert has seen more residents become "full-timers", mainly from the coasts and urban centers of California, who have come for both affordable and high-valued homes. The City of Palm Desert was founded and incorporated in 1973. In 1980, the city’s population was 11,081, and as of 2022, Palm Desert has a population of around 51,081. A. Fair Housing Defined Equal access to housing is fundamental to each person being able to meet essential needs and to the pursuit of personal, educational, employment, and other goals. In recognition of equal housing access as a fundamental right, the governments of the United States and the State of California have both established fair housing as a right protected by law. Federal fair housing laws prohibit discrimination in the sale, rental, lease, or negotiation for real property based on race, color, religion, sex, national origin, familial status, and disability. The California fair housing 8 | Page laws are built on the federal laws and add marital status, ancestry, source of income, sexual orientation, and “any arbitrary factor” as protected categories under the laws. To affirmatively promote equal housing opportunity, a community must work to remove or to mitigate impediments to fair housing choice. The City of Palm Desert is dedicated to providing fair housing opportunities to all residents, to assuring compliance with all applicable laws throughout the City, and to conduct its business fairly and impartially. B. Analysis of Impediments to Fair Housing Choice The AI is an assessment of how laws, governmental policies, real estate practices, and local conditions may affect the location, availability, and accessibility of housing. The analysis of their impact on housing choice can highlight areas where corrective actions might broaden the housing options of persons protected by fair housing laws. This AI adheres to the recommended scope of analysis and format in the Fair Housing Planning Guide developed by the U.S. Department of Housing and Urban Development (1996). C. Purpose of the Analysis of Impediments The purpose of an AI is to review conditions in the jurisdiction that may impact the ability of households to freely choose housing and to be treated equally, without regard to race, ethnicity, religion, gender, national origin, source of income, age, disability, or other protected status. The AI reviews the general state of fair housing, the enforcement of fair housing law, efforts to promote fair housing, access to credit for the purpose of housing, and general constraints to the availability of a full range of housing types. An AI also examines the affordability of housing in the jurisdiction with an emphasis on housing affordable to households with annual incomes classified as low-income. Low-income is defined as equal to or less than 80% of the adjusted Area Median Family Income (AMI) as most recently published by the U.S. Department of Housing and Urban Development. For Palm Desert, 80 percent of the AMI is $85,000 according to the 2022 income limits issued by HUD.1 The document has three major goals: • To provide an overview of the City of Palm Desert and current conditions that may impact fair housing choice. • To review the impacts of policies and practices and how they may impact fair housing choice and the provision of housing, specifically affordable housing and housing for special needs households. • To identify impediments to fair housing choice and actions the City will take to remove those impediments or to mitigate the impact those impediments have on fair housing choice. Fulfilling these goals includes the following: • A review of the population demographics, current housing affordability, laws, regulations, private market and public sector, and administrative policies, procedures, and practices of the City of Palm Desert. • An assessment of how those laws affect the location, availability, and accessibility of housing. 1 FY 2022 Income Limits Summary for the County of San Joaquin, U.S. Department of Housing and Urban Development, May 2022. 9 | Page • An assessment of conditions, both public and private, affecting fair housing choice. Pursuant to CDBG regulations [24 CFR Subtitle A §91.225(a)(1)], to receive CDBG funds, a jurisdiction must certify that it “actively furthers fair housing choice” through the following: 1. Completion of an Analysis of Impediments to Fair Housing Choice (AI). 2. Actions to eliminate identified impediments, and maintenance of fair housing records. D. Legal Background Fair housing is a right protected by both Federal and State of California laws. Among these laws, virtually every housing unit in California is subject to fair housing practices. Additional federal and state laws related to fair housing are included in Appendix A - Federal Fair Housing Laws. i. Federal Laws The federal Fair Housing Act of 1968 and Fair Housing Amendments Act of 1988 (42 U.S. Code §§ 3601- 3619, 3631) are federal fair housing laws that prohibit discrimination in all aspects of housing, including the sale, rental, lease, or negotiation for real property. The Fair Housing Act prohibits discrimination based on the following protected classes: • Race or color • Religion • Sex • Familial status • National origin • Disability (mental or physical) Specifically, it is unlawful to: • Refuse to sell or rent after the making of a bona fide offer, or to refuse to negotiate for the sale or rental of, or otherwise make unavailable or deny, a dwelling to any person because of race, color, religion, sex, disability, familial status, or national origin. • Discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of race, color, religion, sex, disability, familial status, or national origin. • Make, print, or publish, or cause to be made, printed, or published any notice, statement, or advertisement, with respect to the sale or rental of a dwelling that indicates any preference, limitation, or discrimination based on race, color, religion, sex, disability, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. • Represent to any person because of race, color, religion, sex, disability, familial status, or national origin that any dwelling is not available for inspection, sale, or rental when such dwelling is in fact so available. • For profit, induce or attempt to induce any person to sell or rent any dwelling by representations regarding the entry or prospective entry into the neighborhood of a person or persons of a particular race, color, religion, sex, disability, familial status, or national origin. Reasonable Accommodations and Accessibility: The Fair Housing Amendments Act requires owners of housing facilities to make “reasonable accommodations” (exceptions) in their rules, policies, and operations to give people with disabilities equal housing opportunities. For example, a landlord with a "no pets" policy may be required to grant an exception to this rule and allow an individual who is blind to keep a guide dog in the residence. The Fair Housing Act also requires landlords to allow tenants with disabilities to make reasonable 10 | Page access-related modifications to their private living space, as well as to common use spaces, at the tenant’s own expense. Finally, the Act requires that new multi-family housing with four or more units be designed and built to allow access for persons with disabilities. This includes accessible common use areas, doors that are wide enough for wheelchairs, kitchens and bathrooms that allow a person using a wheelchair to maneuver, and other adaptable features within the units. HUD Final Rule on Equal Access to Housing in HUD Programs: On March 5, 2012, HUD published the Final Rule on “Equal Access to Housing in HUD Programs Regardless of Sexual Orientation or Gender Identity.” It applies to all McKinney-Vento-funded housing programs, as well as to other housing assisted or insured by HUD. The rule creates a new regulatory provision that generally prohibits considering a person’s marital status, sexual orientation, or gender identity (a person’s internal sense of being male or female) in making housing assistance available. The proposed rule is currently on display for 60-day public comment period. Affirmatively Furthering Fair Housing, Notice of Proposed Rulemaking: In February 2023, HUD notified all entitlements they will imminently publish in the Federal Register a Notice of Proposed Rulemaking entitled “Affirmatively Further Fair Housing”. The proposed rule, which builds on and refines HUD’s 2015 rule, would faithfully implement the Fair Housing Act’s statutory mandate that HUD ensure that recipients of its funding affirmatively further fair housing (AFFH). The AFFH mandate requires the agency and its program participants to proactively take meaningful actions to overcome patterns of segregation, promote fair housing choice, eliminate disparities in opportunities, and foster inclusive communities free from discrimination. HUD expects that implementation of this proposed rule will greatly enhance equity, human dignity, social welfare, and justice for all protected class groups. ii. California Laws California fair housing laws are built upon the federal laws and add marital status, ancestry, source of income, sexual orientation, and “any arbitrary factor” as protected categories under the laws. The State Department of Fair Employment and Housing (DFEH) enforces California laws that provide protection and monetary relief to victims of unlawful housing practices. Fair Employment and Housing Act (FEHA) (Government Code Section 12955 et seq.) prohibits discrimination and harassment in housing practices, including: Advertising: • Application and selection process • Unlawful evictions • Terms and conditions of tenancy • Privileges of occupancy • Mortgage loans and insurance • Public and private land use practices (zoning) • Unlawful restrictive covenants The following categories are protected by FEHA: • Race or color • Ancestry or national origin • Sex 11 | Page • Marital status • Source of income • Sexual orientation • Gender identity/expression • Genetic information • Familial status (households with children under 18 years of age) • Religion • Mental/physical disability • Medical condition • Age In addition, the FEHA contains similar reasonable accommodations and accessibility provisions as the federal Fair Housing Amendments Act. The Unruh Civil Rights Act provides protection from discrimination by all business establishments in California, including housing and accommodations, because of age, ancestry, color, disability, national origin, race, religion, sex, and sexual orientation. While the Unruh Civil Rights Act specifically lists “sex, race, color, religion, ancestry, national origin, disability, or medical condition” as protected classes, the California Supreme Court has held that protections under the Unruh Act are not necessarily restricted to these characteristics. Furthermore, the Ralph Civil Rights Act (California Civil Code Section 51.7) forbids acts of violence or threats of violence because of a person’s race, color, religion, ancestry, national origin, age, disability, sex, sexual orientation, political affiliation, or position in a labor dispute. Hate violence can be: • Verbal or written threats • Physical assault and or attempted assault, and or • Graffiti, vandalism, or property damage. The Bane Civil Rights Act (California Civil Code Section 52.1) provides another layer of protection for fair housing choice by protecting all people in California from interference by force or threat of force with an individual’s constitutional or statutory rights, including a right to equal access to housing. The Bane Act also includes criminal penalties for hate crimes; however, convictions under the Act are not allowed for speech alone unless that speech itself threatened violence. And, finally, California Civil Code Section 1940.3 prohibits landlords from questioning potential residents about their immigration or citizenship status. Landlords in most states are free to inquire about a potential tenant’s immigration status and to reject applicants who are in the United States illegally. In addition, this law forbids local jurisdictions from passing laws that direct landlords to make inquiries about a person’s citizenship or immigration status. In addition to these acts, Government Code Sections 11135, 65008, and 65580-65589.8 prohibit discrimination in programs funded by the State and in any land use decisions. Specifically, recent changes to State law require local jurisdictions to address the provision of housing options for special needs groups, including: • Housing for persons with disabilities • Housing for homeless persons, including emergency shelters, transitional housing, and supportive housing • Housing for extremely low-income households, including single-room occupancy units • Housing for persons with developmental disabilities 12 | Page The California Department of Housing and Community Development (HCD) prepared the 2020 Analysis of Impediments to Fair Housing Choice. To effectively combat housing discrimination and affirmatively further fair housing, HCD has identified a multi-pronged approach that includes recommendations and action steps to address the 10 impediments to fair housing choice identified through the 2020 AI process. The recommendations and action steps will inform HCD’s efforts to affirmatively further fair housing; to promote inclusive communities, further housing choice, and address community disparities through HCD’s programs, policies, and operations. HCD’s AFFH efforts will also follow guidance from state fair housing law, including AB 686 (2018). Some of these actions are within HCD’s authority, while others will require on-going, collaborative work with state and local entities. Chapter 13 provides 10 key implements to fair housing and detailed action steps. This section can be found here: Ch. 13 Impediments and Action Steps, Final 2020 Analysis of Impediments to Fair Housing Choice (ca.gov) . In 2021, HCD prepared a status update to the CA AI including implementation measures and actions taken thus far to reduce barriers to fair housing. 2020 AI Implementation Status Report (ca.gov) THE STATE OF CALIFORNIA 2020 AI IMPLEMENTATION STATUS REPORT TOP 10 IMPEDIMENTS TO FAIR HOUSING • Impediment #1: Supply and Production of Affordable Homes Inadequate supply and production of affordable homes available to lower-income households and persons in protected classes. • Impediment #2: Housing Preservation Vulnerable supply of affordable homes threatens housing options for lower-income households and persons in protected classes. • Impediment #3: Housing Instability and Homelessness Unequal access to supportive services, shelter, and affordable housing opportunities increases housing instability and risk of homelessness for protected classes. The Coronavirus pandemic has exacerbated existing inequalities and vulnerabilities. • Impediment #4: Fair Housing Education and Enforcement Limited community awareness of fair housing protections and enforcement resources. • Impediment #5: Tenant Protections and Anti-Displacement Lack of uniform enforcement and adequate anti-displacement protections have left protected classes more vulnerable to displacement. • Impediment #6: Disparities in Housing Quality and Infrastructure Lower-income households, rural communities, and persons in protected classes, are disproportionately experiencing severe housing problems, a lack of adequate housing options, and disparities in infrastructure. • Impediment #7: Climate and Environmental Vulnerabilities Lower-income households and protected classes are often disproportionately impacted by climate change, environmental injustice, or unsustainable land use and development practices. • Impediment #8: Historic and Lasting Impact of Segregation Despite the repeal of explicitly racist and discriminatory housing laws, there remains a lasting legacy of segregation and resource disparities. Housing choice is often limited for persons of protected classes, including communities of color, to segregated concentrated areas of poverty. • Impediment #9: Local Resistance and Exclusionary Land Use Policies Constrain Access to Opportunity Denying, preventing, or rendering infeasible multifamily housing development, alternative housing strategies, and affordable housing limits access for lower income households, protected classes, and persons experiencing homelessness. • Impediment #10: Insufficient Accessible Housing Stock Lack of adequate accessible housing options, compared to the need, limits housing choice for people with disabilities. 