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Home My WebLink AboutExhibit1 FY2015-2020 DATE CREATED: MAY 2015 � U '� U UUCTU EXECUTIVE SUMMARY OFTHE ANALYSIS PURPOSE The Federal Fair Housing Act, Section QOg(e)(S),requires the Secretary ofthe U.5.Department of Housing and Urban Development (HUD) to administer housing and urban programs in a manner affirmatively furthering fair housing (\FFH). Although the extent ofthe AFFHobligation isnot defined statutorily, HUD establishes the following requirements': • Jurisdictions must conduct an analysis to identify impediments to fair housing choice within the jurisdiction; • Appropriate actions must be taken to overcome the effects of any impediments identified inthe analysis; and IN Jurisdictions must maintain records reflecting the analysis and actions taken in this regard. HUD interprets the objectives to "affirmatively further fair housing" to mean that the Jurisdiction vviU': m Analyze and eliminate housing discrimination in the jurisdiction; • Promote fair housing for all persons; ~ Provide opportunities for inclusive patterns of housing occupancy regardless of race, color, religion, sex, familial status (pregnancy, family, or individual in the process of adopting or having legal custody of child under the age of 18), disability (having a record of such impairment, persons diagnosed as being HIV - positive, and recovering substance abusers), and national origin; � Promote housing that is structurally accessible to, and useable by all persons, particularly persons with disabilities; and � Foster compliance with nondiscrimination provisions of the Fair Housing Act. The Analysis of the Impediments to Fair Housing Choice U\|) is required of state and local governments that receive federal funds from HUD. This includes Community Block Grants (CD8G), HOME Investment Partnerships Program (HOME) funds, and Neighborhood Stabilization Program (NSP)funds. The Al is an extension of the Consolidated Plan 2014-2018 filed with U.S. HUD in early 20I4 and serves as an assessment of housing, housing related policies, and practices in use throughout the Jurisdiction that inadvertently or deliberately prevent its residents to choose where they live. The analysis includes a discussion of the barriers to housing choice within the City of Miami, a plan of action to overcome the identified impediments, and a strategyto maintain records and results nfthe actions taken. Although the AFFHobligation arises inconnection with the receipt of federal funding, the obligation extends to all housing and housing related activities in the City of US Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Fair Housing Guide. Section Miami whether publicly orprivately funded.' Factors that could restrict housing choice include, but are not limited to: • Discrimination based on race, color, national origin, sex, religion, familial status and disability asdefined bvTitle VU|ofthe Civil Rights Act of1968; m Discrimination in the sale or rental of housing and other prohibited practices on the basis of race, color, religion, ancestry, national origin, sex, pregnancy, age, disability, marital status, familial status, gender identity, gender expression, sexual orientation, source of income or actual or perceived status as a victim of domestic violence, dating violence orstalking, asdefined by the Miami-Dade[ountyCode Chapter 1lAand recent amendments tothe latter = Lack ofaffordable housing; m Severely cost burdened households; • Lack ofhousing that baccessible tothe disabled; • Lack ofreasonable and accessible transportation services; The City of Miami D f Community and Economic ' CED\last conducted an mm2UlU.|nMay 1014,itfiled its most recent Consolidated Plan withU,S.HUD mspan the years of2U14'2O18 incorporating new population data frorn the '2010 Census. In a complementary fashion, the City is now updating its Analysis of Impediments/ to Fair Housing to pick up where the previous Al left off. PLAN PERIOD This new Al will span from October 1, 2015 through September 30, 2020, and will further address where the City opresently fair housing matters, given the most recent demographic information available U.S. Census and the subsequent American Community Surveys (ACS) that have been issued. MONITORING OFAl The City' of Miami works thro ' ughout the year to implement its Analysis of Impediments to Fair Housing and is actively engaged in monitoring the actions outlined in this document to overcome the impediments to Fair Housing Choice within its purview. Based on yearly meetings with the Housing Unit and the Deputy Director overseeing all housing -related activities, the Assistant Director of the Reporting & Specialized Housing Division is in charge of this task and works in conjunction with the Public Information Officer to ensure that all tasks are being met within preset It should be noted that as part of this monitoring effort, many of the actions include input provided byHOPE, Inc. This entity is our local FHIP and conducts fair housing educational workshops in our [by and County (Miami -Dade) aimed to educate community based organizations, disability advocacy agency staff and clientele, and local housing industry professionals. These seminars provide attendees with key information regarding fair housing laws and how to seek redress of grievances related to housing discrimination, issues regarding reasonable accommodations, dwelling unit modifications for the disabled, housing opportunities for people with AIDS, and 3 US Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Fair Housing Guide. DRAFT —zo/o-2nzoAnalysis o,Impediments toFair Housing Choice 3 compliance with fair housing laws that protect against housing discrimination due to race, color, religion, national origin, sex, disability, familial status, age, marital status, or sexual orientation. The DCED also provides individualized technical assistance in affirmative marketing and makes sure that federal, state and local fair housing policies are adhered to by its [DBG/HOMEfunded [D[s and [HDOs and its HOPVVAand Section 8 sub -recipients (agencies, landlords and clients). It should be noted that [DBG dollars are distributed amongst the Citysfive districts. Besides the 15% allocated to public service activities, the remaining CDBG dollars are utilized as needed and at the City Commission's discretion for miscellaneous economic development activities, infrastructure needs (sidewalk and/or street improvements) and the improvement of public facilities (parks, fire stations) that serve lower -income census tracts. All the while, CDBG funding is meant to complement other ongoing activities in those areas, with preference always towards the Neighborhood Development Zones (NDZ) identified in the City of Miami's Consolidated Plan. This way, a more concentrated effort is implemented in particular areas by multiple City Departments. The latter is accomplished after extensive meetings and discussions between the Department (DCED), the City's Capital Improvements Department which is tasked with the identification and execution of necessary street efforts, and the particular Commissioner's office (five total). The DCED is responsible for distributing fair housing marketing materials (in English and Spanish) to the city's community Neighborhood Enhancement Team (NET) offices, which are located in all five city commission districts and accessible to city residents. The [itysfair housing strategy is alsoreviewed on a yearlyb by the DCED's Assistant Director of the Reporting and Specialized HousingDivisiont that itisrneetingbuthitsshurt-and long-term objectives; —if it is determinedthat° certain objectives are not being accomplished, then adjustments are made accordingly. ` y.^` METHODOLOGY VVHCJ CONDUCTED THE ANALYSIS��. The City of mm"^ coordinating=x` ^z^ ' aspects of the Al. Economic Development (DCED)isthe lead agency PARTICIPANTS Key informant interviews were conductedwith city and county officials; aswell ascommunity stakeholders and private organizations. The agencies involved in the interview process orthat provided valuable information are: • Florida Housing Coalition = The Florida Housing Finance Corporation • Housing Opportunities for Excellence, Inc. (HOPE,|nc]—local FH|P • The Miami Realtors Association � University ofMiami Office nfCivic and Community Engagement � Citrus Health Network, Inc. � City ofMiami Planning Department DRAFT —oo/5-co2oAnalysis mImpediments mFair Housing Choice 4 M Miami -Dade County's Public Housing and Community Development Department The Al began with a review of available social, economic, and housing data gathered from a variety ofsources including: * U.S.Census Bureau the 2OlOCensus and American Community Survey (ACS) * U.5.Department ofHousing & Urban Development (HUD)and One CPDmaps ~ the University ofFlorida's ShimberCCenter for Affordable Housing And from existing studies and reports, including but not limited to * the2O14'2OI8CityofMiamiConso|idotedP|an,Pub|icHousingAuthorityP|an � the HIV/AIDS Housing Needs Assessment & Strategic Planning documents for the HOPWA Program inthe Miami'Miami'DadeCounty MlA ° The most recent City ofMiami Consolidated Plan, Annual Plan and CAPER * Financial lending institution data from the Home Mortgage Disclosure Act (HMDA)database * Public policies affecting the siting and development of housing (Miami 21 — City of Miami Zoning Code) � Research requests were conducted with State and local public and private sector representatives from area banking, lending, insurance, real estate, property management, educational, health, community service, and neighborhood organizations. The impediments to fair housing choice and the conclusions and recommendations were identified through analyzing the data previously mentioned, as well as by obtaining info/mationthrough the key informant dialogues of the participants listed above and by additional public input gathered via a survey issued in ear|y2Ol5 and atpublic meetings. . The development of the Action Plan, and the Analysis of Impediments to Fair Housing Choice FY2015-2020 began in 2014. With the gathered data, several tables and maps were also created to give context tothe issues discussed herein. ` PUBLIC NOTICE AND REVIEW ' ` As recommended by HUD, the D[EDo|so utilized its Action Plan meetings (which itfacilitates) to coincide with public meetings addressing fair housing. These public meetings were held as follows: Neigh borhood-|eve|Public Hea — Activities` zues_Aug. z2,z014'� D��uz 6 p� ` .� ' Commissioner Wed.,A*s\ 2014, District 4 mrrimissionecrrancis Suarez District Db�c ~�` z 'Cvpnmissionez7rJredvGoo' � M-,mi City Hall, Commission Chambers o00mmAmerican 'Drive' Our Lady pfLebanon Church � �zo55Coral Way � Q�6= ' oc x��y^6�c�mounitruoom 130Nrvsn3��cx��ez�j�o�� - - ^ Allapartah Activpa= � �2257 NW North P�veroav,� DRAFT —m9/5-onc0Analysis u/Impediments mFait, Housing Choice 5 District 3 Commissioner Frank Carollo CvxvA"*idePublic /eu,bqp/br/k%Pm3 Jose Marti Park Gymnasium 434 SW 3 Avenue Tues., Aug. 12,2014, Central Miami -Dade County Joseph Caleb Center- Room 110 Thurs., Aug. 21,2014, South Miami -Dade County Senibrando Flores. 162 SW I Ave., Homestead, The following 1. Published notice of activities in general circulation newspapers; N Miami Herald advertisement published on July 28, 2014 (English). 2. Made notices (flyers) with public hearings dates/times available in English and Spanish to all funded public service agencies and developers, at all NET (neighborhood offices) locations, to all Commissioner offices (five); at the City Clerk's office located at City Hall in Coconut Grove and in the lobby of the main City of Miami administration building in downtown Miami; 3. Used the City of Miami website to convey information on the times and schedules of the public meetings; Posting on City of Miami website, City's public meetings webpage, and Community& Economic Development website. 4. Worked in conjunction with miscellaneous community groups and neighborhood associations to help disseminate information and assure attendance at public meetings; Emailed blast of Action Plan hearings schedule to current City of Miami funded public service agencies, housing developers, and constituents who have signed up to receive outbound departmental communications (approximately 1,000 subscribers combined). 5. Utilized the Neighborhood Enhancement Team (NET) Offices to advertise and market the public hearings to the local communities; Action Plan schedule flyers sent to NET's list of community contacts which include their individual residents and community activists (approximately 500+ persons). 6. Channel 77 (City -run cable station) broadcast Public Service Announcements with Action Plan schedule, in English, Spanish, and Creole. On May 8m, an ad was published in the newspaper of greatest circulation, The Mkon/ Herold, advising the public of the A|'s draft being available at the D[ED's main office and on the vvebsite, starting on that date and of the 30'day comment period and how to properly submit written comments to the deft (via e-mail or the U.S. Postal System). This assure the D[ED that residents had an opportunity to provide input and review the proposed polices in the Al. The same ad also advised the public of the DCED presenting the final draft to the City Commission on June 11, 2015. DRAFT -eorn-2n20 Analysis mImpediments wFair*ovsin Choice 6 PUBLIC INPUT SURVEY For the first time ever, the Department drafted and issued an 18-cluestinn general, fair housing survey for housing stakeholders in the City. It blasted the web -based survey link via e-mail to its list of developers, activists, community organizations and Departmental twitter — amounting to a total ot7OO persons or so. It also posted the survey link on its main web page. It forwarded the link to the Miami Realtors Association for dissemination to their members aswell. After60 days, 57 surveys were received. The most interesting data gathered from the results isnoted below — * 5096 felt that fair housing laws were not adequately enforced in the City; * 37%we/e Miami renters; 6I96were homeowners; * close to 90% of respondents said they were familiar with fair housing laws; * 9096 believe housing discrimination isan issue in Miami; � 34Y6said they thought they had personally experienced discrimination; ° Over 50Y6had heard ofrecent fair housing violations inthe news. REAL ESTATE PRACTICESThe Miami Association of Realtors is the local organization of real estate brokers which encompasses both Miami -Dade and Broward County (including operating within the City of Miami) and includes more than 30,000 members (agents). It has an open membership policy and does not discriminate. Members are bound by the Code of Ethics and Standards of Practice of the National Association of Realtors (NAR). In order to become a Florida realtor, a 63-hour sales association pre- licensure course and subsequent exam are required. Following that, sales associates are required to complete a 45-hour post -license course within the licensee's first renewal cycle. After that, in order for realtors to maintain their licensing in the state, they must annually complete a 14-hour continuing education courses (every other year) which include fair housing education. Multiple options are provided to realtors as part of these CE courses related to affordable housing programs and fair housing requirements. NAR's Code of Ethics obligates' professional standards including efforts to affirmatively further fair housing. Specifically, Article 10 of that Code elaborates on a relators' duties tothe public which include: ° ''RealtorsO shall not deny equal professional services to any personfor reasons of race, color, religion, sex, handicap, familial status, national origin, sexual orientation, or gender identity. Realtors' shall not be parties to any plan or agreement to discriminate against a person or persons on the basis of race, color, religion, sex, handicap, familial status, national origin, sexual orientotion,'or gender identity. (Amended 1114) m xeoltoo~ in their real estate employment practices, shall not uocnm/nuteogomotany peoono/ persons on the boss of race, color, m»g/n/\ sex, handicap, familial status, national origin, sexual orientation, or gender identity. (Amended 1114) The NAKenforces its Code of Ethics through a disciplinary commission consisting ofNAR members. If a person believes that a realtor has violated one or more Articles of the Code of Ethics, they can file an ethics complaint alleging a violation(s) through the local association of rea|tors where the /ea|torholds membership. During the development of the Al, several communications were shared with administrators of the Miami Association of Realtors who reported that the organization is very conscious of Fair Housing Law and prohibited practices, such as steering. Members refer clients with sensitive questions on DRAFT —2015-202oAnalysis of Impediments mFair Housing Choice 7 neighborhood features to sources of impartial data. While preparing for the updating of its A], the City ofMiami reached out tothis organization for its input on any fair housing impediments they have identified in the City's real estate market. After discussions, it was agreed that the City would co -host a forum for those rea|too interested in participating that would address fair housing concerns amidst other topics. An e-vite was issued to all realtors working the low- to middle market in the City of Miami by the Miami Realtors Association. The forum was held on Monday, November 24,2O14atCity Hall inCommission Chambers. Some 20nea|to/sattended and ameaningful dialogue was shared between D[EDadministrators and the nea|tors. All comments were noted and have been incorporated into this document and one particular impediment was identified based on these conversations and this public meeting. Laxvs—StateandLoca| On a State level, Chapter 760ufFlorida Statutes delineates that "it is against the law to discriminate in the sale, rental, financing, appraisal, or insuring of housing, in the provision of real estate brokerage service, or in the advertising of a dwelling on the basis of race, color, religion, sex, national origin, handicap or familial status (families with children under 18, pregnant women and people securing custody of children under 18). Steering and blockbusting are also illegal. In addition, it is against the law to fail to design and construct new multi -family housing in an accessible manner, or to refuse certain modifications or accommodations to persons with a mental or physical disability." The Florida Building Code, with a 2014 draft currently under public review, provides specific instructions on the legal requirements of making buildings accessible. Aside from this, the Florida Fair Housing Act, which parallels the Federal Fair Housing Act, declares itillegal todiscriminate inthe oa|e,renta[advertising, �nancin��nrproviding ofbrokerage semices forhousing. O level, '` discriminationcomplaints (including those related tnfair housing) are filed with the FloridaRelations, who are tasked with the investigation and resolution of discrimination complaints in the areas of: ° Employment ° Housing ° Pub|�cAccommodations ' Florida's Whistle -blower's Act The of Miarni does not have a fair housing ordinance in its Municipal Code, but looks and adheres to Miami -Dade County's Code to define unlawful housing practices. Miami -Dade County's civil and human rights ordinance, codified as Chapter 11A, (Article 11, Sec. 11A-12) of the Miami - Dade County Code (as amended by the Miami -Dade County Commission in December 2014), specifies the classes protected from housing discrimination in Miami -Dade County (and as such, in the City of Miami). These are as follows: race, color, religion, ancestry, national origin, sex, pregnancy, age, disability, marital status, familial status, gender identity, gender expression, sexual orientation, mrsource ufincome. As an entitlement, the D[ED already adhered to HU[/s Equal 4znass Rule (NOTICE P|H 2014'20 HA) as issued on AugustZ0, 2014vvhich requires HUD's assisted and insured housing programs are open to all eligible individuals regardless of sexual orientation, gender identity ormarital status. Also, the City adheres to the Violence Against Women Reauthorization Act of2Ol3 (VAVVA3O13) While VAWA amendments in 2005 provided protections to eligible residents of public housing and residents of the Section 8 tenant -based and project -based programs, other HUD programs were not covered. VAWA 2013 expands protections to some other HUD programs. The prograrns newly DRAFT -zn10-2n20Analysis ofImpediments to Fair Housing Choice 8 covered by VAVVA 2813 include H0PVVA, HOME, Section 202, and K8cKinney4/ento Homeless Programs (Emergency Solutions Grant, Continuum ofCare). The County unit responsible for adherence to the civil and human rights ordinance is the Office of Human Rights and Fair Employment Practices and its related &Y/unni-Dode County Commission on Human Rights, a quasi-judicial advisory board of18volunteers, including attorneys. Residents of the County can file a complaint directly with this entity which has the legal rights to investigate it, mediate it, issue aprobable cause finding, etc. The Commission also has under its purview fairness and equal opportunity in employment, public accommodations, credit and financing practices, family leave and domestic violence leave. We have reached out to this entity several times requesting data related to housing, but have received no response. DRAFT —m15-202nAnalysis of Impediments mFair Housing Choice 9 A '� U 'A U�~l� U U �� U | �X ��—�� v��'� n^ CONTEXT FOR A FAIR HOUSING DISCUSSION � Title VU|ofthe Civil Rights Act ofI968(Fair Housing Act)'asamended, prohibits discrimination in the sale, rental, and financing of dwellings, and in other housing -related transactions, based on race, color, national origin, religion, sox, familial status (including children under the age ofl8living with parents or legal custodians,t women, and people securingcustody ofchildren under the age ofl8\,and handicap (disabi| ) report provides a profile of the protected classes in the City of Miami and other related general information. SOCIAL TRENDS One aspect of assessing fair housing involves determining the representation of protected classes in the population and determining if any socio-economic disparities exist. Miami's residents are of an unusually diverse ethnic and racial background, with a large share of foreign born residents, among the poorest in the nation and an increasingly aging population of persons 65 and over. In the following sections, these and other social trends in the City of Miami will be reviewed, with most data pulled directly from the 2010 Census. Appendix 1 includes several maps providing visual representations of the distribution of the population throughout the City's limits. POPULATION GROWTH` | The t state of`Florida has seen significant population growth in the past decade. In December 2Ul4,the Census figures that indicate thatF|o/ida'spopu|ationsurpassed New York's, making it the nation's third largest state with an estimated population of 19.7 million persons. Miami -Dade County and the City of Miami have also seen significant growth and the 2010 Census showed early signs of a significant shift in the area's composition when compared to data from the 2000 Census, signaling what many predict will be steady population growth in the City during the next decade. According to the Census, 15% of the growth in Miami -Dade County between the 2000 and 2010 Censuses can be attributed to tile City of Miami, whereas in prior decades the average population contribution from the City within the County was 4%. According to the latest population estimate frorn the Census' Population Estimates Program (PEP), the City's population (2014) sits at 408,750. It is difficult to anticipate if this population spike will continue and also to speculate if the demographic trends that emerged within the past decade —which are detailed further into thisdocument—vviUcontinueorchange.However, itbears mention that interms ofland area, Miami is one of the smallest major cities in the U.S., encompassing a total area of 55.27 square miles, with some 36 miles ofland and the remainder being water. This means its reported population on just 36 miles makes it one of the most densely populated cities in the U.S., along with New York, San Francisco, Boston, Chicago and Philadelphia. It is important to address this congestion, because the D[ED believes it relates directly tothe recent massive wave ofvertical development that has taken place inthe City. DRAFT —co/n-2ozoAnalysis uvImpediments mFair Housing Choice 10 Table 1 offers a comparison of the Citys population in 2000 and I010 amongst racial and ethnic populations. The data makes several things clear: (a) the City gained White, non - Hispanic population; (b) the City lost Black/African American population; (c) and, the City lost persons of two or more races (both Hispanic and non -Hispanic). In later sections, we will compare City statistics to the region (Miami -Dade County) and the State of Florida to understand ifour area isunique. Table 1: RACE AND ETNN|CITY, 2OO8vs. 2D1OCe Census City of Miami 2000 2010 Change 2000-2010 Number Percent Number_ ^ Percent Number Percent Not Hispanic srLatino 124,119 342% I20,001 30.0% -4,118 -33% White 42,097 11.8% �47,622 `11.9% 4`725 11.0% Black, African American 32,190 29.9% 64,993 16.3% -7,197 -10.0% Other Race 2,930 0.8% 4`744 1.2% ��, 1,814 61.9% Two orMore Races 6i102 1.7% ` 2,642 0.7% -3,460 -56.7% Hispanic or Latino 238,351 65.8% 279,456--^ 70.0% 41,105 17.2% White 198,573 � 54.8% 242,w'8 60J% 43'725 22.0% Black, African American 8,668 �2�4�� '� 1�887 � `/� 3.0% 3,219 37.I�� Other Race , ' / � ` 24030 ' ^' 55% 17,173 43% -2,857 -I4.396 Two orMore Races �� ' " 1I�8U 5z76� ' 8,098 ``` `` 2.0% -2,982 -26.9% ` ` Total � 362,470 100.0%` 399,457 100.0% 36,987 10.2% White '��241,470 �66.6Y6 289,920 72.6% 48,450 201% ~ African � American : 0l858 22�Y� 7�88O l93�� -�978 4396 Other Race 22,960 ' 5.3% 21,917 5.5% -1,043 4.5% Two or MoreRaces , RACE &ETHNIC COMPOSITION The City of Miami's designation since the 1970s as a "majority minority" municipality adds a layer ofcomplexity when analyzing data. Miami has a unique context for this discussion because it is among the nation's largest cities with a large share of non -white population. The growth in the minority population inthe City ofMiami islargely due tothe increase in Hispanic and Latino populations. Assuch, the "majority minority" designation does not mean that Miami has become more racially diverse; rather it has become increasingly a city of immigrants from the Caribbean and Latin America. |nZ01U,the Census found that the growth of the Hispanic population continues and now comprises 7096 of the cit/s population. This snapshot is not unique to our area. In fact according to vvvvwmigrationpo|icy.oqq, the U.S. Census 8ureau's pooled 2008'2012 A[S indicates that Miami -Dade Count/o immigrant Population is the second highest of any County in the nation with an approximate number of DRAFT —zo/n-2oonAnalysis nfImpediments mFair Housing Choice /Y 1,285,200 persons. As noted by the non'profit, the term "immigrants" (or "foreign born") refers to people residing in the United States who were not U.S. citizens at birth. This population includes naturalized citizens, lawful permanent residents (LPRs), certain legal nonimmi8rants (e.g, persons on student orwork visas), those admitted under refugee or asylum status, and persons illegally residing in the United States. The State of Florida ranks fourth (of all U.S. states) in immigrant population with approximately 3.64 million persons total. The latter means that many of our residents come from countries where fair housing policies differ o/don't exist atall. This lack ofknowledge orawareness offair housing rights creates an automatic impediment that other communities do not have to address. According tothe most recent Census, the Hispanic population's wth over the past decade outpaced the growth rate of the city as a whole; the dt/s population grew by 102 percent, while h Hispanic | i by 17.2 percent. Different from past decades, the White Non -Hispanic population also experienced growth, adding over 11,000 people to the city, to now make up 11.9 percent of the population. This is important because the only group to continue to lose population, when comparing the 2010 Census to the 2000 Census, is the Black community. In the last decade, Census figures indicate that the Black population in the City of Miami fell by almost 4,000 people to now make up 19.2 percent of the population. In addition to the changes described above, there is one other aspect to the racial and ethnic composition of the city that bears noting. Due to changes in the Census survey since 2000, race and ethnicity are two different categories. Since the Hispanic population in the City of Miami is significantly large and can additionally select a race in the census survey, the traditional racial categories become skewed. For example, the 2010 Census found that there is a White population of 289,920 (72.6%); however, 84 percent of that White population is Hispanic. To a much smaller degree, there is also a portion of the Black population that is Hispanic —approximately 15 percent. In Appendix 1, maps prepared by the City of Miami Planning Department illustrate the population distribution amongst major racial/ethnic groups in the City, based on the 2010 Census. The map shows that the Black population is clustered north of downtown Miami while the Hispanic population is concentrated in the Southern and Western areas of the City. Meanwhile, the white, non -Hispanic population seems to primarily be concentrated on the easternmost border of the City (near the water). This polarization — which has long existed — creates challenges for the City in furthering fair housing choice. Demographic patterns of income, race and ethnicity reveal great disparity and insular racial and ethnic enclaves. Table 2: Growth Rate by Race and Ethnic ty, 2000 to 2010 RACE #Change %[hange Total population 36,987 10.2% One race 43'429 13.6% White 48,450 20l% DRAFT —uo/n-2nznAnalysis mImpediments to Fair Housing Choice 12 Black orAfrican American -3,978 -4.9% American Indian and Alaska Native 385 47.5% Asian 1,577 66.4% Native Hawaiian and Other Pacific Islander 45 '34.6% Some other race '2'960 -15.I% Two or more races f6,442 '37.5LA HISPANIC OoLxTmm Number pe,peru Total population 36'987 102% Hispanic or Latino (of any race) 4].l05 17.2% Mexican 2'161 % Puerto Rican 2'532 ��247% Cuban 13,538'��`�10.9% Other Hispanic nr Latino 22,874 ^ ~' 2p`` 0otHispanicorLot/no ^^^` ' ^'-4,1I8 ~ '3.3y6` White alone 1' 725 I1.0Y6 The bar graphs below take a closer look at the Hispanic and Black populations and their growth rates from 2000 to 2010, compared to the region and state. As noted, the City and County's growth rates in the Hispanic population from 2000 to 2010 are both outpaced by Florida's growth rate in this ethnic category, which saw a 57.4% as a state. Regionally, both the City (Miami) and County (Miami -Dade) lost Black population from the 2000 to 2010 Census, with Miami's drop much more significant. The Statelof Florida, however, saw solid growth in the Black population (25.9%). Hispanic or Latino Population by Region, 2000 to 2010 City ofMiami Miami -Dade COLIntY State of Florida DRAFT —zn,n-2nzoAnalysis orImpediments toFair Housing Choice 13 Black, African American by Region, 2000 to 2010 City uiMiami m Miarni-Dade County State of Florida zommof Population eGmwth Rate 2000 to200 Dissimilarity Dissimilarity (and/or make up a larger area. The index score can also be interpreted as the percentage of one of the two groups included in the calculation that would have to move to different geographic areas in order to produce a distribution that matches that of the larger area. The index of dissimilarity can also be used as a measure of inequality. 