HomeMy WebLinkAboutExhibit LANALYSIS OF IMPEDIMENTS TO FAIR
HOUSING CHOICE
CITY OF MIAMI
FY2015-2020
DATE CREATED:
MAY 2015
TABLE OF CONTENTS
INTRODUCTION 3
EXECUTIVE SUMMARY OF THE ANALYSIS PURPOSE 3
METHODOLOGY 5
JURISDICTIONAL BACKGROUND DATA 11
SOCIAL TRENDS 11
HOUSING 32
ECONOMIC TRENDS 58
LEGAL STATUS EVALUATION 62
FAIR HOUSING COMPLAINTS 64
COMPLIANCE 67
DISCRIMINATION SUITS FILED 71
CURRENT PROGRAMS 72
PROGRAMS 72
ACTIVITIES 77
AFFIRMATIVE FAIR HOUSING EFFORTS 89
IMPEDIMENTS 91
PRIVATE SECTOR 91
PUBLIC SECTOR 92
PUBLIC AND PRIVATE SECTOR 94
OTHER FINDINGS 96
CONCLUSIONS AND RECOMMENDATIONS 102
STRATEGY TO MAINTAIN RECORDS TO SUPPORT THE AFFIRMATIVE FURTHERING FAIR HOUSING (AFFH) CERTIFICATION 102
ACTIONS TO OVERCOME THE IMPEDIMENTS TO FAIR HOUSING CHOICE 104
INTRODUCTION
EXECUTIVE SUMMARY OF THE ANALYSIS PURPOSE
The Federal Fair Housing Act, Section 808(e)(5), requires the Secretary of the U.S. Department of
Housing and Urban Development (HUD) to administer housing and urban programs in a manner
affirmatively furthering fair housing (AFFH). Although the extent of the AFFH obligation is not
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 in the analysis; and
• 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
will2:
• 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 a 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 (Al) is required of state and local
governments that receive federal funds from HUD. This includes Community Block Grants (CDBG),
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
2014 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 strategy to maintain records
and results of the actions taken. Although the AFFH obligation arises in connection with the receipt
of federal funding, the obligation extends to all housing and housing related activities in the City of
Miami whether publicly or privately funded.3 Factors that could restrict housing choice include, but
are not limited to:
1 US Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Fair Housing Guide.
Section 1
2 Ibid.
3 US Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Fair Housing Guide.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 3
City of Miami
• Discrimination based on race, color, national origin, sex, religion, familial status
and disability as defined by Title VIII of the Civil Rights Act of 1968;
• 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 or stalking, as defined by the Miami -Dade County Code
Chapter 11A and recent amendments to the latter (2014);
• Lack of affordable housing;
• Severely cost burdened households;
• Lack of housing that is accessible to the disabled;
• Lack of reasonable and accessible transportation services;
The City of Miami Department of Community and Economic Development (DCED) last conducted an
Al in 2010. In May 2014, it filed its most recent Consolidated Plan with U.S. HUD to span the years
of 2014-2018 incorporating new population data from the 2010 Census. In a complementary
fashion, the City is now updating its Analysis of Impediments (Al) 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 is presently in relation to fair housing matters, given the most recent demographic
information available in both the 2010 U.S. Census and the subsequent American Community
Surveys (ACS) that have been issued.
MONITORING OF Al
The City of Miami works throughout 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
timelines.
It should be noted that as part of this monitoring effort, many of the actions include input provided
by HOPE, Inc. This entity is our local FHIP and conducts fair housing educational workshops in our
City 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
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.
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 4
City of Miami
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 CDBG/HOME funded CDCs
and CHDOs and its HOPWA and Section 8 sub -recipients (agencies, landlords and clients).
It should be noted that CDBG dollars are distributed amongst the City's five 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 City's fair housing strategy is also reviewed on a yearly basis by the DCED's Assistant Director
of the Reporting and Specialized Housing Division to ensure that it is meeting both its short- and
long-term objectives; if it is determined that certain objectives are not being accomplished, then
adjustments are made accordingly.
METHODOLOGY
WHO CONDUCTED THE ANALYSIS
The City of Miami Department of Community & Economic Development (DCED) is the lead agency
coordinating all aspects of the Al.
PARTICIPANTS
Key informant interviews were conducted with city and county officials; as well as community
stakeholders and private organizations. The agencies involved in the interview process or that
provided valuable information are:
• The Florida Housing Finance Corporation
• Housing Opportunities for Excellence, Inc. (HOPE, Inc.) — local FHIP
• The Miami Realtors Association
• University of Miami Office of Civic and Community Engagement
• Citrus Health Network, Inc.