13 | Page E. Organization of the Report This report is divided into eight sections: I. Introduction – Explains the purpose of the analysis of impediments to fair housing, defines fair housing, lists the data and funding sources for the report, and describes the public participation process. II. Community Participation Process – Provides a description of public outreach efforts to obtain community input on community needs and possible impediments. III. Community Data – Describes the housing and population characteristics of the City. Population characteristics include income, age, race, ethnicity, familial status, and disability. Employment characteristics are also included. Housing characteristics include unit type and tenure, housing cost, and overcrowding. The geographic distribution of households by income, race, and ethnicity is also examined. IV. Public Policies – Reviews public policies and practices to determine the potential impact on fair housing and the provision of an adequate number and appropriate types of housing. V. Lending Practices – Assesses the general level of fair housing and housing rights awareness in the private sector. Specifically, rental housing, residential real estate sales, and mortgage lending are evaluated. The analysis relies on an array of tools including interviews with stakeholders and the review of local advertisements, published data on mortgage lending, and reports of unfair housing practices. VI. Fair Housing Profile – Evaluates existing public and private programs, services, practices, and activities that aim to assure fair housing in the City. This section describes the City’s recent actions to promote fair housing, provide affordable housing, and remove barriers to affordable housing. In order to identify actions taken to affirmatively further fair housing, this section reviews the City’s most recent Consolidated Plan, Annual Action Plans, and Consolidated Annual Performance and Evaluation Reports (CAPERs). VII. Five-Year Progress – Summarizes impediments identified in 2015 and actions taken to accomplish objectives and goals used in addressing the impediments identified in the City’s previous AI. VIII. Actions –Summarizes the findings regarding fair housing issues in the City and provides recommendations for furthering fair housing. In this section, the reader can find the impediments identified and the actions proposed to address those impediments. IX. Appendices – Appendix A (Federal Fair Housing Laws) and Appendix B (Community Outreach Summary). F. Data Sources In preparation of this Analysis of Impediments to Fair Housing Choice (AI), the following data sources were consulted. American Community Survey (ACS) 2013-2017 - 5-Year Estimates, U.S. Census Bureau. ACS data are obtained from a nationwide survey on demographic, social, economic, and housing information conditions. The 5-Year Estimate includes 60 months of collected data for all population size areas. It utilizes the largest sample size of all the Survey forms (1-Year, 3-Year and 5-Year Estimates) and is the most reliable. It is, however, the least current of the Survey forms. The 5-Year Estimate is best utilized when precision is more important than currency, and when examining tracts and other smaller geographies. 2000 and 2010 Decennial Census, U.S. Census Bureau. The Decennial Census provides comprehensive data describing demographic and housing characteristics. 14 | Page California Department of Finance (DOF). The Department of Finance provides estimates on current population and housing stock based on housing construction and demolition data submitted annually by local jurisdictions. Employment Development Department (EDD). The Employment Development Department provides current and projected labor market data. Comprehensive Housing Affordability Strategy (CHAS). Developed by the Census Bureau for HUD, the CHAS database contains information on low- and moderate-income households, as well as housing problems (i.e., cost burden, overcrowding, and substandard conditions). In June 2018, HUD posted CHAS data based on the 2011-2015 ACS. The five-year (2010-2014) data are used by HUD and state and local governments to examine housing needs and make funding decisions. The data are available at the state, county, place, and census-tract level. U.S. Bureau of Labor Statistics. The U.S. Bureau of Labor Statistics provides labor market data, including data on employment, wages, and earnings. 15 | Page II. Community Participation Process The Analysis of Impediments for the City of Palm Desert has been conducted in several ways: community outreach survey, public meetings, stakeholder interviews, a public meeting, and public hearing. Significant outreach efforts were made to the public, faith-based organizations, educational institutions, housing services, and health and social service organizations (including organizations providing services to homeless persons and families, persons with HIV/AIDS, victims of domestic violence, senior citizens, and extremely low to low- income populations. A. Community Ou treach Survey A community development survey was used to help establish priorities for the City by gathering feedback on the level of need for housing and community development categories. The survey was launched via Survey Monkey on the City’s website and Facebook page. Consultation with local and regional agencies is an important element in the process of the development of the plan. These consultations help to determine areas of need, or gaps in services provided by health services, social services, the County of Riverside Continuum of Care, public housing agencies and Fair Housing. i. Survey Results The Community Outreach Survey was used to gather public feedback and information for the 2023-2028 Consolidated plan. The survey was open to the public throughout the month of January 2023. A large majority of the survey respondents, 44 were city residents. ii. Community Needs The community survey asked several questions about community facility needs. The top 5 highest rated priority community facility needs are: 1. Youth Centers 54.84% 2. Parks and Recreational Facilities 50.54% 3. Neighborhood Facilities 41.94% 4. Child Care Centers 39.78% 5. Senior Centers 32.26% 6. Health Facilities 27.96% The community survey asked about public transit accessibility: 1. 30% of survey respondents use transit regularly to get to work 2. 59% of survey respondents do not feel transit services are readily available to everyone 3. 32% of survey respondents do not use transit at all iii. Housing Discrimination The community survey asked several questions about housing discrimination. When asked about housing discrimination, 19.44% of the survey respondents had encountered discrimination issues while 41.67% of respondents said they did not know anyone who had encountered discrimination issues. When asked about discrimination reasonings, 36.36% said it was because of Race/Ethnicity, Religion, or Disability; 30.30% said Criminal History / Record Source of Income, and 27.27% said it was because of age. 33.33% of participants believe housing discrimination occurs in the city, 22.22% said it is likely, 13,89% said not likely, and 27.78% participants said they did not know. 16 | Page iv. Housing Needs The community survey asked respondents to what the priority housing needs are (in priority order): 1. Affordable rental housing 2. Energy efficiency improvements 3. Senior housing 4. Down payment assistance 5. Supportive housing 6. Housing for the disabled 7. Homeowner housing rehabilitation When asked if affordable housing was available to them, 42.86% of participants said no. v. Homeless Needs The top needs for homeless populations reported in priority order are: 1. Mental health / addiction services 2. Emergency shelter space 3. Transitional housing 4. Food and clothing assistance 11.43% of participants said homeless were vulnerable to natural disasters, 52.78% said homeless should be considered in the 2023 – 2028 Consolidated Plan cycle, and 34.29% believe services and shelters for homeless people should receive financial support from the City of Palm Desert. B. Public Meeting and Hearing A public meeting was held on February 16, 2023, designed to solicit public input. Attendees were asked to answer key questions that collected input on the priority community and housing needs. A summary of the meeting was prepared. What do you think City funding priorities should be? • Staffing and operations costs for services to address the needs of low and moderate-income people • Improvements to public facilities • Construction projects to improve neighborhoods and community facilities • Decent housing and a suitable living environment for the City’s low- and moderate-income residents. What challenges does your organization have with program delivery? 1. Agency staffing capacity 2. Funding – due to elimination of RDA 3. Inadequate program reporting What are the changes you see with the needs of your clients? Demographic shifts in in population specifically: • Changes in neighborhood ethnicity • Increase in age • Increase in family households • Increase in veteran households The public meeting was duly advertised from February 3, 2023 to February 16, 2023, and notices were emailed to organizations from the contact list of partners and service organizations the City has compiled from past 17 | Page stakeholder and community meetings related to grant funding from HUD. A Public Meeting Summary is included in Appendix B – Community Outreach. C. Consultation with Stakeholders Several stakeholders were consulted both in-person and over email all answering the same questionnaire. Such stakeholders included, but were not limited to, housing providers, health services, social service agencies, fair housing organizations representing protected classes, broadband internet providers, emergency management organizations, and local and regional housing and or homeless providers. The purpose of the consultations and or interviews was to carry out a needs assessment for: • Housing needs • Homelessness services needs • Priority CDBG allocation activities to fund For consistency, the stakeholders interviewed were each asked the same eight questions to elicit input and gather data on community and housing needs. A Stakeholder Summary can be found in Appendix B – Community Outreach. D. Evaluation of Community Participation Efforts All information was documented, and summaries have been included in Appendix B - Community Outreach. Valuable information was obtained that have been analyzed along with the Community Profile and Lender data to determine the specific Impediments to Fair Housing Choice and the Analysis of Impediment Goals and Actions. E. Reaching Underrepresented Populations The City provided meaningful access to Limited English proficiency (LEP) persons during meetings and outreach activities. Public notice of the project’s public meeting and hearing, and the online community needs survey were translated into English. Significant efforts were made to reach out to the Spanish speaking community regarding the community outreach, which included distribution of the translated fliers and surveys to over 50 emails, phone calls to the City’s contacts at local community organizations. Links to survey as well as the public meeting dates were also distributed to the contacts. i. Limited English Proficient The City provided meaningful access to persons with LEP during meetings and outreach activities, such as through translation of documents. The City ensured effective communication with individuals with disabilities during such events, such as through the use of auxiliary aids and services (e.g., sign language interpreters, real-time captioning, large print and braille documents, etc.). ii. R/ECAPs There are no areas designated as Racially or Ethnically Concentrated Areas of Poverty in Palm Desert. iii. Persons with Disabilities or Special Needs To notify persons residing in Palm Desert about the process was done by notifying organizations that provide services to the disabled that work throughout the City of Palm Desert. 18 | Page III. Community Data The City of Palm Desert is located in Southern California, within Riverside County. This charter city was incorporated November 26th, 1973 and is the ninth city established in the County of Los Angeles. Its history includes Native American sites of the Cahuilla, a division of the Morongo Band of Mission Indians that lived here for over 10,000 years. The area was formerly known as Old Macdonald Ranch until date palms were planted in the 1920s, when it became known as Palm Village. Its first residential development occurred in 1943 as part of an Army maintenance camp, and more followed during the middle of the 20th century. The area became known as Palm Desert in 1951. Now a major center of growth in the Coachella Valley, Palm Desert is a popular retreat transplants from colder climates (the Eastern and Northern United States, and Canada), who swell its population by an estimated 31,000 each winter. Palm Desert has seen more residents become "full- timers", mainly from the coasts and urban centers of California, who have come for both affordable and high-valued homes The City of Palm Desert has made a commitment to providing equal housing opportunities for residents of the City. As a recipient of the Community Development Block Grant (CDBG) in past years, Palm Desert has worked to provide a higher quality of life in the City. A study of the demographics of the City will describe the needs of different segments of the population, the location of homeowners and renters in the City, and describe trends over time that will be useful in determining future needs. A. Demographic Summary The City’s population is estimated at 53,087 people, an increase of over 9.38 percent since the 2010 Census. At the same time the average household size increased from 2.07 to 2.12 persons per household. This could indicate a slight trend towards larger families, or a slight trend towards extended families sharing living quarters. During this same period, the housing stock increased by percent. Most of the City’s land uses have been built residentially. Single-family homes make up about 60 percent of the housing stock, the multi-family share is approximately 32 percent, and mobile homes comprise 8 percent. Figure 1: The City of Palm Desert Mapped Location 19 | Page The median price of a housing unit in the City of Palm Desert was estimated at $361,200.2 Median Gross Rent was 1,353.3 This chapter is dedicated to providing a plethora of data used to determine fair housing issues that may exist in the City or region. Population growth, age characteristics, housing, income and race/ethnicity all help determine a community’s housing needs and play a role in exploring potential impediments to fair housing choice. B. Population Characteristics Population characteristics are an indication of the housing needs of a community. Such characteristics include population growth over time, the aging trends of the local population, age and race. The City experienced population growth by eighteen percent between 2000 and 2010. The City’s population increased nine percent from 2010 to 2020. Table 1: Regional Populations Increase Total Population 2000 2010 2020 City 41,155 48,534 53,087 County 1,545,387 2,109,464 2,437,864 State 33,871,648 36,637,290 39,346,023 Source: Census 2000, 2010 & 2016-2020 Census Table 2 shows that the City has experienced large population increases between 2000 and 2020. A trend of increased growth can indicate several causes: more families and individuals transitioning to full-time residences in the area as opposed to seasonal. Table 2: Regional Populations Percent Increase Area 2000-2010 2010-2020 2000-2020 City 17.93% 9.38% 28.99% County 36.50% 15.57% 57.75% State 8.17% 7.39% 16.16% Source: Census 2000, 2010 & 2016-2020 ACS C. Population Age Household age is a factor in housing choice and determines different housing needs.4 Households containing (18 to 24) typically can afford smaller, more affordable units; households between the ages of 25 and 44, typically look for single-family units for a growing family; empty-nesters (ages 45 to 64) are still living in a FY 2022 Income Limits Summary for the County of San Joaquin, U.S. Department of Housing and Urban Development, May 20 22. DIAN GROSS RENT BY BEDROOMS, Universe: Renter-occupied housing units paying cash rent, 2013-2017 American Community Survey 5-Year Estimates. 4 Joint Center for Housing Studies of Harvard University, The State of the Nation’s Housing 2019, Harvard Graduate School of Design, Harvard Kennedy School, 2019, 14. 20 | Page larger family home and older populations of 65 and older tend to want to scale down from their bigger home to a smaller home such as a condominium or an apartment with less floor space.5 The largest age cohort in the City is persons between the ages 65 or older at roughly 36 percent, a larger percentage as compared to the County at 14 percent. Adults ages 45 to 64 make up 24 percent of the City’s population, an equal share to that of the County estimated at 24 percent. A senior citizen is someone 65 and older. The senior population in the City is growing, therefore increased access to housing, services, recreation and healthcare will be a focus. Table 3: Age Characteristics (2020) Age City City % County Under 18 7,499 14.13% 613,823 18-24 3,726 7.02% 236,238 25-44 10,291 19.39% 654,005 45-64 12,591 23.72% 581,423 65 or older 18,980 35.75% 352,375 Total: 53,087 100.00% 2,437,864 Source: 2016-2020 ACS 5-Year Estimates D. Race and Ethnicity The definition of race, a group of persons related by common descent or heredity, is different from the definition of ethnicity, a social group that shares a common and distinctive culture, religion, language, or the like. As such, persons of different ethnicities possess distinct preferences when choosing types of housing.6 As of 2020, there were 41,611 persons classified as White race/ethnicity or 78% of the City’s total population, a decrease of roughly 1 % since 2010. The largest noticeable shift in race in the City was the increase in the “two or more races” category (+441.32 percent) and the Black or African American population (+117.57 percent). Table 4: Current Race & Ethnicity Comparison Race/Ethnicity City County 2010 2020 % Change 2010 2020 % Change White 41,925 41,611 -0.75% 1,365,281 1,358,654 -0.49% Black or African American 757 1,647 117.57% 131,258 157,908 20.30% %American Indian and Alaska Native 337 359 6.53% 20,289 18,852 -7.08% Asian 1,729 2,389 38.17% 121,846 164,464 34.98% 5 Rose Quint, “Housing Preferences Across Generations,” NAHB Economics and Housing Policy Group Studies (March 1, 2016). 6 Esther Havekes, Michael Bader, and Maria Krysan, “Realizing Racial and Ethnic Neighborhood Preferences? Exploring the Mismatches Between What People Want, Where They Search, and Where They Live,” Population Research and Policy Review (2016): 102. 21 | Page Native Hawaiian and Other Pacific Islander 70 80 14.29% 6,436 7,915 22.98% Some other race 2,944 2,822 -4.14% 383,974 539,108 40.40% Two or more races 772 4,179 441.32% 80,380 190,963 137.58% Total 48,534 53,087 9.38% 2,109,464 2,437,864 15.57% Source: 2006-2010 ACS 5-Year Estimates and 2016-2020 ACS 5-Year Estimates. 