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 moderate levels of segregation. For this particular topic, the City looked closely at Brown University's US 2010 reseorch project4, where it is noted that the Miami - Miami Beach —Kendall area scored a DI of 73, the 7'� highest score amongst the top 50 metro areas in the U.S, with the largest Black populations in 2010. In 2010, the City of Miami's (jurisdiction alone) DI was 75.5. the evenness with which two groups are distributed across particular geographic areas that segregation in Miami has been consistently high since 1980 (first decade analyzed in the report*) and the value has oscillated around the mid-70s for over 30 years. The national average for metropolitan areas is in the range of 60-65. The U.S. national average of dissimilarity levels has been declining slowly but steadily, about 10 points in two decades, so it is unusual to see Miami's averages not follow suit and remain consistently higher than the norm. When analyzing White -Hispanic segregation, the number has also climbed 10 points in the past 38years, from a4O.9 to 50.3 value. The current value isspot on with the national average ofS0for Hispanicswhichisconsidered amoderate level ofsegregation. The Hispanic - White D| in the City has also increased since 1980, and in the 2010[ensus hit SO.3,which is considered a moderate level of segregation. Meanwhile, the 0 in the Miami -Miami Beach - Kendall area for 2010 was much higher, 75.9 — making it the 5m of the 50 Metro Areas with the Largest Hispanic Populations in 2010. ' American Communities Project, Brown University, http:i/www.s4.brown.edu/us2Ol 0/seqreqation201 O/Default.aspx DRAFT —zn15-20z Analysis n/Impediments mFair Housing Choice 14 History indicates that "large southern cities provide examples of persistent segregation." s It has proven difficult for researchers to pinpoint why integration has seemingly slowed down across most ofAmerica. Some conjectures byresearchers include: /l\asignificant part ofthe white population that is unwilling to live in neighborhoods where minorities are close tothe majority of the population (aka white flight); (2) possible se|f-segregation' such as particular choices immigrants may make about where they want to live based on areas where others of their ethnicity, national origin, and/or first language reside (the establishment of ethnic neighborhoods); (3) and affordability, and the often extremely disparate cost ofhousing in certain cities. ' � _ wm��I a &.115 1 a c k.-Vmi [ e- \Nbxe-Kspani c/H is pan irAfVh ite- vm/te-Aaivo,1Aoiv"-1,^hite- u|uuk-mspm"c�mopanic-a/mox- o/nok-Asi^n,'Avion-Blaok mop,mc-/�,siun2w,,;iun-*ispmnic- � Aw",o� 21) 40 m so 1100 �m ��z�uuy�s ��m / � m� w� Impediments toFair Housing ChoiCity of Miami ce EDUCATIgreat ON ' ~ Education is an area of concern in the State of Florida ' and in Miami as kallows for successful job placement, development, and resident retention. In the City ofMiami, dose to 3 of the population d less than high school degree, much higher than the averages of both the County and State. The data indicates that2Z.496ofthepnpu|adonhadaBache|or's degree orhigher with the majority fthose personsbein8VVhiteorAsian. Table 3. Educational Attainment " Miami Miami -Dade County Florida Less than High School 29.6% 21.4% 14.0N High School Degree nr Higher 70.4% 78.6% 86.0% White 937y6 93.7% 91.0% Black nrAfrican American 65.4% 753% 79.1% American Indian and Alaska Native 687% 75.7% 5 Jownn. Logan and Brian Stuus.mo11. "The Persistence mSegregation inthe Metropolis: New Findings from the co1OCensus" Census Brief prepared for Project uSzn1u.mtp://vwvws4.bmwn.cmmbozn1o. , Segregation inAmerica: Dragging onand on.^Feb. 2011.»xp:8=wwopr.nrg/2011/02/18/133848837/segregadon' in-america-dmogng-oo*nd-on DRAFT -oo/oencoAnalysis n/ 15 � Asian 75.7% 86.0% 85.2% Hispanic or Latino 66.6% 75.1% 75.0% Associate's Degree (2-year) or Some College 18.2% 24.0% 29.8% Bachelor's Degree (4 year) or Higher 22.4% 26.1% 26.2% White 56.2% 47.8% 29.3% Black or African American 9.7% 14.3% 16.1% American Indian and Alaska Native 16.6% 15.6% Asian 58.8% 50.6% 45.7% Hispanic or Latino 18.4% 22.9% 20.8% Graduate or Professional Degree 8.2% 9.6% 9.4% (Source: 2010-2012 ACS 3-year estimates). ISOLATION Isolation also merits a closer look. Defined as the percentage of a particular minority in neighborhoods where the average minority group member lives, the Miami -Miami Beach - Kendall area indicator is 56.6. In 1990, the level was 61.1. As reported by The Miami Herald in an article published in May 2014 [7], isolation is also widely found in the local school system operated by Miami -Dade County Public Schools, where an analysis showed that "dose to half of Miami-Dade's roughly 460 traditional and charter schools now meet the bar the court once set to define 'isolated' - comprised of 85% of one racial group." The article further mentions that the diversity of many public schools is mostly defined by their surrounding neighborhoods which have also become increasingly isolated. White -White Black -Black Hispanic -Hispanic Asian -Asian "4 /4, /e,Bd,4ededeed' .4"C 2.1.7 2.S.5 4.4 2.€ 43,4 Alrvvxdr 20 LINGUISTIC ISOLATION 40 60 SO 100 1112 1.925 199'2 1115 2000 2005-09 ACS UM 2:010 7 David Smiley, May 19, 2014, 'Re -segregation trend: 60 years after ruling, dozens of Miami -Dade schools remain 'isolated,' The Miami Herald. DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 16 To understand linguistic isolation in Miami, we must first understand that the leve I of diversity in Miami is significantly higher than that seen across most other parts of the country. The Census estimates from 2007-2011 indicate that an astounding 58.4% of Miami's population is foreign born and 77.596 speak a language other than English at home (ages S and up). Meanwhile, the state of Florida's foreign -born population is drastically lower — 192Y6 — and its population of persons speaking a language other than English at home is 27%. The national averages are even |ovver—ond data indicates that approximately 20Y6 to 2196 of persons in the country speak alanguage other than English athome. Linguistic isolation is another thing all together. According to the Census, "a linguistically isolated household isone /nwhich nuperson age 14years orover speaks English ot/eurt^vp/y well.' That is no person age 24 or over speaks only English at home or speaks another language othome and speaks English "very m/e8^|t makes sensethat inanarea where many persons are foreign born, that levels oflinguistic isolation will behigher. While h not itself a protected class, it is related to ' ^ national origin and may affect an individual's ability to comprehend basic information pertaining to housing and housing opportunity if information is provided only in English. As indicated in the table below, ACS 2007-2009 estimates indicated that 35.4% of Miami's Spanish speaking population is linguistically isolated. Table 4:Household Language by Miami, FL inguistic Isolation Household Language Miami Share Households Total Households ,162,726 English only ! 38,224 23.5% | SpanishI12,534 69.2& —L/ngu��co0y8o/oted ! 57,525 35.4% —Nutlinguistically isolated 55,009 33.8% Other Indo-European languages 10'170 62% --Linguistically Isolated i 3,789 23% � —Not linguistically isolated 6,381 3.9% Asian & Pacific Island languages 945 1.6% --Linguistically Isolated 352 02% —Notlinguistically isolated 593 0.4% Other languages 853 0.5y& —L/nguisUto0yIsolated ! 124 0.1% —Notlinguistically isolated ' 729 0.4% Source: US Census Bureau, Arnerican Community Survey 2007-2009, 3-year estimate (1316002) LIMITED ENGLISH PROFICIENCY (LEP) PERSONS DRAFT —cu/n-2nzoAnalysis uvImpediments mFair Housing Choice 17 Persons who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English can be Limited English Proficient, or''LEP.''To be clear, the Census Bureau does not define the limited English proficiency or non -limited English proficient populations. The Census Bureau reports data based on the four categories of English speaking ability very well, well, not well and not atall. Aaindicated below, the Census indicates that 35.5% of the households in the City of Miami meet the criteria they define as "being a household where no one age 14 and over speaks English only or speaks English "very vveU"," with the bulk of that consisting of Spanish speaking households (47.4Y6)' followed by other Indo-European languages (3Z.896). Because asalready explained, Miami iscomprised ofmany immigrants d we are a"minority majority" City, the DCED followed HUD's recommendation and conducted a preliminary LEP assessment in accordance to the final guidance issued to Federal Financial Aszistonus Recipients Regarding Title V1 Prohibition Limited English Proficient Persons, Fed. Register, Vol. 72, No. 13, Jan. 22, 2007. That assessment utilizes the four factor method: (1) The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or grantee; (2) the frequency with which LEP persons come in contact with the program; (3) the nature and importance of the program, activity, or service provided by the program to people's lives; (4) and the resources available to the grantee/recipient and costs. Based on our City's population, the DCED concluded that the different, existent (already in place) language assistance measures are sufficient for the different types of programs or activities in which the DCED engages. More specifically, all tenant -based rental assistance programs (Section 8 HCV, Section 8 moderate rehabilitation and HOPWA Long-term Rental Assistance (LTRA)) have all materials translated to Spanish and Creole. The City also makes every attempt to translate Housing materials for the public to both Spanish and Creole, as well. The DCED's automated program phone line provides up-to-date information in both English and Spanish, and a dial in option for Creole speakers. RACIALLY ETHNCIALLY CONCENTRATED AREAS OF POVERTY (RCAP/ECAP) The U.S. Department of Housing and Urban Development (HUD) defines a Racially Concentrated Area of Poverty (RCAP) as an area with one or more census tracts that contain the following characteristics: (1) a family poverty rate greater than or equal to 40 percent, or a family poverty rate greater than or equal to 300 percent of the metro region's tract average, whichever is lower; and (2) a non -white population that is greater than 50 percent (i.e., 51 percent or higher). Please note, because Miami is a minority -majority City where the bulk of our population is Hispanic, we DO NOT include census tracts where over 50% of the tract is Hispanic. Nine tracts in the City qualified as an RCAP based on data pulled frorn the 2010 POVERTY Although poverty is not protected class, itdoes fundamentally affect a person's/f mi|y's ability to rent or purchase a home and to become economically mobile. Tothat end, an analysis of poverty levels in the City of Miami bears mention. The U.S. Census Bureau, 2009- 2013S'YearACSestimatesthatZ9.g96ofMiami'spopu|ationisbe/ow/thepnverty|eve|,that's dosetoone'thirdofitsresidents.Thenationa|averaReisdnsetnha|fofthat—lS.4%,vvhi|e inFlorida 163%ofthe total population isbelow the poverty level. DRAFT —201n-2o20Analysis mImpediments to Fair Housing Choice 18 As noted in table 6 below, nearly half ofthe population in the City determined to be below the poverty level is Black (469&). Hispanics (of any race) comprise approximately 28.5% of those persons in poverty. Table h:POVERTY STATUS |NTHE PAST 1ZMONTHS (|ND|V0UAL5) 2009-2013 ACS 5-YEAR ESTIMATES Total Population for who poverty status is determined Race and Hispanic orLatino Origin One race White Black orAfrican American American Indian and Alaska Native Asian Native Hawaiian and Other Pacific Islander Some other race Two or more races Percent below Poverty Level WMAOM 29.9% Hispanic orLatino (of any race) ~�28.5% White alone, not Hispanic orLatino 13,8% . The b| below d data related poverty according to the 2009-2013 ACS 5-Year Estimate. As expected and as is most prevalent, poverty is most seen amongst female headed households with children under 18 years of age. Table 7:POVERTY STATUS |NTHE PAST Percent 12MONTHS (ALL FAMILIES) below %OO9'%013A[55'YEARESTIMATES Poverty Level 779740 All Families With related children under 18 years Married -couple families With related children under 18 years Families with female householder, no husband present With related children under l8years 16.9% ZZJ% 39.9% Besides this, as noted in the Family Assets Count, a study issued in December 2014 by the Corporation for Enterprise Development (CFED) in partnership with City Community Development, 67Y6 (roughly two-thirds) of Miami's residents are liquid asset poor. The latter DRAFT —2n10-2nz0Analysis mImpediments mFair Housing Choice 19 means that there is no padding in the household budget and that the family is living from paycheck to paycheck. This also means that these households are unable to save for the future, as explained in the study, "the inability to bounce back from financial pitfalls not only hurts Miami families, itstifles the dt/slong-term economic growth."n City leaders and the City's five commissioners are aware of the City's poverty levels and have engaged in multiple public discussions on how to address the matter. In September 2014, the Commission set aside $1.25 million towards anti -poverty efforts for the following fiscal year. In early Z815they approved a plan to allocate this earmarked anti -poverty money amongst the dt/s five districts, proportionate to the percentage of poverty levels based on the five- year poverty rate as determined by A[S data, thereby sin8 need more directly. Concurrently, the city manager's office researched programs where money could be allocated including job training programs. Outside of this effort, Miami continues to operate its much lauded ACCESS Miami program, Developed just over a decade ago out of what had been the then -Mayor's Anti -Poverty Initiative, City leaders united multiple poverty initiatives that had been successful or were showing potential, and combined these into one cohesive yet flexible program that could be tailored to respond to the demands of Miami's unique community where language and cultural differences abound. Known as ACCESS (Assets, Capital, Community, Education, Savings and Success) Miami, the program is a comprehensive, cost effective poverty reduction strategy aimed at increasing residents' access to the financial tools and education that are fundamental to economic prosperity and success. In order to meet these goals, ACCESS Miami runs several different programs. They are grouped around the program's four cornerstones:(I) Access to benefits: (a)tax preparation assistance (EITC campaign) at several locations; (b)The Benefit Bank;(c) Access Miami Jobs web site, www.miamigov.com/accessmiamijobs; (2)Access to Capital for Small Businesses: (a)Micro- lending in cooperation with the local Small Business Administration office; (b) Buy Miami marketing effort, www.miamigov.com/buymiami; (c) Minority Business Development Agency (MBDA) Business Center in cooperation with the U.S. Department of Commerce, www,mbda.gov/businesscenters/miami, which provides strategic business consulting services to minority -owned firms resulting in the creation and retention of jobs; (3) Accumulating Wealth & Assets: (a) Matched Savings Fund; (4) Improving Financial Literacy: (a) Access to, Financial Education (free trainings for the public); (b) Pastoral Roundtable meetings (hosted quarterly in orderto disseminate information to the public in the inner city); (c) Financial Coaching. INCOME INEQUALITY The latest U.S. Census Bureau data indicates that overall, big cities remain more unequal places by income than the rest of the country. As detailed in a recent Brookings Institute study where big cities' 95/20 ratios were analyzed, Miami was the City with the third highest 95/20 ratio — topped only by Atlanta, GA and San Francisco, CA. The 95/20 ratio is defined as the income at which a household earns more than 95 percent of all other households, divided by the income at which a household earns more than only 20 percent of all other households. The average 95/70 ratio for the country osa whole is9.l, while Miami's clocked in at 157 based on an analysis by the Brookings Institute of2Ol2 American Community Survey (ACS) data. Cities with high income inequality "may struggle to maintain mixed -income school ^vmwwjami|vansetscount.nrg DRAFT —zo/n'zozoAnalysis o,Impediments to Fair Housing Choice City nrMiami 20 environments that produce better outcomes for low-income kids. It may have too nannvv a tax base from which to sustainably raise revenues necessary for essential city services. And it may fail to produce housing and neighborhoods accessible to middle-class workers and families, so that those who move up or down the income ladder ultimately have no choice but tomove out"» The Brookings study went on to indicate that Miami's ratio is high primarily because its poor households have such low incomes -- a household in the bottom 20th income percentile earned approximately $lO,40Uayear in2O12. Less than $m,0oo $10,000to$14,9e9 s15,00t,$z4,yys $25,000u,$34,999 $35'000to$49'999 $50'000m$74'999 $rs'nnoto$yy'yys $100'000tu$149'e99 $150'000tu$199.ee9 $2oo'000u,more U Income byHousehold City ofMiami, 2OOV&20O7-011 Source: u.s.Census Bureau, zmmCensus mumpzm11 mz 2000 Census 9 AGE' Of large cities of 100,000 persons or more, the City of Miami ranks as the 1011h place" in relation to the number of residents aged 65 and over, with the total amounting to 63,987 (16%) of the total City population. This percentage is high, but is in keeping with the age 55+ population across the state of Florida -- where an estimated 3.25 million persons aged 65 and older live (17.3% of the total population), giving the state the second highest number of persons in this age group ofany of the states. This is worth noting because elderly populations are often limited as to public transportation options, tend to require more health -related services and potential in -home care or supportive housing. Furthermore, many elderly persons who are retired are on fixed incomes and may have o diminished ability to afford housing and a greater tendency to be in low-income categories. According to U.S. Census Bureau, 2007'20I1 American Community Survey 5-Year Estimates, Selected Economic Characteristics (ACS), 32.4% of individuals age 65 and over in the City have income in the past lZ months that is below the poverty level. When looking specifically atthe number nfCity residents who are aged GZ years and older group, the percentage hikes up to 18.9% of the population (75,474 people) in the City of vAll Cities are Not Created Unequal, enmboFeb. un.on14 '" Note: places of1nn.00nnrmore total population. Source: u.s.Census Bureau, uo1OCensus Summary File DRAFT —zn,5-2nooAnalysis orImpediments to Fair Housing Choice 2/ City o/Miami Miami. While the City's higher age groups tend to climb in numbers, its younger age groups have not. In fact persons aged S to 9, 10to 14, and 15 to 19 years of age all dropped in the general population from 2OOOto2O1O. Table 8:Growth Rate byAge inMiami, zVO0toIO10 Subject #[hange — Change Total population 36,987 10.2% Under 5years 2,660 12.5% Sto9years '2'890 'l3.2% IOtoI4years '3,818 '172% 15tol9years I.259 '5.6% 2Uto24years 5'605 243% Z5to34years 11'560 21.3% 35to44years 3'787 6.8% 45to54years I1,780 26.6% 55to59years 5'244 292% 6Uto64years 2'099 1I.8% 6Sto74years '153 -0.5� 75toD4years I'607 7.6% D5years and up 770 92% 18years and up 42,338 14.9% 2Iyears and up 41'816 15.5% O2years and up 3,292 4.6% 65years and up 2'219 3.5% FAMILIAL STATUS According to the Fair Housing Act, unless a building or community qualifies as housing for older persons, it may not discriminate based on familial status. Familial status is defined as families with children under the age of 18 living with parents or legal custodians, pregnant women, and people securing custody of children under the age of 18. The decade households in the City of Miami. The City lost family households. It isworthy tonote that the family households did grow over the past ten years, but only modestly. On the other hand, non -family hmuseho|ds^—watan impressive 34.1 percent during the same time period. In particular, the greatest gains in non -family households were among those living alone. Along this same vein, the only household type that lost population were families ofmarried couples with children. This information is confirmed by the age table that illustrated how the number of children has fallen within the City of Miami. When compared to the region, the loss of this household type was most pronounced inthe City. DRAFT —2015-202oAnalysis of Impediments to Fair Housing Choice 22 Type of Households in the City of Miami, 2000 and 200 o 201 n [% 20% 40% 60% 0% 100% m � Family households m mnnfami|vho"seho|ds Source,-U.S. Census Bureau, 2000 & 2010 Census, Summary File I Table 9: Growth Rate by Household Type ZO0Otu 2010 2010,��y' 2000 "ee` Percent Change HOUSEHOLDS 8YTYPE Number Percent Number Percent Number Percent Total households 158,317 IOO 134,198 100 24119 18.0% Family households (fami|ies) 90,032 56.9 83'281 62.1 5'751 8.1% With own children under I8 years 35'903 22.7 35,277 26.3 526` 1.8% Husband+mifefami|y (2010)/K8ar/ied'coup|e fami|y(2OOO) 49'6I0 313 49'139 36.6 471 1.0% With own children under 1J years 18,515 11.7 19,741 14.7 '1,226 '5.2% Female householder, no husband present 28,633 18.1 25,029 187 3,604 14.4% With own children under 18years 13,213 83 12,357 92 856 6.9% Nonfami|yhouseho|ds 68,285 43.1 50\9I7 37.9 17'568 �41% Householder living alone 52'644 33] 40\834 30.4 11'8I0 28.9% Householder 65years and over 17,812 332 16,723 123 1'089 6.5% Households with individuals under I8years 43'304 27.4 42'360 31.6 944 22% Households with individuals 55years and over 47'428 30 44`729 333 2,699 6.0% Average household size 2.47 (X) 2.61 (X) (X) (X) Compared to the region, the married couple household is exceptionally low in the City of MiamiThe|nvvgrnvvhrate (l.O%)inthishousehold type between IUOOand20lOsigna|sthat this trend will most probably remain steady. |tisalso interesting to note that the percent of single women households trends higher in the City than in both the County and the State. Table IO:Household Type by uegion'IO10 DRAFT City ufMiami Miami -Dade County Florida Family households (fami|ies) 90'032 100.00% 602,911 I00.0% 4'835'475 100.0% —zn/o-2o20Analysis ofImpediments m Husband+wifefami|y (2UlO)/Married-couple family (2000) 49,510 55,11A 380,24I 63.1% 3,457,149 71.50% Female householder, no husband present 28'633 51DY, 162,937 27.0% 1,005'042 20,80Y6 PERSONS WITH DISABILITIES The Fair Housing Act provides additional protection tothose individuals that have physical or mental disability (including hearing, mobility and visual impairments, chronic alcoholism, chronic ta| illness, AIDS, AIDS Related Co | d mental retardation) that substantially limits one or more major life activities. The Fair Housing Act has three broad purposes in relation to people with disabilities: to end segregation of the housing available to people who have disabilities; to give people with disabilities greater opportunity to choose where they want to live; and to assure that reasonable accommodations be made to the individual needs of people with disabilities in securing and using housing. Sadly, there has been little research done on the disabled population in South Florida and/or Miami so it is difficult to truly identify housing need for this population and we further address this within this document. As indicated in the 2009-2011 American Community Survey (ACS) 3-Year Estimate, of the estimated 51,384 persons in the City of Miami who have a disability (13% of the total In the 65+ age group, the bulk of persons have ambulatory (28.6%) and independent (23.3%) living difficulty. Table 11: Disability Characteristics 20092011ACS 3-Year Estimate* Miami, Florida Subject Total With a disability Percent with a disability Total civilian non -institutionalized population 394,466 51,384 13.0% Population under oyears 24,150 U O Population xm/ryears 49,8I2 1916 3.8% With ahearing difficulty 239 0.5% With wvision difficulty 208 0.4% With acognitive difficulty 1390 2.8% With anambulatory difficulty 198 0.4% With aself-care difficulty 355 07Y6 Population 1xmuwyears 257,389 23841 9.3% With ahearing difficulty 2952 1.1% With avision difficulty 3798 1.5% With acognitive difficulty I1460 4.5% With anambulatory difficulty 12475 4.8% With self -care difficulty 4200 1.6% With anindependent living difficulty 9692 3.8% Population ooyears and over 63,105 25627 40'6y6 With ahearing difficulty 6290 10.0% With avision difficulty 5437 8.6% With cognitive difficulty 10551 16.7% DRAFT —cnr5-202oAnalysis of Impediments to Fair Housing Choice 24 With anambulatory difficulty 18029 28.6% With aself-care difficulty 9162 14.5% With anindependent living difficulty 14621 23.2% ^ Note: Individuals mnvhave multiple difficulties Under Section 504 of the Rehabilitation Act new federally funded multi -family housing projects (including public housing projects) shall be designed and constructed to be readily accessible to and usable by individuals with handicaps. A minimum of five percent (5%) of the tota|dvveUingunitsora<|eastoneunitinamu|ti'fami|yhousingpnject,vvhicheverisgreater, shall be made accessible for persons with mobility impairments. An additional two percent (ZY6)ofthe units (but not less than one unit) in such a projectshall beaccessible for persons with hearing or vision impairments /24 C.F.R. § es to multi -family housing projects (containing five or more dwelling units (2 C.F.R. 6 83] that are designed, constructed, or altered after July 11, 1988. As to local requirements, indicates on its website that Florida is one of only five states whose accessibility codes have been certified by the federal Department of Justice as being in compliance with the Americans with Disabilities Act. The Florida Accessibility Code for Building is available on-line. Building owners may apply to the Florida Building Commission for waivers from the code if faced with extreme or unnecessary hardship in meeting the code requirements, and/or in the event their building qualifies as historical. The 2012 Florida Accessibility Code for Building Construction was adopted (Florida Statutes, Section 553.503) for consistency with the 2010 ADA standards for accessible design. It is 206 pages long. Because of the complexities of balancing the rights of the physically disabled and the technically specific requirements of the built environment, no single agency has been charged with enforcement of all issues pertaining to accessibility. in relation to the Florida Building, Code's Accessibility Requirements, local governments and their code enforcement agencies are responsible for the enforcement of the requirements. Besides this, the City of Miami does have a designated ADA liaison who receives disability discrimination or accommodation grievance forms from the public in relation to accessing City programs, services or activities. After conferring with this liaison, she indicated that she receiv ' ed three formal complaints in 2014 related to parks, streets, sidewalks and the City's trolley service. There were no complaints related to housing. Please note that the City is not a landlord and operates no housing and so housing -related matters concerning "reasonable accornmoclations," are most frequently handled within the landlord -tenant relationship. The City does receive a handful of reasonable accommodation requests from its Section 8 moderate rehabilitation clients, who are based at specific buildings within the City. Achart below indicates a quick recap of those requests during the last several calendar years and their basis, in each case. The bulk of the cases are tied to the client's physical limitations, and a request to be transferred to a first -floor unit. Most of the Section 8 moderate rehabilitation contracts are in smaUer/mid'sizetvvn'story buildings with no elevator. Aside from this, most of the City's Section 8 moderate rehabilitation clients are elderly, and it is not uncommon to find seniors that suffer from some type ofphysical ailment. Table l%:City ofMiami Section 8Mod rehab Reasonable Accommodation Requests (Mod - Rehab) DRAFT —2n15-2020Analysis of Impediments mFair Housing Choice 25 Year Total Requests Request Mental Health Physical Disability (1" Floor) Allergies/Interi or Change to Unit ZOII 4 3 1 2012 1 1 2013 4 1 3 2014 5 Z 3 In June 2014, the Board of Miami -Dade County Commissioners approved an ordinance establishing disabled housing set aside incentives for County funded rental housing projects and horneownership projects, creating Chapter 17, Article X1 of the Miami -Dade County Code. The Code addresses how "as part of any competitive process for the acquisition, constructions or rehabilitation of Rental Housing Projects of Homeownership projects, the County Mayor . . . shall provide additional incentives, including but not limited to awarding extra points to those developers and applicants who prosed up tofivepercent (55vo) additionalset aside units for the Disabled Households beyond that which may be required by applicable, federal, state or local fair housing laws or other applicable laws." In the County Code, a disabled household means any moderate, low, very low (as defined by Florida Statutes) or extremely low incorne households (as defined in 17-131 of the Miami -Dade County Code) that has one or more persons who (a) have a physical impairment or mental impairment that substantially limits one or more major life activities (b) have a record of such impairment; or (c) are regarded as having such an impairment in accordance with the Federal Fair Housing Act, State of Florida Fair Housing Act, and Chapter 11A of the Code of Miami -Dade County. Information jscurrently being proof read by the P&Z department Community Residences (aka Community/Group Homes) The Fair Housing Act makes it unlawful to utilize land use policies or actions that treat groups of persons with disabilities less favorably than groups of non -disabled persons. An example would �beanordinance prohibiting housing for person` ' with disabilities or a specific type of disability, such as mental illness, from locating in a particular area, while allowing other groups of unrelated individuals to live together in that area. In the Olmstead (1999), the Court ruled that "states are required to place persons with mental disabilities in community settings rather than in institutions when the State's treatment professionals have determined that community placernent is appropriate, the transfer from institutional care to a less restrictive setting is not opposed by the affected individual, and the placement can be reasonably accommodated, taking into account the resources available to the State and the needs of others with mental disabilities." Two primary purposes of a group home — especially those for the disabled -- are community integration and providing a non -institutional experience in accordance with the Olmstead Supreme Court decision. By holding group residences to the same standards applied to other residential uses occupied by a family, housing choice for the disabled is not hindered. DRAFT —2015-202oAnalysis of Impediments to Fair Housing