• City of Miami Planning Department
• The Office of the Manager (City of Miami)
• Miami -Dade County's Public Housing and Community Development Department
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City of Miami
The Al began with a review of available social, economic, and housing data gathered from a variety
of sources including:
• U.S. Census Bureau - the 2010 Census and multiple years of the American Community
Survey (ACS)
• U.S. Department of Housing & Urban Development (HUD) website and One CPD maps
• the University of Florida's Shimberg Center for Affordable Housing
• The City of Miami Zoning Code (Miami 21)
• Multiple local and national newspapers
And from existing studies and reports, including but not limited to:
• the 2014-2018 City of Miami Consolidated Plan, Public Housing Authority Plan, Annual Plan
and CAPER
• the HIV/AIDS Housing Needs Assessment & Strategic Planning documents for the HOPWA
Program in the Miami -Miami -Dade County MSA
• 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 information through the key informant dialogues of the
participants listed above and by additional public input gathered via a survey issued in early 2015
and at public 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 to the issues discussed herein.
PUBLIC NOTICE AND REVIEW
As recommended by HUD, the DCED also utilized its Action Plan meetings (which it facilitates) to
coincide with public meetings addressing fair housing. These public meetings were held as
follows:
Neighborhood -level Public Hearing Activities
Tues., Aug. 12, 2014, District 2 Miami City Hall, Commission Chambers
6 p.m. Commissioner Marc Sarnoff 3500 Pan American Drive
Wed., Aug. 13, 2014, District 4 Our Lady of Lebanon Church
6 p.m. Commissioner Francis Suarez 2055 Coral Way
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City of Miami
Thurs., Aug. 14, 2014, District 5 Charles Hadley Park, Community Room
6 p.m. Commissioner Keon Hardemon 1300 NW 50 Street, Miami, FL 33142
Tues., Aug. 19, 2014,
5 p.m.
Fri., Sept. 5, 2014, 5 p.m.
District 1
Allapattah Community Action, Inc.
Commissioner Wifredo Gort 2257 NW North River Drive
District 3
Commissioner Frank Carollo
IllJose Marti Park Gymnasium
434 SW 3 Avenue
Countywide Public Hearings for HOPWA
Tues., Aug. 12, 2014, 4:30
p.m.
Thurs., Aug. 21, 2014,
4 p.m.
District
Central Miami -Dade County
South Miami -Dade County
Joseph Caleb Center- Room 110
5400 NW 22nd Avenue, Miami, FL 33142
Sembrando Flores. 162 SW 1 Ave., Homestead,
FL 33030
The following activities were carried out below to ensure public participation at said hearings:
1. Published notice of activities in general circulation newspapers;
■ 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.
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City of Miami
On May 8th, an ad was published in the newspaper of greatest circulation, The Miami Herald,
advising the public of the Al's draft being available at the DCED's main office and on the website,
starting on that date and of the 30-day comment period and how to properly submit written
comments to the draft (via e-mail or the U.S. Postal System). This assure the DCED 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.
PUBLIC INPUT SURVEY
For the first time ever, the Department drafted and issued an 18-question 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
of 700 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 as well. After 60 days, 57 surveys
were received. The most interesting data gathered from the results is noted below --
• 50% felt that fair housing laws were not adequately enforced in the City;
• 37% were Miami renters; 62% were homeowners;
• close to 90% of respondents said they were familiar with fair housing laws;
• 90% believe housing discrimination is an issue in Miami;
• 34% said they thought they had personally experienced housing discrimination;
• Over 50% had heard of recent fair housing violations in the news.
REAL ESTATE PRACTICES
The 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 its members to maintain professional standards including efforts to
affirmatively further fair housing. Specifically, Article 10 of that Code elaborates on a relators' duties
to the public which include:
• Realtors° shall not deny equal professional services to any person for 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 orientation, or gender identity. (Amended 1/14)
• Realtors®, in their real estate employment practices, shall not discriminate against any
person or persons on the basis of race, color, religion, sex, handicap, familial status,
national origin, sexual orientation, or gender identity. (Amended 1/14)
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City of Miami
The NAR enforces its Code of Ethics through a disciplinary commission consisting of NAR 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 realtors where the
realtor holds membership.
During the development of the AI, 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
neighborhood features to sources of impartial data. While preparing for the updating of its AI, the
City of Miami reached out to this 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 realtors 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, 2014 at City Hall in Commission Chambers. Some 20 realtors attended and a meaningful dialogue
was shared between DCED administrators and the realtors. 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.