22 | Page Figure 2:Predominate Race/Ethnicity by Census Tract 23 | Page Figure 3: Minority Population by Census Tract Source: American Fact Finder 2017, US Census Tract data, LA County GIS data, ESRI Street Map 24 | Page As indicated in Table 5, 24 percent of the City’s residents speak a language other than English and 6 percent speak English less than "very well". Such findings indicate language barriers may prevent residents from accessing services, information, and housing, and may also affect educational attainment and employment. Executive Order 13166 ("Improving Access to Services by Persons with Limited English Proficiency”) was issued in August 2000, which requires federal agencies to assess and address the needs of otherwise eligible persons seeking access to federally conducted programs and activities who, due to Limited English Proficiency (LEP), cannot fully and equally participate in or benefit from those programs and activities. This requirement passes down to grantees of federal funds as well. Table 5: Language Spoken At Home (person 5 years old and older) Number Population 5 years and over 51,342 English only 39,187 Language other than English 12,155 Speak English less than "very well" 3,158 Spanish 8,375 Speak English less than "very well" 2,164 Other Indio-European languages 1,943 Speak English less than "very well" 226 Asian and Pacific Island languages 1,578 Speak English less than "very well" 680 Other languages 259 Speak English less than "very well" 88 Source: Language Spoken at Home, 2016-2020 ACS 5-Year Estimates. E. Limited English Proficiency According to Figure 4, the concentrations of persons of limited English proficiency are spread throughout the City. Next to English, Spanish is the most spoken language in the City. Persons that are limited in English proficiency can become culturally or linguistically isolated, tend to have less education, and earn less. To get information to these populations, regarding public services related to housing, health, or other valuable resources can be challenging without properly integrating factors related to resources, race, culture, and language.7 Immigrants also have limited accessibility to their jobs because they cannot receive a driver’s 7 Enhancing Public Health Emergency Preparedness for Special Needs Populations: A Toolkit for State and Local Planning and Response, Jeanne S. Ringel, 2009. 25 | Page license or may not be near transit routes. Limited English Proficiency can also have an impact on the workforce and local economy. Some employers may require English speakers.8 Figure 4: Limited English Proficiency Source: AFFH Mapping Tool, U.S. Department of Housing and Urban Development, (2023) F. Dissimilarity Index The dissimilarity index measures whether one particular group is distributed across census tracts in the metropolitan area in the same way as another group. A high value indicates that the two groups tend to live in different tracts. The index scale ranges from 0 to 100. A value of 60 (or above) is considered very high. It means that 60% (or more) of the members of one group would need to move to a different tract in order for the two groups to be equally distributed. Values of 40 or 50 are usually considered a moderate level of segregation, and values of 30 or below are considered to be fairly low. According to the indices shown in Table 6, segregation is low in the City. Table 6: Index of Dissimilarity 1980 1990 2000 2010 2020 White - Black 4.8 11.7 19.4 24.9 21.6 White - Hispanic 9.3 17.6 39.4 37.5 32.8 White - Asian 8.5 11.0 16.4 23.7 20.7 Black - Hispanic 8.8 8.8 25.3 25.6 23.2 Black - Asian 7.6 7.5 11.1 17.5 13.6 Hispanic - Asian 1.7 9.7 27.2 25.6 27.2 8 Cheeseman Day, Jennifer and Shin, Hyon B. “How Does Ability To Speak English Affect Earnings?” Population Division, U.S. Census Bureau (2005). 26 | Page Source: Diversity and Disparities, American Communities Project, https://s4.ad.brown.edu/projects/diversity/segregation2010/city.aspx?cityid=660018 G. Household Characteristics The U.S. Census Bureau defines a household as a family, two or more families living together, a person living alone, or unrelated persons living together. As mentioned, younger persons usually require smaller, more affordable units; families require single-family units for a growing family; though empty-nesters and the elderly prefer to age in place, if necessary, they generally scale down from bigger homes to smaller ones.9 i. Household Type and Size According to the Table 7, families make up 54 percent of all households; 15 percent of all households are families with children. Households with seniors (65 and older) accounts for 53 percent of total households. Overall, households with families have increased slightly by 2 percent. However, households with families with children has decreased slightly by 2 percent. Nonfamily households have increased significantly by 10 percent. Households with seniors has increased significantly as well by 17 percent. Female-headed households saw an extremely high increased between 2010 and 2019, jumping by 449 percent. Overall, housing is needed for families and seniors. Table 7: Household Type and Size 2010 2019 (No 2020 Data for Children) % Change Total Households 23,041 24,396 5.88% Family Households 13,004 13,294 2.23% With own children under 18 yrs 3,744 3,663 -2.16% Married couple with family 10,580 10,835 2.41% With own children under 18 yrs 2,398 2,465 2.79% Female householder, no husband present 1,370 7,527 449.42% With own children under 18 yrs 712 713 0.14% Nonfamily households 10,037 11,102 10.61% Householder living alone 8,620 8,736 1.35% Householder 65 years and over 4,638 5,134 10.69% Households with individuals under 18 years 4,008 4,091 2.07% Households with individuals over 65 years 10,983 12,816 16.69% Average household size 2.09 2.14 2.39% Average family size 2.77 2.77 0.00% Source: 2010 U.S. Decennial Census, 2015-2019 ACS 5-Year Estimates (2016-2020 does not feature data on children) 9 Joint Center for Housing Studies of Harvard University, The State of the Nation’s Housing 2019, Harvard Graduate School of Design, Harvard Kennedy School, 2019, 6. 27 | Page H. Special Needs Populations The special needs population are persons who are not homeless but require supportive housing. Special needs persons include the elderly (defined by HUD to be 62 and older), frail elderly (defined as an elderly person who requires assistance with three or more activities of daily living, such as bathing, walking, and performing light housework), persons with mental, physical, and/or developmental disabilities, persons with alcohol or other drug addiction, persons with HIV/AIDS and their families, and victims of domestic violence, dating violence, sexual assault, and stalking.10 While age is not a protected class under the Fair Housing Act, information on elderly households is provided because it is often relevant to how programs operate at the local level, with some buildings or programs designated or designed to serve seniors. Since the Fair Housing Act protects families with children and persons with disabilities from discrimination, it is important to assess whether there are differences in the patterns of siting of publicly supported housing that serves families with children versus publicly supported housing that serves elderly populations. The same comparison should be done for publicly supported housing that primarily serves persons with disabilities. i. Senior Population and Characteristics Because of the high birth-rate during the mid-20th century and improved healthcare, seniors are living longer and are becoming a larger portion of the population everywhere.11 An increase in the senior population wanting smaller homes and needing ADA accessibility, and other amenities that give seniors greater access to community services. Housing need is becoming greater for seniors in the City as well as the need for affordable housing. Table 8: Percent of Elderly Population Percent of Population Age 2010 2020 65-74 16.30% 17.40% 75-84 11.70% 12.90% 85 and older 4.70% 5.50% Source: 2016-2020 ACS 5-Year Estimates In the coming years, the baby-boom generation will be significant as will housing need for this demographic. According to survey studies, 70% of the baby-boom generation feel they may not be adequately financially prepared for retirement.12 However, seniors prefer to age in place, which creates a need for home upgrades to accommodate their changing needs, e.g., ADA accessibility. Seniors that relocate generally opt for smaller 10 Title 24 Housing and Urban Development, Volume 1, Subtitle A-Office of the Secretary, Department of Housing and Urban Development , CFR 91.205(b, d). 11 Dowell Myers & SungHo Ryu. “Baby Boomers and the Generational Housing Bubble: Foresight and Mitigation of an Epic Transition,” Journal of the American Planning Association, Volume 74, (2008): 17-33. 12 Senioriving.org, HUD-Sponsored Senior Housing Programs, https://www.seniorliving.org/hud-senior-housing- programs/ (accessed October 1, 2019). 28 | Page homes.13 According to the 2016-2020 ACS, elderly persons accounted for approximately 36 percent of the City’s population. I. Disabled Population For the most part, disabled persons earn less than the non-disabled.14 If disabled persons are earning less due to their disability, a need for affordable housing exists for this population. Additionally, physically disabled persons require housing that is accessible, for example, wheelchair accessibility. Also, under fair housing law, persons with a disability are a protected class. Section 504 of the Rehabilitation Act of 1973 prohibits discrimination against people with disabilities in programs that receive federal financial assistance. Studies have shown that persons with disabilities experience discrimination more often than there protected classes under fair housing law.15 As such, it is important to educate the public on the preventing the discrimination of physically and mentally disabled persons. According to the 2013-2017 ACS 5 Year Estimates in Table 9, 7.3 percent of the population who lived in the City reported a disability. Table 9: Persons with Disabilities Profile 2020 % of Population Hearing Disability Vision Disability Cognitive Disability Ambulatory Disability Self-Care Disability Independent Living Disability 15.2% 5.90% 3.70% 5.40% 8.30% 3.40% 6.10% Source: 2016-2020 ACS 5-Year Estimates J. Population Living with HIV/AIDS The Fair Housing Act prohibits housing discrimination against individuals with disabilities, including HIV or AIDS; this includes all types of housing, such as apartments, houses, mobile homes, nursing homes, assisted living centers, group homes, student housing, and homeless shelters.16 The California HIV Surveillance Report-2017 published by the California Department of Public Health, Center for Infectious Diseases in Sacramento, California in 2020 reported a total of 9,765 persons living with HIV/AIDS in the County, including 239 new cases. Supportive services for this population can be found at: http://www.rivcohivaids.org/ K. Families with Children 13 Joint Center for Housing Studies of Harvard University, The State of the Nation’s Housing 2019, Harvard Graduate School of Design, Harvard Kennedy School, 2019, 6. 14 United States Census Bureau, In Most Occupations, Workers with or Without Disabilities Earn About the Same, Jennifer Cheeseman Day and Danielle Taylor March 21, 2019. 15 Margery Austin Turner, Carla Herbig, Deborah Kaye, Julie Fenderson, Diane Levy, Discrimination Against Persons with Disabilities: Barriers at Every Step, The Urban Institute Washington DC (June 2005). 16 U.S. Department of Justice Civil Rights Division Disability Rights, Section, Protecting the Rights of Persons Living with HIV/AIDS, https://www.ada.gov/hiv/ada_aids_brochure.pdf. 29 | Page Familial status is a protected class under fair housing law. Households, under law, cannot be denied because they have children. In some cases, landlords have created policies that include but have not been limited to limiting the number of children, restrict the ages of children permitted in units cap the number of children permitted in a unit discourage the sharing of bedrooms by children of the opposite sex, restrict buildings or floors of buildings in complexes where children were permitted, charge higher rents or require larger security deposits from renters with children, policies which landlords and property owners do not have the right to do.17 Additionally, past studies found that some landlords will flatly deny rent to female heads of household.18 The City features less families with children and less single parent households than the County. Table 10: Families with Children 2018 (no 2020 data for children) All Families with Children Female Headed Households with Children Jurisdiction Total Households Number % of Total Households Number % of all Families with Children City 24,396 3,663 15.00% 713 19.50% County 724,893 236,498 32.60% 36,990 15.60% Source: ACS 2015-2019, Households and Families Table 11: Single Parent Households, 2019 City County Total Households 24,396 724,893 # of Single Parent Households 1,074 46,632 % of Single Parent Households 4.40% 6.40% Source: 2015-2019 ACS 5-Year Estimates, Selected Social Characteristics in the United States L. Large Households Large households are defined as households containing five or more occupants. A large household can sometimes indicate overcrowding, which can be related to ethnicity, age, immigration, and poverty.19 The 2016-2020 ACS identified households in the City with five or more persons, representing nearly 5 percent of all households. Of large households, 52 percent are owner-occupied, 48 percent are renter-occupied. Overall, large households and persons who own or rent have increased very little between 2010 and 2020. This percentage of large households is too small to determine if there are overcrowding exists. 17 HUD Charges Georgia Landlords with Discrimination Against Families with Children, September 12, 2019, https://www.hud.gov/press/press_releases_media_advisories/HUD_No_19_137 18 Ibid, 5. 19 The Changing Problem of Overcrowded Housing, Dowell Myers , William C. Baer & Seong-Youn Choi, pages 6626 Nov 2007. 30 | Page Table 12: Household Size - Comparison 2010 2020 Number % Number % Total Occupied housing units 23,041 100.00% 24,335 100.00% Owner occupied 15,882 68.93% 15,720 64.60% Renter occupied 7,159 31.07% 8,615 35.40% Owner & Renter occupied 23,041 100.00% 24,335 100.00% 1 person HH 8,620 37.41% 8,383 34.45% 2 persons HH 9,679 42.01% 10,966 45.06% 3 persons HH 2,168 9.41% 2,465 10.13% 4 persons HH 1,476 6.41% 1,308 5.37% 5 persons HH 505 2.19% 846 3.48% 6 persons HH 267 1.16% 277 1.14% 7 or more persons HH 326 1.41% 90 0.37% Owner occupied 15,882 100.00% 15,720 100.00% 1 person HH 5,389 33.93% 5,061 32.19% 2 persons HH 7,715 48.58% 7,807 49.66% 3 persons HH 1,175 7.40% 1,470 9.35% 4 persons HH 854 5.38% 750 4.77% 5 persons HH 416 2.62% 352 2.24% 6 persons HH 172 1.08% 251 1.60% 7 or more persons HH 161 1.01% 29 0.18% Renter occupied 7,159 100.00% 8,615 100.00% 1 person HH 3,231 45.13% 3,322 38.56% 2 persons HH 1,964 27.43% 3,159 36.67% 3 persons HH 993 13.87% 995 11.55% 4 or more persons HH 622 8.69% 558 6.48% 5 persons HH 89 1.24% 494 5.73% 6 persons HH 95 1.33% 26 0.30% 7 or more persons HH 165 2.30% 61 0.71% Source: 2006-2010 and 2016-2020 ACS 5-Year Estimates 31 | Page M. Homeless Population The Riverside County Continuum of Care is the continuum of care for the region that includes Palm Desert. Each year, the Riverside Continuum of Care coordinates a Shelter/Housing Inventory Count (HIC), which is a Point-In-Time (PIT) inventory of service projects, and a record of utilization of services. HIC records how many beds and units are dedicated to serving people experiencing homelessness (e.g., emergency shelter, transitional housing, and safe haven) or people who have experienced homelessness and are now in permanent housing. Information gathered through the PIT survey is used by the Continuum of Care to understand the issues associated with homelessness, including causes of homelessness, service needs of the homeless, the region’s unmet housing needs, and trends over time of homelessness in the region. The 2022 PIT was held at night in January. A total of 26 unsheltered households and 0 sheltered persons were counted in Palm Desert. The majority of homeless persons are White men found living on the street, between the ages of 25 and 54. Table 13: Homeless Point-In-Time Count Sheltered Unsheltered Total Persons 0 26 26 Source: Riverside County 2022 Point in Time Count Table 14: Homeless Point-In-Time Count Survey Responses # % Persons in Cars 1 6% Persons in Vans 0 0 Persons in RVs or Campers 0 0 Persons in Tents 3 19% Persons in Makeshift Shelters 0 0 Persons on the Street 12 75% Total 16 100.0% Source: County of Riverside Continuum of Care, 2022 Riverside County Point in Time Count Table 15: Demographics Summary City of Palm Desert PIT Count Number Percent Gender Male 21 81% Female 3 12% Transgender 0 0 Gender Non-conforming 1 3% Unknown 1 3% Race/Ethnicity Hispanic/Latino 8 31% Black/African-American 1 3% White 19 73% 32 | Page American Indian/Alaskan Native 2 7% Asian 0 0 Native Hawaiian/Other Pacific Islander 0 0 Multi-Racial/Other 4 15% Age Under 18 0 18-24 1 3% 25-54 23 88% 55-61 0 3% 62+ 1 3% Unknown 1 3% Source: Riverside County 2022 Homeless Point in Time Count N. Income Profile A household’s income determines the affordability of housing and other life activities. When a household’s costs for housing and utilities consumes a large percentage of income, they are limited in their ability to increase housing size when needed or obtain access to amenities. Such limitations can become a fair housing issue. Though economic factors that affect housing choice are not a fair housing issue, some neighborhoods can become concentrated with poverty. For example, potential tenants can become victims of discrimination due to having lower incomes in various ways: stringent credit checks, flat denial due to fear of inability to pay, and more. i. Median Income As referenced in Table 16, the median household income for Palm Desert shows $64,295 for the 2020 American Community Survey. Between the years 2010 and 2020, the median household income increased by 13 percent. Table 16: Median Household Income (2010-2020) % Change 2010 2020 $56,897 $64,295 13.00% Sources: Census 2010, ACS 2016-2020 5-Year Estimates. For determining eligibility for assisted housing programs, which include Public Housing and the Section 8 Housing Choice voucher, the Department of Housing and Urban Development (HUD) sets income limits. Every year, HUD develops income limits based on the Median Family Income estimates and Fair Market Rent area definitions for each metropolitan area, parts of some metropolitan areas, and each non-metropolitan county. The table below lists the 2019 income limits issued by HUD for the limit income categories. 