Choice 26 In accordance that Community Residences are allowed by right in the same areas (T3, T4, T5, T6) that allow single-family residences, but must satisfy State (Florida) established distance requirements, based on the number of persons (residents) living in the residence. The City ofMiami Zo i Cod (Mi i22) defines these (a) A Dwelling Unit of six orfewer residents that meet the definition in section 419.001, Florida Statutes for a "community residential home" of such size; or (b) A Dwelling Unit licensed to serve clients of the State Department of Children and Families, which provides a living environment for seven to fourteen unrelated residents who operate as the functional equivalent of family, including such supervision and care by supportive staff as may be necessary to meet the physical, emotional and social needs of the residents, as defined in section 419.001, Florida Statutes; or (c) An adult family -care home as defined in section 429.65, Florida Statutes, which provides a full-time, family -type living arrangement, in a private home, under which a person who owns or rents the home provides room, board, and personal care on a 24-hour basis, for no more than five disabled adults or frail elders who are not relatives. A" for the purpose ofaCommunity Residence, may include any persons asdefined inthe following statutes: ^' °Adisabled adult or frailelder asdefined insection 429.65(8) and (9)Florida Statutes A physically disabled or handicapped person as defined in section 760.22(7), Florida Statutes A developmentally disabled person as defined in section 393.063(9), Florida Statutes A non -dangerous mentally ill person as defined in section 394.455(18), Florida Statutes; or ° Achi|d as defined in section 39.01(1I), Florida Statutes A Zoning verification is required in order to confirm State established distance requirements are being required. The State Statutes indicates that, "A home that is located within a radius of 1,200 feet of another existing community residential home in a multifamily zone shall be an overconcentration of such homes that substantially alters the nature and character of the area. A home that is located within a radius of 500 feet of an area of single-family zoning substantially alters the nature and character of the area." All such facilities shall be required to provide a signed and sealed survey to the City's Office of Zoning which demonstrates that the distance limitations required pursuant to state statutes are met. To the extent applicable by state law, the location of a facility may be denied if it results in an over concentration of Community Residences in proximity to the site selected such that the nature and character of the Neighborhood would be substantially altered. The Department of Planning and Zoning works with the State's Agency for Health Care Administration (AHCA) Department, who monitors community homes. Its Division of Health Quality Assurance licenses and/or certifies and regulates 40 different types of health care providers, including hospitals, nursing homes, assisted living facilities, and home health agencies. In 201.3, the City Commission updated its Code via Ordinance 13393 (Ch. 62, Article 15, Sec. 62-650) to -further formalize a procedure for the establishment and regulation of Group Homes of seven to 14 persons, pursuant to Florida Statutes 419 and 429, as amended. The City's Planning and Zoning Department maintains an updated database of all Group Hornes within its boundaries that is updated several times a year to reflect the latest information frorn all participating state agencies. DRAFT —co1n-2o20Analysis orImpediments to Fair Housing Choice 27 As of May 2013, the City had 190 community residential homes withinits geographic limits with sites in all of the City's five districts. Approximately 40% of these homes were in District 4 of the City of Miami. Also, the bulk of these homes are defined as Assisted Living Facilities PERSONS WITH HK/IAIDS The City of Miami serves as the administrator of the formula grant -funded Housing Opportunities for Persons with AIDS (HOPVVA) program for the entire geographical area of Miami -Dade County. The Miami -Dade County metropolitan re has the fourth highest numberof|iving4|D5cases inthe country (the top ranked in orderof highest numberofcases are the metropolitan areas of New York City, Los Angeles, shington, DI]. HIV/AIDS disproportionately affects minority populations in Miami -Dade County, as is the case The goal and intent of the local HOPWA Program is to ensure that a continuum of housing options and related housing services is available to low income persons with acquired immunodeficiency syndrome (AIDS) or related diseases (HIV) and their families to prevent homelessness of such individuals and their families. The City provides Long Term Rental Assistance (LTRA) to approximately 1,000 clients who have AIDS and are 80% area median income (AMI) or below. The HOPWA LTRA and project -based application and waitlist process is managed via one advertised application period, followed by a final waitlist established via a random computerized lottery. At time of application submission, prospective participants must submit a Client Medical Eligibility Form (Form H40), completed and signed by their physician, certifying that the applicant has received an AIDS diagnosis. Said form is part of the application packet. The opening of the waitlist is marketed through the county -wide HIV/AIDS care network to reach persons with AIDS, including but not limited to, Ryan White Case agencies, public hospitals and clinics. The City uses HOPWA monies to provide operational subsidies for24 set -aside, project based units for people living with AIDS (PLWAs) at three different developments throughout Miami - Dade County. The City makes every effort to support project based units at sites throughout the County to provide location options to HOPWA clients as a cost-effective permanent housing alternative. � The and Mortgage Utility Assistance (STRMU) of no more than 2Iweeks <o approximately 100 persons each year who are H|V+, who are O096AM| or below, and who are participants inthe LTRA program. This program isadministered bva sub -recipient (non-profit) selected via an advertised, Request for Proposals process and STKMU applicants are processed on a first -come, first -eligible basis, requiring an H|V+ diagnosis byalicensed medical professional. Upon entrance into the HOPVVA LTRA program, all clients are provided with the LTRA Client Handbook which provides the most important information concerning the HOPVVA LTRA program, its requirements and potential violations. All clients must sign the last page indicating their review of the Handbook, which they keep for reference. Attachment B of the handbook includes a concise review on the federal Fair Housing Act and the local Miami -Dade County ordinance and all gender. The three -page Attachment also advises the HOPVVALTRA DRAFT —20/5-202vAnalysis of Impediments mFair Housing Choice 28 client of steps to follow in the event they feel their fair housing rights have been violated and notes the multiple locations where they can report the alleged fair housing violation for review by proper authority. The November 2D14Monthly HHV/A8JS Surveillance Report issued bythe Florida Department of Health in Miami -Dade County noted that there were a cumulative number of 35,274 reported AIDS cases in Miami -Dade County (excluding persons in the Department of Corrections /DO[U. Approximately 35Y6 of the cases were Hispanic (all raced; 50.4Y6 of the cases were Black and 23%were White. Atnta| ofl4,638 HIV (not AIDS) cases were reported that month, excluding DOC. Approximately 42.7% were Hispanic (all races), 42.6% were Black, and I3.3Y6were White. As required by federal law and state law, status record inquiries. To that end, all public t i | (lease, landlord package) associated with the Ot/sHOPVVALTRAand/or RMU programs make no mention of the client's medical diagnosis ofAIDS orHIV () Because of this, the City hashad few issues and no reported cases of discrimination landlords ofits tenants due to their AIDS status. � Yi The City of Miami HOPWA Program Policies and Procedures Manuol (Manual) provides guidance on tenant/client and landlord rights and responsibilities in relation to Fair Housing. Chapter XV of the Manual is entitled Equal Opportunity and Reasonable Accommodation and elaborates on federal and local laws related to this subject. The Manual defines disability as follows: Having one or more of the following: i. A physical or mental impairment that substantially limits one or more of the major life activities of an individual; ii. A record of such an impairment; iii. Being regarded as having such an impairment; To clarify the reference above to ct physical or mental impairment that "substantially limits" a person in one or more of the "major life activities," this means that the physical or mental impairment causes substantial difficulty in a person's ability to: See, hear, speak, or breathe • Learn, think, or read • Work, walk, or perform manual tasks • Care for himself or herself • Engage in some other "major life activity." As per the HOPWA Manual ChapterXV-5,three requirements must be met in order for a HOPWA client to be granted a reasonable accommodation and these are as follows — a. the subject of the request is a qualified "individual with a disability", as defined above; b. the requested accommodation is necessary, because ufthe disability, to provide an equal opportunity to use and enjoy the housing. To show that a requested accommodation may be necessary, there must be an identifiable relationship, or nexus, between the requested accommodation and the individua|'sdisability (see Joint Statement of the Deportment of Housing and Urban Development and the Department of Justice on Reasonable Accommodations under the Fair Housing Act, May l4,J004); c. and, the requested accommodation isreasonable. DRAFT —20r5-202oAnalysis of Impediments mFair Housing Choice 29 |n2Ol4,the Miami -Dade County HIV/AIDS Housing Survey & Needs Assessment was carried out between the months of March and May 2014 forthe purpose of determining the housing needs and preferences ofpersons living with HIV/AIDS in the Miami -Dade EMSA in order to establish housing profile ofthis population and toassist the City in its strategic planning and resource allocation process in consultation with the Housing Committee and the Miami -Dade [ountyH|V/4|D5 Partnership, In total, 243 surveys were collected and analyzed at different HIV/AIDS care provider sites. The survey found that there is a need arnongst PLWAs for 10,039 subsidized rental units orrent subsidies. Close to84Y6ofthe respondents reported that they were NOT receiving housing assistance of any kind, compared to 59Y6 of respondents in the 2012 survey. When k d if they respondents answered no, compared to 71% in the 2012 survey. The survey also found that the average income of respondents was $943 a month. As noted in the assessment, "The average rent of those without assistance is $673.13. Using this rent amount, persons with incomes of $1000 would be spending 67.4% of their income on rent. Of those surveyed, 60.2% have incomes less than $1000." To recap, below is important crucial data gathered through the 2014 survey of Persons Living With AIDS (PLWA) and Persons Living with HIV (PLWH) for purposes of this Al — • There was a significant increase in respondents expressing difficulty locating accessible units - 17.1% reported that it is not easy to find such housing as there are only some accessible apartments available and 22.5% stated that is almost impossible as there are very few accessible units; • There was a significant drop in respondents who reported experiencing housing discrimination. Close to 13% of respondents reported having experienced discrimination compared to 20% in 2012. The top four responses for the basis of the discrimination were HIV status (25%), alcohol or drug use, other (credit or income), and physical disability. In the last by most accounts, unexpected. When the last Al was drafted, the City had suffered the direof Miami's urban core has undergone a transformation that was after effects of the collapse of the real estate market and US economy in 2008, which triggered what was one of the largest foreclosure rates in the nation and dotted many City neighborhoods with vacant, abandoned properties leading to significant property devaluations. A significant uptick in multi -family building permits took place sometime in 2012 hinting at what ultimately has become a solid real estate rebound for the City of Miami. However, because Miami's real estate market is heavily influenced byforeigners and out-of- state residents who purchase investment, seasonal, and orsecond', third' homes here, our real estate market is nothing but unique, and a closer analysis of the new housing stock is of importance. To begin with, Florida has no state income tax, which coupled with mild winters, has long been an attractive enticement for seasonal residents, snowbirds and persons/families seeking vacation homes. It is also important to note that just because DRAFT —zo/5-202oAnalysis of Impediments to Fair Housing Choice 30 additional housing is being built, this does not mean that the volume has made housing more accessible and/or affordable to Miami's permonent residents, who both live and work here. Forthe first time, the majority of the properties in the City of Miami are made up of structures of 20 or more units. According to the 2007'2011 A[S, 36.5Y& of the Chv s housing structures now feature 20 or more units. This is a significant departure from the 2000 Census, where the majority ofthe [it/sstructures (30.6Y6)were one'unit,detached single-family homes. Based on recent permit data, this multi -family trend seems to continue, Table 13 shows the amount of building permits issued in the City of Miami from 2011 through 2014 as noted on the State ofthe Cities Data Systems (SO[DS) Building Permits Database (vvwvv.huduser.org), based on unit type. Asnoted inthe table, the bulk ofthe permits during the past three years have been issued in the All Multi-fo/nilvcategory with the peak happening in 2013 /4371\ and a slight leveling off in 2014 (3507). Table 13:Housing Unit Building Permits for Miami,-- (preliminary^ — data) from the SOCoSbuilding permits database Unit 2012 2012 _2013 2014 |nSingle family Structures 21 40 � `^ 65 |nAll Multi -family structure 266 911 4371 350/ mz'unit Multi -family structures sn . �o `� � ms'and 4-unit Multi- family structures * V{� ' �8 n ms+Unit Multi -family structure, 232 897 4*05 3439 Total �� '' 287 951 4486 3572` � Miami's trend towards vertical growthisnot unusual _when looking otother comparable cities, many ufwhich have seen increased attention and focus onreturning to, and/or living in, the urban core, which typically hasmore accessibility to public transportation and business centers ) has doubled in 10years with reports indicating that as of 2014, the population was somewherearound 74,00Opersons. As noted in Table area is logging the greatest number of pre -construction units in all of South Florida. This A|' Attachment s up-to-date City maps ofland use in Miami As is evident in the maps, there is little t land remaining in the City presently, with the bulk of it located in the north/northeastern part of the City (Districts Z 8k S). Further review of current zoning maps demonstrates that the percentage of land dedicated to low -density, single-family housing is in fact equitably distributed with the exception being the southeastern most part of the City (District 2) which has historically been the City and County's business center where vertical commercial space dominates. Minimum lot size for single-family homes is 5,000' square'feetvvhichagaincomparedtootherdties,isnotextneme|y|arAe.Assuch,vvebe|ieve that the change in the predominant housing type is a result of what is limited available, vacant land coupled with additional demand for housing in urban areas. DRAFT —2o1n-2o20Analysis nfImpediments to Fair Housing Choice 31 There are other side effects related to the switch in the dominant housing type. Most notable, an analysis on HUD's website indicates that as of October 2014, only five condominium buildings within City limits were FHA approved. According to the Miami Association of Realtors' senior vice president of governmental affairs, South Florida "buyers need more financing options for condominiums."" We will elaborate on the repercussions of the latter further this document. Additional data also reinforces the prevalence ofplanned multi -family developments in the Miami area. As of August 2014, 256 multi -family towers were planned in the in the tri'countyarea (these include K4iami'Dade, Brovvard, and Palm Beach Counties). Of those towers, approximately 52% of these proposed new units (note: ultimately, not all of these planned units may bedeveloped) are located inGreater Downtown Miami which is entirely within City of Miami limits. Table 14: South Florida projects' market rankings as of August 18uh 2014 � Rank Market rowers Floors Units Share of Units South Florida zss sosy 35132 Miami z Hollywood/Hallandale Beach zo ^ zas 3254 sa% a West Palm Beach 12 261 2122 '' am 4 Avemum za 215 2108 .6% s Sunny Isles Beach 14 547 4924 ssm� s Miami Beach z/ 270 1355 3.9m��' r aa|Surf Bay ' ` ao zzs 1286 3.7% ' o Coral Gables . '' ' ' e 48 `` , 113s� ' 3.2m s Fort Lauderdale 15` zm ' '` `'7ag 2.2m� m North Bay Village 4 93 549 1.6% 12 Pompano emcx 11 45 374 1.1u �13 2 23 230 .7%��^ Source; CroneSpotters.com, Gray highlights indicate buildings within City ofMiami limits. HOUSING Despite tmarket housing options inthe City ofMiami, data h that | half ho|d» cannot find housing that would not cost - burden them. burden indicate that the affordable housing supply is not meeting the demands ofcity residents. As previously discussed, bulk of Miami's housing units are now in multi -family buildings — with dose to 4O%ofMiami's housing stock found in multi -family buildings of2O or more units. These multifamily developments include owner occupied condominiums, rental condominiums/apartment complexes. This is a significant change from the last Census (2000), where single-family homes still comprised the majority of the City's housing stock. The most recent data indicates that 2696 of the dt/s housing stock is comprised ofone'unit detached structures (single-family homes). Also new in the 2010 Census, data showing that the bulk of Miami's housing stock was built between 2000 and I009 (19.396), no doubt fueled by the recent wave of development. In the previous Census, the bulk of the City's housing stock had oSusan oansey r,^nna|torspvch for more condo financing optiono.^Miami Today, April un.2o1o� DRAFT —ao,o-2o2oAnalysis ofImpediments mFair Housing Choice City of Miami 32 been built between 1970to 1979, but now that date range approximates more modest 13.596 of the total housing stock in the City. TOTAL HOUSING UNITS Occupied housing units Vacant housing units UNITS /mSTRUCTURE z'unitdetached structure z'un/tattached structure zun/ts so,«units ME 187,em 150,974 a6,ya* 19.7% Mobile home 1,029 0.5 ' Boat/RV/van�c um uz *Source: 200-9-2013 American Community Survey 5-Year Estimote HOUSING UNIT SIZE As noted in (38.8%) followed byand housing comprises close to7O96 of the housing itindicates that most households in the City are in fact households, and that larger families might have a more difficult time locating a residence that accommodates their size. TOTAL HOUSING UNITS` i '�147e8 No bedroom e1515 az zbednmm �^� ` 5e754 31.8 zbednmno 71991 38.3 3 bedrooms �� 34582 18.4 ` 4 bedrooms 8037 *.3 5o,more bedrooms zose 1.1 ACITY OFRENTERS The City of Miarni has long been a city of renters. One can especially appreciate the extent of this when comparing local data to the region. In the Census (2010), 65.3Y6 of the total occupied housing units in Miami were made up of renters, while a lower 442 percent of Miami -Dade [ount/s occupied units were renters and an even lower 32.6 percent of the DRAFT —20/5-202nAnalysis of Impediments mFair Housing Choice 33 State of Florida's residents were renters. According to a new report from New York University's Furman Center and Capital One Financial Corp, 65% of Miamians rented in 2013, making it the highest percentage of ony majorArriericon city, even surpossing New York City." As noted in the table below, as housing supply grew, so did the number of renters. Data also indicates that renters tend to occupy smaller size units (one' and two -bedrooms) while homeowners tend tooccupy larger units /Z and 3 or more bedroom properties. Indicators support that this trend will continue. This scenario is not uncommon , and as reported by the NYU Furman study in February 2013, nine citiesof the 11 largest metro areas have more renters than homeowners, a trend that could be ih d to the| estate bust andmany their homes to foreclosure, being of owning a home given theconsequences ofthe real estate bust, or finally first-time homebuyers inability to purchase a home due to slow income growth,a lack ofsavings, and higher-than'average rents. The U.S Census defines h monthly cost of utilities (electricity, gas, water, and sewer) and fuel (oil, coal, kerosene, wood, etc.). Gross rent cis o percentage of incorne is defined as the ratio of gross rent to household income. It is used as a measure of housing affordability by policyrnakers and as a determinant of eligibility for federal housing programs and is often referred to as a housing cost burden. Below Table 18 analyzes gross rent as a percentage of household income. As indicated, approximately 65% of occupied units paying rent, are paying 30 percent or more towards rent as a percentage of their household income. HUD defines cost burdened households as families who pay more than 30 percent of their income for housing. Table 19 and the bar graph that follows it also show how gross rents for occupied units have changed in the City since the 2000 Census. Specifically, in 2000 the bulk of the rents being paid were on the lower side of the rental scale, some 78% was comprised of units paying $749 and below. However, data from the 2007-2011 ACS Survey indicates that the bulk of units paying rent (67.3%) were paying $750 and above. The spike in rents also coincides with the spike in renters. According to NYU Furman Center's study titled "Renting in America's Largest Cities," five majorAmerican cities saw growth exceeding 20% in a seven-year period, with Miami being one of those. Miami's rental population grew 25% between 2006 and 2013, the report states. 12 NYU Furman/Capital One National Affordable Rental Housing Landscape Research Study, vw^wfunnancontecnnq/wauonmncnta|:sndscapo DRAFT —zo/5-ouooAnalysis nfImpediments mFair Housing Choice City o,Miami 34 Table 17 T °'°5IgAI4 lord Occupied housing un Owner -occupied Renter -occupied Average HH size of owner -occupied unit Average HH size of renter -occupied unit Florida h, arrii- CityofAhiarrni Ei yw arrtli[irwaP�°i' yGp�d rim& 156,317 100,0'% 134,196 100.0% 24,119 51,,1E6 ._.._._32.3% 46 vo b,._... 34 9''',. 4,350 107,131 653% 87,362 65.1 % 19,769 HousingTenure by Regio amp, 0v, net -occupied 2010 60% 80% E R enter- octopi ed. So. rce: US Census, Table 18: GROSS RENT AS A PERCENTAGE OF HOUSEHOLD INCOME (GRAPI), City of Miami, 2007-2011 ACS Number Percent Occupied units paying rent (excluding units where GRAPI cannot be computed) 92,656 100.0% Less than 15.0 percent 5,004 5.4% 15.0 to 19.9 percent 6,394 6.9% 20.0 to 24.9 percent 8,797 9.5% 25.0 to 29.9 percent 10,388 11.2% 30.0 to 34.9 percent 9,388 10.1% 35.0 percent or more 52,685 56.9% Table 19: GROSS RENT for Occupied Units paying rent 2007- 2011 ACS 2000 Census Less than $200 4.3% 8,8% $200 to $299 4.7% 4.8% $300 to $499 5.6% 28.5% $500 to $749 18.2% 36.5% $750 to $999 26.6% 11.8% $1,000 to $1,499 26.8% 5.6% $1,500 or more 13.9%d 1.9% Median (dollars) 910 535 100 DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice 35 City of Miami $1,5UOo/more $1,000to$1,499 $75Oto$999 $50Oto$749 $300to$499 $ZOOto$299 Less than $2OO � � 1:/�� m .8% v 121 18 00 �IEVAMEMR, 0112OOOCensus w,Z0O7-ZOl1ACS Gross Rent for Occupied Units Paying Rent mthe City mrMiami, zoonmom7-2nzz ! � CITY HOMEOWNERS The state ofbeing aCity homeowner has also changed in the past decade or so. Asinthe previous Al, the majority ofowner-occupied housing units i City (SO96)have amortgage on their housing unit. Table %0: Mortgage Status, Owner Occupied Units City ofMiard�° Owner -occupied units Number Percent � Owner+occupiedunbs�` � ' ' ^ 100% �r ~ Housing units _ _ , ` 28,058 58% / Housing units without amortgage 20,345 42% When looking at the selected monthly (home)owner costs of housing units with a mortgage as a percentage of household income, these too have risen. The bulk (57%) of City homeowners are paying more than 35% of their income towards their monthly owner costs as noted in Table 21, Table 22 indicates that the bulk of homeowners with a mortgage are now $1,500 and up (69%). Whereas in the 2000 Census, the bulk of owner costs was $1,500 and below. Table Iz:SELECTED MONTHLY OWNER COSTS 4S&PERCENTAGE OFHOUSEHOLD INCOME (SxxO[AP|),City ufMiami, 2VO7' aU1lACS Number Percent Housing units with amortgage (excluding units where SMOCAP|cannot be computed) 31,783 I00.0% Less than 20.0percent 5,022 15.8% 20.0to 24.9 percent 3'521 11.1% DRAFT —zo,5-202oAnalysis of Impediments to Fair Housing Choice 36 25.0to29.9percent 2,557 8.0% 3O.Utn34.9percent 2,570 8.2& 35.Opercent ormore 18,I07 57.0% Table 22: SELECTED MONTHLY OWNER O]STS(5N1O[) 2007- 2011A[S 200 Census Less than $3O0 0.0% 0.3% $300to$499 1.0% 2.5% $500to$699 1.9% 6.0% $700to$999 6�0% 14.6% $1,000to$1,499 213% 22.5% $1'500to$1,999 19.7% 9.4% $2'UOUormore 49.9% 82% Median (dollars) 1'997 1,163 $z'O0Oormore $1,500to$1,999 $1'000to$1,499 $7o0tn$99s $s0Otn$ssy $aootn$*99 Less than $aoo NUMMIS RIA1232MI), Selected Monthly Owner Costs for Housing Units with aMortgage inthe City of Miami, Z0OO&3OU7'zU11 PUBLIC AND SUBSIDIZED HOUSING The City of Miami does not manage public housing (PH) units; The Miami -Dade Public Housing Agency (MDHA) is responsible for doing so throughout our City and the entire county. MDHA provides federal subsidies for about 9,141 units of public housing, which it manages, maintains, and inspects on an annual basis." However, an internal analysis by the DCED found that approximately 74% (@ 6,800 units) of the County's PH inventory is located within City of Miami limits at6Sdifferent sites. " Miami -Dade Housing Agency PHA Five -Year and Annual Plan for Fvbeginning 1m2o15 DRAFT —zu/n-2nzoAnalysis ofImpediments to Fair Housing Choice City of Miami 37 Based on its most recent 5-year PHA plan, the MDHA is in the process of demolishing old, deficient PH units and replacing these with new ones. |nJanuary 2O2S, the Department announced a plan to demolish the Liberty Square Apartments (known as Pork and Beans[ located within the City of Miami just off of62nd Avenue in Liberty City and built in 2936 The 753'p|us public housing project has been riddled with crime for several years and residents have long complained about the substandard conditions of the development. The redevelopment plan - which the County anticipates will take 5 years to roll out - will include $48 million in funds to build a new public housing development along with another $26 million towards job development, new single-family homes and other initiatives around Liberty City. County leaders also indicated that it would be built in phases so it would not require relocating residents. The County also indicated that it would include private investment but details on the latter had not been released asofJanuary Z0l5.The plan would still require approval of the Miami -Dade County Commission and U.S. HUD. With regard to otherb idi d housing (not includingmoderate rehabilitation program, or County VASH program), an analysis of all assisted rental units as provided by Shimberg Center for the University of Florida, along with the addition of a handful of buildings solely funded by the City, indicates that as of 2014 there are approximately 14,343 subsidized rental units in the City of Miami, contained in mostly multi- family rental developments that receive assistance under federal, state, and/or local government funding programs to offer affordable housing units with certain rent and income restrictions. As indicated in Table 23, the majority of assisted units in the City are in the category noted as Family/Family Link (44 percent) followed by the category of Elderly/Elderly Link (41 percent). Developments specifically serving other populations, such as the Homeless and Persons with Disabilities, make up a very small percent of the assisted affordable rental housin�dave|opmentsvvithhnthe[hy _-_�"-- _-_ .._-.-'_ _`� Table 23 Summary Table of Assisted Housing Units, City of Miami (not inclusive ofpublie housing andlor Section 8 pm�zl-ams) mu ' ved� ` Number ^ of units --n-g- projects/'�|� ',� ' ' Elderly� Elderly/Link �� /`. 41% Elderly~`^ Family , , 3% ' ` ' Family | ' 44% Homeless »` ` 1 � � .5 % Persons with Disabilities 1 .5% Could not confirm 13 8% Source: The m>mnbmgCmmfoxHousing Judio Florida Housing Data ormmghmoecombined with the Utv'sxSrlists. ,"Nomv/metotal ayfivm/units noted mall miegou=units mnvx under development are included mthe lis/ing.mi.5 number vxmm/tsm/'o/5mvuxdunits currently under mmm/cm,v. Lon upJ le»vz According to this same data report by Shimberg, within the next ten years exactly 33 assisted housing developments will have satisfied their affordability periods, 20 of which serve the elderly category. Below is map plotting these 159 developments within City limits. As is seen, the majority of the projects are located near the City's urban core (on the east side). The DCED makes every effort to provide additional Request for Proposals (RFP) points to proposed projects in the Districts where the least assisted housing is seen (Districts DRAFT -m/5-202nAnalysis ofmipemmntsmFair Housing Choice 38 2 and 4). Historically, it has been difficult to develop new housing in those areas due to the higher costs ofland, coupled with smaller vacant parcel sizes. City of Miami /lGG'ot8d HC)U8'nO [l8Ve|(]0meDt8. 201/1 tool, rr* .v~��.