Laws — State and Local
On a State level, Chapter 760 of Florida 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
it illegal to discriminate in the sale, rental, advertising, financing, or providing of brokerage services
for housing. On a state level, discrimination complaints (including those related to fair housing) are
filed with the Florida Commission on Human Relations, who are tasked with the investigation and
resolution of discrimination complaints in the areas of:
• Employment
• Housing
• Public Accommodations
• Florida's Whistle -blower's Act
The City of Miami 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 II, 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
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 9
City of Miami
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, or source of income. As an entitlement, the DCED already adhered to HUD's
Equal Access Rule (NOTICE PIH 2O14-20 HA) as issued on August 20, 2014 which requires HUD's
assisted and insured housing programs are open to all eligible individuals regardless of sexual
orientation, gender identity or marital status.
Also, the City adheres to the Violence Against Women Reauthorization Act of 2013 (VAWA 2013)
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 programs newly
covered by VAWA 2013 include HOPWA, HOME, Section 202, and McKinney-Vento Homeless
Programs (Emergency Solutions Grant, Continuum of Care).
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 Miami -Dade County Commission on
Human Rights, a quasi-judicial advisory board of 18 volunteers, 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 a probable 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.
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City of Miami
JURISDICTIONAL BACKGROUND DATA
CONTEXT FOR A FAIR HOUSING DISCUSSION
Title VIII of the Civil Rights Act of 1968 (Fair Housing Act), as amended, prohibits discrimination
in the sale, rental, and financing of dwellings, and in other housing -related transactions, based
on race, color, national origin, religion, sex, familial status (including 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), and handicap (disability). This section of the 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 entire state of Florida has seen significant population growth in the past decade. In
December 2014, the Census released figures that indicate that Florida's population surpassed
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 the
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 from 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
this document —will continue or change. However, it bears mention that in terms of land 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 of land 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 DCED believes it relates directly to the recent massive
wave of vertical development that has taken place in the City.
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City of Miami
Table 1 offers a comparison of the City's population in 2000 and 2010 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 if our area is unique.
Table 1: RACE AND
ETHNICITY, 2000 vs.
2010 Census
City of Miami
2000
2010
Change 2000-2010
Number
Percent
Number
Percent
Number
Percent
Not Hispanic or Latino
124,119
34.2%
120,001
30.0%
-4,118
-3.3%
White
42,897
11.8%
47,622
11.9%
4,725
11.0%
Black, African
American
72,190
19.9%
64,993
16.3%
-7,197
-10.0%
Other Race
2,930
0.8%
4,744
1.2%
1,814
61.9%
Two or More Races
6,102
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%
242,298
60.7%
43,725
22.0%
Black, African
American
8,668
2.4%
11,887
3.0%
3,219
37.1%
Other Race
20,030
5.5%
17,173
4.3%
-2,857
-14.3%
Two or More Races
11,080
3.1%
8,098
2.0%
-2,982
-26.9%
Total
362,470
100.0%
399,457
100.0%
36,987
10.2%
White
241,470
66.6%
289,920
72.6%
48,450
20.1%
Black, African
American
80,858
22.3%
76,880
19.3%
-3,978
-4.9%
Other Race
22,960
6.3%
21,917
5.5%
-1,043
-4.5%
Two or More Races
17,182
4.7%
10,740
2.7%
-6,442
-37.5%
RACE & ETHNIC COMPOSITION
The City of Miami's designation since the 1970s as a "majority minority" municipality adds a
layer of complexity 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 in the City of Miami is largely due to the increase in Hispanic
and Latino populations. As such, 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. In 2010, the Census found that the growth
of the Hispanic population continues and now comprises 70% of the city's population. This
snapshot is not unique to our area. In fact, according to www.migrationpolicy.org, the U.S.
Census Bureau's pooled 2008-2012 ACS indicates that Miami -Dade County's immigrant
population is the second highest of any County in the nation with an approximate number of
1,286,200 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
nonimmigrants (e.g., persons on student or work visas), those admitted under refugee or
asylum status, and persons illegally residing in the United States. The State of Florida ranks
DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice 12
City of Miami
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 or don't exist at all. This lack of knowledge or awareness of fair housing rights
creates an automatic impediment that other communities do not have to address.