33 | Page Table 17: HUD Median Income Limits Median Family Income FY Income Limit Category Persons in Family 1 person 2 person 3 person 4 person 5 person 6 person 7 person 8 person $87,400 Extremely Low (0-30%) $18,500 $21,150 $23,800 $27,750 $32,470 $37,190 $41,190 $46,630 Very Low $30,800 $35,200 $39,600 $44,000 $47,550 $51,050 $54,600 $58,100 (30%-50%) $58,450 $66,800 $75,150 $83,500 $90,200 $96,900 $103,550 $110,250 Low Income (50% to 80%) $49,300 $56,350 $63,400 $70,400 $76,050 $81,700 $87,300 $92,950 Source; HUD User, 2022 Income Limit Area, Riverside County O. Low to Moderate Target Areas The City has two low to moderate target areas, census tracts where at least 51% of incomes are between zero to 80% of the Area Median Income. According to the American Community Survey’s 2016 to 2022, 9.3 percent of the population were found to live below poverty level in the City. Figure 5: Low to moderate income areas by census block groups. 34 | Page P. Income by Household Characteristic The table below illustrates that approximately 45 percent of the total households in the City are extremely low, very low and low income. Additionally, the number of low-income renters and owners are relatively comparable, both representing about an even split. Table 18: Household Income Owner Rental Total # % # % Extremely Low Income (0%-30%) 1,590 6.52% 1,875 7.69% 3,465 Very Low Income (30%- 50%) 1,455 5.96% 1,670 6.85% 3,125 Low Income (50%-80%) 2,325 9.53% 2,000 8.20% 4,325 Source: CHAS 2015-2019 i. Income by Race/Ethnicity As described earlier, of race, a group of persons related by common descent or heredity, is different from the definition of ethnicity, a social group that shares a common and distinctive culture, religion, language, or the like. In Table 19, data is analyzed to find percentages of the various incomes based on race/ethnicity. Between 2010 and 2020, the following race/ethnicity groups experienced the largest increase: Some Other Race, Black, Asian. Table 19: Median Household Income Per Race Race 2010 2020 % Change White $59,039 $65,087 10.24% Black $41,173 $65,469 59.01% Indian $34,583 $41,221 19.19% Asian $54,348 $72,917 34.17% Native Hawaiian $17,083 NA NA Some other race $30,361 $50,049 64.85% 2 or More Races $66,792 $78,648 17.75% Hispanic $42,368 $50,221 18.54% Source: 2016-2020 ACS 5-Year Estimates, 2006-2010 ACS 5-Year Estimates, Median Household Income In The Past 12 Months. Q. Racially or Ethnically Concentrated Areas of Poverty Federal regulations require grantees of HUD Community Planning and Development programs to identify and describe any areas within their jurisdictions that are concentrations of racial or ethnic minorities and low- income families. These areas are known as racially/ethnically concentrated areas of poverty (RCAPs and ECAPs). 35 | Page In order to analyze the RCAPs/ECAPs in Palm Desert at a meaningful geographic scale, data was collected for block groups. Low to moderate concentrations meeting the threshold of 51 percent of residents that are low income at the tract level could not be identified in the City. Block group data was collected from the 2016- 2020 American Community Survey 5-Year Estimates, which HUD currently uses for its most up-to-date low- to moderate-income designations. For the purpose of this analysis, racial minorities are all ACS respondents who identified as a race other than white, and ethnic minorities are all those who claimed Hispanic origins. The results showed there are no areas of Racially or Ethnically Concentrated Areas of Poverty. Table 20: RCAP/ECAP % Race/Ethnicity Per Block Group-51%or more LMI Tract Block Group % Racial Minority % Ethnic Minority Source: ACS 2016-2020 – No Data at this time R. Housing Profile An AI requires an assessment of several aspects of housing in the City. Such an assessment includes the condition of the existing housing stock, locating where and how segregation occurs due to race, ethnicity, disability, and families with children, and analyzing the cost of housing, both rental and units for sale. The amount and availability of housing accessible for persons with disabilities is also evaluated. i. Housing Growth Most housing development took place in the City between the middle of the 20th Century, as it did for the County. Increases in housing stock in the City have been modest in the last decade. The total number of housing units has increased by 5.94 percent since 2010. A lack of housing drives up housing costs making the City unaffordable to low-income households. Table 21: Housing Unit Growth 2010 2020 % Change (2010-2020) 36,868 39,058 5.94% Source: ACS 5-Year Estimates, 2016-2020, U.S. Census 2010. S. Housing Unit Type The housing stock in the City is primarily comprised of single-family homes (59%) increased slightly between 2010 and 2019. The stock of smaller multifamily units (2-4 unit dwellings) decreased 12% and larger multifamily homes increased 1%. Again, the City has had very little new housing units built in the last 20 years. 36 | Page Overall in the last 20 years the number of units in the City has increased by 4.5%, the population has increased 7.4%, the persons per household has increased 5% and the vacancy rate has only increased 1%. Table 22: Housing Characteristics 2010 2020 1-unit, SF detached 14,584 15,417 1-unit, SF attached 10,761 8,009 2 to 4 units 2,927 5,078 Five Plus units 4,912 7,476 Mobile home 3650 3078 Occupied units 23,041 24,335 Vacancy Rate 37.5% 37.7% Persons per Household 2.07 2.12 Total housing units 36,868 39,058 Source: US Census 2010, ACS 5-Year Estimates 2016-2020 T. Condition of Housing Units Conducting an assessment of the current condition of housing units can support the development of City policies and programs that will preserve existing housing stock. Housing preservation increases safety, neighborhood stability, and likelihood seniors are better able to age in place. In addition, housing constructed prior to 1978 may contain lead-based paint, which must be addressed before Federal programs can fund rehabilitation to such units. Table 23: Year Unit Built Year Unit Built Owner-Occupied Renter-Occupied Occupied Number % Number % Number % 2014 or later 466 2.96% 214 2.48% 680 2.79% 2010 to 2013 277 1.76% 245 2.84% 522 2.15% 2000 to 2009 1,727 10.99% 1020 11.84% 2,747 11.29% 1980 to 1999 7,437 47.31% 4,082 47.38% 11,519 47.34% 1960 to 1979 4,793 30.49% 2,584 29.99% 7,377 30.31% 1940 to 1959 908 5.78% 402 4.67% 1,310 5.38% 1939 or earlier 112 0.71% 68 0.79% 180 0.74% Total 15,720 100.00% 8,615 100.00% 24,335 100.00% 37 | Page Source: ACS 5-Year Estimates, 2016-2020. As shown in the table below, the majority of home building in the County as well as the City took place between the 1960s to 1990s. Homes in the City built 1979 and earlier totaled 12,330 and account for nearly 32 percent of total housing stock. Table 24: Year Unit Built- City v. County Year Unit Built City County Number % Number % 2014 or later 807 2.07% 27,162 3.21% 2010 to 2013 832 2.13% 24,528 2.90% 2000 to 2009 4,622 11.83% 214,458 25.38% 1980 to 1999 20,467 52.40% 311,586 36.87% 1960 to 1979 10,595 27.13% 183,408 21.70% 1940 to 1959 1,555 3.98% 65,896 7.80% 1939 or earlier 180 0.46% 18,028 2.13% Total 39,058 100.00% 845,066 100.00% Source: ACS 5-Year Estimates, 2016-2020 U. Lead-Based Paint Hazard Though lead based paint is a critical concern that identifies housing as substandard in the community, it presents conditions that can be corrected through rehabilitation. Projects funded by Federal programs must be tested for lead-based paint if they were constructed prior to 1978.20 Children under six years old are particularly vulnerable to negative effects of lead-based paint. For the long-term safety of a community, lead- based paint should be mitigated. Nearly 32 percent of housing stock in the City were built prior to 1978. V. Housing Tenure- Own Versus Rent and Vacant Units As defined by the U.S. Census Bureau, Housing Tenure refers to a unit that is owner occupied if the owner lives in the unit, even if it is mortgaged or not fully paid for. All other occupied units are classified as "renter occupied," including units rented for cash rent and those occupied without payment of cash rent. Tenure preferences are primarily related to household income, composition, and age of head of household.21 In some cases, renters experience violation of fair housing laws more frequently than owners due to a lack of proper oversight on the part of landlords and property managers. To make housing accommodations for various incomes and needs, a city must have both ownership and rental units in its housing supply. 20 US Department of Housing and Urban Development, “Making it Work - Reference Manual,” https://files.hudexchange.info/resources/documents/MakingItWorkReferenceManual.pdf. 21 Joint Center for Housing Studies of Harvard University, The State of the Nation’s Housing 2019, Harvard Graduate School of Design, Harvard Kennedy School, 2019, 17-18, 21. 38 | Page Table 25: Household Tenure – Owner v. Renter Households 24,335 100.00% Owner-Occupied 15,720 64.60% Renter-Occupied 8,615 35.40% Source: 2016-2020 ACS 5-Year Estimate Table 26: Housing Unit Tenure Comparison Tenure Type 2010 2020 # of Units Percent # of Units Percent Rental 7,159 19.42% 8,615 22.06% Owner Occupied 15,882 43.08% 15,720 40.25% Vacant 13,827 37.50% 14,723 37.70% Total 36,868 100.00% 39,058 100.00% Source: 2006-2010 and 2016-2020 ACS 5-Year Estimates The table below indicates that homes with a higher number of bedrooms are occupied by homeowners the number of owners of four-bedroom units is seven times that of renters. A higher number of small units, no bedroom and one-bedroom units, are occupied by renters. Table 27: Unit Size by Tenure Owners Renters Number % Number % No bedroom 44 0.28% 520 6.04% 1 bedroom 163 1.04% 2,210 25.65% 2 or 3 bedrooms 13,299 84.60% 5,561 64.55% 4 or more bedrooms 2,214 14.08% 324 3.76% Total 15,720 100.00% 8,615 100.00% Source: ACS Community Survey 5-Year Estimates, 2016-2020 W. Housing Costs Affordable housing provides stability, allowing for budgeting for other life necessities, such as food, healthcare, transportation, and the ability to contribute to the local economy.22 When housing costs are too high, there is 22 Enterprise Community Partners, Inc., Knowledge, Impact and Strategy Department Impact of Affordable Housing on Families and Communities: A Review of the Evidence Base, Enterprise:3. 39 | Page cost burden occurs, creating instability for the household. This section summarizes cost and affordability for the City. Table 28 shows a 6 percent decrease in the cost of purchasing a home in the City, however there has been a 17 percent increase in the cost of renting a home. Median income has increased 13 percent between 2010 and 2020. Table 28: Changes in Value, Rent, and Income 2010 2017 % Change Median Housing Value $384,300 $361,200 -6.0% Median Gross Rent $1,160 $1,353 16.6% Median Household Income $56,897 $64,295 13.0% Source: 2006-2010 ACS 5-Year Estimates, 2016-2020 ACS 5-Year Estimates Table 29: Housing Sale Prices (2021 and 2022) Units Sold in 2021 Median Sale Price December 2021 Units Sold in 2022 Median Sale Price December 2022 % Change City SF Homes 1,105 $697,500 756 $640,000 -8.2% Condos/Towns 1,265 $460,500 808 $508,440 10.4% Source: 2021, 2022 Sales Report, reported by Redfin The high cost of home ownership makes it prohibitive for low-income households to purchase housing in the City. As shown below, affordable rent for a four-person household with low income, earning $70,400 annually is $1,760 per month. However, according to recent data from Rent.com, the average rent for a two bedroom is $2,602. The affordability gap is over $800 per month. Table 30: Average Rental Housing Prices Studio 1-Bedroom 2-Bedroom 3-Bedroom 4+Bedrooms City $729 $974 $1,307 $1,691 $2,082 County $861 $944 $1,205 $1,532 $1,946 Sources: ACS 5-Year Estimates, 2016-2020 Table 31: Housing Affordability (2019) Affordable Mortgage/Rent Amounts 1 Person 2 Persons 3 Persons 4 Persons Extremely Low (0%-30%) Annual Income $18,500 $21,150 $23,800 $27,750 Monthly Income $1,541.00 $1,762.00 $1,983.00 $2,312.00 Affordable Purchase Price $101,000.00 $115,000.00 $130,000.00 $151,000.00 40 | Page Affordable Monthly Rent $462.50 $528.75 $595.00 $693.75 Very Low (30%-50%) Annual Income $30,800 $35,200 $39,600 $44,000 Monthly Income $2,566.00 $2,933.00 $3,300.00 $3,666.00 Affordable Purchase Price $168,000.00 $192,000.00 $216,000.00 $240,000.00 Affordable Monthly Rent $770.00 $880.00 $990.00 $1,100.00 Low (50%-80%) Annual Income $49,300 $56,350 $63,400 $70,400 Monthly Income $4,108.00 $4,695.00 $5,283.00 $5,866.00 Affordable Purchase Price $269,000.00 $308,000.00 $347,000.00 $385,000.00 Affordable Monthly Rent $1,232.50 $1,408.75 $1,585.00 $1,760.00 Moderate (80%-120%) Annual Income $73,920 $84,480 $95,040 $105,600 Monthly Income $6,160.00 $7,040.00 $7,920.00 $8,800.00 Affordable Purchase Price $353,000.00 $404,000.00 $454,000.00 $467,000.00 Affordable Monthly Rent $1,848.00 $2,112.00 $2,376.00 $2,640.00 Source: 2022 HUD Income Limit. Note: Affordable Monthly Rent = (HH income * .3)/12 Assumptions: 30% gross household income as affordable housing cost; includes monthly affordable cost for taxes and insurance; 10% down payment; and 4.0% interest rate for a 30-year fixed-rate mortgage loan; https://smartasset.com/mortgage/how-much-house-can-i-afford#PCGmA6nHyA Table 32: Fair Market Rent- Riverside-San Bernardino-Ontario, CA 2022 2023 Efficiency $1,062 $1,281 1 bedroom $1,202 $1,398 2 bedroom $1,509 $1,751 3 bedroom $2,065 $2,376 4 bedroom $2,542 $2,922 Source: HUD 2022 and 2023 Fair Market Rent, https://www.huduser.gov/portal/datasets/fmr/fmrs/FY2022_code/2022summary.odn Table 33: Affordable Rental Housing Units in Palm Desert Units 2010 2020 # % # % Less than $500 640 9.19% 413 4.97% $500-$999 1,968 28.26% 1,519 18.27% $1,000-$1,499 2,626 37.70% 3,373 40.58% $1,500 or more 1,731 24.85% 3,008 36.18% Total 6,965 100.00% 8,313 100.00% Source: 2006-2010 ACS and 2016-2020 ACS 5-Year Estimates 41 | Page X. Housing Problems Quality of life the standard of health, comfort, and happiness experienced by an individual or group is a community’s highest priority. HUD assesses housing need within a community according to several criteria: (1) the number of households that are paying too much for housing; (2) the number of households living in overcrowded units; and (3) the number of households living in substandard housing conditions. An analysis of housing problems assesses whether groups of persons, based on race, color, religion, national origin, sex, familial status, or disability, experience greater housing needs when compared to other populations the City. An assessment of cost burden, severe cost burden, overcrowding, and substandard housing is a necessary analysis in order to set goals and priorities, and develop strategies to address barriers to fair housing choice. CHAS data provides further details on housing cost burden and overcrowding. These conditions are discussed below. Housing affordability is measured in terms of the percentage of income spent on housing costs. Over the past decades 30% of income spent on housing is the accepted indicator of affordable housing costs.23 HUD defines cost burden as monthly housing costs (including utilities) exceeding 30% of monthly income; severe cost burden is defined as monthly housing costs (including utilities) exceeding 50% of monthly income. i. Cost Burden According to the federal government, cost burden is the fraction of a household’s total gross income spent on housing costs. A cost burden of 30 to 50% is considered a moderate burden; payment in excess of 50% of income is a severe cost burden. Cost burden is an important housing issue because paying too much for housing leaves less money available for basics such as food and living expenses as well as for emergency expenditures. According to the most recent CHAS data, 5,545 renter households and 5,370 owner households earned less than 80% of the area median income (AMI) in the City. Of these, 1,875 renter households and 1,590 owner households fell into the extremely low-income category (incomes less than 30% of AMI). Table 34 shows that renters experience cost burden at higher rate than owners at all levels of cost burden. However, 4,965 households suffer from severe cost burden, accounting for approximately 20 percent of total households in the City; and an additional 19 percent of the total households experience cost burden between 30 and 50%. Table 34: Housing Cost Burden Overview Cost Burden Factor Owner Renter Total # % # % Cost Burden > 30% 5,105 33% 4,540 50% 9,645 Cost Burden >30% to <=50% 2,450 16% 2,230 25% 4,680 Cost Burden > 50% 2,655 17% 2,310 25% 4,965 Source: CHAS 2015-2019, https://www.huduser.gov/portal/datasets/cp.html 23 Defining Housing Affordability, PD&R Edge Home, under HUD User, https://www.huduser.gov/portal/pdredge/pdr-edge-featd-article-081417.html. 42 | Page As listed in Table 35, 2,740 of the City’s residents that are extremely low income experience and are cost burdened and 2,370 experience severe cost burden. Approximately 39 percent of all homeowners and renters combined living in the City experience cost burden issues. Table 35: Income by Cost Burden (Owners and Renters Combined) Cost Burden > 30% Cost Burden > 50% Total # % # % Extremely Low Income (0% - 30%) 2,740 79.08% 2,370 68.40% 3,465 Very Low Income (30%-50%) 2,330 74.56% 1,445 46.24% 3,125 Low Income (50%-80%) 2,555 59.08% 855 19.77% 4,325 Source: CHAS 2015-2019, https://www.huduser.gov/portal/datasets/cp.html Table 36: Income by Cost Burden - OWNERS Cost Burden > 30% Cost Burden > 50% Total # % # % Extremely Low Income (0% - 30%) 1,220 76.73% 1,085 68.24% 1,590 Very Low Income (30%-50%) 1,060 72.85% 675 46.39% 1,455 Low Income (50%-80%) 1,205 51.83% 665 28.60% 2,325 Source: CHAS 2015-2019, https://www.huduser.gov/portal/datasets/cp.html. Table 37: Income by Cost Burden - RENTERS Cost Burden > 30% Cost Burden > 50% Total # % # % Extremely Low Income (0% - 30%) 1,520 81.07% 1,285 68.53% 1,875 Very Low Income (30%-50%) 1,270 76.05% 770 46.11% 1,670 Low Income (50%-80%) 1,350 67.50% 190 9.50% 2,000 Source: CHAS 2015-2019, https://www.huduser.gov/portal/datasets/cp.html. ii. Overcrowding Households having more than 1.01 to 1.5 persons per room are considered overcrowded and those having more than 1.51 persons per room are considered severely overcrowded. The person per room analysis excludes bathrooms, porches, foyers, halls, or half-rooms. The City experiences a 1.4 percent rate of overcrowding for owner-occupied households. Renter-occupied households have a much higher rate of overcrowding at 7.1 percent. 