� DRAFT —20/5-202oAnalysis of Impediments mFair Housing Choice City of Miami 39 HOUSING CHOICE VOUCHER ADMINISTRATIVE PLAN The most recent City of Miami Section 8 Administrative Plan "the Plan" addresses fair housing and equal opportunity in [hapterl8 (page 177 184) in both the H[V Program and the Moderate Rehabilitation Program as overseen by the D[ED. The Plan elaborates on the protected classes including race, color, religion, ancestry, national origin, age, sex, pregnancy, disability, marital status, familial status, sexual orientation, and gender identity. The City's policyfor requesting b| d ti is set forth here as well.Section 5.3 of the Plan states as follows, "The PHA will provide additional assistance on behalf of families that include persons with disabilities by attempting to collect a listing of available housing units that are handicap accessible units and providing this information to the family. Additional time may be granted as outlined in the "term of the voucher" section and a higher payment standard may be granted (if possible) as a reasonable accommodation due to a Section f the Plandimproving access to persons with Limited English Proficiency (LEP). LEP is defined as persons who do not speak English as their primary language and who have a limited ability to read, write, speak or understand English. The services provided include both oral and written translation by PHA staff members (at no cost to the LEP person) who speak English, Spanish and Creole. LEP persons will be permitted to use, at their own expense, an adult interpreter of their own choosing, in place of, or as a supplement to, the free language translation services offered by the PHA. Aside from this, the City advertises in both English and Spanish newspapers (one each) whenever a Section 8 program opens for applications, and translates the application to Spanish and Creole, with copies of these available at all application pick-up sites. Although the City has no formal LEP Plan in place, it does translate as much material as possible to Spanish and Creole. The City's waiting list preference is for persons who are disabled and/or elderly. The [by retains the right to k| income families on the waiting list if necessary to meet the statutory requirementtha of newly admitted families inany fiscal year befamilies who are extremely low-income as defined by HUD. The local preference Section 8programs application process isfor persons/families who qualify as disabled or elderly. These preferences are defined in the Plan as follows: Elderly w A family whose head or spouse (or sole member) is 62 years or older and/or a family that includes anelderly pen/un(s). Disobledfomily: * A family whose member(s) include a person(s) who is under a disability as defined in Section Z23mfthe Social Security Act (42U.S.c4Z3)orhas adevelopmental disability asdefined insectinn|0](7)ofthe Developmental Disabilities Assistance and Bill ofRights Act (4Z U.I C. 6001(7)); or • Afamily whose member(dinclude aperuonb\having aphysical ormental impairment that (a) is expected to be of a long -continued and indefinite duration; DRAFT —zn1n-2000Analysis v,Impediments toFair Housing Choice 40 (b) substantially impedes his or her ability to live independently; and (c) is of such nature that such ability could be improved by more suitable housing. WAITING LISTS FOR HCVAND THE MODERATE REHABILITATION PROGRAM As the PHA, the DCED opens and doses registration periods bvannouncing these via public notice advertised in a newspaper(s) of local general circulation and posted on the PHA's website. The notice always includes the Fair Housing logo and slogan and is otherwise in compliance with Fair Housing requirements. The local TDD/TTY phone number is included and a dedicated phone number for persons with a disability or mobility issue was included. The most recent Housing Choice Voucher (HCV) wait list, opened in October 2014, was advertised in both English and Spanish local newspapers. The application itself was posted on the City web site and distributed in the [itv's three main languages` English, Spanish, d Creole. Applications were made available offices (known as the Neighborhood Enhancement Team (NET)throughout the City in2l different neighborhoods and accessible bvand toall City neighborhoods. Applications were also made available at the Miami -Dade County MAIN library in downtown Miami, accessible by bus, Metrorai|and vehicle. Because the[ ram`(136 vouchers) and the program's level of ' Table ' ^ of Miami Table : Characteristics Total number ufeligible applicants 4,091 100% � Hispanic�� 2576 63% Gender —Female �� ~�� 2908 71% --Male `8�� I183 29% Race --African American 1647 4026% --American Indian 1 0.02% —Asian 8 0.20% --Other 19 0.46% --White 2416 59.06% American citizen —,es 3288 80% —No 803 20% Preference Identified /Bderly/Disnbk,oU DRAFT —zo1n-2n20 Analysis vfImpediments mFair Housing Choice City of Miami 41 —Yes 2097 51% --No 1994 49% *Note: Hispanic ethnicity ucounted independently nrrace. Source: City of Miami, Dept. uCommunity asmnom/cDevelopment No study of the rejection rate for Housing Choice Vouchers (HCV) clients has been done, but HCV Section O clients do not report finding an available unit to be a problem. There were 9100/79O2O,000persons unthe list for the [it/s Section Dmoderate rehabilitation (pnject' based) program, which dosed in 20OlAtthat time, data collection did not include specific demographics on the applicants and so we cannot provide that information in this document. We are still working through this list. LOW INCOME HOUSING TAX CREDITS (UHT[) The Federal Low-income Housing Tax Credit (L|HTr) program `is now the major source of federal support for affordable housing. The program providesdevelopers ith a federal income tax credit and in the case of non-profit developers, creates an incentive for private investors to participate in the construction and rehabilitation of low-income housing. In Florida, h L|HT[ program is administeredbythe Florida Housing Finance Corporation (FHFC), started in 1987, and overseen by a nine member board of directors. FHFC administers a tax credit application process whereby it establishes an annual "Qualified Allocation Plan" (QAP), which defines the criteria for ranking applications. As noted on the FHFC website, "Each development must set aside a minimum percentage of the total units for eligible low or very low income residents for the duration of the compliance period, which is a minimum of 30 years with the option to convert to market rates after the 14th year. At least 20 percent of the housing units must be set aside for households earning 50 percent or less of the area median income (AMI), or 40 percent of the units must be set aside for households earning 60 percent or less of the AMI." In an analysis of the LIHTC projects within the City limits, the latter option dominates. Applicants that are requesting tax credits frorn Florida Housing are required to set aside for Extremely Low Income (ELI) households 10% of the total units for which they are applying. The municipalities within the state are in no way involved in the FHFC's QAP process (or the awards process for that matter) but in a state as diverse as Florida, a recent QAP merits a closer look. During an application period, it reviews different requests for funding from private/public developers and allocates funding to those developments that score highest based on specific criteria it defines for ranking applications. State municipalities (including Miami) do not have a direct role in the administration of the LIHTC program, which creates a unique set of issues. For example, in a recent QAP additional points were awarded for Transit Oriented Development (T0Ds) across the State.T0D is a planning and design trend that seeks to create walk -able communities centered on a transportation node (transit station, transit route, or bus stop). The positioning of affordable housing near transit locations makes perfect sense, but in a City laid out like Miami it created an unintended side effect that bunched five tax credit projects (not necessarily funded the same year) along one particular City corridor alone (3VV Z Avenue). Because parcels in that general area are zoned to allow for higher densities, many private developers focused their location search in the City within this area. Although the buildings added more than 350+ affordable units to the East Little Havana area, DRAFT —20/5-202nAnalysis of Impediments mFair Housing Choice 42 it also created another albeit unintended side effect — the concentration of subsidized housing inaparticular area. Although TODmakes sense, given the cost of transportation and its effects on household budgets and cost of living, it is important to address the existent transit system in Miami and K4iami'Dade[ounty,whichisopemtedbyMiami'DadeTrandt(MDT),aCountyDepartment. Most importantly, the County's grid is such that the bulk of traffic travels north -south or east - west, along several major corridors. Miami is one of34 cities located within Miami -Dade County, Florida's third largest county in terms of land area. Miami was settled in 1825 along the Miami River while Miami -Dade County (originally known as Dade County) was founded elevenloter in 1836. Because the bulk of early development within what are now City limits, in 1844 Miami became the County seat, given that much of the County's population at the time lived in what is present day Miami. This historical significance continues today and the City of Miarni is very much considered the County's urban core -- home to the area's main Performing Arts Center (Arsht Center), fine art museum (Perez Art Museum Miami), its Financial District (Brickell), the area's largest public hospital (Jackson Memorial Hospital) and more. First openedi May 1984,tharea's Metrorail system (heavy rail metro line) openedhs Green Line connecting Dadeland South (County) to Overtown (City). The Orange Line was introduced in 2012, but it shares much of its line with the green with an additional extension to Miami International Airport. An automatic downtown people mover known as the Metromover opened in downtown Miami in early 1986 and expanded further into downtown in the mid- 90s. As you'll notice in the map below, the bulk of the County's Metrorail stations are in fact, located within City of Miami limits (13 of 22) and all of the Metromover stations are in downtown Miami (City). This means that much of the mass transit in the entire County — not inclusive of rapid bus transit aside — has hubs within City of Miami limits. This fact leads us to the TOD bonus included in recent QAPs issued by the FHFC. DRAFT —uo/5-202oAnalysis mImpediments to Fair Housing Choice 43 MIAMI 21 ARTICLE 4.DIAGRAM 11TRANSIT ORIENTED DEVELOPMENT 'TO0 AS ADOPTED - MAY 2014 � _ i -OIRN� � r-�� OF � n ~~~ ------ �1� �! METRORAIL �, 4W, �mmREmE7RORAIL FigmoROmDVsx STREETCAR71-1 BUS ROUTES HEALTH DISTRICT CIRCULATOR HEALTH DISTRICT STOPS FUTURE TRANSIT SHEDS �u 1/2 MILE TRANSIT SHED |e|1/4MILE PEDESTRIAN SHED IV 28 More recently, the FHFC has I imited Miami -Dade County too nly two new funded construction projects per year. This limitation means projects from our County are carefully scrutinized which is a cause of concern for many local stakeholders. For example, current (2014) FHFC tiebreaker rules for competitive applications are based on proximity to a three -route express bus, a grocery, a medical center and a pharmacy. This means that Miami -Dade and Brovvard require a higher score (1375 points) in the QAP in order to meet the "perfect" proximity caveat while other large Florida counties (5) only require 1225 points. This means certain potential applicants from the Citywill never meetthat high score because their particulararea DRAFT -20/5-202oAnalysis of Impediments to Fair Housing Choice City of Miami 44 lacks grocery stores or has a one' or two -bus stop. It has also meant that the bulk of the applicants from Miami -Dade have been high-rise communities versus lower density housing. In a report issued in the Fall of 2012 (OPPAGA Report #12-10) the Florida Legislature Office of Program Policy Analysis and Government Accountability indicated that it considered that the FHF[should reduce "the frequency ofrule development workshops; revising the time allowed for applicants to identify problems with each other's projects; and increasing the emphasis on considering market feasibility and project costs." The report further indicated that "other states' tax credit allocation processes are more streamlined." L|HTC|NVENTORY In rd have an accurate inventory of tax credit units located within City limits, tile City requested a master listing of funded projects from the Florida Finance Housing Corporation (FHFC), who manages the tax credit program for the State of Florida. An analysis of the projects located within City limits found that a total of 117 had been funded dating back to 1990, 18 were no longer in the program, one had returned its credits, and four had swapped their credits, leaving the total project count at 91. Tobeclear, Miami -Dade County is comprised of multiple citi the county's Eastern half, including 34 municipalities (including the City of Miami) and 16 unincorporated communities. See the Figure belowforan illustration of where the tax credits projects are located in Miami -Dade County. As you'll note, the bulk are in the South Miami - Dade area or the northeastern part of the County. For reference purposes, the royal blue image in the top right corner of the figure encompasses the City of Miami's limits , whereas all the surrounding grey is the rest of Miami -Dade County. In the County, a total of 206 projects that have been funded are still in the program, while eight of these projects swapped their credits, leaving a total CountV count of 198 tax credit developments. This means that approximately 46% of the tax credit projects in all of Miami -Dade County ore in fact located within the City of Miami. For reference purposes, it should be noted that the City of Miami is 35.68 sq. miles (land) and Miami -Dade County is 1,898 square miles (land). DRAFT —co,5-zoznAnalysis cvImpediments mFair Housing Choice 45 City ofMiami Tax Credits in Miami (Blue) and Miami -Dade County (Gray) HOUSING MARKET � Miami's housing market grew bv24%from ZOUUto 2010, adding some 35,000 units tothe [it's available stock with the bulk of that activity centered in the Bricke||/Downtown neighborhoods near the Bay. Historically, for the first time, the majority of the City's properties are now made up of structures with 20 or more units. Data also indicates that the bulk ofthe City's residents are in fact, renters. Oua|ifvingthatsupp|y—its pricing and who the end -users will be—iswhat becomes difficult. To shed further light on the market, it is important to note that the City'scurrent housing market has been strongly influenced by combination of real estate supply conditions that are unique on both a state and national level. Recent demand factors have contributed to a significant increase in housing development activity, with the latter hinging onthe major role that non-residents An many cases, foreigners) play in nurCit/s real estate market. According to Realtor.org, the website of the National Association of Realtors, Miami was the third most searched U.S. City by International consumers in 2015, behind New York (#1) and Los Angeles DRAFT —oo,n-2n2uAnalysis ufmpemmontsmFair Housing Choice 46 (#2). Additional local data seems to further reiterate that many local property owners are not necessarily full-time Miami residents. According to the Miami -Dade Property Appraiser's 2014 preliminary tax rolls (current up to I7/31/2013), only 37% of all condominium units in the County have a hu/nesteodoxemption which is remarkably low given that Florida |avv a||omo for homeowners to claim a homestead exemption (tax exemption) ofupto$SO,OOOon a single-family home or condominium unit when the owner uses it as a primary residence. This would indicate that the bulk of condominium units in the County are NOT the primary residence of their owner and are either an investment property and/or a second/third home. Based onthe County Property Appraisers' Just Value, the average just value of a single-family home in Miami is $200,882 while the State-wide average is $166,535. The average just value of a condominium was even higher in 2013, amounting to $243,414. However, when we look at average sales prices in Miami, the amounts are even more startling, with an average just value of $427,396 for a single-family home in 2013 with a median sales price of $235,000 compared to a statewide median sales price of $170,000. Source: Florida Department of Revenue, Soles Doto Files. Even more startling is that based on Census data, the average household in the City of Miami cannot afford to purchase a single-family home or condominium without becoming cost -burdened. As recently as October 2014, the S&P Case-Shiller indices `' metro Miami area rose 9.5 percent from a year earlier, making it the biggest gain amongst the 20 big cities tracked, meaning Miami home prices are at their highest levels since May 2008." This is in line with the state of Florida, which has seen single-family home prices rise 6% from January 2014 to January 2015, which is higherthan the U.S. average of approximately 5.7%, according to the latest Home Price Index from CoreLogic. When distressed sales were excluded that increase jumped to 7.4%. Besides this, there is a tremendous disparity in housing prices from neighborhood to neighborhood in the Miami are ' a. Below is a quick analysis of residential sales related data in major Miami neighborhoods as provided by Trulia in March 2015. Yet again, extremes are seen, with listing prices in Model City (Liberty City) averaging $110,000 vs. more than ten times that average in neighborhoods like Coconut Grove and the Upper East Side. Miami Avg. listing price Avg. sales price Median sales Price per sqft neighborhoods Week ending Mar oec'14 Mar'ln pnvo oec'14 Mo,'15 4 ooc'14 Ma '10 Name Amount w* 03 w Model City *110.642 $78008 334% $72000 385(1/, mla»auax $220.920 o5"& *115.600 4&9% $104,000 1-11.211% F|agami $23*224 $194200 100% $207500 loa% Eaoum� � $241.923 4.5% $180.246 21.2% *112.000 '5�9% Havana 14 The Miami Herold, "Miami home prices No. Imyearly mcreoue,^Martha amnoignn $59 18,0% $88 �.«% $161 39% $131 ^,Wlu DRAFT —zo1oeo2nAnalysis o/Impediments mFair Housing Choice 47 Miami Avg. listing price Avg. sales price �odiansales Price per avft nc/exumrmomus Week ending Mar oec'14 Mar'15 price onc'14'mar'15 4 oec'14 war'ln Amount w* ° West Little Havana $253.186 8,2Y� $100.055 24,2% $199.800 34�81X, $164 29.1% Overtnwm $261.597 - $328.500 259o% *328.500 245�8% $240 150�0% Little Haiti $340.331 03Y� $126.814 -2&8X, $101.800 -7�51/0 $108 'z.O� vvvnwonu Eunowa»r $567758 1�6y6 $381.162 oe& $355.000 20,39� $non 2�9% Coral Way $725.700 $�� 4� *��0 *� �� 13� ��8Y6 ' ' � Upper East $1 1957U4 4.7Yo $581 746 *448250 731'�'o $302 166% Side Northeast Coconut Grove $1.e01.890 oa% *687.507 «4.11/, $530.000 *1.31% $oss 16�91/(, Southwes t $1 958895 $789O43 -23�� 6J5000 -28 �Y6 $347 -15.4% Coconut Grove ' ' 18Yt ' � ' � Source: Trulia.corn, y-o-y: year over year percentage changes, as printed oil 3/17/2015 The Miami -Fort Lauderdale -Miami Reach, FL area's housing`affordability index continues tu decline, as reported by Realtor.org,the website ofth National Association of Realtors. The higher thegrowth ofthe housing the more affordable the metro area is and vice h '62Y6 in growth in the area. Growth in 2013, was '21.3Y6. The housing affordability index iscalculated based on the sales price of the Existing Single - Family Homes.ThesanneneQativegrowthisseena|ongmostofF|orida'seastcoast. Concurrently, the City's First-time Homebuyer Program has been significantly affected by the escalation in Miami home prices and the number of assisted households has dropped by more than 50% in the last four years. Even though construction has spiked in Miami, and additional housing options are now available, we have seen a significant decline in requests (general interest) in the City's available first-time homebuyer loans for low -to -moderate income persons/families (80% AM[ and below) seeking to live in the City. We believe this drop in applications/requests is directly related to the City's escalating home prices and the inability of low -to -moderate income persons to find an eligible home, and afford to maintain it. The maximum sales price of a primary home that we can assist via the program (HOME funded), as established by U.S. HUD in 2014 for our MSA, is $176,000 for an existing home and $2l4,000for anew construction home. Overinflated real estate prices have created what is bymost accounts, an abnormal market. As identified in the most recent Consolidated Plan, these overinflated prices are also one of the two main contributors to what has become a stark mismatch between housing and local wages. The second critical variable leading to this large affordability gap is the high concentration oflow median household incomes. omoFr—zv/oeozoxnalyomo,xnvodinmntsmpairmzuxmgCooice 48 Table 25: City of Miami Closed First- time Homebuyer Program Loans 2011 35 2012 22 2013 20 2014 13 *loans noted including funding provided via HOME, NSP, and state SHIP funding sources Table 26: Affordability Gap for Home Purchase, City of Miami 1 ..", . "4, 0 ,11,4/N. 'SO" , jOrity41,4 Velirle 0,11, 1.0/19101. i..,..:ti,,, , .10.14,14mposvo ii„„tnii.04110 01, :#111.)iiiigtii,',4,1114 iip4'40401.444,60i li:lk1C li .1.1.171).1P,„gd,,A if OM' laiiMiglh lid,I..:(' '1:104.14,idtdriii6;.) . u' 1.41.„..ot RtAluMA,04.304.00,.441do ..,0, it,','A A Annual income $ 29,762 Planned loan term '''',,,'H'',.. 30 Years Interest rate Phit 004.3 141,00140, toem64,14,0thilk4,. • 4.55% Monthly debt 0 Percentage of down payment 5% Maximum value for affordable purchase $97,448 170, 1 Woo 6 lowig"g6 Atow Median Sales Price (2012) Affordable Purchase Affordability Gap Sources: Median income - Cenuls Ifenvart,,,,lenerican Commetni(y Surqy, Alcie reeks and Ma.vinneen nilne fordable home purcha.re ca/ceilaltni on the I neow.boneepaily.come Inieres/ Rile — liankrok.com on I -6-2014; Median ,leles triee — 41,10„di.(ii!,4.1,,,,•Kii,,,oi w,$t.+0 IkAlat414161.4,,, d,„kib,V;1 1114#1,11/411013' 01111)' 1411"liPtiM1410 Single Family, Condo $ 176,950 $ 295,000 $ 97,448 $ 97,448 ($79,502) ($197,552) 5-111',11'E.C11171ate.1; Perceve door pqyment base() 017 'done el,forl,g‘q Canoe/won, Rninloold IJ 1Volll, RENTS The Fair Market Rents in Miami -Dade County are noted below. These actually dropped by a few dollars in each room -type from the 2014 rates. An analysis prepared by the National Low Income Housing Coalition (NLIHC), Out of Reach 2014, concentrated on dissecting FMRs and housing costs in MSAs across the nation, which led to some startling findings in our area. The report indicated that the hourly wage needed to afford a two -bedroom unit under the 2014 FMR for a two -bedroom ($1,166) in the Miami -Miami Beach -Kendall HMFA was $22.42. The annual income needed to afford the two -bedroom was $46,540 which would require at least 2.8 full-time jobs at minimum wage. However, the estimated hourly mean renter wage in 2014 for renter households in the same MSA is $15.01.15 (Source: http://nlihc.ordoor/2014/MS) 15 http://nlihC.Org/000014/MS DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miarni 49 Miami/Miami Beach/Kendall HUD Metro FMR Areas for all bedroom sizes Studio 1-bedroom 2-bedroom 3-bedroom 4-bedroom 2015 $745 $907 $1,162 $1,594 $1,863 ource: www.huduser.org Utilizing 2014 FMR, the DCED ran a brief analysis to try and pinpoint the affordability gap in our marketplace based on unit sizes, and assuming $29,762 as the median household income. The graph below shows the gap in multiple categories including HOME assisted units and tax credit developments. Table 27: Rental Affordability Gap by Unit Size, City of Miami ormuctroplifipirsorvirr vrparfirriVig' rso7 f ,, ,� r IYl9i�l��'4ylb �'�'(dY !"'�'�li'bi�R'Vh34dJi'Y94ai tP4?l ' , City of Miami Median HH Income 30% of Median HH Income divided by 12 Months City of Miami Median Gross Rent (2008-2012 ) Fair Market Rent, FY 2014 High HOME Rent ow HOME Rent Miami -Dade Affordable Rentals Developments) 29,762 $ 744.05 925 (: 0 Bedroom 1 Bedroom 2 Bedroom 1,166 3 Bedroom 1,600 4 Bedroom 1,869 (] 124-.50) 0 Bedroom..._..�.�..u..�..� 760m..w_..,_._.�_�_ (15.50) 1 Bedroom 81 9 (74.50) 2 Bedroo 984.�,�.... (239.50 , m 3 Bedroom...-�.. W �_ 1,128._.._.....(383,50)� 4 Bedroom 1,239 0 Bedroom 602 142.50 1 Bedroom _...,.... �._......_�....�-645 99.50 2 Bedroom ...�_..,..773 ,_._...... _ .� _.(28.50) 3 Bedroom-_-... _ ..__..�......... 894�. 4 Bedroom Tax Credit Overall 4 997 (252.50) $819 �.........._... _ (74.95) 0 Bedroom $519 225.05 1 Bedroom $711 33.05 2 Bedroom (84.95) 3 Bedroom._....._.. ._.... _.._... $943...._ n ...m..(198,95) DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice 50 City of Miami 4 Bedroom $986 (24.195 ) Sources: City Gross rent and Median Household Income, US Census Bureau American Community Survey; Fair Market Rent, US HUD; High/Low HOME Rent, CHAS Table 6; Miami Dade Affordable Rental from Tax Credit Developers, Reinhold P Wolff Economic Research. Median Contract Rent As per the Census ACS, 2011-2013 3-year estimates, the median contract rent in Miami is $838. Percent of Income Paid for Housing in the City of Miami 0-30% e 30-50% 50% or more Source: Shimberg Center for Housing Studies INCOMES — GOOD NEWS AND BAD NEWS According to recent data released by the ACS in 2013, the median income for a household in the Miami -Ft. Lauderdale -West Palm Beach metro area was $46,946. This median income is the second lowest level in the nation's top 25 metro areas, with the lowest being Tampa's. When looking at the City of Miami on its own, average incomes don't fare much better. Even though there were gains in the share of all income brackets making $35,000 and above in the American Community Survey (2007-2011), data indicates that 67% of households in the City earn 80% AMI or less than the HUD Area Median Family Income (HAMFI) and that households making below the $35,000 income bracket make up over half (55.4%) of the City's households. The latter means the bulk of the City's families are still vulnerable to become cost -burdened given the rising costs of both homeownership and rental housing, along with the cost of living expenses. COST BURDEN IN MIAMI Cost -burdened households are defined as those spending more than 30 percent of their household incomes on housing costs, including utilities. As discussed in our most recent Consolidated Plan, according to the Shimberg Center for Housing Studies nearly HALF (46%) of the City's households are cost -burdened and projections estimate that the trend will continue through 2030. This is an issue for both City homeowners and renters. Research indicates that cost -burdened households must cut back on other expenses including food, healthcare, childcare and transportation. Cost burdened households also have an inability to DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 51 City of Miami save for the future, leaving them with a tentative foothold on household stability in the event ntanunexpected setback, ie.|ay'of[injury, health issue, etc. Assuch, housing cost burden is the most common housing problem in the City across incomes, tenure, race and ethnicity. We will address both cost -burdened and seve/e|ycost'burdened households inthis section. " Cost -burdened households: are defined as those spending 30.02 percent to BJ percent of their household incomes on housing costs, including utilities. According to the University of Florida's Shimberg Center for Housing Studies' 73'137 city households (46 percent) pay more than 30 percent of income for housing as noted in the pie chart below; by comparison, 29 percent ofhouseholds statewide are cost -burdened. Upon analysis of the City's cost -burdened households, significant aj i ( 96) are renters. As indicated in Table 29 below (based on CHAS Table 17), the Hispanic community presents the greatest share and number (based on population) of cost -burdened households in the city across all income brackets —but especially in sheer numbers in the 0-30 percent AMI cohort. However, when taking the HUD definition into consideration, only two household type emerges: Asian and White households in the 0-30 percent AMI bracket. Severely Cost -burdened households: As per HUD, Households spending more than 50 percent are considered to be "severely cost -burdened." Of the City's 46 percent of cost - burdened households, about half (24 percent) meet the definition being severely cost - burdened. Also, as one would suspect, households with the lowest income brackets (0 to 30% AIVII) are the most cost -burdened. It is important to note that yet again, a significant majority (65.5%) of the severely cost -burdened households in the City are renters. Percent ofIncome Paid for Housing inthe City of Miami � Source: Shimberg Centerfor Housing Studies DRAFT -co15-202nAnalysis of Impediments to Fair Housing Choice 52 0 >30 1,120 ~3O >50 >30 >5U 9 � 'O 1� 40 n� Cost CostBur d e n b y Tenure and d Type of Household based on CMA5 Tables and w, � Owna � / ' 2009 2010 2015 2020 2025 2030 #mn p :- ,p 2009-2030 3,999 4,029 297 4'642 5,010 5'382 1,383 2,/53 2,779 2,946 3'159 3'400 3'630 877 ^2,619 2,755 2,929 3,087 3,232 628 9,356 9,421 9,998 10J40 11,497 12,244 2,888 #|ncrease 2009-2030 18,903 18,984 19\887 21,098 22,314 23,458 4,555 6,563 6,587 6,870 7,251 7,613 7'937 1'374 1'199 1,201 I'243 1,303 1'351 1'410 211 26^665 26'772 28,000 29'652 31,I88 sI'nos 6,140 wes ^ / Source: Jhimbe,g{enter/brHousing Studies DRAFT -zo/5-o02nAnalysis o//m»dinentsmFair Housing ChoicCity of Miami e 53 Table 29: DISPROPORTIONATE GREATER NEED: Percent of Cost -Burdened Households in the City of Miami by Race, Ethnicity and AMI — based on CHAS Table 17 42% 26% 32% 100% 524,4, 22%, 26% 100% 45% 22% 34% 100% 57A.6 17% 20% 100% 40% 27% 33% 100% Table 30: GREATER NEED BY TOTAL SHARE: Percent of Cost -Burdened Households in the City of Miami by Race, Ethnicity and AMI — based on CHAS Table 17 i411 ,1014' '01!'4 4,3fr/cr 11.4511,,J,edt,‘, *Ili it* :11+ +0 /./ 4 t 100% 100% 100% 100% 17% 12% 11% 19% 13% 17% 29% 1% 1% 1% 1% 70,000 1- Greater Need BY Total Share: 60,000 50,000 40,000 30,000 - 20,000 10,000 <=30% Cost burden by Race -based on CHAS Table 17 30-50% >50% White '% Black/African American kit Asian ig Hispanic Table 31: City of Miami Housing Cost Burden Housing Cost Burden <=30% 30-50% >50% No / negative income (not computed) DRAFT 2015-2020 Analysis of Impediments to Fair Housing Choice 54 City of Miami Jurisdiction asa whole 6I540 39\530 49,500 3,395 White 11,415 4'835 5'640 655 Black /African 10\9I5 5'260 8'245 975 American Asian 790 220 255 30 American Indian, 0 U O 0 Alaska Native Pacific Islander 20 O 0 O Hispanic 42'095 22,985 35'200 1'715 HOMEBUYER AFFORDABILITY FOR SPECIAL NEEDS POPULATION Several mechanisms have been set in place recently, both on a local and state level, to make additional affordable housing options available to special needs populations. Applicants that are requesting tax credits from Florida Housing are required to set aside for Extremely Low Income (ELI) households 10% of the total units for which they are applying. Starting with the 2009 FHFC Cycle, Florida Housing began requiring Applicants commit to reserving 50% of those ELI units for special needs households, defined as households consisting of homeless families, survivors of domestic violence, persons with a disability, or youth aging out of foster care — through a process called the LINK initiative. Referral Agencies throughout Florida have agreed to provide a coordinated system to assist special needs households with supportive services to obtain and retain permanent housing in their community. The LINK initiative requires that the tax credit developer and referral agency create a Memorandum Of Understanding (MOU) and that this executed MOU is a component of Final Credit Underwriting Report. The Referral Agency creates and implements a referral system to produce a waiting list of eligible prospective tenants when units are completed. In Miami, there are two agencies serving this purpose and for the purpose of this Al, the DCED interviewed one of them — the Housing Assistance Network of Dade, Inc. (HAND) to inquire about the system and how it is working. As of February 2015, there were 188 units in Miami - Dade under the LINK program. The City sought additional information from the FHFC directly, but that was not provided in time for this report. The City utilizes including (but not limited to) single-family rehabilitation assistance, emergency home repair assistance, the single-family replacement home program, and/or the SHIP Homebuyers Financing Program. Starting in FY 13-14, the State required that 20% of any SHIP allocation it made to an entitlement be utilized towards a special needs household. In its most recent Local Housing Assistance Plan (LHAP) spanning FY13-14, FY14-15, and FY15- 16 and filed by the DCED with the State of Florida, persons who have special housing needs are defined as "individuals who have incomes not exceeding modemte'incomeand because of particular social, economic, or health related circumstances, have a greater difficulty acquiring ormaintaining affordable housing," as stipulated in Chapter 67'37.O02(Zl), F.A.C. (page 8). In all rases, the persons being assisted must be very low, low or moderate income with the latter not exceeding 120% AM[ as delineated by the State of Florida every year. In Fi Statues 420.0004 "persons with special needs" means an adult person requiring independent living services in order to maintain housing or develop independent living skills DRAFT —2m/o*o20 Analysis o/Impediments to Fair Housing Choice 55 and who has disabling condition; a young adult formerly in foster care . . . ; a survivor of domestic violence as defined in the statutes; or a person receiving benefits under the Social Security Disability Insurance (SSD|) program or the Supplemental Security Income /SQ\ program orfrom veterans' disability benefits. ECONOMIC TRENDS The City of Miami's economic indicators are mixed — one area of concern is the wide disparities between race and ethnic groups. According to the 2011'2013 American Community Survey 3'YearEstimate, Blacks have the lowest median household income in the City of Miami followed by the Hispanic/Latino population (Table 32). Iubbc3Z: T xdiauHousehold Income byRace, City of MUund Estimate inflation Adjusted DoUam(ZO13) White alone (Not Hispanic orLatino) Black orAfrican American alone ^' ` Asian alone Some other race alone householder Two or more races Hispanic or Latino Householder (of any race) $64,849 $19,922 $59'659 3'337 $38,340 $27,824 Source: u1Census Coiumm/rSu,*mThree-Year Esumx*Median Household 000mrmthe Income and employment are two essential characteristics thatimpact a h h |d' sustainability and economic growth. Table 31 shows the City of Miami's general economic characteristics according to the 2011-2013 ACS (3-year estimates). The median household income is $30,126 while per capita income within the City of Miami was about eight thousand dollars less. Table 33: Selected Economic Characteristics in the City of Miami, 2011-2013 3-year estimate Number Percent |nLabor Force (I6years and older) 212,997 61.9% Mean travel time towork inminutes (l6years and older) 25.9 N Median Household Income (doUan) $30,I26 (X) Median family income (doUan) $33,475 (X) Per capita income (doUan) $21,416 (X) Source: U.S. Census umrou 201/-20 /xC3 Vxvc-yommumumx DRAFT —20/5-202nAnalysis of Impediments mFair Housing Choice 56 INCOME The median household income in Miami is$3O,37Swhile Miami -Dade [ount/sis$43,lUO (ACS I009'2013, 5-year estimate). Historically, this is usually the case—vvith the Count/s median income averaging significantly higher than the Cit/s median income. Keep in mind that Miami -Dade County has significantly more households (estimated 828,032) when compared tVMiami (estimated 15O,974). When further analyzing Miami's household income brackets (seeTab|e34),it'seasytodiscern that the bulk of the renter -occupied units in the City correlate to the lower income brackets. In fact, just over 60% of the renter -occupied unitsare occupied by households making$34,999 and below (ACS 2011'2013, 3'yearestimate). � Table 34:Household Income byIncome Brackets iothe past I%,muo|hy (in IUl3inflation- adjusted doUor¢City ofMiami ZO12-20D3City of Miami - Financial Characteristics Occupied Housing Owner Occupied Housing Renter - occupied housing units Households 152,200 48403 _�'�� 103,797 Income Brackets Estimated Percent Estimated Percent Estimated Percent Less than $14'999 26.9 �� I4.9 ., 32.4 $15'000to$24'999 16J 132 17.9 $25,000to$34'999 12.5 '122 . 