According to the most recent Census, the Hispanic population's growth over the past decade
outpaced the growth rate of the city as a whole; the city's population grew by 10.2 percent,
while the Hispanic population grew 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 Ethnicity, 2000 to 2010
RACE
# Change
% Change
Total population
36,987
10.2%
One race
43,429
12.6%
White
48,450
20.1%
Black or African 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
-15.1%
Two or more races
-6 442
-37.5%
HISPANIC OR LATINO
Number
Percent
Total population
36,987
10.2%
Hispanic or Latino (of any race)
41,105
17.2%
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 13
City of Miami
Mexican
2,161
58.9%
Puerto Rican
2,532
24.7%
Cuban
13,538
10.9%
Other Hispanic or Latino
22,874
22.7%
Not Hispanic or Latino
-4 118
-3.3%
White alone
4,725
11.0%
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 State of Florida, however, saw solid
growth in the Black population (25.9%).
70.0%
60.0%
50.0%
40.0%
30.0%
20.0%
10.0%
0.0%
Hispanic or Latino Population by Region, 2000 to 2010
City of Miami
Miami -Dade County State of Florida
■ 2010% of Population ■ Growth Rate 2000to 2010
30.0%
25.09%
20.09E
15.09E
10.09E
5.0%
0.0%
-5.0%
-10.09E
Black, African American by Region, 2000to 2010
City of Miami
-0.396
Miami -Dade County State of Florida
■ 2010 % of Population ■ Growth Rate 2000to 2010
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 14
City of Miami
Dissimilarity
Dissimilarity (and/or the index of dissimilarity (aka segregation)) is a demographic measure of
the evenness with which two groups are distributed across particular geographic areas that
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. Avalue 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 research projecta, where it is noted that the Miami -
Miami Beach —Kendall area scored a DI of 73, the 7th 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.
When further analyzing dissimilarity in Miami, the selected Index reveals that Black -White
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 30 years, from a 40.9 to 50.3 value. The current value is spot on with the national
average of 50 for Hispanics which is considered a moderate level of segregation. The Hispanic -
White DI in the City has also increased since 1980, and in the 2010 Census hit 50.3, which is
considered a moderate level of segregation. Meanwhile, the DI in the Miami -Miami Beach -
Kendall area for 2010 was much higher, 75.9 — making it the 5th of the 50 Metro Areas with
the Largest Hispanic Populations in 2010.
History indicates that "large southern cities provide examples of persistent segregation." 5
It has proven difficult for researchers to pinpoint why integration has seemingly slowed down
across most of America. Some conjectures by researchers include: (1) a significant part of the
white population that is unwilling to live in neighborhoods where minorities are close to the
majority of the population (aka white flight); (2) possible self -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 of housing in
certain cities. 6
4 American Communities Project, Brown University, http://www.s4.brown.edu/us2010/seoregation2010/Default.aspx
5 John R. Logan and Brian Stults. 2011. "The Persistence of Segregation in the Metropolis: New Findings from the
2010 Census" Census Brief prepared for Project US2010. http://www.s4.brown.edu/us2010.
6 Segregation in America: Dragging on and on," Feb. 2011, http://www.npr.org/2011/02/18/133848837/segregation-
in-america-dragging-on-and-on
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 15
City of Miami
White-Blackf Black -White-
White-Hispanief His pa n is-Wh ite-
White-AsianfAsian-White-
Black-HispanicIHispanic-Black-
Black-Asian/Asian-Black -
Hispanic-AsianfAsian-Hispanic-
EDUCATION
20.2
9
55.1
59.3
4
5E.2
45.9
45 7
S
49.. 5.5
82.2
7Gg91
0
20
40
sa
BD
100
Education is an area of great concern in the State of Florida and in Miami
successful job placement, development, and resident retention. In the City of
30% of the population had less than a high school degree, much higher than
both the County and State. The data indicates that 22.4% of the population h
degree or higher with the majority of those persons being White or Asian.
1990
1990
2006
2065-29.ACS
2010
as it allows for
Miami, close to
the averages of
ad a Bachelor's
Table 3. Educational Attainment
Miami
Miami -Dade
County
Florida
Less than High School
29.6%
21.4%
14.0%
High School Degree or
Higher
70.4%
78.6%
86.0%
White
93.7%
93.7%
91.0%
Black or African
American
65.4%
75.3%
79.1%
American Indian and
Alaska Native
-
68.7%
75.7%
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%
DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice 16
City of Miami
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 ['], isolation is also widely
found in the local school system operated by Miami -Dade County Public Schools, where an
analysis showed that "close 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—
Bleck-Black —
Hispanic -Hispanic —
Asian -Asian —
T;4
-2:�:.- w.
f` '
s
f4.s
71.e.6
1980
8 — 1990
M 2060
812 M 2005-09 ACS
gRs — 2010
20 40 60 S0 100
LINGUISTIC ISOLATION
To understand linguistic isolation in Miami, we must first understand that the level 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 77.6% speak a language other than English at home (ages 5 and up).