43 | Page Table 38: Overcrowding Household Tenure Owner-Occupied Renter-Occupied Occupied Units 15,720 8,615 Overcrowded 224 611 Severely Overcrowded 62 284 Percent Overcrowded 1.4% 7.1% Source: American Community Survey (ACS), 2016-2020 Notes: 1. Overcrowded: (1+ occupants per room) 2. Severely Overcrowded (1.5+ occupants per room) iii. Substandard Housing There are two types of substandard housing problems: 1. Households without hot and cold piped water, a flush toilet and a bathtub or shower; and 2. Households with kitchen facilities that lack a sink with piped water, a range or stove, or a refrigerator. According to 2025-2019 CHAS data, 145 low income renter households experience substandard Housing - Lacking complete plumbing or kitchen facilities. Of low-income homeowners, 0 experience substandard housing. Overall, more renters experience substandard housing than homeowners. Table 39: Housing Problems (Households with one of the listed needs) Renter Households Owner Households 0-30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Total 0-30% AMI >30-50% AMI >50-80% AMI >80-100% AMI Total Substandard Housing - Lacking complete plumbing or kitchen facilities 45 15 85 0 145 0 0 0 0 0 Source: CHAS 2015-2019 Y. Public Housing & Housing vouchers The Housing Authority of Riverside County (HACR) provides rental assistance to extremely low- and very low- income households. The federal Section 8 Housing Choice Voucher (HCV) Program provides rental assistance to very low-income households for housing. Eligible tenants pay 30% to 40% of their adjusted monthly income toward the rent 44 | Page and utilities. As an example, a family who earns $600 per month pay roughly $180 for a month’s rent. The program is open to families and individuals. Preference is given to families and disabled and elderly persons over other singles. Housing data available indicates that the agency assists approximately 8,500 families with Housing Choice Vouchers in Riverside County. Of those families, 125 families have been assisted in the City of Palm Desert. See Table 40 for details regarding households using the HCV program. Table 40: Housing Choice Vouchers (Riverside County) Housing Choice Vouchers Number of Families on Waiting List 68,000 Extremely Low Income (0-30% AMI) 6,375 Very Low Income (31-50% AMI) 2,125 Low Income (51-80% AMI) Not Available Families with Children Not Available Elderly Families Not Available Families with Disabilities Not Available Veterans Not Available Race: White Not Available Black Not Available Asian Not Available American Ind/Native Hawaiian Not Available Unknown/Multiple Not Available Hispanic Not Available Source: Housing Authority County of Riverside, (2023). Note: AMI Public Housing Income Limits: At HUD’s 80% Area Median Incomes (AMI) i. Assisted Housing It is advised by HUD that program participants should consider a balanced approach when setting goals for overcoming the effects of contributing factors and related fair housing issues. A balanced approach may include, but is not limited to, undertaking place-based solutions to improve areas, as well as pursuing options to increase mobility for protected classes, as appropriate. Place-based strategies may include but are not limited to: (1) economic development and investments in high poverty neighborhoods that will improve conditions and thereby reduce disparities in access to opportunity between impacted neighborhoods and the rest of the jurisdiction; and (2) efforts to maintain and preserve the existing affordable rental housing stock, including HUD assisted housing, to help respond to the overwhelming need for affordable housing. The City’s 15 assisted housing properties, Table 41, are owned and operated by the Housing Authority, which provides 376 units for senior, very low, low, and moderate-income housing in efforts to continue to address the needs of its residents. 45 | Page Table 41: Assisted Housing Project Type Affordable Units Total Units Program One Quail Place Family 382 38 Palm Desert Housing Authority Desert Pointe Family 62 64 Palm Desert Housing Authority Neighbors Garden Apartments Family 23 24 Palm Desert Housing Authority Taos Palms Family 16 16 Palm Desert Housing Authority California Villas Family 139 141 Palm Desert Housing Authority Laguna Palms Family 47 48 Palm Desert Housing Authority Palm Village Apartments Family 35 36 Palm Desert Housing Authority Santa Rosa Apartments Family 19 20 Palm Desert Housing Authority The Pueblos Senior 15 15 Palm Desert Housing Authority Catalina Gardens Senior 71 72 Palm Desert Housing Authority Las Serenas Apartments Senior 149 150 Palm Desert Housing Authority Candlewood Apartments Senior 29 30 Palm Desert Housing Authority La Rocca Villas Senior 26 27 Palm Desert Housing Authority 46 | Page Carlos Ortega Villas Senior 72 73 Palm Desert Housing Authority Source: Housing Element of City of Palm Desert, 2021-2029. Z. Access to Opportunities Housing choice greatly depends on location, not only affordability. Adequate access to jobs and schools is imperative to households to function well in the local economy. Adequate public transportation, which includes easy and safe access to bus shelter, for example, may be required for some individuals and families to obtain access to jobs and schools. i. Public Transit SunLine Transit Agency provides routes of bus service that serve the Coachella Valley. The service area includes Palm Desert, Coachella, Bermuda Dunes, Indian Wells, Cathedral City, North Shore, and Palm Springs. Route 1WV, Route 1EV, Route 4, Route 5, and Route 6 serve Palm Desert Mall. See the system map below. 47 | Page Figure 6: SunLine Transit Agency service system map, 2023. AA. Major Employers According to the City’s Economic Development Department, employer locations are spread out through the City. For the purpose of this report, a major employer is defined as one with 500 or more employees. 48 | Page Table 42: Top Employers Number of Employees JW Marriot-Desert Springs Resort and Villas 2,304 Universal Protection Services 1,500 Securitas-Security Service USA 700 Organization of Legal Pro's 501 Sunshine Landscape 500 Costco Wholesale 250 Bighorn Golf Club 250 Whole Foods Market 150 Source: City of Palm Desert, Housing Element 2021-2029 Table 43: Workforce by Industry # of Total Industry % Share Median earnings Agriculture, forestry, fishing and hunting, and mining 349 1.77% $60,900 Construction 1,799 9.10% $62,529 Manufacturing 594 3.00% $70,385 Wholesale trade 568 2.87% $101,310 Retail trade 2,494 12.61% $34,861 Transportation and warehousing, and utilities 423 2.14% $69,688 Information 441 2.23% $43,397 Finance and insurance, and real estate and rental and leasing 1,829 9.25% $46,625 Professional, scientific, and management, and administrative and waste management services 2,543 12.86% $61,984 Educational services, and health care and social assistance 3,667 18.55% $60,940 49 | Page Arts, entertainment, and recreation, and accommodation and food services 3,374 17.06% $36,742 Other services, except public administration 1,049 5.31% $34,038 Public administration 643 3.25% $99,404 Total 19,773 100.00% Source: 2016-2020 ACS 5-Year Estimate Industry by Occupation for the Civilian Employed Population 16 Years and Older INDUSTRY BY SEX AND MEDIAN EARNINGS IN THE PAST 12 MONTHS (IN 2020 INFLATION-ADJUSTED DOLLARS) FOR THE Full-Time CIVILIAN EMPLOYED POPULATION 16 YEARS AND OVER BB. Public Schools The Palm Desert area is serviced by two school districts: Palm Springs Unified and Desert Sands Unified. See below for the boundary map. 50 | Page Figure 7: Palm Desert Unified School District boundary map 51 | Page IV. Public Policies A potential barrier to housing opportunities can be related to public policies. Such policies include tax policy, land use controls, zoning ordinances, building codes, fees and charges, growth limits, and other policies that affect the return on residential investment. Amending local zoning and land use laws or allocating funding for affordable housing through grants are mechanisms that can support the development of affordable units. Changes in policies can also help a community to overcome disparities in access to opportunity by the implementation of plans that will revitalize areas with existing affordable housing by improving services, schools and other community assets, sidewalks, and other infrastructure. Policies to guide future development and achieve a vision for the community are contained in the City’s General Plan. Two of the seven State mandated General Plan elements – Housing and Land Use Elements – have direct impact on the local housing market in terms of the amount and range of housing choice. The Zoning Ordinance, which implements the Land Use Element, is an important document that influences the amount and type of housing available in a community – the availability of housing choice. A. The Housing Element As part of evaluating potential impediments to fair housing choice and housing development, the City of Palm Desert’s Housing Element was reviewed. State law requires that each local government develop a general plan as a guide for future development and must include seven elements. A Housing Element is one of the seven required elements. The Housing Element is also required by the State of California’s Housing-Element Law. The purpose of the housing element is to assess the need for housing for all levels of income and establish policies to meet those needs. The policies should include the identification of sites to accommodate low- income units as well as programs geared to provide housing for low-and moderate-income residents. The Housing Element is updated and is valid for a four-year planning period. The purpose of the housing element is to identify the community’s housing needs, state the community’s goals and objectives regarding housing production, rehabilitation, and conservation to meet those needs. It also defines the policies and programs to be implemented to achieve the stated housing goals and objectives. Part of the Housing Element includes city-wide assessments that includes an analysis of population and employment trends and projections, as well as an analysis of any special housing needs for the elderly, persons with disabilities, large families, farmworkers, families with female heads of households, and families and persons in need of emergency shelter. Housing characteristics, which include issues such as overcrowding and current housing stock conditions are also analyzed. California housing element law requires each jurisdiction to: • Identify adequate sites which will be made available through appropriate zoning and development standards and with the services and facilities needed to facilitate and encourage the development of a variety of types of housing for all income levels in order to meet the city’s regional housing needs. • Assist in the development of adequate housing to meet the needs of extremely low-, very low-, low-, and moderate-income households. • Address and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing. • Conserve and improve the condition of the existing affordable housing stock. • Promote housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability. 52 | Page B. Land Use Policies and Practices The City’s existing Development Code regulates the type, location, density, and scale of residential development and exists to protect and promote the health, safety, and general welfare of residents. In addition, the Development Code serves to preserve the character and integrity of existing neighborhoods. The City periodically evaluates local zoning laws and policies that may affect fair housing choice. C. Zoning for Housing The City’s General Plan is implemented by the Zoning Ordinance. Development standards and permitted uses in each zoning district are specified to govern the density, type, and design of different land uses for the protection of public health, safety, and welfare. The Zoning Ordinance can have the effect of restricting the development of certain types of housing, such as housing of higher densities, emergency shelters, or supportive/transitional housing. i. Residential Density The Residential Density Summary provided is derived from the City’s Land Use Element (Table 2), Land Use Plan Classifications. The highest allowed density permitted by right, is 162 dwelling units per acre. ii. Residential Care Facilities Residential Care Facilities are for the Elderly (RCFE) and serve persons ages 60 and older. They provide room, board, housekeeping, supervision, and personal care assistance with basic activities like personal hygiene, dressing, eating, and walking. There are seven senior apartment projects in the City which are owned and operated by the Housing Authority, providing 376 units for very low-, low- and moderate-income senior households. Nursing care facilities in the City include the Carlotta, with 192 beds; Manorcare Health Services, with 178 beds; and Monterey Palms, with. 99 beds. Numerous senior communities are located in the City, including Atria Palm Desert, Atria Hacienda, Segovia, Palm Desert Senior Living Oahu Cottage, and Fountains at the Carlotta, Legend Gardens, which provide a range of services including medical transport, assistance with housekeeping and personal care, hospice and dementia care, and onsite recreational and social opportunities. iii. Emergency Shelters Emergency shelters provide temporary housing with supportive services for homeless persons and families. Occupancy is limited to six months or less by persons experiencing homelessness. Under Health and Safety Code Section 50801[e], no individual or household may be denied emergency shelter because of an inability to pay. State law requires jurisdictions to identify adequate sites for housing which will be made available through appropriate zoning and development standards to facilitate and encourage the development of a variety of housing types for all income levels, including emergency shelters and transitional housing (Government Code Section 65583[c][1]). State law (SB 2) requires local jurisdictions to calculate the need for shelter, to identify a zone where shelters are allowed without discretionary review, and to limit application of development standards for shelters to those that are applied to other development in the same zone, with the exception of objective, written standards allowed in 8 specific categories. The City permits homeless shelters in the Service Industrial (SI) zone. The City currently has no requirement for parking for emergency shelters. AB 139 requires that parking be provided for employees of emergency shelters. Program 5. 