12.6 $35,000to$49'999 12.8 ` '� 12.5 13.0 $50'000to$74,999 12.5 ^` ` �J�z4.l `».`` .� 11.8 $75,000to599\999 6.3 '^'�� 9.4 4.8 $I00,000to$I43999�'` �� 6.6 ��' 11.4 43 $l5[\Q000rmore } ^ `�^�^ 6)0 ` \ 12.3 3.1 Source: US. ramxs,Z0//-2ms3-.yearEvunmmxcS, When lki incomes when comparing the 2000 Census data to that of the ACS 2007-2011, 5-year estimate — the data further reveals that the City of Miami is a city in flux, whose housing demands are changing in real time. The city's household wealth is also changing. According to a comparison between 2000 Census and the 2007-2011 ACS (see chart below), the city's share of household earnings less than $10,000 fell from 24% to 16%. In fact, during this same period, the share of every low-income category fell while the share of higher income households rose. It is important to understand that these figures do not say that the city lost residents in low- incomecate8oriesasmuchostheyrevea|thatthe|andscapeofthechYhaschangedbKquite possibly, adding more households to the higher income brackets, and, thereby changing the share ofhouseholds inthese income categories. DRAFT —on/5-2oznAnalysis o,Impediments mFair Housing Choice 57 Less than $z0,000 $10,000m$14,9e9 $15'000m$24,99e $25,000m$34,99e $35'000to$49'999 $50,000m$74,999 $75,000m$99,e99 $100,000to $149,9e9 $150\000m$1e9,99e $2oummo,more � � AN � � W � g Income byHousehold City ufMiami, I00O&IOO7'%Q1l Source: u.S.Census Bureau, zoouCensus &znur LABOR FORCE The i well-being of a community is largely determined by how wellthe residents are connected to the labor market. Currently, f the population 16 years and over is in the labor force. The 2011'2013 Three'YearAmerican Community Survey shows that about7.9Y6 percentofthe OtY' workforce populationisunemp|oyed.Thisfiguremust|ike|y does not reflect the current(act |)economiccnnditions. Therefore, animportant proxy for ' theAgency for Workforce Innovation's (AVV|)market statistics estimates. According to the Florida Department of Economic Opportunity's Local Area Unemployment Statistics 1, in October 2014 (seasonally adjusted) the State of Florida had a 6 percent unemployment rate; a 6.5% was the unemployment rate determined for the Miami, I<endall, and Miami Beach Metropolitan Divisions. Please note that the data is not available solely for the City of Miami, the city is included in this larger metropolitan division. Tob|c3S: City of Miuud Employment ULuburForce) Status, %0ll'2Vl3 Population 16years and over ,^ 344,289 100% |nlabor force `,��/ 212,997 61.9% Civilian labor force' 212,844 61.8% Employed I85`503 53.9% Unemployed 27,341 7.9% Not inlabor force 131,292 38.1% WORK Labor force issues, industry challenges, and opportunities are important to understand together. It is essential to have a perspective about the industries and occupations in which the majority of a city's residents have found employment. Employment and incorne are DRAFT —20/5-202oAnalysis of Impediments to Fair Housing C17oice 58 directly correlated to economic oustainabi|hy and therefore also impact access to home ownership. It is important to note that more than 4O%ofMiami's employed civilians 16years and over hold service and sales occupations, The bulk ofindividuals employed are in low end jobs mostly related tothe service industry sector. Ljfv vilanii --_'-- - Civi|ianemployed population 1Gyears and 180,453 100% over Agriculture, forestry, fishing and hunting, and 484 27% mining Construction 17'372 9.62% Manufacturing 7,718 4.28% Wholesale trade 6'352 3.52% Retail trade 21'577 1I.96Y6 Transportation and warehousing, and utilities I0,854 6.01% Information 3'675 2.04% Finance and insurance, and real estate and I2'30I 682% rental and leasing Professional, scientific, and management, 22,850 12.66% and administrative and waste management services Educational services, and health care and 30\475 16.89% social assistance Arts, entertainment, and recreation, and 25'71I 1425y6 accommodation and food services Other services, except public administration 16,027 8.88% Public administration 5,057 2.80% Jomre 2009-20/3, 5-Year 2sti"^le/ 4m9'iCaTl(Ommu uyJonI�Y� As further broken down in the Table 37, the majority of the occupations in the Miami MS4 are h7retail sales with a invv median hourly wage of$9.86; asof2O15, Florida's minimum wage is $7�93per hour. Thetable shovvsthe top �fteenoocupadons(by count) inthe K8iami htable1 ~ Community survey with the tact that the majority of employmentisfound inservice, low -end income jobs. Wages and wage growth rud | to a household's capacity but according tothe U.5.Bureau ofLabor Statistics, South Florida's wage growth was running about 296 last year. Table 37: Miami -Miami Beach -Kendall MS/t(Q|xni'Dade County) Leading Selected Occupations for 2014, based on 2013 surveys Occupation 2013 2014 Emp|oymem W1edianMr. #of persons Wage Retail Salespersons Registered Nurses Customer Service Representatives 47,220 Zf`22O 9.86 DRAFT —2o,5-202oAnalysis of Impediments to Fair Housing Choice 59 Jomre 2009-20/3, 5-Year 2sti"^le/ 4m9'iCaTl(Ommu uyJonI�Y� As further broken down in the Table 37, the majority of the occupations in the Miami MS4 are h7retail sales with a invv median hourly wage of$9.86; asof2O15, Florida's minimum wage is $7�93per hour. Thetable shovvsthe top �fteenoocupadons(by count) inthe K8iami htable1 ~ Community survey with the tact that the majority of employmentisfound inservice, low -end income jobs. Wages and wage growth rud | to a household's capacity but according tothe U.5.Bureau ofLabor Statistics, South Florida's wage growth was running about 296 last year. Table 37: Miami -Miami Beach -Kendall MS/t(Q|xni'Dade County) Leading Selected Occupations for 2014, based on 2013 surveys Occupation 2013 2014 Emp|oymem W1edianMr. #of persons Wage Retail Salespersons Registered Nurses Customer Service Representatives 47,220 Zf`22O 9.86 DRAFT —2o,5-202oAnalysis of Impediments to Fair Housing Choice 59 Cashiers 25`120 921 Combined Food Preparation and Serving Workers, Including Fast Food 24,670 9.0I Waiters and Waitresses Secretaries and Administrative Assistants, Except Legal, Medical, 22,580 14.18 Office Clerks, General 21,320 1237 Laborers and Freight, Stock, and Material Movers, Hand IE\640 11.46 Security Guards Sales Representatives, Wholesale and Manufacturing, Except Technical and Scientific Products �. 18,470 2127 Stock Clerks and Order Fillers 18,110 10.57 Janitors and Cleaners, Except Maids d Housekeeping Cleaners 16,010 ��9.41 Bookkeeping, Accounting, and Auditing Clerks 13,180'16.85 Accountants and Auditors I2'500 3027 ` Maids and Housekeeping Cleaners ��' _ ' .` 11,400 9.25 ' ' First -Line Supervisors ofOffice andAdmd Support Workers Total all occupations (not all included above) 1/023,360 $15.11 Source.-Agencyfbr Innovation, Florida /&n��A,17m71i, MialviBeach, &mda8MSA A, � ~�U�� U�� -�� CURRENT FAIR HOUSING LEGAL STATUS EVALUATION '^ "^ The of Community & Economic Development is actively engaged in promoting fair housing for City of Miami residents through the monitoring of fair housing complaints and promoting and securing compliance with fair housing regulations. The city's fair housing program is designed to affirmatively further fair housing objectives of Title VI of the Civil Rights Act of 1964, Title VIII of the Civil Rights Act of 1968, as amended, and other relevant federal, state, and local fair housing laws. In 2013, HUD asked all H0PVVAadministrators to document and collect information onthe tnansgender population amongst the HOPVVAclients we serve This data is important to the City, especially in relation to its operation of the Housing Opportunities for Persons with AIDS Program (HOPVVA), as the City serves as the H0PVVA administrator for all of Miami -Dade County and receives approximately $11 million dollars in HOPVVAfundinQ each year to assist approximately 1000 low-income persons living with AIDS with Long -Term Rental Assistance DRAFT -oo/5-202vAnalysis mImpediments to Fair Housing Choice 60 In order to facilitate said data collection, the City hosted a Transgender Sensitivity and Competency Training in September 2013 for all of its HOPWA staff and client support agencies which are located throughout Miami -Dade County. The training was underwritten by SAVE DADE, a local non-profit with a mission to promote, protect and defend equality for people in Miami -Dade County who are lesbian, gay, bisexual and transgender. The last three years, the City has publically acknowledged its commitment to Fair Housing during the month of April, issuing Proclamations recognizing the important for affirmatively furthering fair housing and acknowledging Housing Opportunities for Excellence, Inc. (HOPE, Inc.) for its commitment. In prior years the City had retained HOPE, Inc. to assist us in data gathering for our Al, specifically with the execution of a testing component. During the preparation of this Al, we could not contract with HOPE due to what has been a significant reduction in our CDBG funding, followed by a reduction in Departmental staffing, which started in 2009. The provision of fair housing services is eligible as either a program administration cost, per 24 CFR 570.206, or as a public service, per 24 CFR 570.201(e). Because of recent cuts in federal funding, the City does not currently allocate CDBG funds exclusively to undertake fair housing activities. Later in this document, we do identify the funding situation as one of our major impediments, specifically because we feel that good, anonymous testing is vital to recognizing the level of discrimination (of protected classes) taking place in any community. It is our goal, during the course of this current AI, to be able to fund a round of paired testing ultimately performed. However, we do want to thank HOPE, Inc. for their cooperation with this Al, as they have provided vital information and statistics and continue to be a vital partner in our fair housing efforts. HOPE, Inc. is a private fair housing not -for -profit organization dedicated to eliminating housing discrimination and promoting fair housing in South Florida. HOPE, Inc. employs a three -tiered system of private enforcement, education outreach, and counseling to achieve its mission to affirmatively further fair housing. Its programs are designed to ensure that residents, including those living in the City of Miami, are offered the right to select housing of their choice without discrimination based on race, religion, color, national origin, sex, disability, marital or familial status, or such other protected classes as may be conferred by federal, state, or local laws FAIR HOUSING CO PLAINTS As a local FHIP, the private, not -for -profit Housing Opportunities Project for Excellence, Inc. (HOPE, Inc.), documents calls, e-mails, and takes in -person requests from persons throughout Miami -Dade County and its municipalities, that allege housing discrimination based on one of the protected classes. The City of Miami does not currently have a contract with HOPE, Inc. due to funding shortages. However, HOPE, Inc. accepts and processes fair housing inquiries and complaints from City residents providing said data in annual intake reports. HOPE, Inc. provides these public reports to us noting the complainant's zip code -- not their exact address, in order to protect the anonymity of the caller. We should note that some City zip codes do overlap with other jurisdictions so there is a possibility that some of the data we are DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 61 City of Miami attributing to persons in one of our City zip codes, might in fact fall within a neighboring community. Nonetheless, analyzing HOPE |nc.~s data allows the [itvs D[ED to better understand any trends or concentrations of discrimination aUegations/tomp|aintswithin our boundaries. This allows us to better focus our fair housing information efforts in particular areas. As a disclaimer, we should also clarify that because an inquiry is filed, it does not mean that a discriminatory act occurred or that it was taken to court. As noted in Table 38 below, the bulk of the inquiries in the past three years have pretty consistently come fromthesame zip codes —these are 33125,3313Q,33142 an633147.VVith one exception (zip code 33138), three of the noted zip codes run alongside one another in the northern end of the City of Miami. In the color coded map below, the two clarker blue sections again illustrate the zips with the highest reported number of complaints (based on three-year City of Miami Fair Housing Complaints 3 year average (2012-2014) by Zip Code Legend «'20 | n�w | m�upvm ° DRAFT —zo,5-202nAnalysis mImpediments mFair Housing Choice 62 When looking at the category of inquiries on any given year, the overwhe I ming majority (more than 75%) of these in each of the three given years identified in the table fall under category basis of discrimination that HOPE, Inc. identifies as "Other." According to HOPE, Inc., "Other" simply means the inquiry was based on a class other than one named in our federal, state, or local fair housing |ovvs. The assumption that discrimination did not take place should not be made. The second largest number of inquiries falls under the basis of discrimination HOPE, Inc. identifies a»"Disabi|ity,"followed by"Race." Toble30 HOPE, Intake for City Zip Codes 33125 33126 33127 }3lZ8 33129 33130 33131 33132 33133 33134 33135 33136 33137 33138 33139 33142 33144 33145 33146 33147 33149 33150 2 4 11 3 2 1 4 7 ;3 7�''^ 9 6 2 \t S � Tuta|casesin 94 City zips I '5 3 132 2' Tn1olperzip 313112013 ' 13 3 1 7 3 3 � . 13 3 2 2 2 4 117 Total cases in County zips *The most reoentfiscal year reported bincomplete, as 5mnnths remain. Table 39:HOPE, Inc. Basis ofDiscrimination for City zip code Based on intake reports = 411/2014' 4/1/2013' 2Cy3l/2D14* 3132/2014 3/32/2013 code 4 18 1 3 9 10 8 ` 28 8 5 ] 2 O 23 DRAFT —20/5-202nAnalysis of Impediments to Fair *msingChoice 63 Disability Familial Status National Origin Other Race Sexual Orientation Blank Rental Total 9 14 17 l 2 O I O l DO 106 93 3 7 3 O O 2 O 3 O O O 1 94 l3I 117 | NATIONAL TRENDSAccording to the National Fair Housing Alliance's (NFHA) 2014 Fair Housing Trends report, ' "Expanding Opportunity: Systematic Approaches to Fair Housing," fair housing cornplaints (amounting to 27,352 filed in 2013, nationwide) have remained r I elatively steady compared to recent years. HUD estimates that the number of reported complaints represents less than one percent of the four million instances of housing discrimination that occur each year. The highest count of complaints reported by HUD in 2013 were disability related (53.5%), followed by 28.6% complaints reported to HUD that were race -related. It is interesting to note that although HUD witnessed an increase in six of the seven protected categories under the Fair Housing Act, race -based discrimination complaints have declined over the past two years (though it still remains the second -highest type of complaint). Discrimination complaints from renters with disabilities are the category with the highest number (44 percent) of complaints. COMPLIANCE / The following section provides informationoutlining the actions taken since the last Al to address the fair housing ' complaints identified in the City ofMiami. EDUCATION, OUTREACH, AND MONITORING The City of Miami continuously works throughout the year to implement the Affirmative Fair Housing Marketing Plan via seminars to multiple segments of the community, in conjunction with general outreach via the city's cable TV and radio operations and department. In addition, the city distributes free fair housing material at different city locations and at city sponsored events relevant to affordable housing. Aside from this, HOPE, Inc. conducts its own fair housing educational workshops within the County and City, also educating community based organizations, disability advocacy agency staff and clientele, and local housing industry professionals. These seminars provided attendees with key information regarding fair housing laws and how to seek redress of grievances related to housing discrimination, issues regarding reasonable accommodations, dwelling unit modifications for the disabled, housing opportunities for people with AIDS, and compliance with fair housing laws that protect against housing discrimination due to race, color, religion, national origin, sex, disability, familial status, age, marital status, or sexual orientation. Please see Table 20for a complete listing of workshops. Specialized workshops for housing providers, including Community & Economic Development Block Grants ([DBG)/Home Investment Partnerships Program (HOME) funded Community & Economic DRAFT —zor5-202oAnalysis of Impediments to Fair Housing Choice 64 Development Corporations (CDCs), and Community @ Economic Development Housing Organizatinns(CHDOd, have also been provided through HOPE, Inc. In addition to the workshops, a media campaign was undertaken that provided an opportunity to outreach to the citvs residents about fair housing rights. The city implemented a fair housing campaign, including HUD public service announcements on radio and television, and other public relations efforts. The campaign aired on the city -operated cable network (channel 77), with a potential viewership of over 64,000. Radio public service announcements are broadcast on the city -operated station (1680AM). Fair Housing materials were distributed at city related events as well as included in the Department's quarterly newsletter and posted on the city'sCommunity & Economic Developmentvvebsite. In addition, the City has issued proclamations for the last twoyears 7014,ZO23)during National Fair Housing Month (April) further reinforce its commitment � upholding the Fair Housing Act and affirmatively -furthering fair housing. |tshould benoted that fair housing marketing ter |s(i are available at all of the chys NET offices, which arelocated in all five city commission districts and accessible to city residents. Table 40:Fair BouobzeEducation and Outreach Activities. ' Date Description Address #Attendees February 18/2 ,- Staff training, Furthering Fair -'Housing ` Training � � --- CommunityNational ' Reinvestment Coalition 80 ~~ � �d Orlando, FL32MO4 2City employees September �Training for HOPWA age including^4O4NVV3 and working with the transgender community Street 40 24^2O14 Wor � -----''- �-=��--ng-_ Predatory Land----na (Creole) ^ ' ^ Haitian American hua» CDCJo- (Little Haiti) Varies February 1.2014 Housing 'Community South Florida Development Coalition VariesPresentation �f March ''~^ Community^Fair Participation CnnneodFami|�eR�r Miam�DadoCoUege |ntenamehconCompus Varies March ^�Predatory C��rHouong�o '' � ' ' Lending Sessions Chapman families meeting Varies March 20 2O�4 HOPE FHC. Fair Housing &/or Predatory Lending Sessions Aoo�n Community Service Center Varies' Munch 22 2014 HOPE FHC, Fair Housing Wor Predatory Lending Sessions Neighborhood Housing Services Varies' April 1.2O14 HOPEFHC� �FairHoueingWor Predatory Lending Sessions (Community Meeting) ConneutFami|iam(Litt|e Varies DRAFT -zo1n-2o20Analysis n/Impediments mFair oousin Choice City of Miami 65 April H0PEFHC Fair ' Predatory Lending Sessions MiamiVVorkamCenter Varies April � Housing Provider HOPE FHC� Presentation Miami -Dade Homeless Trust Varies May 5.2014 HOPE: Housing Provider Presentation Miami Rescue Mission Varies May 2O.2U14 HOPE FHC.Fair Housing &or Predatory Lending Sessions VVynwmodCommunity Advisory Committee ` Varies K��y21'2014 Letter toall 10O+Section 8 HCVlandlords including fair ']Nu�pe�' hou�ngbmchureand reminder , N/A May 23.2O14 HOPE FHC, Fair Housing Predatory Lending Sessions (Creole) Haitian American Vehoa May 3O.2O14 Periodic mailings tofunded developers reminding them of� alerting H ` to initiation marketing oonvnee' ' Multiple developers ! `'^ . ' (�5� Junn0' 2O14 HOPE FHC: Community, Cultural, Health & Job Fairs, �� _ Folk Life (Ovedown)� Varies July 18,2014 HOPE FHC: Community ,Hosanna Community (' Varies July 19.2U14 ^ HOPE FHC: Fair Housing Wor Predatory Lending Seoeonay� Nieighborhood Housing Services� Varies July H Community HC�ComFair HOPE�.^� ~~~�^ Aa000abonofA0eno�a otMiami-Dade College Wolfson Compue8Niami- Dade County Commission on Disobi|iflyIssues (AJ]A 25» anniversary celebration) Varies July25. 2014 ' FHC: Community Fair Miami Rescue Mission Varies July 2S 2O14 y . � HOPE FHC�FoirHoueing&or Pnad�oryLending Sessions Hadley Park Homeowners Association (Liberty City) Varies--� August 2.2014 HOPE FHC: Community Fair 54m Street �adiou| Plaza ` Community Fair Varies August O.2014 HOPE FHC: Community Fair FanmAyieyennan Miyami(FANM) CommunityFair—Littlo Havana Varies DRAFT —m/5-202oAnalysis of Impediments to Fair Housing Choice City of Miami 66 August 7.2O14 HOPE FHC:Housing Provider Presentation Haitian American CDC Varies September 24.2O14 HOPE FHC:Community Fair Dade County Bar Association Young Lawyers Division (Hadley Pork. Liberty City) Varies September 27.2014 HOPE FHC:Community Fair CNCCommunity Fair, Marlins Park (Little Havana) Varies September 1Q.20l4 HOPE FHC: Community fair Miami -Dade College Wolfson Campus (Downtown Miami) Varies October Fair Housing &P�d�ory Lending Presentation (Creole) �Haitian American CDC Varies November8.2O14 Community, Culture, andbrJob F�r �� ~~ ^'`~' ~^^' Miami ^~a~`~~^' ege |ntenamehoanCampue�` yahoo November 12.2014 FairH � Lending Presentation Liberty City Community rmRevitalization /,ua 'yahee Nuvember22' Lending '~'' Housing~Predatory| `Development ^ NHS at Coconut Grove CollaborativeVaVaLending��6� ~~`~'"p'"^""'p. November 24.2O14� ' � .'' ` Public Forum for Interested�' Miami~�� '-- --- ^' concern.....e~~estate �a �� market Miami sU| ~' ^�.�' ' Commission Chambers 15 ` December '1o'�O�� and/or Job Fair (Mo8day) Jessie Trice Community Health Center Varies ,^' J 5Uhm — �� --_- Surveyon . � -` matters issued to 'over 1,000 ~~~ posted on Department web site for 45days ', Via mailing 57 `�� April `�� housingAssistant Director of Policy attended HOPE, Inc.'s Fair � — declaring April 2015, Fair 'Housing Month in the City of Jung|*|�and' Cdyof Miami, FL 100+ Source: oiffinnationprovided bYo0PL,mu Finally, in addition to education and outreach, HOPE, Inc. conducts continued monitoring of the following newspapers, apartment magazines, and books for housing discrimination and prohibited advertisement. • The Apartment For Rent • Senior Outlook • The Miami Herald DRAFT -zo,5-202oAnalysis of Impediments mFair Housing Choice 67 ° Homes8y'Ovvner �The New Times � Harmon Homes • CasasHarmon South Florida = Co|dvveU Banker Real Estate Buyer's Guide = Greater Miami Apartment Guide • The Flyer ° For Rent Magazine = South Florida Senior Outlook � E| Flyer � New Times � E| Oahn " Apartment Magazine and Street " Para Rentar DISCRIMINATION SUITS FILED HOPE, Inc.also conducts independent testing ofadvertisedrental or sales' propertiesto determine hthlandlords, | y withtheir responsibilities under the Fair Housing Act. Upon consulting three fair housing s could be identified that have been litigated inthe City ofMiami since the|astAi Be|nvvisabrief description of ` these: I. Wells Fargo '- In early 2012, the National Fair Housing alliance filed a formal complaint against three big banks with U.S. HUD. HOPE -took part in a nationwide survey of foreclosed homes conducted by the National Fair Housing Alliance (NFHA). The alliance examined foreclosed properties controlled by three of the largest banks Wells Fargo, U.S. Bank, and Bank of America in the country — Wells Fargo, U.S. Bank, and Bank of Arnerica for failing to maintain its REO properties in minority neighborhoods ` . Evidence �^regular maintenance and efforts to sell hanvacanthomesinminoritycommunities. More than 2400 REO propertiesthirty major metropolitan areas were investigated and results were detailed in "Zip code Inequality: Discrimination by Banks in the Maintenance of Foreclosed Homes in Neighborhoods of[o|or." 2. Design | ogoin/nDecember 2024,Sl75NEZCt.-HOPE, Inc. sued SPVRealty (propertynvvner)ofaSUOunitapartmentcomp|ex,aUeginQthat sales staff discriminated based on race (Blacks), telling them that units were not available while telling a second person (White) they were on the same day. The lawsuit also alleged the Africa n`American renters were quoted higher rental rates than theirAng|o counterparts. Asettlement was reached. Asecond lawsuit against the same property was filed in December 2014 after recent testing found that the same discriminatory practices were still in place. HOPE isseeking financial damages for both the wrongdoing and because the site isarepeat offender. 3. Elite River View Apartments Moy 2014 - - HOPE, Inc. sued Bite River View Apartments for race -based discrimination atthis apartment complex located at 1750 DRAFT -zo/5-202oAnalysis of Impediments mFair Housing Choice 68 NW 27 Ave. After testing on three separate dates, it was found that the sales/leasing office staff systematically refusing to show vacant apartments to Africa n-Americans. The rental complex settled the case out ofcourt inNovember 20I4. 4. In Dec. 2013 and mid-2014, the City of Miami filed separate lawsuits in Florida federal court claiming that Bank of America, JP Morgan Chase, Wells Fargo and Citigroup violated the 1968 Fair Housing Act by targeting minority communities with high - interest loans (predatory lending) dating back to 2004, thereby creating a foreclosure crisis that decreased tax revenues and increasing the need for municipal services. As of July 2014, Judge William Dimitrou|eas of United s District Court for the Southern District ofFlorida had dismissed two ofthe lawsuits. 5. In April 2015, HOPE, Inc. filed a lawsuit against two South Florida apartment buildings, Terrace). Both sites were tested for discrimination against protected classes — on three occasions --- between Aug. 2014 and Feb. 2015. The lawsuit alleges that both apartment complexes violated the Fair Housing Act of 1965 — specifically discriminating based on race in relation to offering housing at the sites -- and that the property owners/managers pay punitive and compensatory damages to HOPE and the Black plaintiffs, as well as attorney and court fees." one which is located in the City of Miami neighborhood of Allapattah (1434 NW 19 - A BRIEF SUMMARY CURRENT PRAND ACTIVITIES TO AFFIRMATIVELY FUTHER FAIR HOUSING IN THE CITY OF K4|AM| This chapter briefly summarizes the current programsandactivitiescarhedoutbythe[ity of Miami. Both federal and non-federal programs are included in the assessment. The activities cited in this chapter were identified in the 2010 — 2011 Action Plan and are currently underway. In addition to the programs and activities, this chapter will also state the City's Affirmative Fair Housing policies pursuant to HUD regulations, 24 CFR 92.351 and consistent with Davis -Bacon and Section 3 protocols. Specifically, the City of Miami has adopted affirmative marketing procedures and requirements for rental and homebuyer projects containing five or more HOME/CDBG-assisted housing units. PROGRAMS FEDERALLY FUNDED PROGRAMS Community O' Economic Development Block Grant Entitlement Program (QJBG): As an entitlement City, Miami receives an annual CDBG grant on a formula basis. The formula takes into account total population, overcrowding, and poverty. [D8G funds must be used for /6The Miami Times, "Blacks turned away from housing —agam.^Jose Cassola.April 8,co1». DRAFT —zo/n-2ocoAnalysis u,Impediments to Fair Housing Choice City of Miami 69 activities that benefit low- and moderate -income persons. Eligible activities include affordable housing, public service, and economic development activities. The City (via the D[ED) allocates most ofits [DKGgrant funding on a competitive bads, making funds available to non-profit agencies via a Request for Proposal (RFP) process held every two years. Priorities for these funds are established at annual public hearings, held in each of the five districts of the City of Miami Different districts have different priorities and the priorities for each District are noted in the RFP issued by the City for agencies to respond to, and workshops are held toaddress any questions related to the RFP. All RFPs submitted are reviewed and scored and the DCED makes funding recommendations to the City of Miami The City updates (as needed) its CDBG Policies and Procedures Manual for all sub -recipients which is made available to them at the beginning and during the fiscal year. The last update to the manual was finalized in 2014. In the manual (page 23), the City details the different Civil Rights and Fair Housing requirements that all sub -recipients are bound to, including Title VI of the Civil Rights Act of 1964, the Fair Housing Act (Title VIII of the Civil Rights Act of 1968, Executive Order 11063/amended by 12259,,and Section 104(b) and 109 of Title I of the Housing and Community Development Act of 1974. The manual (page 24-25) also addresses the requirements of Section 3 of the Housing and Community Development Act of 1968, Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act (ADA) of 1990, and the Age Discrimination Act of 1975 (as amended). In the last [DBG RFP competitive cycle (for FY14-15), approximately 30 non -profits were awarded CDBG funds. Home Investment Partnerships Program (HOME): The purpose of the HOME Program is to increase the housing for low and very -low- income hh|U capacity nfnonprofit housing providers through�CHDOs. Jurisdictionscan'a HOME funds to carry out a wide variety of housing activities for low- and very low-income families, including: •� Homebuyer programs, hic include down payment and closing costs vassistance, construction loans, rehabi|itation, o/ new construction or soft cost pre -development. m Rental housing programs, consisting of construction loans, permanent mortgage loans, bridge loans, or loan guarantees for acquisition, rehabilitation, new construction, and refinancing. p Homeowner rehabilitation programs, including grants, loans, interest subsidies, and loan guarantees to pay for hard costs, related soft costs, and refinancing expenses. The City (via the DCED) also issues Requests for Proposals (RFP) for its HOME program based onfunding availability and recommendsKFPs based on a competitive basis. In each HOME proposal issued, the DCED addresses any priority housing needs the City may have based on its current Consolidated Plan. The DCED issued its last RFP inJanuary 2014. In said RFP, an additional 20 points (out of total 100 points) were awarded to any projects that were to be developed in District Z or District 4 of the City of Miami. This preference was identified because these are the two districts of the City where land prices are highest and where we DRAFT —cv1n-2o20 Analysis mImpediments mFair Housing Choice 70 have historically seen the least amount of affordable housing development. The City believes in furthering fair housing choice whenever possible and saw this KFP as an opportunity to incentivize developers to seek locations where subsidized housing is lacking. We are happy to say that out of a total 21 RFPs received, the two recommended, and ultimately funded, projects were located inone ofthose two districts. All HOME related contracts require anAffirmative Fair Housing Marketing Plan AFHMP(HUD 935.2A) attachment/exhibit that developers must sign and attest to during the duration of the agreement with the City ofMiami/D[ED. Each recipient ofHOME funds must comply with several requirements including, but not limited to: • Describe proposed methodof advertising to be used'to market to those least likely to apply * Display Fair Housing Poster in any location where the sale/rental co assisted units (more than S)takes place m Ensure that a City orMiami (standard) Solutions Housing Opportunities for Persons with AIDS (HOPWJA):The City ofMiami serves asthe administrator of the formula grant -funded Housing Opportunities for Persons with AIDS /HOPVVA> program for the entire geographical area ofMiami'Dade County. The goal and intent of the local HDPVVA Program is to ensure that a continuum of housing options and related housing services are available to |ovv income persons with Acquired immunodeficiency Syndrome (AIDS) or related diseases to prevent homelessness of such DRAFT —o//o-2o20Analysis orImpediments mFair Housing Choice 71 individuals and their families. We address this population in further detail elsewhere in this document. Neighborhood Stabilization Program (NSP): OnJuly 3O, 2008,the Housing and Economic Recovery Act of2OO8 was signed into law to address the nation's severe housing crisis. Title III of the Act appropriates grant funds under NSP for states and local governments to purchase and redevelop abandoned orforeclosed properties. The Housing and Economic Recovery Act of 2008 directed the United States Department of Housing and Urban Development (HUD) to target funding to areas with the greatest needs based on the extent of foreclosures, subprime mortgages, and mortgage delinquencies and defaults. As part of the NSP allocations made to governments throughout the State ofFlorida, the City ofMiami wasawardedapproximately $12.06 million. All activities funded by NSP must benefit low-andmoderate'income persons whose income does not exceed 1ZO96nfarea median income. NON -FEDERALLY FUNDED PROGRAMS Affordable Housing Trust Fund (AHTF): The City of Miami Planning & Zoning Departments also collect financial contributions (as stipulated by the current Zoning Ordinance) from private developers who opt for specific provisions allowed by the City of Miami Zoning Code (Miami2l) to developments providing a certain number of affordable units in a given project, as defined by the Code. These collections are then dedicated to the City's Affordable Housing Trust Fund (AHTF), with funding from this source used to further the DCED's existent housing programs, aiding both homebuyers (first-time and existent) and for -profit or not -for -profit developers (multi -family rental and homeownership projects), as delineated in the Affordable Housing Trust guidelines approved by City Commission in Resolution #07-0203. In the case of homeownership housing, households must qualify as having income of up to 150%of the AMI; in the case of rental housing, the income of renters must be at or below 80% AMI. Building Bonds: passed by County residents in November 2004, is the largest capital construction bond program in the County's history, encompassing over $2 billion and spanning total project completion between 15 to 20 years. The bonds are legally backed by the full faith and credit of the County which has committed future taxes over the next 40 years to repay the bonds. Bond awards are made to projects — including affordable housing projects — at the discretion of the Miami -Dade County Commission. Community Redevelopment Agencies (CRA): Two CRAs operate within City of Miarni boundaries one in the east Overtovvn Park West neighborhood, and a second in the OMNi Both are independent government agencies established by the City ofMiami and Miami Dade County in the 1980s, pursuant to the Community Redevelopment Act of1969. The main objective of the agencies is to eliminate slum and blight within their respective boundaries. The agency is governed by the Board of Commissioners of the City of Miami. The [RAfunds its programs and projects primarily through Tax Increment Financing, which uses the increased property tax revenues collected by the City ofMiami and Miami Dade County. In turn, the CRA reinvests these funds back into the Redevelopment Area by funding infrastructure and capital improvements, affordable housing and economic development DRAFT —zo15-202nAnalysis of Impediments to Fair Housing Choice 72 State Housing Initiatives Partnership program (SHIP): The State Housing Initiatives Partnership program is the first permanently funded state housing program in the nation to provide funds directly to local governments to increase affordable housing opportunities on a noncompetitive basis. The funds are used to produce and preserve affordable homeownership and multifamily housing for very low, low and moderate income families. The City of Miami uses SHIP dollars to fund emergency repairs, new construction, rehabilitation, down payment and closing cost assistance, construction and gap financing, mortgage buy'dovvns, matching dollars for federal housing grants and programs, and homeownership counseling. After a freeze on SHIP allocations for several years related tmthe national and state economic downturn, the City received @ $SUO,0OOinFYZOI3'2Ol4and just over $Imillion in2014'281S.The program isfunded bvadocumentary stampproO/ammade possible by the State's Sadowski Act. Miami -Dade 201.131 of the Florida Statutes, certain counties are ' authorized to levy a surtax on documents that transfer interest in Florida real property (transfers of interest in single-family residences are exempt from this surtax). In 1984, Miami -Dade County exercised that authority, establishing a Housing Assistance Loan Trust Fund and implementing the Documentary Surtax Program ("Surtax Program"). This program requires that at least 75% of the funds are allocated to successful agencies to benefit low-income families with incomes of 80% or less of AMI for the County. The remaining 25% are to be made available to moderate income families with incornes of up to 140% AM]. Surtax awards are made based on application process handled entirely by the County's Public Housing & Community Development Department, and presented for the review and approval of the Miami -Dade County Board of County Commissioners. Typically, surtax funds are used for activities including rental housing development, rehabilitation, homeownership, and mortgage assistance. In 2014, approximately $48 million were recommended for funding throughout all of Miami -Dade Low-income Housing Tax Credit Program: The Low-income Housing Tax Credit Program is a tool for private developers and not -for -profit entities to construct or rehabilitate affordable rental units. This program is operated by the Florida Housing Finance Corporation (FHFC) based in the state capital (Tallahassee) and via a competitive application process awards developers 9% tax credits in exchange for substantially rehabilitating or constructing (new) rental housing projects that set aside either 40 percent of the units at 60% of AMI or 20 percent or more units at 50% AMI or below. Miami -Dade County Food and Beverage Tax Funds: The Food and Beverage (F&B) tax is a 1% sales tax levied on food and beverages to provide a dedicated source of funding collected County -wide to fund the County's two Homeless Assistance Centers (HAQ or supportive housing projects (for the formerly homeless) and/or homeless services but these funds are solely administered and managed by the Miami -Dade Homeless Trust (Trust), the main Continuum of Care (CoC) operator in our County (85% of the funds toward homeless and 15% toward domestic violence services). Again, F&8funds are awarded via a Request for Proposal (RFP) process. Approximately $18.4 million was collected in 2014, through October. DRAFT —20/5-202oAnalysis of Impediments mFair Housing Choice 73 ACTIVITIES The City of Miami stated in its FY2015-2016Action Plan that the current activities would focus on implementing po I icies that advance housing preservation and neighborhood revita I ization, with the overall goal of improving the quality of life of the residents and preserving the social and historic character of low income neighborhoods threatened by gentrification. Specifically, the focus has been onthe following activities: � Affordable housing preservation through single-family rehab and residential code compliance assistance, supportive fair housing activities, dovvnpaymentasd»tance, and funding affordable housing developments. � Neighborhood revitalization through supporting economic development activities in the Commercial Business Corridors ( funding for projects that will stimulate revitalization within the Neighborhood Development Zones (NDZs). Other city areas are also being taken into consideration. PRESERVE AFFORDABLE RENTAL HOUSING ACTIVITIES In order to preserve affordable rental housing opportunities within the City of Miami, the Department of Community & Economic Development is encouraging the construction of new rental units within the target areas as specified in the 2014-2018 Consolidated Plan, as well as the funding of existent LIHTC and/or affordable rental buildings in need of upgrades/renovations. Through this initiative, the City seeks to increase and preserve the inventory of affordable rental housing available to low and moderate income households. As recommended in the Housing Needs Assessment in the Consolidated Plan, the focus will be on serving those that are most in need of rentalassistance, namely low-, very -low-, and low to moderate income residents. Below is a description of the activities. Multi -Family RentaNewConstruction: To increase the inventory —f affordable rental housing in the Model Blocks and the NDZs, the City of Miami encourages the construction of unitsnew rental for -profit housing developers. The City provides construction loans,t mortgage loans, bridge loans, or loan guarantees for acquisition, rehabilitation, new construction, and refinancing. Multi -Family preserve the affordable rental housing inventory, the City ofmulti-family rental rehabilitation loans and/or grants for the preservation f affordable rental housing available to extremely low-, very low-, and low to moderate'incomere Housing Choice Voucher Assistance: The City ofMiami provides rental subsidies to 136 low - and very -low, and moderate -income households through the Section 8 Program. Participants in the HCVprognam are free to choose any qualified housing inthe private housing market located within -the boundaries of Miami -Dade County. Generally, each participant pays at least 30% of their household income towards housing costs (including rent and utilities). A voucher that covers the rest of the costs, up to a limit, is issued by the administering housing agency. The DCED oversees the program from the City of Miami which serves households with incomes at or below 80 percent of the median income for the Metropolitan Statistical Area (MSA). Due to the high cost of rental units in Miami, the gap between what working poor, elderly and disabled people can afford in the rental market and what rents are has grown DRAFT —co/o-2n20 Analysis of Impediments mFair Housing Choice 74 exponentially in recent years. This has placed even more demand on the program which has a very low level of attrition in our community. Section U Moderate Rehabilitation Program (Rental Assistance): The chvs Housing Choice Voucher Assistance program allows qualifying households to choose and lease or purchase safe, decent, and affordable privately -owned rental housing. The City oversees moderate - rehabilitation units in 16 buildings located in two of the Cit/s five districts. The bulk of the units inthis program are one -bedrooms (2Z7),with 38 units offering two bedrooms, and a total of 15 studio apartments. The last waitlist for the S8 Mod Rehab program was established in I003. Atthat time, data on applicant's race, sex, ethnicity, was not logged sovvecannot address the characteristics ofthat vvait|irLatthis time. PRESERVE EXISTING AFFORDABLE HOUSING HOMEOWNER ACTIVITIES The City of Miami has focused on providing housing rehabilitation assistance to low and moderate income households in order to help them maintain and retain their homes, and prevent the existing housing stock from continuing to decline. This is important because there are a substantial number of the single family homes in the City that fall below minimum housing quality standards (disrepair). Many of these homes are owned by low and moderate income homeowners who lack the financial capacity and/or credit history required to obtain home repair financing from private lenders. The goal is to assist homeowners with rehabilitation of housing, the removal of code violations, and replacement of unsafe structures. Preference has been given to the elderly and disabled. Below are the specific activities used to implement this policy. Single -Family Rehabilitation provides home improvement and rehabilitation assistance to homeowners throughout the City in order to improve the condition of existing housing stock. Under this rehab program, existing income -eligible homeowner(s) that reside and maintain a property as their principal residence in the City of Miami will be able to obtain a deferred loan to bring their property to decent, safe, and sanitary housing standards, or to correct existing code violations. Through this program, the City has been able to encourage low to moderate income owners that have illegal units to bring their properties up to code or to remove the illegal structures. The Department of Community & Economic Development plans to continue to work closely with the Code Enforcement Division of the city to target areas that have a high number of code violations. The intent is to provide incentives for homeowners to correct such code violations. Recently, the City had to up it's maximum assistance amount under this program to $50,000, from the previously approved amount of $35,000, because of the serious conditions of the properties in the program, along with the rising local costs of construction materials. Housing Replacement: The City provides assistance tn replace dilapidated owner -occupied housing units which are not suitable for rehabilitation due to the extent of their needed repairs. Funds are used to defray the cost of temporary relocation expenses, demolition of the dilapidated structure, and soft and hard construction costs associated with the reconstruction of the new home. In Miami, the maximum loan under this program is $150,000. Because of the shortage of housing funds, very few home replacements take place onany given year. DRAFT —20/5-202oAnalysis of Impediments to Fair Housing Choice 75 HOMEOWNERSHIP ACTIVITIES The City of Miami continues working toward providing affordable homeownership opportunities for working class and moderate income families who are seeking to become homeowners, but need additional financial assistance to be able toafford their home. The City plans to continue to increase the inventory of affordable homeownership units through new construction of affordable housing units and its homeownership financing program. In addition, the City helps renters prepare for homeownership by referring them to Homebuyer Counseling Programs. The following describes the specific activities. Finance Construction ofNew Homeownership Units: The ' promotes affordable homeownership opportunities for |ovv and moderate income families by financing new construction. The City also provides hard and soft construction financing and permanent Provide STIMULATE HOUSING DEVELOPMENT - OTHER NON -HUD ACTIVITIES |naddition tothe activities listed above, it has been important forthe City ofMiami toprovide incentives to stimulate housing development. Such incentives help to off -set the barriers that make it difficult undertake affordable housing projects. The following is a list of the incentives that the City ofMiami ' provides inorder tofacilitate the development ofaffordable Affordable Housing Incentives:' The City of Miami continues to provide incentives to developers through the Affordable Housing Incentive Plan. This plan provides developers of affordable housing projects with a number of local incentives that are intended to expedite the pre -development process and reduce certain cost(s) in connection with the production of affordable housing projects in the City of Miami. The incentives — which are ongoing —include: • Expedited, • Review of Legislation, Policies and Plans that impact Affordable Housing. • Impact Fee • Reduction of Parking and SetbackRequirements Miami 2lallows for parking reduction for Low -Income Housing byprocess ofexemption — only uptofifty percent (5OY6)ofthe spaces generally required. ° Lien Removals for Affordable Housing properties Train (nr/VVorkshops for Developers onCity Programs and Regulations: The Community & Economic Development Department seeks opportunities to work with otherCity departments and Miami -Dade County to provide training to developers on the rules and regulations that govern the development process. Such training may include workshops onthe permitting process, zoning, and environmental clearances. DRAFT —2u,n-2020 Analysis mImpediments to Fair Housing Choice 76 Increase Capacity of Non-profit Housing Providers: To help improve the capacity of non- profit housing providers, the City of Miami provides various services intended to assist these organizations. Furthermore, the City encourages [DCsto partner with private developers by giving developers extra credit points in their RFP applications if they have a 51 percent partner that isanon'profit SPECIAL NEEDS AFFORDABLE HOUSING ACTIVITIES The City of Miami is committed to assisting persons with special needs, and their families, obtain affordable housing. Special needs populations include the elderly, individuals living vvithH|V/A|DS and persons with disabilities who are within the' very low tomoderate income range. The activities for special needs populations are described below. Housing Opportunities for the Elderly: The City continues to seek opportunitiesto fund rehabilitation and new construction of residential -- projects that Section 2U3 Supportive pnqe s e on uppo ve Housing Opportunities for People with AIDS: Through the HOPWA Long Term Rental Homeless AFFORDABLE HOMEOWNERSHIP An FHA mortgage i by an FHA approved lender but backed by the Federal Housing Administration (providing additional security tnthe |ended.This loan program only requires a 3.5% down payment (or equity for a refinance) for people with good credit scores. It is possible for someone with a weaker credit score to qualify for the FHA program with 10% down. The lS96down payment program ishighly desirable to people that have the income to buy a home, but may not have much of down payment (or those who just want to minimize their down payment). The inability to get certification hurts condos' affordability, since buyers who seek financing without it face greater interest rates, and down payments of around 20percent, rather than the FHA'scustomary 3.5percent. Afterthe real estate collapse, and the tightening of FHA rules, many communities saw a sharp decline in the number ofFHA approved condominium buildings and Miami was no exception. DRAFT —zn/n-2o2oAnalysis orImpediments o»Fair Housing Choice 77 After conversations with the M|AM| Realtors association, the lack of FHA approved condominiums has become a housing impediment. Foremost, for one buyer in a condominium building to be approved for an FHA loan, the entire complex must follow specific guidelines including that at least 5096 of the development's units must be owner - occupied, no more than 15% of the total units can be over 60 days late in their association fees, and the association cannot be partyto a pending legal action. Getting FHAapproved also requires extensive documentation — both financial and insurance documents (hazard, Moor, liability, fidelity bond/insurance) and many developers opt to not gothrough that process. Aside from these difficulties, there is also a common misconception that FHA Loans are for the low-income although statistics indicate that some 6096ofhomebuyers use an FHA Loan. This too can create a "stigma" tied to FHA loans amongst condo owners (assodation»)who can opt to avoid the complicated FHA review/approval process altogether.id hi Florida law allows condominium boards to waive reserves and there is a ban of co-insurance on hazard insurance policies. The Miami Association of Realtors has also reported that estimates indicate that approximately 95% of conclorniniums in South Florida have co- insurance, as such making them ineligible for FHA insured loans. Moreover, the Association also points out that the FHA doesn't have a policy to accept pooled or state -run insurance As already explained,the bulk of Miami's housing k is comprised of conclorninium units, yet a short list of FIVE is FHA approved which affects the local buyer's ability to purchase a condo as a primary home under this program. Reports indicate that in the County's entire roster of 4760 condo projects, only 21 are approved. Upon discussions with the MIAMI Realtors Association, and the issues the latter creates for their business, several factors were brought up as potential reasons why most buildings' homeowners associations' are opting to NOT obtain FHA approval for their building including (but not limited to): 1.) the long and overall cumbersome process of acquiring the approval, and the need to hire someone to facilitate it at a heavy cost to the HOA; 2) the requirement of the ten percent of income that must be regularly deposited in a reserve account; 3.) the requirement of a minimum of a 50% owner occupancy rate; 4.) and finally, the misconception by many persons that household's wanting to use an FHA loan are in fact, low income, or receiving some type of government subsidy and will be a "liability" the building and become delinquent on their fees and/or their mortgage, creating a stigma in the marketplace associated with these types of loans. An FHA loan requires the loan applicant to live in the apartment as a principal residence (homestead Based on conversations with the local real estate industry, there is misinformation, or the misconception amongst some members of the public, that because the FHA insures loans with down payments of as little as J percent and borrowers with less -than -perfect credit that these factors always correlate to excessive risk. According to recent analysis from the Urban Institute, all else being equal, the default rates on loans with down payments of3'5 percent are actually quite similar to the default rates an loans with down payments of 5-10 percent Upon pulling a list from the HUD website for all FHA approved condominiums in Miami- Dade[ountyasof]anuaryZUl5,thetob|ebe|ovvindicatesthaton|yF|VE|ocationsare eligible in the City. We also note the average price points of those locations for reference. Table 41: FHA Approved Multi -family DRAFT —20/5-202oAnalysis of Impediments mFair Housing Choice City of Miarni 78 buildings in the City /f Miami Average Price nmmt Project Name p/ojectxddress Description Start End Date (1/1$ amcxcuowTHE 3/ S.c. 5rxsr. *o+Units- yo4residential units, zo 4/22/20/4 4/22/2016 s374.900 RIVER NORTH mmw/, rl-s3/n mmm°ic/"/"nxs. / buoamy op, BRICKELL PLACE 192SnmcnELL Three Buildings, two mxsc i'^=m 7/23/20o ,/a/znn $530,00 pHASso AVENUE, mum/.a o/zy m°nmmes: Bldg /1915aicke// menoo'r=e,cnym�Bldg z-/yz�, mickel/mm"LIC T"wnmz5n; Bldg 3- p/2\ ' � /snmmkel/Ave LiO'm°nhonn°uo> conxL WAY uxnocws osomv`6TnAVE, w�w/.na3/4s Consists ofouunits .� !s/m1a ' /v/zm2m/5 $/3amm o/2» cosTAnsu» wmnmcnoL.BAY 8,n/2013 o/r/n »3s�n� CONDOMINIUM o�.mmw/.a os all`^` p/� 33n1 legal documents, ~ ~ ` ,=AFlood =r information and specialassessment ^ ' xEYsrowc mu»s x comuom/wmM 3syoCORAL WAY, mwm/.FLm'm /Nine Story Building, 60 residential units, / Commercial 4iw/2014 $349,000 p As listed on www.hm±pov .°1~20 *Providing lowest price on recordfor a 212 as listed on condo.com The DCED believes that FHA condo approvals can dramatically increase the pool of potential buyers in any community. Also, buyers who use FHA loans are more likely to reside in the unit, and not rent it out. This is a win for the building as they will not have absentee landlords renting their units. PUBLIC HOUSING As noted previously, all public housing within the City of Miami are operated by the Miarni- Dade Public Housing & Community Development (PHCD) Department. In a 2004 review of Miami-Dade's public housing units, U.S. HUD determined that PHCD would need to bring an additional 478 public housing units into compliance with uniform federal accessibility standards (UFAS). In 2005, the county entered into a VCA agreement with U.S. HUD requiring the county to address deficiencies identified in the county's housing, non -housing, (i.e., common entrances, management offices, laundry rooms common areas, corridors, hallways, elevators, community programs and day care facilities,) and administrative offices as follows: (1) PHCD must select and hire a VCA administrator within 120 days of the execution of the VCA that shall report to the PHCD director to coordinate all compliance activities of the VCA. The county is required to procure a surveyor, architect/design firm(s) and contractors to perform the work specified under the VCA. The county shall construct or convert a minimum ofS%,ie,47Oofits 9,543 total housing units tocomply with section SO4,title iiofthe ADA, the uniform federal accessibility standards (UFA3), the fair housing act and the architecture barriers act. (2) the county shall ensure that non -housing programs are accessible to persons with disabilities, including, but not limited to all common areas, accessible routes, management and regional offices (including resLrooms), laundry room mail delivery, trash disposal, meeting rooms, recreation rooms, community center (including restroomd and day care centers (including recLrnoms)The county shall complete accessibility modifications to its central office, private rental housing division offices and administrative offices housing its DRAFT —z0r5-202nAnalysis of Impediments mFair Housing Choice 79 ADA coordinator. (3) the County must meet all the terms and conditions of the VCA within six (G) years from the date it is executed. Based on a report dated FebruaryS, 2013, PHCD has brought a total of 111 of the required 478 units up to the UFAS standard, with an additional 367 units to be completed by no later than FYZO15. Based on PHCD'scurrent schedule, 94 additional units are to be completed in FY2Ul3; 75 units are to be completed in FYZO1/k and, the remaining 198 units are to be completed during FY 2015. It is anticipated that all of the funds necessary to comply with the VCA agreement will be funded through the capital fund program ([FP)funds. The Home Mortgage Disclosure Act 'HK8DA HMDAwas enacted byCongress in1974and requires that certain financial institutions /banks, savings associations, credit unions, and other mortgage lending institutions) make public information about their home loans by: 1)the applicant's d income, 2) the type, purpose, and amount ofthe loan, 3\the loan application and 4) the census tract of the property tohefinanced. The loan data discussed ithissectiowas U ddinect|yfrom the Federal Financial Institutions Examination [ound|'svvebsite vvYvw.fOec.gov. HUD recommends thatHMDA data b of mortgage applications and their outcornes can identify possible discriminatory lending practices and patterns in a community. Home Mortgage Disclosure Act (HMDA) data contains records for all residential loan activity, reported by banks. Any commercial lending institution that makes five or more home mortgage loans annually must report all residential loan activity to the Federal Reserve Bank, including information on applications denied, withdrawn, or incomplete by race, sex, and income of the applicant. HMDA reports several types of housing loans including purchase loans, refinancing loans, and home improvement loans. Purchase loans are simply loans that are being used to purchase (transfer the title of) a home. This is distinctfrom home improvement loans which are loans being used to modify an existing home without having the property change hands. Finally, refinancing loans are utilized to take advantage of better interest rates, to consolidate loans, to reduce monthly payments amounts, and in some instances to reduce the risk level by switching from a variable -rate to a fixed-rate loan. The most recent free data availablera|area encompasses what the FF|E[reports refer to as the Miorni-Micnn/ Beach -Kendall MIA� The data included in this analysis— MlA.Tobe encompasses data for the last three available years (2012-2014) across this entire clear, Miami inoted here encompasses a geographic area much widerand larger than that ufour City alone. A more careful analysis of |0a have oo|ek/ focused on loans made within our City was not possible, as it would require both an indefinite research expense and a significant investment of time to sort through loans within particular tracts and the an additional qualification of the property address. Given our City and Department resources, our analysis here is more general. Please note that the demographic and income information provided in the loan tables below pertains tothe primary applicant only. In order to address HMDA data accurately within our M3A, we would also need to stress the highe r-tha n-ave rage amount of real estate cash transactions the Miami MSA has experienced for several years, which would obviously not be reflected in the HMUA data below. For reasons already stated, Miami sees a large amount of foreign capital and many investors frorn outside the U.S. have elected to purchase property here, either for rental purposes or for DRAFT -20r5-202oAnalysis of Impediments to Fair Housing Choice 80 Conventional (Home Purchase second/third home purposes. These cash sales are difficult totrack by municipality (and our Department) and so we must rely on industry reports for some type of general data to better understand their role inour marketplace. Because South Florida had one of the largest foreclosure rates in the nation, there was a large supply ofbank owned properties in 2012 and 2013. Many lenders (that might have been sitting on long lists of foreclosed homes and bad loans) were interested in selling said properties quickly to investors who paid cash versus waiting for traditional buyers to secure mortgage financing. Besides this, finding traditional buyers with good credit who could buy became more difficult as mortgage requirements were strengthened. Reports indicate that in 2012, cash sales made up 57% of Florida's home sales, while in 2013 the average climbed to the |ovv 6096 levels. According to o recent release byCone . gic as recently as October 2014, "of the nation's largest 100 Cone Based Statistical Areas ([8SAs) measured by population, Miami -Miami Beach -Kendall, Fla. had the highest share of cash sales at 56.6 pe/cent.1117 |nthe tables that follow, uelook at conventionalloans followed byFHA loans between 20lI and 2Ol3.