1). requires that the City add this requirement to the Zoning Ordinance in 2021- 2022, as part of its annual Zoning Ordinance update. iv. Transitional and Supportive Housing 53 | Page Transitional housing serves persons waiting for secure housing. This type of housing is known as “bridge” or “interim housing.” State law (Senate Bill No. 2- Local Planning) requires local jurisdictions to address the provisions for transitional and supportive housing. Under Housing Element law, (California Government Code Section 65582(h)), transitional housing is defined as buildings configured as rental housing developments but operated under program requirements that require the termination of assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance. Pursuant to SB 2, transitional housing constitutes a residential use and therefore local governments cannot treat it differently from other types of residential uses (e.g., requiring a use permit when other residential uses of similar function do not require a use permit). The City permits homeless shelters in the Service Industrial (SI) zone and transitional and supportive housing in all residential zones. Program 5. D commits the City to bring its Zoning Ordinance in compliance with AB 101 for Low Barrier Navigation Center requirements on homeless shelters, and AB 139 for parking requirements at homeless shelters. The City allows transitional and supportive housing in all residential districts subject to only those restrictions that apply to other residential uses the same type in the same zone. The General Plan allows for an additional 8, 049 residential units on 610 acres of vacant land in the City, in a range of densities, which will accommodate the City' s need for transitional and supportive housing. v. Supportive Housing Supportive Housing has no limit on length of stay, is occupied by the target population, and is linked to health and social services that assist the resident in retaining the housing, improving his or her health status, and maximizing the ability to live in the community. Target population means persons with low incomes who have one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health condition, or individuals eligible for services provided pursuant to the Lanterman Developmental Disabilities Services Act (Division 4.5 (commencing with Section 4500) of the Welfare and Institutions Code) and may include, among other populations, adults, emancipated minors, families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, and homeless people (California Government Code Sections 65582(f) and (g)). Currently, a number of other organizations provide shelter and services to the homeless throughout the Coachella Valley ( see Table III-33 for a list of available homeless facilities in the Coachella Valley). Shelter from the Storm, which provides comprehensive services to victims of domestic violence in the Valley, operates its administrative offices in the City. Desert Horizon and Desert Vista permanent supportive housing is a program in the western Coachella Valley managed by Jewish Family Service of San Diego with 18 and 40 beds, respectively. Supportive services, including living skills, budgeting instruction, case management, employment assistance, food , distributions, advocacy, and community referrals and access to benefits, are provided. vi. Single-Room Occupancy (SRO) Assembly Bill 2634 amending the State Housing Element law mandates that local jurisdictions address the provision of housing options for Extremely Low-income households. Single Room Occupancy (SRO) units are small, one room units intended for occupancy by a single individual. California Housing and Community Development (HCD) considers SRO units to be a suitable housing type to meet the needs of Extremely Low- income individuals. It is distinct from a studio or efficiency unit in that each is a one-room unit that must contain a kitchen and bathroom. Although SRO units are not required to have a kitchen or bathroom, many SROs have one or the other. SRO units are one of the most traditional forms of affordable private housing for lower income individuals, including seniors and persons with disabilities. These protected classes are required to have suitable housing options and SROs provide these options. Currently, more than 28% of the units within the City -owned affordable housing portfolio are designated for extremely low-income households. SROs are permitted in the SI zoning district with a Conditional Use Permit. ADUs are permitted in the RE, R- 1, R-2, R-3, HPR, and PR zoning districts. G 54 | Page vii. Employee Housing The California Employee Housing Act requires that housing for six or fewer employees be treated as a regular residential use. The Employee Housing Act further defines housing for agricultural workers consisting of 36 beds or 12 units as an accessory agricultural use in agricultural zones, subject to the same permit process as the primary agricultural use. Because there is a small number of persons employed in agricultural-related industries, the City can address the needs of the farm worker population through its affordable housing programs. Persons identified in the City as having agricultural jobs are most likely employed at ancillary uses to agriculture thus are not anticipated to have seasonal housing needs. viii. Reasonable Accommodation Under State and Federal law, local governments are required to “reasonably accommodate” housing for persons with disabilities when exercising planning and zoning powers. Jurisdictions must grant variances and zoning changes if necessary, to make new construction or rehabilitation of housing for persons with disabilities feasible. ix. Permitting Process There are different permitting procedures and timelines for development of different housing types. The table below lists the permitting process for the City. The permitting process, if not efficient, can become expensive and time consuming for developers. Costs from development review is typically passed on to the property owner/developer, making housing more costly. As a pro-development city, staff works with developers on reaching mutually beneficial solutions. Table 44 : Processing Times Project Type Reviewing Body Public Hearing Required Appeal Body Est. Total Processing Time Single-Family Subdivision Community Yes-Planning Commission City Council 2-3 months Multiple-Family (2-3 units) Community Not Required Planning Commission Less than 2 months Multiple-Family (4+ units Community Yes-Planning Commission City Council 2-3 months Multiple-Family (with subdivisions) Community Development Yes-Planning Commission City Council 2-3 months Mixed Use Community Development Yes-Planning Commission City Council 2-3 months Table 44: Processing Times D. Development Incentives The City’s Zoning Ordinance allows for a density bonus program as an incentive for the residential development of affordable housing. Government Code Section 65915 requires that a local government grant a density bonus and one additional incentive to a developer of affordable dwelling units, or other incentives of equivalent financial value. The City shall grant one density bonus, with concessions or incentives, as specified in Section 25.34.040.D (number and types of density bonuses and incentives and concessions allowed), when the 55 | Page applicant for the residential development seeks and agrees to construct a residential development, excluding any units permitted by the density bonus awarded pursuant to this article, that will contain at least one of the following. The applicant shall specify which of the following is the basis for the density bonus. a) 10 percent of the total units of a housing development for lower-income households. b) 5 percent of the total units of a housing development for very low-income households. c) A senior citizen housing development or age-restricted mobile home park. d) 10 percent of the total dwelling units in a common interest development as defined in California Civil Code Section 1351 for persons and families of moderate income, provided that all units in the development are offered to the public for purchase. Table 45: Units Required to be Affordable Income Level Percent of the units shall be reserved by income level Lower income 10% Very low income 5% Moderate income 10% Qualifying residents <70% E. Regional Housing Needs Allocation (RHNA) Palm Desert’s Regional Housing Needs Allocation (RHNA) for the planning period has been determined to be 2,790 housing units with 337 units for extremely low income, 338 units for very low income, 460 units for low income, 461 units for moderate income, and 1,194 units for above moderate income. The table below is derived from the Housing Element and includes a list of sites the City has determined suitable for new residential development. Table 46: Residential Development Potential on Underutilized Sites Sites Acreage Allowable Density Realistic Density Potential Units Regional Retail 15 of 64.26 10 to 15 14 200 Town Center Neighborhood 8.43 22 20 169 Town Center Neighborhood 2.52 22 20 50 Town Center Neighborhood 16.32 22 20 326 Total 42.27 81 74 745 56 | Page F. Equal Housing Opportunity The City strives to support the housing needs of all members of the community, regardless of religion, sex, family size, marital status, ancestry, national origin, color, age, or physical disability. Through the Housing Rights Center, with whom the City contracts, the City provides fair housing law education and awareness of the potential of housing discrimination. The Housing Rights Center also investigates cases of housing discrimination. 57 | Page V. Lending Practices Lending practices is a contributing factor to fair housing choice because of the financial purchasing power it provides through loans. Lending is often needed to access credit financing to pay for the house mortgage and home repair loans. Conscious and unconscious bias from lenders can unfairly prevent members of some groups from accessing this financial support which affects individuals’ overall access to housing and wealth accumulation. This chapter of the AI focusses on the City of Palm Desert’s effort to determine and evaluate the lending practices within their own city. This includes analyzing the policies and practices that real estate agents, property managers, and mortgage lenders follow. A. Laws Governing Lending Discussed below are laws that govern lending practices. These laws are designed to protect consumers, support local economies, prohibit housing discrimination, and protect fair housing law. Additionally, banks are rated on their performances and this information is made available to the public. i. Community Reinvestment Act (CRA) The Community Reinvestment Act (CRA) was enacted in 1977 and requires the Federal Reserve and other federal banking regulators to encourage financial institutions to help members of the community in low- and moderate-income (LMI) neighborhoods meet their credit needs. B. Banking Regulators for the CRA There are three federal banking agencies, or regulators, that are responsible for the CRA. Banks that have CRA obligations are supervised by one of these three regulators. Each regulator has a dedicated CRA site that provides information about the banks they oversee and those banks' CRA ratings and Performance Evaluations. • Federal Deposit Insurance Corporation (FDIC) • Federal Reserve Board (FRB) • Office of the Comptroller of the Currency (OCC) C. Federal Reserve’s Role The Federal Reserve supervises state member banks or state-chartered banks that have applied for and have been accepted to be part of the Federal Reserve System for CRA compliance. To carry out its role, the Federal Reserve does the following: • Examine state member banks to evaluate and rate their performance under the CRA; • Consider banks' CRA performance in context with other supervisory information when analyzing applications for mergers, acquisitions, and branch openings; and • Share information about community development techniques with bankers and the public. Figure 8 below shows the rating of banks from the CRA for the City of Palm Desert. An institution’s CRA Rating is assigned using a four-tiered rating system and is updated quarterly. These ratings are: Outstanding, Satisfactory, Needs to Improve, and Substantial Noncompliance. All banks rated by CRA in the City of Palm Desert received a rating of “satisfactory” except for one bank called Firstbank, N.A., which received a rating of “outstanding” and has an asset size of $47,400. 58 | Page Source: Federal Financial Institutions Examination Council, Interagency CRA Rating Search for Palm Desert, CA, https://www.ffiec.gov/craratings/ (Accessed January 24, 2023) D. Home Mortgage Disclosure Act (HMDA) The Home Mortgage Disclosure Act (HMDA) was enacted by Congress in 1975 and is implemented by Regulation C. HMDA requires many financial institutions to maintain, report, and publicly disclose loan-level information about mortgages. This data helps show whether lenders are serving the housing needs of their communities; provides public officials information that helps them make decisions and policies; and sheds light on lending patterns that could be discriminatory. The public data are modified to protect applicant and borrower privacy. E. Equal Credit Opportunity Act Issued by the Bureau of Consumer Financial Protection (Bureau), this law applies to creditors to promote the availability of credit to all creditworthy applicants without regard to race, color, religion, national origin, sex, marital status, or age, to the fact that all or part of the applicant's income derives from a public assistance program, or to the fact that the applicant has in good faith exercised any right under the Consumer Credit Protection Act. of any of these factors and requires creditors to notify applicants of action taken on their applications; to report credit history in the names of both spouses on an account; to retain records of credit applications; to collect information about the applicant's race and other personal characteristics in applications for certain dwelling-related loans; and to provide applicants with copies of appraisal reports used in connection with credit transactions. F. Types of Loans Conventional financing involves market-rate loans provided by private lending institutions such as banks, mortgage companies, savings and loans, and thrift institutions. To assist lower and moderate-income households that may have difficulty in obtaining home mortgage financing in the private market, several government agencies offer loan products that have below market rate interests and are insured (“backed”) by the agencies. G . G overnment Backed Loans Figure 8: CRA Rating for the City of Palm Desert 59 | Page Many approved loans are government back loans. There are different types of government backed loans. These loans include Federal Housing Administration (FHA) loans, Veterans Administration (VA) loans, and the Rural Housing Services/Farm Service Agency (RHA/FSA). The State of California has its own set of loan programs for low- and moderate- income households. i. Federal Housing Administration Loans from the Federal Housing Administration (FHA) loans have been helping people become homeowners since 1934. The Federal Housing Administration (FHA) - which is part of HUD - insures the loan, so your lender can offer you a better deal with regards to: • Low down payments • Low closing costs • Easy credit qualifying ii. State of California’s Government Loan Programs The California Housing Finance Agency (CalHFA) offers several different types of government and convention loans which are the following: • CalHFA FHA Loan Program – This program is an FHA-insured loan featuring a CalHFA 30-year fixed interest rate first mortgage. • CalPLUS FHA Loan Program – This program is an FHA-insured first mortgage with a slightly higher 30-year fixed interest rate than the standard FHA program and is combined with the CalHFA Zero Interest Program (ZIP) for closing costs. • CalHFA VA Loan Program – This is a VA-insured loan featuring a CalHFA fixed interest rate first mortgage. This loan is a 30-year fixed interest rate first mortgage. • CalHFA USDA Program – This is a USDA Guaranteed first mortgage loan program, which can be combined with the MyHome Assistance Program (MyHome). This loan is a 30-year fixed interest rate first mortgage. H. VA Home Loans Veterans Administration loans (VA) helps Service members, veterans, and eligible surviving spouses become homeowners. The VA loans provide a home loan guaranty benefit and other housing-related programs to help Service members buy, build, repair, retain, or adapt a home for their own personal occupancy. VA Home Loans are provided by private lenders, such as banks and mortgage companies. VA guarantees a portion of the loan, enabling the lender to provide you with more favorable terms. I. Rural Housing Services/Farm Service Agency (RHA/FSA) FSA/RHS-guaranteed USDA’s Rural Housing Service offers a variety of programs to build or improve housing and essential community facilities in rural areas. They provide loans, grants and loan guarantees for single- and multi-family housing, childcare centers, fire and police stations, hospitals, libraries, nursing homes, schools, first responder vehicles and equipment, housing for farm laborers. The FSA/RHS also provides technical assistance loans and grants in partnership with non-profit organizations, Native American tribes, state and federal government agencies, and local communities. J. Conventional Loans 60 | Page A conventional loan is a mortgage that is not sponsored by government but is available through a private lender. Conventional loans make up for most mortgages issued. Some conventional loans must meet the requirements of Fannie Mae and Freddie Mac, the two largest buyers of mortgage loans in the United States. Studies of conventional loans in HMDA data have shown that commercial banks and thrift institutions lend less to areas (or tracts) that are low-income and predominantly minority concentrated. Such practices have the potential to constitute discrimination and are known as redlining. The practice of redlining is a barrier to fair housing. The State of California’s CalHFA provides two types of conventional loans which are listed below: • CalHFA Conventional Loan Program – This is first mortgage loan insured through private mortgage insurance on the conventional market. The interest rate on the CalHFA Conventional is fixed throughout the 30-year term. • CalPLUS Conventional Loan Program – This program is a conventional first mortgage with a slightly higher 30-year fixed interest than the standard conventional program and is combined with the CalHFA Zero Interest Program (ZIP) for closing costs. K . Lending Findings In analyzing the data, several findings revealed implications of potential impediments to fair housing. This section reviews lending practices of financial institutions and financing allowed to all households but with an emphasis on lending to minority and low-income households. However, a jurisdiction’s control over lending is limited due to federal laws and regulations. Data used in this analysis are taken from the 2021 National HMDA- LAR published by the Federal Financial Institutions Examination Council. Table 47 below lists the loans by type, number of applicants, and percentage of applicants. Nearly all applicants are applied for conventional loans. The table in Section L – HOME IMPROVEMENT breaks down further they usage of the Conventional Loan Types. Table 47: Loan Type Loan Type Number of Applicants Percentage of Applicants Conventional 6,722 88.89% FHA 421 5.57% VA 419 5.54% FSA/RHS 0 0.00% Total 7,562 100.00% Source: HMDA Data 2021 i. Refinancing Refinancing is the process of replacing an existing mortgage with a new loan. Typically, people refinance their mortgage to reduce their monthly payments, lower their interest rate, or change their loan program from an adjustable-rate mortgage to a fixed-rate mortgage. 