|ncomparing atTables 4Z,43,and 44 vvefirst make some general observations. To begin, the largest number of loan applications'received for our MSA in the conventional loan category was inthe Refinancing category, with approximately106,91Ureceivedin three years. That was followed up by the number of Home Purchase loans, which amounted to some 42,483 applications in three year. Finally, the fewest number of applications received was in the Home Improvement category with a total of some 8,759 in the last three years. Conversely, the highest denial rates are seen in the Home Improvement category with athree-year average of6796denials. When focusing on Table 42 (Conventional Home Purchases), the amount of applications has steadily increased since 2011. The percentage issued has remained fairly steady with a slight hike in2O13 up to approximately S9y6.The percent denied has also remained pretty steady, oscillating somewhere in, or around 24%. Conventional Loan Three -Year Breakdown Table 42: Results o Rac 17 212 38 13872 94 On ' --^ - —' '—''— Percent � ^ / Issued-� �ue`�o,' drawn, �� oansin K1ia -Dade 567% 55.4% Z l§ Z 4 56 22 239 17 "Cash Sales Continue to Decline in US, Miami Still Top Market," World Property Journal, Michael Gerrity. DRAFT -oo/n-2o20Analysis o,Impediments to Fair Housing Choice City of Mian7i 81 0 13 25 445 7 96 586 American Indian ,o Alaskan" A__n.` xace/Eznnoity�,� American Indian or Alaskan |Asian �B�ck'orAfhca�`� n 'American�� ` ' Vmite'��'i Dther', Unknown,~ `Total by Race',�, Total,�� ` 13275 524 9315 96 1677 11899 246 5151 46 957 6545 46.9% 55.3% 47.90� 57.1% Approved,Not Accepted .. 53 718 Il 114 915 � 158 2099 22 327 2677 20.3% 21.04 � ^ � .With- ^ o/mwn' 50 1027 13 187 1315 xun 17 320 92 447 Hispanic* 6146 3388 55.1% 431 1479 24.1% 648 199 souoe:pr/c4 *Hispanic ethnicity is counted independent of race. Home Refinance Loans There has also been a steadyincrease in the amount of applications submitted for home refinance loans (Table 43) from 2011 to I011 Even though the amount of applications in 2013 was more than double the tsubmitted i 2O1I th percent d i 201� n uu e eamoun n , the issued n was just slightly above (46Y6)that of2Ol1's percentage (42%). The popularity ofhome refinance loans makes sense, given that interest rates have dropped to low levels below 4 percent. With industry insiders predicting that interest rates will climb, this trend might not stick. Table 43:Resu| sofHome Refinance Loans inMiami-Dade 5 37.8% DRAFT —20Y5-202oAnalysis of impediments to Fair Housing Choice City of Miami 12 38 31.9% 15 �I-Josect�� plote 82 g Black '3123 1367 410% 238 986 316% 312 220 - 32327 I6781 51.9% 2558 8211 25.4% 2886 189 7387 4429 22917 Arnericzin Indian or Alaskan 20299 16230 .e`a"ai="=/-^ � Total by 21764 11166 IN, Number Denied 25.5% Percent .� �Denied � 32.8% 38.5% 28.94 337% ! Closed Incomplete 75 829 11 Source: FFIEC *Hispanic ethnicity is counted independent of race. Home Improvement Loans In relation to home improvement loans (Table 44), although the applications for these have steadily climbed in the past three years, denial percentages continue to be high. These are in fact much higher than those seen amongst the other two conventional loan categories (purchase and refinancing). These overall higher denial rates could be attributed to the fact that many Miami -Dade homeowners are underwater and owe more on their homes than DRAFT -o0/5-2020Analysis of Impediments mFair Housing Choice 83 what they are worth. According to CoreLogic, negative equity continues to be an issue for nearly a third of Miami -Dade homeowners.' Approximately 27% of Miami -Dade homes were underwater in the fourth quarter of 2014. Although that percentage is better than 2013's report, which indicated that some 34% of Miami -Dade homeowners were underwater. Table 44: Results of Home Improvement Loans in Mia i-Dade 11111W1111111111,11111.111111114.1,i01,11,11,11,1111111111111111"111,11511111111iiiiiiiiiiiIlii°11,1111'1,111111111111111"11111111111I111111111m111""""1111111111111.111111111IIIIIIIIIIIIIIIII111111111111111111 111#1111 11[111111 ""' Race / Ethnicity American Indian or Alaskan Asian Black or African Arrieri can bite Other**, Unknown(Race not available) Total spanic* Total Applications 6 56 2484 47 458 3648 2030 Approved Percent Not Isstied Accepted 83 681 12 132 932 486 1.1110 utviti,1,1111,11,111ililiviJ111,11,1111111V„Il,111,i111111111111 " ' 111111111, 14.7% 27.4% 25.5% 28.8% 24.3% 23.9% Total Number Percent Race / Ethnicity Applications Issued Issued American Mdian or Alaskan Asian Black or African American hi e Other** Unknown(Race not available) Total Hispanic* 11111111111,1„1„r ip,g111111111111,641fippm Race / Ethnicity 40 7 491 2001 43 6 551 4 552 114 64 747 1667 76 Total Applications Number Issued 15.0% 24.3% 12.8% 27.5% 9.3% 20.7% 8.3% 22.6% 42 240 134 Approved Not Accepted 9 109 2 5 176 76 ..ioo1?11,111?1?lt;;;;;;;jij:!!!ou!E!ll0000 Number Percent With - Denied Denied drawn 8 54.5% 41 65.1% 449 79.8% 460 58.8% 119 33 70.2% 1 247 2248 1308 Number Denied 2 402 1240 5 59 2092 115 JpilogimpIpEnqj rbIIIIIift 111111 1111, 1'11111111r]111(il11111111111111IOIl 1111" ' "10"""10 .11111111111 .11 "11,,,,161,1„1111111M1 ""'"' I.1111,1111111:1111.1,1,11 11111E41.,1,,,,11,1111111111,11,111,1,111,1,1,.",0. I '1 11'1111 mloolholopopool000loor"I I. Approved Percent Not Number Issued Denied Accepted 53.9% 31 63.7% 64.4% 168 111'1,1111111111111,1111/111111 74 Percent With - Denied drawn 82.5% 0 62.2% 81.9% 62.0% 81.4% 65.0% 72.5% 69.2% Closed incomplete 6 48 0 6 60 28 '''111111110,, iiui 21 123 49 Closed Incomplete 2 9 0 5 26 Percent With- Closed Denied drawn Incomplete American Indian or Alaskan Asian Black or African Aniericart 2 8 302 53 21.9% 16.7% 17.5% 23 234 7 .9% 72.2% 77.5% 6 " The Miami Herald, "Nearly a third of Miami -Dade homeowners owe more than their property is worth/' Nicholas Nehamas, March 18, 2015. DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 84 White . /�r� `� 1315 344 26.2% 63 828 63.0% 53 37 other** ��'' 33 13 39.4% 4 13 39.4% 2 1 -.� not avaUabe).�_`' 247 49 19.8% 11 156 632% 23 8 Total ,�� 1947 469 23.8& 88 1267 64.5% 85 38 Hispanic''x `� '' 1130 258 22.8% 46 771 68.2% 38 17 sovrce:rns *Hispanic ethnicity is counted independent of race. FHA Loan Three -Year Breakdown When looking at the trends in applications for FHA loans in the Miami -Dade MSAhnm 2011 to I013, data differs. First, the amount ofapplications has steadily declined with on|y7,OOZ applications submitted in 20I3. In this same year, the number ofapplications for conventional home purchase loans was more than twice that amount- 17,309 total. Denial rates for the FHA loans remain fairly stable, with an average of2l2% or so. Approval rates during those years have also remained fairly steady -inthe mid'5OY6range. Table 45 : Results of FHA, FSA/RHS, and VA Home Purchase oansinMiami-Dade WHOM pl ~^ , rn ica r Indian brAlaskan lO .' 7 70.0% 1 J O � Inbomplote ~4sian�� 48 32 66.7% 3 6 12.5% Z 'Black or African,' 878 446 50.0% 41 245 5550 3508 62.1% 275 1084 70 35 50.0% 6 19 346 147 42.5% 20 I13 7002' 4175 ' 57.0% 346 1469 4975 3051 61.3% 236 989 Applications Accepted , 118 628 8 50 806 563 � ^ 28 155 2 lh 206 136 or Ala , skain "Asia»��'��' O 4 50.0% 1 12.5% 1 Black or,'African 976 511 52.4% 55 246 25.2& 135 29 6199 3912 63.1% 262 1193 19.2% 7 7 2 =,`�.�'-` ~,^ 00 20 DRAFT -2o/5-202oAnalysis of Impediments to Fair *oushgChoice City of Miami 85 5517 3447 62.5% 233 I061 19.2% 623 lB Em Number / \ issued� IndianAmerican �� orfuaskan-�`'�.` 4aian��i�!� Black or African American — �Unknmmn(gace�^ � , � ___—`^ Issued', ^ Percent �Denied'� ' With- drawn �not awaHab�)�� ' 563 255 45.3% 29 249 26.5�6 ill 19 7od�� -��`'�8536 4766 523% 554 1950 243% 1056 20I |Hispanic* ._.'i`� 5779 3328 57.6% 382 1277 22.2% 657 135 Source: pnsc *Hispanic ethnicity iscounted independent ofrace. "Other indicates combined totals of Native Hawaiian/Pacific Islander, 2 or more minority races, and joint (white/minority race) AFFIRMATIVE FAIR HOUSING EFFORTS Pursuant to HUD regulations, 24 CFR 92.351, the City of Miami adopted affirmative marketing procedures and requirements for rental and homebuyer projects containing five or more HOMF/[D8G'assisted housing units. Furthermore, City's policies are consistent with Davis -Bacon and Section ]protocols. Affirmative marketing consists of providing information and attracting eligible persons in the housing market area toavailable housing without regard to race, color, national original, sex, religion, familial status ordisability. Affirmative marketing procedures do not apply to families with Section 8 tenant -based rental housing assistance or families with tenant -based rental assistance provided with HOME funds. The City's affirmative marketing policy and procedures addresses the following elements: 1. Informing the Public, Owners, and Potential Tenants: Acceptable methods for informing the public, owners, and potential tenants about the applicable Federal Fair Housing Laws and HOME Prngram'saffirmative marketing policy may include, but are not limited to, using the Equal Opportunity logo OR slogan in relevant printed materials, project signage, posting this information on the Department's web site, and explaining the policy in general to property owners, and tenants involved with the HOME/HOPWA/Sec. 8 Programs. 2. Advertising Units andlor Community Outreach: In order to meet the obligations towards the [it/c/D[ED's affirmative marketing policy requirements as required byZ4CFR92.3Sl, each propertyovvner/deve|ope/ who receives federal funding from the City/DCED must submit a completed and DRAFT -co/5-2moAnalysis mImpediments mFair Housing Choice 86 signed AFHMP Plan (HUD 9352A//8), as an exhibit to their executed contract with the DCEC\ that clearly specifies activities they will use to advertise vacant units, including but not limited to any printed advertisement/s\, any local community contacts they will reach out to assist in informing the public of available units, and the use mfany possible printed material (brochunes,leaflets, etc]This final AFHMPplan must also be submitted by the deve|ope//ovvne/vvith the local Fair Housing & Equal Opportunity Office and serves to satisfy the requirements ofZ4 [FR 200.620vvhich indicates that all FHA subsidized or unsubsiclized programs shall require the applicant (developer) to carry out an affirmative program to attract buyers or tenants, regardless of sex, handicap or familial status, of all minority and majority groups to the housing for initial sale or rental. As indicated on the form itself, the advertisement(s) should be published/placed in manner calculated to inform eligible persons who may otherwise beleast likely toapply for the unit. 3. The City ofMiami requires recipients' maintain records by the recipients and by the owners to affirmatively market units for the period covered by the loan agreement. The City will use those records to assess the results of these actions. The developer is responsible for updating the AFHMP with the local FHEO office as outlined by U.S. HUD, at a minimum of once every five years or if the property's circumstances change (changes to area dernographics or local housing market area). 4. Limited nglish Proficiency (LEP) Requirements: Housing owners/developers must take reasonable steps to ensure meaningful access to the information and services they provide for persons with Limited English Proficiency (LEP). This may include interpreter services and/or written materials translated into other languages. HUD -specific LEP Guidance was published in the Federal Register on January 22, 2007, as "Final Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons," as required by EO 13166. 5. Assessment of Affirmative Marketing Efforts of Owners: The City of Miami Housing unit requires that assisted owners/clevelopers submit copies of their advertisement(s) for rental units and homeownership opportunities, correspondence and information, in advertising such units to the DCED for inclusion in the project file. Marketing efforts begin once the loan agreement is signed and executed (with the signed AFHMP an attached exhibit to said loan agreement). The DCED's Housing unitwill assessthe owner's affirmative marketing plan and the results of these efforts. Should an owner fail to follow these affirmative marketing efforts, the DCED will refer to the matter to the local FHEO office and to the local FHIP. DRAFT —on/o-2ozoAnalysis nrImpediments mFair Housing Choice 87 I PE I E TS IMPEDIMENTS TO FAIR HOUSING CHOICE AND THE RECOMMENDATIONS TO ADDRESS THEM The impediments that follow are based on the research, data and information presented in previous chapters of this Al. The impediments identified in the following section elaborate on data/information provided earlier in this document. We break up the Impediments as suggested by the HUD issued Fair Housing Planning Guide. Impediments are divided into three sections: 1.) Private Sector; 2.) Public Sector; and 3.) Public and Private Sector. PRIVATE SECTOR Impediment FH1: Increased Housing (Cost) Burden for approximately 46% of City households due to the rising costs of housing in the City o Miami combined with stagnant wages. A high percentage of City of llli,ami residents — both homeowners and renters — are paying more than 30 percent oftheir income for housing, defining them as cost burdened. This increased ,housing burden must be addressed on a City-wide levelto prevent further loss of homeownership, increases irr foreclosures, errictions, bankruptcies, and potential homelessne' Seek additional opportunities for the creation of other affordable housing options beyond LIHTC projects (i.e., Promise Zone applications, other grants, etc.) Engage, inform, and, work with City leadership (elected officials) of the need to create additional housing opportunities for° e7 trerriely low, very low, and /ova, -to -moderate -income persons Advocate for policies requiring that a larger percentage of rental units financed by government capital dollars (LIHTC) be set aside for VLI households al'30% or below of median income. Research the possibility of ultimately using National Housing Trust Fund dollars (expected in early 2016) to expand the affordable rental housing stock available to very low-income persons/elderly. Continue to implement the actions to increase affordable housing as identified in the 2014-2018 Consolidated Plan. Continue to frond the Single -Family Rehabilitation and Replacement programs to aid in preservation of honteoWnaership, as' well as the. first -tire homebuyer program to encourage new homeownership. - Provide higher point consideration through City RFP processes, for developers/projects that provide a greater percentage of units aimed at serving incomes at 35% AMI in comparable rental projects. - Provide higher point consideration through City RFP processes, for developers/rental projects with lower total project cost per unit. Impediment FH2: Very Few Multi -Family Buildings in the City Seek FHA approval. Even though the bulk of Miami's housing stock is comprised of units in multi -family buildings, there is a significant lack of FHA approved condominium buildings in the City. As of December 20./4, there were a total of five buildings in the entire City. This means low-, moderate- and middle -income working class persons who are interested in purchasing a home with an E[IA loan cannot purchase a unit (primary residence) in the DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 88 City of Miami niajori�y "/14iomi's/ouhi-/�rnJv menw600ay/,oximnw/y,36y6o'the (�^/a hoasiag stock i'scomprised ofonitoininubitildings. Recommendations: The DCED will work with the MIAMI Association of Realtors to further their efforts on a local and state level toaddress this issue onafederal level. TheD[EDvviUexecuteadirectmai|inQtomu|ti'bmi|ycnndominiumassociations,eith information onhow tobecome anFHA approved building, including the Miami Realtors rack brochure on this topic. PUBLIC SECTOR IT Impediment FH3: Scarcity of Developable Vacant Parcels Diminishing the new construction mfdng|e single-family and/ornm�Uer apartment developments -s �r�mmen thereby housing choice. There is a land shortage in the Ci�y of developable, residentially zoned vacant tracts and man�y �t'the available racant parcels are scattered and situated in on an in -fill basis. A property is detennined to be developable for a single a ininirnuin o.f'2 parking spaces per hoine are required. In addition, the city needs to consider how the application o zoning regulations and parking requirernents can be "'tweaked" to encourage the developinent o sin�gde-fatrtily hoines and sinaller- scale buildiikgs (20 units or less) on these sinallerparcels. Recommendation� will continue available city -owned parcels in that program are used for the provision of affordable - The DCED will support any viable efforts by the City's planning and zoning board in relation to amending the City's zoning code to encourage small-scale development, the ' reby expanding housing choice for all City residents. A current effort being considered is: the potential exemption and/or reduction of the city's parking requirement for small new buildings within walking distance of corridors that are served by extensive public transit, including Metrorail or high -frequency bus service. DCED will continue to prepare request for lien removals for eligible affordable housing properties |nnpedinmentFH4: There is a lack ofadequate federal funding for rental assistance programs. DRAFT -zor5-202uAnalysis of Impediments to Fair Housing Choice 89 }roJcn//G/odi,uro6i,les6/r/vu+i,xm,nohousing orotio/i�oum^rmt'vncontinue to be ru/. Doo,uvJ 6^ Su,6vv 8 vouchers in all Ilioroi'DnJ^ ovn`mnoitim, along xid' d,o/ooJ firyvWi, 6v11."i7lg unilt*, is startling. 0u�uono�/y 6,, those who are not randonil, y anleoted6,mvids/ , there is nv 6/m/ingonoJuWo mbeable wassist t6mniom �v�,nvn�/rmn/o/ nx. Ixoddi�po, the latest l//[/JIDS Housing AWdsAxamx/v,o/conducted io2O/4 vx/in'n,m/ that /6oro are nyyroxi/oo/e/v /0,000 individuals lining with //1[(A/DS In Miarni-.I)ade County in need of housing assistance. Recommendations - The U[ED will continue to accommodate as many HOPWA clientsfiscally possible in the City's Long -Term Rental Assistance (LTRA) Program, - The uCcuwill mcontinue u/fund the nvrvv^Short Assistance Program (STRMU) to assist HIV+ persons who are not LTRA recipients (on the LTRA waitlist) remain housed in the event of a valid emergency. - The °Ccuwill mcontinue u/fund private within the limits of the City of Miami. In return for the City funding a portion of the total cost of the project, the developer provides a pre -determined number of affordable rental housing units to be rented to low -to -moderate income families. The number of affordable housing units in a project is based on the arnount of subsidy provided by the City. |rnpedinmentFH5:' ` There is a lack ofadequate federal fundingfor the `p comprehensive `'` Analysis of Impediments. -Presently, anyI potential ` ~Adininistration allowance. --- latter-- already - stretched-- ~`~~ ~~` to the // C{)D(� City`e years. �Consequently, less inoney is available/o contract sub -recipients to cooJou important researchJ testing ro/mrwd to the rvn/u/ oxJ/vr au/v vf600,in� in the A/ nn,i /uorkwn �x order /o �Joo/�/� n�y��p/i/i,`. ` - ^ ^ Recommendation eparation of The DCED will researoh and propose the possibility of regional Al in cooperation with Miami -Dade County. This way, the combined funding oftwo more jurisdictions could be utilized for testing and more specific studies, which tend to be costly. PUBLIC AND PRIVATE SECTOR DRAFT -20/5-202oAnalysis of Impediments mFair Housing Choice City of Miami 90 Impediment FH6: There is not Enough Affordable/Workforce Housing Units to Meet the Needs of City Residents. It is well-known that the term affordable housing is no longer just a euphemism fin low income families. Recent studies reveal that many middle-class 'working citizens cannot afford to live in the communities where they live. The City of Miami's current housing market has been strongly influenced by a combination of real estate supply conditions occurring within the larker Miami -.Dade market and by recent demand factors that have contributed to the escalation of rental rates. Recommendations The City should explore options to create workforce housing opportunities/incentives/ bonuses to encourage private developers to build housing to serve these populations Identify opportunities for intergovernmental collaboration to address housing affordability issues. In particular, examine the most effective manner to partner with the County, State, and Federal governments to coordinate activities and leverage funding. Continue to support the City's Affordable Housing Trust Fund. The DCED will research inclusionary zoning (IZ) in metro areas similar to Miami's and make recommendations to City leaders about how IZ could be incorporated into Miami21 (Zoning code) to add affordable housing stock to the City without any public funding contribution The DCED will work with the City's Zoning Dept. to propose a resolution that provides deferral of impact fees for projects that provide rental units available to moderate/workforce incomes while increasing the level of units for 50% AMI. Impediment FH7: Housing Discrimination on the Basis of Race, Color, National Origin, Religion, Sex, Familial Status, and Disability continues to take place. According to TOPE, Inc. there were 343 fitir housing inquiries/complaints over a, 31 month -period that originated in zip codes within, (or partially within) the Guy of liam-i's boundaries. These complaints represent approximately 34 percent of the complaints processed by HOPE countywide over the same time period. HUD research suggests that as much as 80 percent of housing discrimination, goes unreported. As such, it is reasonable to conclude that there are many more cases of housing discrimination within the City of Miami that are left unreported. Recommendations Conduct fair housing testing at least twice within the span of this Al. Retest in areas where trends (i.e. geographic concentration of complaints by zip code) are identified in the monitoring process. Provide regular fair housing education and training to housing providers to ensure compliance with fair housing laws. Continue to collaborate with other organizations in fair housing training events DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 91 City of Miami Commence (DCED)totrack race and ethnicity ofholders ofSection 8vouchers in order to identify any segregative patterns of where Section 8 vouchers are being used. Continue to implement a fair housing information campaign that specially targets City residents and clearly informs the public about fair housing rights. Continue to ensure that marketing materials (i.e. brochures, post cards, Public Service Announcements (PSAd, web site) are available in inthe Citv'sofficial languages (including Spanish and Creo|e);all material should specify where a resident should call to report a complaint. Use HUD developed collateral (i.e. print, radio, and television ads). - Continue include fair housing fo i during intake process and at the tirne of annual recertification. - Cm.u..uc to "m"c fair housing collateral available /v*variety m mcuuux ,.e. Neighborhood Enhancement Team (NET) offices, ^ ' public places such aslibraries, and/or social agencies such asthe welfare office). Conduct an annual public informational campaign during the ` Fair Housing Month each April. |nnpedinmentFH8: Absentee Landlords in Low-income Neighborhoods Disregard Code Violations and Fines, Leaving Tenants in Buildings/Units Units with Poor Living ' Conditions. S,nmn/ absentee landlords (especially 1n. louc-Incoine neighborhoods in the City) (to not p(q andlov ignove m,idtiple code and bitildin",fines related to theirprivately owned rental baildings. Tenants clairn, that complaints to landlords aboat livin conditions lead to As of January 2015, the City filed a lawsuit against six landlords in Miami who owe approximately $2.5 million in unpaid fines/utilities related to violations at their rental buildings ` actioni st thern -The City should research how other communities attempt to correct said issues with an necessary possible measures including i denial for habitual offenders,asset attachment toallow a municipality garnish property owner's wages ifbuilding isdeemed adanger, and potential threat of property seizure. OTHER FINDINGS The barriers listed below are beyond the scope of this plan, but were deemed important enough tomention ascomments. Statellocal building codes increase the cost of affordablehousing production: The South Florida Building Code is a series of standards and specifications designed to establish minimum safeguards in the construction of buildings to protect the health and safety of the DRAFT —coro-2o20Analysis orImpediments mFair*ousmgCooic 92 public. Unfortunately, the more stringent building codes, especially in relation to hurricane - proofing, The 5Opercent rule increases the cost ofaffordable rehab: Another impediment includes a regulatory barrier known as the "SU'percent rule," which mandates new construction standards if rehabilitation costs exceed 50 percent of the value of the home being renovated. Similar to the South Florida Building Code, the 50 percent rule ensures that rehabilitated buildings are safe (i.e. hurricane shutters are added, electricity updated, sprinklers added to multifamily housing). However, the increase in cost to rehabilitate these structures also affects the affordability ofthe units. This isparticularly aconcern with multifamily structures that do not have funds id for di building to code. As stated in the housing section of the chapter "Jurisdictional Background" in this report, the City of Miami has lost a significant portion of its multifamily housing stock of structures containing 5 to 19 units; a housing stock size that the City considers ideal for affordable rentals. The loss in these structures is, in part, due to the fact that it is more profitable for the owner of the buildings to sell their properties to developers of market rate new construction, than it is to assume the expense of rehabilitating the building. There is an assumption that the Davis -Bacon prevailing wage increases the cost of affordable housing: Davis -Bacon Prevailing Wages (Davis -Bacon Act of 1931) are triggered when federal dollars are used to pay housing construction or rehabilitation labor costs in multifamily projects with more than 11 units. This prevailing wage, which is usually higher than competitive wages, must be paid to laborers and mechanics. Additionally, federal paperwork requirements are extensive, amounting to an increase in staff time required for preparation both the owner (developer/general cb )'and city sides,which also increases housing requirements is to protect workers,developers cost results in higher housing construction expenses. necessary todetermine how much costs are especially N0N8Yism 'As a large, high'denshyCity the Department generally does not experience public dissent to funded housing projects and/or NIMBYism (not in rny backyard attitudes). In recent years, one particular development in Liberty City met with some public resistance from park conservationists given that one of the pnject's parcels had originally been zoned as a pocket park and was being re -zoned to become part of the development's build out DRAFT —20,5-202oAnalysis of Impediments mFair Housing Choice 93 Ultimately, deve|opem—vvho needed the small parcel to develop a multi -family project — purchased a nearby lot asa "swap" to preserve neighborhood pocket park, which activists were most concerned about. Most of the community resistance seen in recent years has been in relation to historic preservation of certain City blocks/neighborhoods and/or potential disagreement in relation to proposed upzoning in particular areas ofthe City. Past credit problems Credit problems lead tnaperson's/fami|v'sinability tosecure abank mortgage in order to purchase a home. When the City encounters persons/households who are dealing with this matter and are attempting to purchase a home, the City refers them to local associations that offer low-cost credit counseling. The City (D[ED)does not fund credit counseling services at this time. Postcrin/no/history' Many L|HTC developments policies which prohibit admission for persons who have been dvvithafe|nny—vvithno restrictions as to how far back that charge goes. Sadly, this type of policy prevents ex' offenders — whose incident might have happened years ago --fronn accessing pub|icaUy funded housing. Servicelsupportive housing needs of specific populations - The State of Florida has a long ` waiting list of low-income disabled persons seeking to access home and community -based services (Medicaid waiver) which isfuncled bythe State of Florida and overseen bythe state's Agency for Persons with Disabilities (APD). For the past three years Florida's governor has recommended state monies be used to serve the critical needs waiting list. The issue of community based care was an area that the DCED was not able to comprehensively review/research for this report and we recommend analysis in future reports. Foreclosures — According to RealtyTrac as of October 2014, the Miami -Fort Lauderdale - Pompano Beach area was identified as leadingthe pack in foreclosures amongstthe 20 largest metro areas in the U.S., with foreclosure filings including default notices, scheduled auctions and bank repossessions. Figures released in January 2015 by RealtyTrac indicated that the state of Florida had a 2.3% foreclosure rate in 2014, making it the highest in the nation. Four metro areas in the state were among the top five cities in the country with the highest rates. These were Miami, Orlando, the Space Coast area and Tampa (Associoted Press, Jonuary 19, 2015). Property Insurance — Recent ports indicate that Florida homeowners now pay more than double h national average for homeowners insurance, withcoasta|areas—indudingmany parts ufSouth Florida the highest rates Data released by the National Association nfInsurance Commissioners indicates that the most common type ofpolicy rose nearly eight percent in 2012 to $2084. Price'wise, Louisiana sits as second in line with the highest premiums, but their average sits at $I742, The national average is $1034, which makes Florida's premiums I8296 higher. In 2014, the state -run Citizens Property Insurance and private insurers reportedly cut rates for most property owners after what has been nine years of no hurricanes and lower reinsurance costs. These costs are an additional burden to homeowners ortopersons looking atpurchasing ahome. Property Taxes - In Florida, real estate taxes are the primary source of government revenue. As mentioned elsewhere in this document there is no state income tax. Obviously, tax increases can be burdensome to low-income homeowners, and increases are usually passed DRAFT —2m/5-202oAnalysis of Impediments to Fair Housing Choice 94 on to renters through rent increases. In 2014, the City of Miami had a miUaQe rate of 7.6435There were seven other municipalities in Miami -Dade County with higher miUage rates. The miUagerates (also called tax rates) and taxes are determined bveach ofthe taxing aothnritiessuchasMiami'DadeCounty,theSchoo|8oard,OtyandRegiona|authnrities,The Tax[oUector— part ofMiami'Dade Count/s Finance Department—coUects current and delinquent real and personal property taxes, special assessments for all local taxing authorities, local business tax receipts and convention and tourist taxes. The State of Florida offers some property tax relief in the form of Homestead Exemptions for qualifying homeowners. These are the Save Our Homes (SOH) exemption for homestead (primary) properties; the homestead exemption for persons 65 and older (also known as the senior exemption); and the exemption for civilian total and permanent disability; the deployed i|ition; the institutional d the widow/widower exemption. As required by state law, the Miami -Dade County Appraiser's Office determines the value of all properties as of the legal assessment date of Jan. I each year, these values are "established by nationally accepted valuation methods, which are sales comparison, cost, and income valuation approaches. Adjustmentslare made for size, condition and extra features of a property." Currently being proof read by the P&Z Department Improvements since the Last Al''' Land use and Zoning Regulations: After years of public meetings and research studies that started back in 2005, the City's new form -based Planning & Zoning code, guided by tenets of NewUrbanisnnandSmartGnowth—knownas Miami 22—was approved bvthe City ofMiami Commission in May 2010. The City made every attempt to establish a code that took the City's evolution and changing landscape into account. The Code allows for varied residential types which reduces potential impediments to housing choice by members of the protected classes. Miami 21 did not include any indusionary zoning regulations, neither voluntary nor mandatory.' Presently, iLspechioaUy addresses affordable housing by offering an incentive - based approach in all T6 (urban core) areas of the city, allowing for bonus Building Height and FLR (floor lot ratio) in exchange for the developer's contribution to one of several specified programs ' that provide public benefits (Miami 21, ArticleSection ) specified programs are as follows: Affordable/workforce housing, Public Parks and OpenThese Space, Green Buildings, Brownfields, and Civic Space or Civil Support space. The City also established a Miami 21 Public Benefits Trust Fund for the cash contributions for Afforclable/Workforce Housing, Public Parks and Open Space, and Green Building certification shortfall penalty made under this section. For of complying with the public benefits program, see the multiple options available to developers (as abbreviated for brevity in A-F) below: A. Affordable/workforce housing --,the development project in a T6 zone may provide ony of the following or combination thereof. 1. Affordable/workforce housing on site of the development. For each square foot of affordable/workforce housing (including pertaining shared space such as parking and DRAFT —2or5-202vAnalysis of Impediments mFair Housing Choice 95 circulation) provided on site, the development shall be allowed two square feet of additional area up to the bonus Height and FLR as described elsewhere in the code. 2. Affordable/Workforce housing off -site. For each square foot of affordable /vvorkforce housing (including pertaining shared space such as parking and circulation) provided off site, in a location within the City approved by the City Manager, the development shall be allowed an equivalent square footage of additional area up to the bonus Height and FLR as described in Section 3.14.1. No additional allowance is given for the purchase of the site. 3. Trust Fund contributions. The Miami 22 Public Benefits Trust Fund (Article X|V) was established for cash contributions towards affordable/workforce housing, Public Parks and Open Space, Green Buildings, Brownfields, and Civic Space or Civil Support space. The City Commission, upon the manager's recommendation, annually decides the allocation of funds from the Trust Fund collected under this section. All cash contributions thus allocated bythe Commission tr support affordable/workforce housing shall bedeposited in the Affordable Housing Trust Fund for expenditures pursuant to the guidelines adopted by the City Commission. All cash contributions thus allocated bthe Commission to support Parks and Open Space shall be deposited in the parks and Open Space Trust Fund.~ For cash contributiontotheK4iami21Pub|icBe'efitT ^stFund,thedeve|opment shall be allowed additional Floor Area up to the bonus Height and FLR described in Section 3.I4.1.The cash contribution shall be determined based on a percentage ofthe market value of the per square foot price being charged for units at projects within the market area where the proposed project seeking the bonus is located. The calculation assumes land value per saleable or rentable square foot within market area to equate to between IO(ten) to 15 (fifteen) percent ofmarket area's weighted average sales price per square foot. The cash contributions shall be adjusted on an annual basis to reflect market conditions effective October 1st nfevery year. , B. Public parks, open space orpark improvements, the development project in aT6zone may provide any oftheƒb0owingorcombination thereof: 1. Public Park or Open Space provided through purchase and in an area of need identified by the City Parks and Open Space Master Plan and the City's Parks Department. In addition park improvements provided through donation for Public Parks with amenity levels that are Moderate or that Need Improvement as defined by the Parks Department Facilities' Assessment Report. (a)For each square foot of dedicated public Park or Open Space provided, the development shall beallowed two times the development Floor Area ofprovided land uptuthe bonus Height and FLR as described in Section 3.24.1.The Open Space may bea Park, Green or Square, asmore fully described inArticle 4 Table 7ofthis Code. (b) Park improvements shallbevaluated and for said value the development project shall be allowed additional Floor Area up to the bonus Height and FLK described in Section 3.14.1 and shall for all applicable purposes be treated as a Trust Fund contribution pursuant toSection 3.14.4,b,/3\. (c) Park improvements for Public Parks in area below 5096median income threshold shall be a||nvved two times the valuation credit. � d) Donations mustmeet all City requirements for design, equipment specifications, construction, warranties, etc. Park its are subjectt i and approval by the City Manager or designee in accordance with Miami 21. 2.Public Open 'pacepnVvided ^~,siteinalocation and ofadesi�ntobeapproved bythe ' � PlanningPark orOpenSpace provided, .hedevelopment - ,shaU b^allowed equivalent amount development ' Floor Area ~upto the bonus Height and FLKas'--described inSection 3.14.]�'� DRAFT -20/5-202oAnalysis mImpediments to Fair Housing Choice 96 lTrust fund contribution C. Historic Preservation. Bonus Floor Area to the maximum bonus `Height and FLR as described in Sectioo3.l4.I shall be allowed for additional square footage qualified under the city Transfer mfDevelopment Rights program established inChapter 23,City Code. D. Green Building. In n TG zone, additional Height and FLR shall be allowed for Buildings certified bythe U.S.Green Building Council asSilver, Gold orPlatinum. E. Broxxnfie|ds. One additional Story of Height shall be permitted for redevelopment on a Brownfield Site osdefined inthe Code. ` F. Civic space and Civil Support space. For a development project in a T6 zone that donates a Civic space or Civil Support space on site to the City of Miami, an additional two square feet of area for each square foot of donated space, up to the bonus Height and FLR, shall be allowed.' ` As noted above developers are provided with multiple options to acquire more buildable living/housing space. However, ' itshould benoted that the Trust Fund ispresently atits lowest level in years and that most of the market -rate developers (developing properties with absolutely no federal/state/and or local public subsidy) who are seeking to access the public benefits program forego the affordable/workforce housing routes described above and opt to comply using another of the delineated methods. It should also be noted that prior to Miami 21, the only option extended under the previous City bonus density program was contributing to the affordable housing trust fund. Recent changes made to the existing Zoning code towards faci|itatingUncentivizingoveraU housingdeve|oprnent—andfurtheringhoudnQchoice— inthe City include the following: * In May 201I, the City Commission adopted Sec. 3.15 of Miami 21 to facilitate affordable housing development by modifying'architectural/design standards and parking reductions, and this has been updated since then, as recently as early 2014. Parking costs can be a significant portion offacility development costs and rents. • In Feb 2014,tho City modified Ordinance No. 13114 to allow the Affordable Housing Special Benefit Program Supplemental ^Regulations to also address mixed income buildings, because the majority of existing and proposed affordable housing development was located in Miami neighborhoods that were removedhn the major employment centers of the urban core of the City and the City Commission was desirous of encouraging the inclusion of affordable housing within the urban core in buildings serving a range of incomes that include market rate components. The ordinance required certification by the City's Community Development Department that the proposed Development will provide a minimum of eighty percent (80%) of the Dwelling Units (Multi -family or Elderly) as Affordable Housing serving residents at or below sixty percent (60%) of the area median income (AMI) as published by the HUD annually; or that the proposed Development is a mixed -income building providing at least forty percent (40%) of the units as Affordable Housing serving residents at or below sixty percent (60%) of AMI or providing at least twenty percent (20%) of the units cis Affordable Housing serving residents at or below fifty percent (50%) of AMI, is not restricted to elderly residents, and is located within a Residential Density Increase Area as setforth in Article 4, Diagram 9 of the Miami 21 Code. • As of March 2015, the City Commission passed (second reading) an amendment to Ordinance #13114 by establishing a new zoning sub -classification known as T6-24(B) that will have a higher floor lot ratio (16) and percentage (40%) of public benefits DRAFT —zo,n-2o2oAnalysis cvImpediments to Fair Housing Choice 97 bonus. City administrators hope this will encourage the development of much - needed m«or&ƒbrca housing (and concurrently, mixed income projects) in these specifically zoned urban areas which are near mass transit options and numerous employment opportunities. The Planning and Zoning Department is currently researching and working on how developers could apply for this benefit (specific requirements of the developer) on a sliding scale basis, and they will be presenting that recommendation at future City Commission meeting. Other ways to earn the extra square footage would be for developers to agree to build public improvements like a landscaped bike path or a new playground in a park, provide public open space, green buildings, Brownfield site rehabilitation, and civic space or civil support space, ortnmake cash contributions tothe Miami 2lPublic Benefits Trust. Although these efforts are all favorable, the DCED feels that in light of the statistics highlighted in this Al specifically related to the cost -burden more and more City residents are facing (both renters and homeowners alike), the City must continue searching for creative solutions to expand the inventory/supply ofhousin8avai|ab|eto|ovv'andvery+|ovvincomepersnns(50y6 AK4| and below). As mentioned, there are no inc|udonaryzoning policies in place in the City of Miami and the DCED continues to feel that finalizing some type of more aggressive, mandatory policy is a viable solution to further expanding the supply of affordable housing units, given that the demand for these particular units far outweighs the supply. In other words, explicit requirements designed to ensure that o share ofnewly developed housing incorporates - by |avv-some affordable unit(s) would create a local mechanism that adds new units to the existent stock, without relying on fluctuating and diminishing state and/or federal dollars. Finally, the Planning Department has recently researched and suggested upzoning in particular parts ofthe City. Although upzoningcou|d lead toadditional housing stock, the DCEU believes that it should be considered carefully, allowing for the public's input and that of the neighborhood(s) residents, so that consideration is given to the neighborhood's historic value and general look/character, and so that potential gentrification is thwarted and housing choice is preserved - especially the preservation of small/medium size apartment developments which historically, have provided Miami with neighborhood housing serving low- to middle -income residents. Based on recent discussions, the Planning Department is looking atcoupling a neighborhood's potential upzoningvvith setting specific designated historical section of the same neighborhood that must remain as is. The idea is that those buildings that lie within the "historic" area can transfer (sell) their development rights to other developers, and utilize those dollars to improve/update the historic property. w� n� A, -F A |U IDENTIFIED ACTIONS AND TIMELINE FOR RECOMMENDATIONS This chapter provides the City ofMiami's strategy to address fair housing from FY2015to FY2020. |nthe first section, the Citv'sfair housing pnogmm'sstrategy to maintain records to DRAFT -2or5-202oAnalysis mImpediments mFair Housing Choice 98 support the AFFHcertification will bediscussed. Afterwards, atable isprovided that identifies the actions that the City plans to implement toovercome the impediments to fair housing choice which were identified in the previous chapter. STRATEGY TO MAINTAIN RECORDS TO SUPPORT THE AFFIRMATIVE FURTHERING FAIR HOUSING (AFFH)[ERT|F|[4T|ON The Department of Community & Economic Development is actively engaged in monitoring fair housing complaints that occur within the City of Miami as well as promoting and securing compliance with fair housing regulations. The [it/v fair housing n/gmm is designed to affirmatively further fair housing objectives of Title VI of the Civil Rights Act of1964,Title VU| of the Civil Rights Act of 1968, as amended, and other relevant federal, state, and local fair housing laws. Monitoring of housing discrimination complaints received from residents of the City of Miami as compiled by HOPE, Inc. organized by basis, issues, disposition, and zip code. Such reports will allow the City to identify existent and/or emerging trends in fair housing. Im The will continue to educate the general public through communicatbn vehicles available toito Fair Housing laws and rights, and how/where tureport alleged discrimination. � The City will continue to monitor the developerswithwNch it has contracts (federal, state assistance) to assure that they'are following 'their signed AFHMP plans. DRAFT —2015-202oAnalysis of Impediments mFair Housing Choice 99 ACTIONS TO OVERCOME THE IMPEDIMENTS TO FAIR HOUSING CHOICE The following tables provide the action steps, timeline and measurable results that correspond to each recommendation. Please note that the action steps are intended to be implemented by the end of the calendar year referred to in the timeline. IMPEDIMENT the rising costs Timeline of housing in the Measurable Results FH1: Increased Housing (Cost) Burden for 461 of City households due to ActionSteps City of FH 1.1 Miami combined al P-omise with stagnant wages. Recommendation Seek additior additional info; projects (i.e., funding opportunities for the creation of (fable housing beyond LIHTCfimded Zone applications, other grants) Assist the city's Grants Department in the completion of a City -sponsored Promise Zone application to revitalize city neighborhoods and generate economic opportunities to residents of designated areas 2015-2016 Application was submitted to HUD during the last quarter of FY2014-2015. FH 1.2 Continue advocating for gjfordable and workforce housing development by engaging and informing City officials of th need to create additional housing opportunities for extremely low, very low, and low -to -moderate -income persons Discuss matter with elected officials and City Manager's office when possible. Work/meet with Director of Planning/Zoning. 2015-2020 Bringing additional affordable housing units to the market FH 1.3 Research the possibility of ultimately using National Housing Trust Fund dollars (expected in early 2016) to expand the affordable rental housing stock available to very low-income persons/elderly Advocate to the State and maintain a close watch on the mechanisms the State will utilize to distribute the funding to local governments. 2015-2020 Receiving Housing Trust Fund dollars to further the City's affordable housing efforts FH 1.4 Continue to fiutd the Single -Family Rehabilitation and Replacement programs to aid in preservation of homeownership. as well as the first-time hoinebuyer program to encourage new homeownership. Continue marketing the Single Family Rehabilitation and Replacement programs as viable alternatives to maintain affordable housing in the city. Continue funding the down payment assistance program to provide additional affordable housing opportunities 2015-2020 Single Family Rehab: 10 Households; Single Family Replacement: 4 Households; Down Payment Assistance: 40 Households FH 1.5 Better delineate Departmental housing related Proposals by providing higher point consideration through City RFP processes for: developers/projects that provide a greater percentage of units aimed at serving Award additional points through the department's Request for Proposals process to developers meeting this criteria 2015-2020 Additional Points added to the rating table for newly issued Housing -related RFPs DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 100 incomes at 35% AMI in comparable rental projects; developers/rental projects with lower total project cost per unit. IMPEDIMENT FH2: Very Few Multi -Family Buildings in the City Seek FHA purchase a home with an FHA loan with fewer housing options. FH 2.1 Work with the MIAMI Association of Realtors to further their efforts on a local and state level to address this issue on a federal level. pprova Support and join the MIAMI Association of Realtors' efforts to have more developments offer FHA units leaving potential buyers seeking to Timeline 2015-2020 Measurable Results Additional Multi -Family buildings in the City offering FHA units for sale FH 2.2 Execute a direct mailing to multi -family condominium associations, with information on how to become an FHA approved building, including the Miami Realtors rack brochure on this topic. Draft and develop marketing material Create a link in the department's website that provides more information on this topic for multi- family condo associations 2015-2020 Mailing of marketing material; Departmental website updated to reflect this information IMPEDIMENT FH3:There;_ is a scarcity of Developable Vacant Parcels in the City Dumunushung the construction of new, single-family, homes and/or smaller apartment developments thereby limiting housing choice. FH 3. Support any viable efforts by the City's planning and zoning board in relation to amending the City's zoning code to encourage small-scale development, thereby expanding housing choice for all City residents. Support the reduction of parking requirements on smaller lots to allow for the development of additional affordable housing units 2015-2020 Bringing additional affordable housing units to the market FH 3.2 DCED to continue to manage a citywide Infill Program and will ensure that available city -owned parcels in that program are used for the provision of affordable housing. Continue developing affordable housing units on 2015-2020 city -owned vacant parcels; Bringing additional affordable housing units to the market FH 3.3 DCED to continue to prepare request for lien removals for eligible affordable housing properties Continue preparing requests for lien removals 2015-2020 Bringing additional affordable housing units to the market DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 101 IMPEDIMENT FH4: There is a lack of adequate_`federal funding for rental assistance programs. Recommendation Action Steps Timeline Measurable Results FH 4.1 DCED will continue to accommodate as many HOPWA 1) Continue to conduct rent comparables to 2015-2020 All clients must have rent clients as fiscally possible in the City's Long -Term Rental ensure that rent paid corresponds to the on- comparables in file and rents Assistance (LTRA) Program and to assist HIV+ persons going market rent. must be equal or below the who are income eligible via the HOPWA funded STRMU 2) Educate clients about looking for more fair market rent for any given program (based on funding availability) affordable rental options. year. 3) Continue to market the availability of the STRMU program Advertise STRMU program through the Miami -Dade HIV/AIDS Partnership and other proper channels. FH 4.2 DCED will continue to fund private developers to build The department will continue to issue Request for 2015-2020 Bringing additional affordable affordable housing units within the limits of the City of Miami. In return for the City funding a portion of the total cost of the project, the developer provides a pre- determined number of affordable rental housing units to be rented to low -to -moderate income families. Proposals to provide gap financing that will allow housing projects to include affordable housing units. housing units to the market PEDIMENTFH5. There mpediments FH 5.1 Recommendation adequate federal funding The DCED will research and propose the possibility of a regional Al in cooperation with Miami -Dade County. This way, the combined funding of two more jurisdictions could be utilized for testing and more specific studies, which tend to be costly. Action Steps , <_ he preparation of a comprehensive Analysis o Contact Miami -Dade County Explore opportunities for joint efforts to plan and draft a comprehensive Analysis of Impediments Timeline 2015-2020 Measurable Results Join Analysis of Impediments to Fair Housing Choice DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 102 IMPEDIMENT Recommendation The housing private workforce Meet The Needs Timeline FH6: There are not Enough Affordable/Workforce Housing Units in the City To `; Action Steps Of City Residents. FH 6.1 Measurable Results City should explore options to create workforce opportunities/incentives/bonuses to encourage developers to build housing to serve the (120 to 140%) Propose increasing the deferral of impact fees for every two market units in exchange for one workforce unit 2015-2020 Bringing workforce housing units to the market FH 6.2 Continue to support the City's Affordable Housing Trust Fund (AHTF) Continue advocating for city officials to consider having a % of the Public Benefit Trust Fund be distributed automatically to the Affordable Housing Trust Fund for housing development 2015-2020 Number of affordable housing units assisted with AHTF FH 6.3 Identify opportunities for intergovernmental collaboration to address housing affordability issues. In particular, examine the most effective manner to partner with the County, State, and Federal governments to coordinate activities and leverage funding Increase the level of collaboration between the city and the county. Specifically, improve coordination when it comes to funding opportunities 2015-2020 Bringing additional affordable housing units to the market FH 6.4 Continue to implement the actions to increase affordable housing identified in the current Consolidated Plan Implement affordable housing objectives identified in the 2014-2018 Consolidated Plan 2015-2020 Meet the goals and measurable results identified in the Consolidated Plan. IMPEDIMENT # , FH 7.1 Status, And Timeline FH7: Housing Discrimination On The Basis Of Race, Recommendation Continue fair housing rights campaign for City residents that will help them identify and challenge discrimination including material during the Section 8 and HOPWA LTRA programs intake/recertification processes Color, National Origin, Religion, Sex, Familial Action Steps Disability Continues. Measurable Results Update fair housing material to include the newest protected classes and disseminate the material to all city of Miami Section 8 HCV and HOPWA LTRA clients at time of intake/ recertification. 2015-2020 Approximately 420 Section 8 and 1000 HOPWA LTRA clients receiving the newest fair housing material FH 7.2 Conduct fair housing testing at least twice within the span of this Al. Contract the services of an agency to perform housing discrimination testing concentrating our efforts on multifamily rental properties 2015-2020 Testing results and follow up FH 7.3 Continue to provide fair housing education and training to housing providers to ensure compliance with fair housing laws. Organize/host community workshops for residents and developers or other target audience as deemed appropriate by the city. 2015-2020 A workshop a year hosted/ led by DCED, besides those led by the area FHIP year- round DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 103 IMPEDIMENT FHB. Absentee Landlords in Lo with Poor Living Conditions. Recommendation FH 8.1 Pursue legal action/recourse so that bad landlords ar banned from operating within City limits ncoo e Neighborhoods Disregard Code Violations and Fines, Leaving Tenants in Buildings/Units Action_Steps Research efforts by other communities to blacklist bad landlords - look to pass necessary legislation to pursue landlords (with repeat violations) via legal mechanisms including permit denial, asset attachment to allow a municipality to garnish property owner's wages if building is deemed a danger, and/or potential threat of property seizure. Timeline: Measurable Results 2015-2020 Reduce the number of incidents where landlords fail to provide decent, safe, and sanitary housing to city residents DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 104 City of Miami ttac ent 1: Geographical Information System (GIS) Maps based on U.S. Census analyzing different groups 65 years old and up CITY OF MIAMI POPULATION 65 YEARS -OLD AND ABOVE 2010 .. 'BY_CEUSUS_BLOCKS-WITH COMMISSION DISTRICT OVERLAY DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 105 miies Black Population 2010 CITY OF MIAM! BLACK POPULATIQN-2010 --BY CENSUS-BLOCKS`WITH COMNIISSI©N DISTRICT C7VERIAY i DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 106 Hispanic Population 2010 CITY OF MIAMI - HISPANIC POPULATION 2O1O--- - -BY-CENSUS-BLOCKS-WITH COMMISSION ©F DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 107 White, Non -Hispanic Population, 2010 CITY OF MIAMI NOT HISPANIC WHITE -PC PULATION 201 , -BY-CENSUS-BLOCKS-WiTH COMMISSION DISTRICT: QV COMOISIV DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 108 Racial Dot Map — from the Cooper Center DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 109 2010 Census Block Data 1 Dot = 1 Person PP White Black Asian Hispanic wnat coo logkmg a(„.? ttac ent 2: Lan, se a s 1. Vacant properties City of Miami Land Use - Vacant Properties Source: City of Miami, ARC GIS, as of 2015 DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 110 City of Miami 2. Single-family housing City of Miami Land Use - Single Family Housing IJ Source: City of Miami, ARC GIS, as of 2015 474 DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 111 City of Miami 3. Multi -family housing City of Miami Land Use - Multi Family Housing Source: City of Miami, ARC GIS, as of 2015 DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 112 City of Miami Appendix 3 Fair Housing Proclamations — City of Miami THE CITY DB :IIA.'\-1i, FLORIDA a peq�eihous {n{g n oRIESt tht eci Fi :mFon'th of 4M1r1 fair Housing Month "Rna�ioi oftestoring Our Communities Block by Block' gr tnh ling-sniiocas APA siliOdur4°al hhc7,1 n6 opR rta re in me in Y{t b}} peeiti Ce11'11E11E0Ft I hereunto set my hand and cause the seal of the City of 1EON . to the Office of the Mayor of the City of Miami, Florida. April 17, 2015 DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 113 Disclaimer related to Census comparisons CAUTION: The Census Bureau cautions when comparing 2000 Census to ACS: Differences in the universe, question wording, residence rules, reference periods, and the way in which the data are tabulated can impact comparability with Census 2000. The strength of the American Community Survey is in estimating characteristic distributions. We recommend users compare derived measures such as percents, means, medians, and rates rather than estimates of population totals. http://www.census.gov/acs/www/guidance_for_data_users/es DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice City of Miami 114