61 | Page L. Home Improvement A home improvement loan is used to remodel or repair a private residence.33 Home improvement loans are usually short-term. They may or may not be secured by the homes whose work they finance, but those that are secured generally carry lower interest rates. The table below lists the purpose for which were loans applied in 2018. As mentioned previously, the loans shown in Table 48 below are Conventional Loans. Out of the 88.89% of Conventional Loans that were applied, 34.82% were for purchasing a home, 3.09% were for home improvements, and more than half of the Conventional Loans were used for refinancing a home. According to Table 49, 1.93% of the applications were rejected. More than half of the applications, about 56.20%, were approved. Table 48: Purpose of Loan Applied For Purchase 2,633 34.82% Home Improvement 234 3.09% Refinance 4,457 58.94% Other 220 2.91% NA 18 0.24% Invalid 0 0.00% Total 7,562 100.00% Source: HMDA Data 2021 Table 49: Action by Lender Action Number of Applicants Percentage of Applicants Originated 4,250 56.20% Denied 812 10.74% Rejected by Applicant 146 1.93% Withdrawn 1,188 15.71% Incomplete 368 4.87% Purchased 796 10.53% PreApproval Denied 0 0.00% PreApproval Rejected 2 0.03% Invalid 0 0.00% Total 7,562 100.00% Source: HMDA Data 2021 62 | Page M. Demographics of Loan Applicants In the table below, White residents’ makeup more than half, 61.36% of all applicants for loans. According to the 2021 American Community Survey 5-year Estimate, 66.3% of the City is White and not Hispanic, making their representation of applicants nearly even with their respective percentage of the City’s population. However, only 6.73% of applicants where Hispanic, making them underrepresented as applicants for loans because they represent 21.7% of the City’s population. Whereas the approval rating for other races - Black, Asian, Native American, Hawaiian- their numbers as applicants were proportionate to their population in the City. Table 50: Demographics of Loan Applicants Race Number of Applicants Percentage of Applicants White 4,893 61.36% Black 105 1.32% Hispanic 537 6.73% Asian 246 3.09% Native American 25 0.31% Hawaiian 12 0.15% Multi Race 8 0.10% Unknown 2,147 26.93% NA 0 0.00% Invalid 1 0.01% Total 7,974 100.00% Source: HMDA Data 2021 N. Income of Loan Applicants For applicants by income, most applicants, 54.21% were in the upper income bracket. As mentioned, above, approximately 56.2% of loans were approved. According to the HMDA reports, the primary reason for denials was income to debt ratio, followed by amount of collateral, and credit history, respectively. Table 51: Applicants by Income Level Income Level Number of Applications % Applications Low 717 9.48% Moderate 1,079 14.27% Middle 707 9.35% Upper 4,099 54.21% Unk/NA 960 12.70% Invalid 0 0.00% Total 7,562 100.00% Source: HMDA Data 2021 63 | Page Finally, lenders with the highest denial rates in the City are listed below. They are listed in order from highest denial rates to lowest. Table 52: Lenders with Highest Denial Rates (Among lenders with 175+ applications) Rank Lenders (see footnote) Applications Denials % 1 Bank of America, National Association 190 62 32.63% 2 US Bank National Association 179 38 21.23% 3 Wells Fargo Bank, National Association 329 68 20.67% 4 Loandepot.com, LLC 309 35 11.33% 5 Rocket Mortgage, LLC 492 55 11.18% 6 United Shore Financial Services, LLC 582 53 9.11% 7 Home Point Financial Corporation 186 11 5.91% 8 Guaranteed Rate, Incorporated 178 8 4.49% 9 Freedom Mortgage Corporation 191 8 4.19% 10 Franklin Loan Corporation 348 3 0.86% Number of Lenders = 10 Totals 2984 341 11.43% Source: HMDA Data 2021 64 | Page VI. Fair Housing Profile This section discusses the institutional structure of the housing industry regarding fair housing practices. Fair housing services available to City residents will also be covered and shall include data regarding fair housing complaints received by the fair housing provider, how fair housing investigation and resolution of housing discrimination complaints are handled, and discrimination auditing/testing results will be discussed. The City can assist residents by providing education and outreach, including the dissemination of fair housing information. A. Homeownership-Private Sector Practices The Fair Housing Act 42 states that it is “the policy of the United States to provide, within constitutional limitations, for fair housing throughout the United States.”24 The Act carries out the policy by prohibiting discrimination in the sale, rental, and financing of dwellings and in other real estate-related transactions because of race, color, religion, sex, familial status 25, national origin, or disability. This section of the AI discusses the City’s efforts to determine and to evaluate the practices of the private sector as they relate to fair housing choice, including the policies and practices of real estate agents and property managers. HOME PURCHASE PROCESS When purchasing a home, a potential buyer must go through a process of steps, including: • Search advertisements • Obtaining a loan • Working with a Real Estate Agent B. Real Estate Advertisement The process usually begins by searching for home for sale in advertisements. Homes for sale are advertised in magazines, newspapers, or the internet. Advertisements cannot include discriminatory references such as the use of words describing current residents, the neighborhood in racial or ethnic terms, that adults or types of adults are preferred, or convenience of local religious institutions. Under 42 U.S. Code § 3604 (c), discrimination in the sale or rental of housing and other prohibited practices, it is unlawful to make, print, or publish, or cause to be made, printed, or published any notice, statement, or advertisement, with respect to the sale or rental of a dwelling that indicates any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. The National Fair Housing Alliance provides guidelines for responsible advertising to housing providers for their use. Basic guidelines they recommend include the following: “Make sure your advertising is compliant with fair housing laws by focusing on the property and the amenities in your rental listing description—NOT on who you think an ideal renter would be.” “Do not make statements that exclude persons in protected classes or express a preference for one personal characteristic over others.” 24 42 U.S.C. § 3601. 25 One or more individuals under the age of 18 years living with a parent or other person having legal custody of the individual or individual. 65 | Page Table 53 is from a sampling of 10 listings, one of which include potentially discriminatory language found at Trulia.com. The language could potentially target particular groups, rather than focusing solely on the amenities offered. The results were filtered to show homes affordable according to HOME and Housing Trust Fund Homeownership Sales Price Limits for fiscal year 2022, which is $409,000 for 1-unit single family existing housing unit in Riverside County 26. Table 53: Potentially Discriminatory Language in Listings of For-Sale Homes Discrimination Type Number of Listings Potentially Discriminatory Language* No Discriminatory Language 4 Income Related 3 (#4 in the heart of highly desirable Deep Canyon Tennis Club) (#9, Palm Valley Country Club community has amenities to satisfy even the most discerning visitors.*) Household Size/Family Related 3 (#3 most in-demand retirement destinations, dream retirement home*), (#6 IDEAL family vacation home or a full-time residence.*) (#10, Close to shopping, dining, golf, schools and universities.*) Source: www.trulia.com, accessed February 3, 2023. *Examples are direct quotes from the listings (including punctuation and emphasis). C. Home Loans The next step is to obtain financing for the home purchase. The potential homebuyer must apply for the loan and the lender must perform an evaluation of credit quality, determine ability to repay the loan and amount eligible for, and choose the type and terms of the loan, etc. Examples of discrimination,27 based on race, color, national origin, religion, sex, familial status, or disability, in lending can include: • Refusal to make a mortgage loan • Refusal to provide information regarding loans or providing unequal information • Imposing different terms or conditions on a mortgage loan, such as different interest rates, points, or fees • Discrimination in appraising property • Steering an applicant toward a bad mortgage loan product • Providing inferior servicing of a mortgage loan D. Real Estate Agents Real Estate Agents can discriminate in ways such as providing different terms, conditions, or information related to the sale or rental of a dwelling to individuals with protected characteristics, or steering individuals with protected characteristics to a particular neighborhood or area at the exclusion of other areas. 26 FY-2022-HOME-HTF-Homeownership-Sales-Limits.xlsx (live.com) 27 U.S. Department of Housing and Urban Development, “Understanding Fair Lending,” under “ Lending Discrimination,” https://files.hudexchange.info/resources/documents/Fair-Lending-Learning-the-Facts- Consumer-Guide.pdf. 66 | Page E. Rental Housing Process When searching for a home to rent, the process is somewhat similar to home purchase but does not require the same outlay of cash. Renting can involve the following steps: • Search advertisements • Viewing rental units • Credit checks • security deposits F. Advertisement for Rental Units As with searching for homes for sale, the process for rentals also begins by searching in advertisements, usually in magazines, newspapers, or the internet. Advertisements for rental units cannot include discriminatory references that indicate preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. For the fiscal year of 2022, HUD’s fair market rate, for the affordable rent for a two-bedroom unit was $1,509 in the Riverside County 28. For the fiscal year of 2023, HUD’s fair market rate for the affordable rent for a two-bedroom unit is $1,751 in Riverside County, CA 29. There were 0 results to reflect affordable rent for a two-bedroom unit using HUD’s fair market rent on Trulia. The lowest rental amount for a two-bedroom was $1,800. Other real estate databases were checked and produced the same results. G. Fair Housing Complaints and Enforcement Patterns of complaints and enforcement are useful to assess the nature and level of potentially unfair or discriminatory housing practices in the private sector. Several public and private agencies may receive complaints about unfair housing practices or housing discrimination. OFFICE OF FAIR HOUSING AND EQUAL OPPORTUNITY (FHEO) At the federal level, the Office of Fair Housing and Equal Opportunity (FHEO) of the Department of Housing and Urban Development (HUD) receive complaints of housing discrimination. FHEO will attempt to resolve matters informally. However, FHEO may act on those complaints if they represent a violation of federal law and FHEO finds that there is “reasonable cause” to pursue administrative action in federal court. CALIFORNIA DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING (DFEH) At the state level, the Department of Fair Employment and Housing (DFEH) has a similar role to FHEO. DFEH also receives, investigates, attempts to settle, and can take administrative action to prosecute violations of the law. HUD and DFEH have overlap in jurisdiction, and depending on the nature of the case, may refer cases to one another. DFEH is a HUD Fair Housing Assistance Program (FHAP) grantee, meaning that it receives funding from HUD to enforce federal fair housing law in the state. FAIR HOUSING COUNCIL OF RIVERSIDE, INC. (FHCRC) 28 FY 2022 Final Fair Market Rents Documentation System — Select Geography (huduser.gov) 29 https://www.huduser.gov/portal/datasets/fmr/fmrs/FY2023_code/select_Geography.odn 67 | Page Locally, the FHCRC takes part in a variety of activities to fight housing discrimination, such as free educational workshops, outreach to the community, and the investigation of housing discrimination complaints. The capacity of the FHCRC enables it to provide fair housing information, outreach and enforcement to 24 cities and communities located in Riverside County plus the unincorporated area of the County. FHCRC includes a total of 15 staff: two Housing Counselors, five Fair Housing Counselors, two Program Managers, Fair Housing Training Specialist, Program Administrator, an accountant, a controller, an Executive Director and an administrative staff member. FHCRC also has three interns. The funding that supports the efforts of the FHCRC includes CDBG funds received from participating jurisdictions within its service area and grant funds such as HUD‘s Fair Housing Initiatives Program (FHIP) and Fair Housing Assistance Program (FHAP). The FHCRC provides a full range of services, including: • Anti-discrimination • Landlord/tenant counseling • First-time homebuyer seminars • Foreclosure prevention • Loan modification • Back-to-Work FHA • Training Additionally, the FHCRC completed a Cultural Diversity Grant through the National Association of REALTORs (NAR) for the Inland Valleys Association of REALTORs (IVAR) members to attend the 2017 Housing Conference. FHCRC also is a continuing credit training agency through the Bureau of Real Estate (BRE), effective January 2017. 68 | Page VII. Five Year Progress The City completed its previous Analysis of Impediments in 2017. The analysis of data from the various sources, as described in the sections of this analysis, resulted in the identification of seven (7) impediments. The discussion below will include the impediment identified, goals to address the impediment, recommended actions, and City accomplishments. To illustrate the effectiveness or ineffectiveness of actions directly affects the accomplishments completed. Action steps were selected because they were deemed achievable by the City and its community. Each year during the previous five years, yearly progress was circulated to the community in the Consolidated Annual Performance and Evaluation Report (CAPER). Table 54: Fair Housing Progress Since 2018 Goal 1: Improve access to opportunity to low poverty neighborhoods Recommendation: Preventing Housing Discrimination Actions Progress 1.1 Continue to enforce the provisions of the Federal Fair Housing Act by continuing in funding a fair housing provider The City is contracting with the Fair Housing Council of Riverside County (FHCRC) and continues its referral program to the FHCRC and shall maintain information at City Hall and affordable housing complexes. Brochures and flyers are available at Housing Authority properties, Library, and apartment managers’ offices. The City provides fair housing information on all its properties and continues to fund programs operated by the FHCRC. During the 2018-2022 planning period, the City used CDBG funds to provide the Council $152,126 to eliminate discrimination in housing throughout the City in joint efforts across the County. Actions taken in FY2021-2022 are the FHCRC’s landlord/tenant services are ongoing. Palm Desert residents received vital information regarding their housing rights, received mediation services and/or referrals for additional assistance. The top three issues/questions residents call in with had to do with notices, rental increases, and repairs. The education provided to tenants assists them in being knowledgeable of their rights and aware of the options that are available to them to resolve their housing disputes. FHCRC's anti- discrimination services are on-going. Individuals and/or households who call in with a discrimination complaint receive vital information regarding their housing rights, receive conciliation services, and/or referrals for additional services. The education provided to tenants on their fair housing laws assists them in being knowledgeable of their rights and aware of the options available to them when they feel they have been discriminated against. Goal 2: Increase the number of affordable units in the existing housing stock 69 | Page Recommendation: Make more units available in the City to accommodate those tenants on the County of Riverside Housing Authority extensive Section 8 waiting list 2.1 Continue to provide rental assistance and encourage the construction of new affordable housing. The following programs are available in the City of Palm Desert: 1. Housing Choice Voucher (Section 8 ) Assistance – The Riverside County Housing Authority administers the Housing Choice Voucher (HUD Section 8) rental assistance program to lower income renters within the City. 2. CalHFA Fist Mortgage Loan Programs – The California Housing Finance Agency (CalHFA) offers a variety of loan programs for low- and moderate-income first-time homebuyers who secure a CalHFA 30-year fixed mortgage. 3. CalFHA Down payment Assistance Program – Moderate income households may receive a deferred loan of up to the lesser of 3.5% of the purchase price or appraised value of a home, to be applied to the down payment and/or the closing costs for the residence, with a cap of $10,000. 4. HomeChoice Program - This State program provides disabled low- and moderate-income households with a low-interest 30-year mortgage for a first-time homebuyer. 5. California Low-Income Housing Tax Credit Program – This competitive State program provides tax credits to private sector developers who provide affordable rental units within their projects. The units can consist of all or part of a project and must meet certain specified criteria. Units must be restricted for a period of at least 55 years. Goal 3: Preserve the affordability of housing units that could convert to market rate housing Recommendation: Facilitate the purchase of the apartment communities by a nonprofit housing corporation, obtain Low Income Housing Tax Credits to rehabilitate the buildings, and thereby extend the affordability controls. 3.1 The City shall continue to utilize restrictions, applicant screenings, and other appropriate mechanisms established as conditions of approval in order to preserve affordable for sale housing units for the long term. Pursuant to Housing Element Program 6B, the City will annually coordinate with private development and management companies to promote the preservation of existing affordable housing units; and may cooperate through state and federal program funding for third party ownership, and other means to assure the long-term affordability of the project(s). Goal 4: Increase the number of new affordable housing units that address the needs of families with children and disabled persons Recommendation: Have more housing available to better suit families and the disabled 4.1 Coordinate with the Inland Regional Center, Desert Arc and other appropriate agencies and organizations that serve The City has and will continue to encourage developers to reserve a portion of affordable housing projects for the disabled, including those with developmental disabilities. The City will support funding applications for such 70 | Page developmentally, physically disabled, including families with children population. projects and will consider fee waivers and reductions when these projects are proposed. The Housing Authority properties are one of the vehicles available to encourage rental to developmentally disabled individuals. The City has a no-fee application process for reasonable accommodation and assisted more than double the disabled residents between 2014 and 2020 (91 to 188 residents) in Housing Authority owned properties. The City does not impose any restrictions or barriers to the organic changes/movements in the community and will continue to approve and assist housing developments for disabled residents. The City has made progress in moving projects forward during the 2014-2021 planning period and will continue with the City’s inventory and be carried forward into the 2022-2029 planning period. The Canterra Phase II, now known as The Sands, was entitled 388 units, including 78 reserved for very low-income households. The project entitlements remain active. The Housing Authority will market affordable housing projects as the one mentioned above, including Palm Desert 103, Dinah Shore and Portola, Carlos Ortega Villas, and Sagecrest Apartments. Goal 5: Increase the number of housing discrimination complaints filed with and processed by the Fair Housing Council of Riverside County, Inc. (FHCRC) Recommendation: Marketing of the FHCRC’s services 5.1 Promote and affirmatively further fair housing opportunities throughout the community for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (FEHA), Government Code Section 65008, and any other applicable state and federal fair housing and planning law. Continue to provide multilingual brochures and informational resources to inform at least 10 residents, landlords, housing professionals, public officials, and other relevant parties annually about fair housing rights, responsibilities, and services, with an emphasis on needs of disabled persons. Brochures and flyers shall be available on the City website (Resources on the Affordable Housing webpage), at Housing Authority properties, the Public Library, and City Hall, and at County social service agency offices in the City, in order to assure that they are available to all community members. Goal 6: Ensure that affordable housing sites are located in high opportunity neighborhoods Recommendation: Accessible to Housing for those families or individuals who can afford a home throughout the City 6.1 The City shall continue to work with affordable housing organizations to preserve the affordability of the Regent Palm Desert, Shadow Hills Estates and Cantera Phase I. Given the development history, land availability would limit the distribution and development of various housing projects, including affordable housing. However, the City has managed to locate/acquire existing affordable housing projects including rental and ownership units in the highest and high opportunity areas such as the Highway 111 corridor and the northern City. With the advantage that the entire City is rated Highest/High Resource, the City strives to distribute new affordable 71 | Page housing sites throughout the City despite the land availability constraint. Goal 7: Increase the supply of housing designed to meet the needs of households with disabled members or other special needs Recommendation: Additional ADA accessible housing units and the Senior population 7.1 The City shall continue to address the needs of senior population in development of housing; encourage the development of assisted living facilities for seniors; and continue to house physically and developmentally disabled residents City-owned housing communities continue to house senior residents in 7 projects totaling 366 units. City-owned housing communities continue to house physically and developmentally disabled residents, which have ranged from 91 to 188 residents in the last planning period. The City has actively participated in moving forward on the Arc Village Project, which will result in 32 units for developmentally disabled residents, in addition to the funds expended to make improvements to Desert Arc educational and vocational facilities. 72 | Page VIII. Actions This chapter will discuss the findings from the Analysis of Impediments to Fair Housing Choice. The following are the major or high priorities that are the contributing factors to fair housing choice in the City of Palm Desert and include: • Lack of affordable housing units that are at HUD’s fair market rate • High cost for rent • Use of potential discriminatory language in advertisements for housing sale • Increase in senior population • Decrease in median home value A. Recommendations for Ongoing Actions The following findings are reiterations of impediments that were identified in the previous chapters of the Analysis of Impediments. i. Lending Practices Based on the data provided by the Home Mortgage Disclosure Act (HMDA) 2021, the Hispanic population in the City of Palm Desert submit the least number of applications for loans at 6.73% despite making up about 21.7% of the City’s total population. As mentioned previously in the Lending Practice chapter, Table X: Demographics of Loan Applicants shows the percentage of applications submitted by racial/ethnic background in 2021. Each racial and ethnic category had a percentage that was almost proportionate to their population except for the Hispanic population. This can be due to the Hispanic population possibly not having access to purchasing homes like the other racial populations in the City, or also because of a language barrier. Additionally, over 50% of applicants are within the upper income level bracket. Less than 10% of applicants are of moderate-income level. This can be another form of barrier because people of lower income levels usually need more financial help; however, they have less time or knowledge to access resources. Note: Not in order of priority. GOAL 1: SUPPORT NON-DISCRIMINATORY LENDING PRACTICES Recommended Actions: Provide financial literacy through public workshops and programs that involves lenders and the public working together and going through financial resources step-by-step that can help alleviate financial burden. Provide resources in Spanish, the second most language spoken in the city for residents whose English proficiency is not strong. Provide information about lending options on the City of Palm Desert’s website both in English and Spanish so that information is easily accessible for the public. B . Keep Existing Housing Affordable As mentioned earlier in the Community Data chapter, about 32% of homes in the City of Palm Desert were built before 1978. This means that there is a high likelihood of these homes having lead-based paint. There is also a disproportionate number of renters that live in substandard housing compared to homeowners in the City. Additionally, the City’s population has shown an increase by 7.4% over the past 20 years while the number of units in the City has only increased by 4.5%. If there are more people than homes this causes a supply and 73 | Page demand issue in the housing stock, and the price for housing becomes more expensive because of the increase in competition. GOAL 2: PRESERVE EXISTING HOUSING STOCK Recommended Actions: 2.1 Continue the City’s Home Improvement Program which provides emergency grants for households that qualify for a low-income AMI. 2.2 Continue and expand the Palm Desert Housing Authority’s Authority Assisted Subsidized Rental Opportunities which subsidizes affordable rental units within the city. 2.3 Create a city-wide program that inspects units, especially rental units, that will combat issues of deterioration, substandard conditions that are maintenance related, and removal of lead-based paint. 2.4 Identify the 14,723 known vacant units (as of 2020) and rehab them for affordable housing. C. Housing Discrimination The Community Data chapter of the Analysis of Impediments goes over several aspects where renters disproportionately experience more fair housing burdens than their homeowning counterparts. There is a disproportionate number of renters that live in substandard housing compared to homeowners in the city. There is a higher number of renters experiencing overcrowding in their homes than renters. Under the Fair Housing chapter of the Analysis of Impediments, it was disclosed that there were six listings under www.trulia.com that utilized potential discriminatory language in their advertisements for for-sale homes. GOAL 3: SUPPORT THE PREVENTION OF HOUSING DISCRIMINATION Recommended Actions: 3.1 Provide educational workshops to the public regarding the Fair Housing Act. 3.2 Provide public events on a monthly or bi-monthly schedule where the public can interact personally with nonprofits and public agencies like the Habitat for Humanity, Valley-Wide Affordable Housing Opportunities, Palm Desert Housing Authority, bank lenders, and more. These events create a personal one-on-one connection and trust with organizations to go over concerns and/or questions they may have. 3.3 Provide translations on the City’s website and resources like the Housing Authority Properties Brochure and Income Eligibility to ensure more accessibility for residents who are not proficient in English. 3.4 Educate and modify advertisements that use language that are discriminatory in regard to the sale of housing. 3.5 Increase public outreach to residents, especially renters, to build trust between the public and the Palm Desert Housing Authority. A stronger relationship where trust is built between the City Administration and the public allows the City to perform quickly and more accurately in knowing and resolving housing related issues that the public are facing. D. Increase Homeownership 74 | Page As mentioned earlier, the City’s population is growing at a faster rate than the City’s housing supply. The City needs to increase the number of housing units available to this growing population. Some of the policies above regarding rehabbing current housing units address this issue. GOAL 4: SUPPORT HOME OWNERSHIP Recommended Actions: 4.1 Incorporate programs into housing development that include: home ownership education, budgeting, and home maintenance education and skills. 4.2 Increase number of FHA loans, which as of 2021, make up 5.57% of loan applications through education and public outreach. 4.3 Continue and expand the Authority Assisted Home Ownership Opportunities program that is already in place. E. Provide Opportunities for Affordable Housing There is enough data to support throughout the Analysis of Impediments that explain the need for affordable housing for the City of Palm Desert. GOAL 5: SUPPORT THE DEVELOPMENT OF AFFORDABLE HOUSING Recommended Actions: 5.1 Create an Accessory Dwelling Units (ADUs) program in the city for single-family units to add additional affordable housing on existing housing properties. These ADUs will be partially subsidized for homeowners and be available for low-income tenants based on AMI. 5.2 Continue and expand the City’s Developer Assisted Affordable Rental Opportunities that provide opportunities for developers to provide affordable units in their projects. 5.3 Continue to work with Habitat Humanity to proliferate the development of affordable housing throughout the City. F. Recommended Actions for Other Impediments The following impediments are also similar and related to impediments identified in the past. However, they recommended new approaches to ongoing issues such as lack of affordable housing are the most common findings. i. Land Use Policies and Practices The State of California requires cities to develop a General Plan Housing Element that addresses impediments to housing through land use policies. The General Plan is updated about every 20 years. The City of Palm Desert’s City Council adopted the 2021-2029 Housing Element Update on September 29, 2022. The Housing Element Update covers twelve policies each with multiple programs to support the policy. Refer to the document link 2021-2029 Housing Element Update starting on page 100 for the list of policies and programs. GOAL 6: UPDATE LAND USE POLICIES AND PRACTICES TO FACILITATE DEVELOPMENT OF AFFORDABLE HOUSING Recommended Actions: 75 | Page 6.1 Dedicate more affordable housing to senior living for the increase in aging population within the city. 6.2 Provide a city program that finances upgrades to housing units that accommodate for disability and age- related living conditions such as handrails, ADA ramps, widening doorways for wheelchair and strollers, and more. 6.3 Build a relationship with local tenant-based organizations that go over needs that tenants in low-income have that City is able to address. G. Collaborating Regionally The Analysis of Impediments has listed and provided evidence-based findings on how the city needs to improve its affordable housing supply and fair housing practices. This task does not have to be accomplished by the City of Palm Desert alone. Collaborating with other organizations regionally strengthens the city’s ability to tackle these issues by incorporating people with specialties on the subject and providing more on the ground help. GOAL 7: IMPROVE COLLABORATION WITH REGIONAL ORGANIZATIONS AND AGENCIES Recommended Actions: 7.1 When conducting outreach, include County and other regionally based agencies and organizations such as Habitat Humanity. 7.2 Continue to hold regular meetings with organizations that serve the homeless as well as with governmental agencies to create awareness and collaboration. 7.3 Continue to ensure that service organizations have knowledge of each other’s ongoing planning studies and initiatives such as the Continuum of Care and the Housing Authority of the County of Riverside. 76 | Page IX. Appendices 77 | Page Appendix A Federal Fair Housing Laws 78 | Page Appendix A – Federal Fair Housing Laws • Title VI of the Civil Rights Act of 1964 (Title VI): Title VI is intended to protect the rights of individuals regardless of race, color, or national origin in programs and activities that receive federal funding or financial assistance. • Title VIII of the Civil Rights Act of 1968 (Fair Housing Act): The Fair Housing Act (adopted in 1968 and amended in 1988) prohibits housing discrimination against any of the following seven protected classes: Race, Color, Religion, Sex, National Origin, Familial Status, and Disability o As amended in 1988, the Fair Housing Act added “familial status” and “disability” as protected classes and increased HUD’s authority to establish mandatory enforcement measures to ensure compliance with federal law. • Section 504 of the Rehabilitation Act of 1973 (Section 504): Section 504 established guidelines that prohibit individuals with disabilities from being denied access to housing under programs and activities that receive federal funding or financial assistance. • Section 109 of Title I of the Housing and Community Development Act of 1974 (Section 109): Section 109 prohibits housing discrimination based on race, color, national origin, sex, or religion under programs and activities that receive federal funding or financial assistance. • Title II of the Americans with Disabilities Act of 1990 (Title II): Title II prohibits discrimination based on disability under programs, services, and activities provided by public entities. HUD is responsible for enforcement of Title II when it is associated with public housing, housing assistance, and housing referrals administered by state and local jurisdictions. • Architectural Barriers Act of 1968 (Architectural Barriers Act): The Architectural Barriers Act mandates that buildings and facilities that received federal funding assistance after September 1969 be accessible to and functional for handicapped individuals. • Age Discrimination Act of 1975 (Age Discrimination Act): The Age Discrimination Act prohibits programs or activities that receive federal funding from discriminating against individuals on the basis of age, unless such discrimination is authorized by federal, state or local laws. • Title IX of the Education Amendments Act of 1972 (Title IX): Title IX prohibits educational programs or activities that receive federal funding or financial assistance from discriminating against individuals on the basis of sex. • In addition to federal fair housing laws that guarantee equal access to housing, a number of presidential executive orders were also issued to minimize discrimination and barriers to obtaining housing. • In 1988, disability and familial status (the presence or anticipated presence of children under 18 in a household) were added (further codified in the Americans with Disabilities Act of 1990).[5] In certain circumstances, the law allows limited exceptions for discrimination based on sex, religion, or familial status. • In 2017, a federal judge ruled that sexual orientation and gender identity are protected classes under the Fair Housing Act. As of May 2018, there is an additional pending effort to amend the Fair Housing Act to make this explicit (HR 1447). 79 | Page Appendix B – Community Outreach 80 | Page Appendix B Community Outreach