Meanwhile, the state of Florida's foreign -born population is drastically lower -- 19.2% -- and
its population of persons speaking a language other than English at home is 27%. The national
averages are even lower — and data indicates that approximately 20% to 21% of persons in
the country speak a language other than English at home.
Linguistic isolation is another thing all together. According to the Census, "a linguistically
isolated household is one in which no person age 14 years or over speaks English at least "very
well." That is no person age 14 or over speaks only English at home or speaks another
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
17
language at home and speaks English "very well." It makes sense that in an area where many
persons are foreign born, that levels of linguistic isolation will be higher.
While the inability to speak English fluently is 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 Linguistic Isolation
Miami, FL
Household Language
Total Households
English only
Spanish
- -Linguistically Isolated
- -Not linguistically isolated
Other Indo-European languages
- -Linguistically Isolated
- -Not linguistically isolated
Asian & Pacific Island languages
- -Linguistically Isolated
- -Not linguistically isolated
Other languages
- -Linguistically Isolated
- -Not linguistically isolated
Miami Share
Households
162,726
38,224 23.5%
112,534 69.1%
57,525 35.4%
55,009 33.8%
10,170 6.2%
3,789 2.3%
6,381 3.9%
945 1.6%
352 0.2%
593 0.4%
853 0.5%
124 0.1%
729 0.4%
Source: US Census Bureau, American Community Survey 2007-2009, 3-year estimate (B16002)
LIMITED ENGLISH PROFICIENCY (LEP) PERSONS
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 at all. As indicated 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
well"," with the bulk of that consisting of Spanish speaking households (47.4%), followed by
other Indo-European languages (32.8%).
Because as already explained, Miami is comprised of many immigrants and 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 Assistance
Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting
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
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 18
City of Miami
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 AND 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 from the 2010
Census: 14.02, 15.01, 15.02, 18.01, 20.03, 26.00, 34.00, 36.01, and 53.02.
POVERTY
Although poverty is not a protected class, it does fundamentally affect a person's/family's
ability to rent or purchase a home and to become economically mobile. To that end, an
analysis of poverty levels in the City of Miami bears mention. The U.S. Census Bureau, 2009-
2013 5-Year ACS estimates that 29.9% of Miami's population is below the poverty level, that's
close to one-third of its residents. The national average is close to half of that -- 15.4%, while
in Florida 16.3% of the total population is below the poverty level.
As noted in table 6 below, nearly half of the population in the City determined to be below
the poverty level is Black (46%). Hispanics (of any race) comprise approximately 28.5% of
those persons in poverty.
Table 6: POVERTY STATUS IN THE PAST Percent
12 MONTHS (INDIVIDUALS) below
2009-2013 ACS 5-YEAR ESTIMATES Poverty
Level
Total Population for who poverty status is
determined
Race and Hispanic or Latino Origin
One race
White
Black or African American
American Indian and Alaska Native
Asian
29.9%
30.1%
26.0%
46.3%
28.3%
15.3%
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 19
City of Miami
Native Hawaiian and Other Pacific
Islander
Some other race
Two or more races
Hispanic or Latino (of any race)
White alone, not Hispanic or Latino
0.0%
31.1%
17.8%
28.5%
13.8%
The table below provides data related to the family composition of those s living below
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 IN THE PAST Percent
12 MONTHS (ALL FAMILIES) below
2009-2013 ACS 5-YEAR ESTIMATES Poverty
Level
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 18 years
24.9%
36.9%
16.9%
22.7%
39.9%
54.2%
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, 67% (roughly two-thirds) of Miami's residents are liquid asset poor. The latter
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, it stifles the city's long-term economic growth."'
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 2015 they approved a plan to allocate this earmarked anti -poverty money amongst
the city's five districts, proportionate to the percentage of poverty levels based on the five-
year poverty rate as determined by ACS data, thereby addressing need more directly.
Concurrently, the city manager's office researched programs where money could be allocated
including job training programs.
8 www.familvassetscount.orq
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
20
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:(1) 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 order to 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 95/20 ratio for the country as a whole is 9.1, while Miami's clocked in at 15.7
based on an analysis by the Brookings Institute of 2012 American Community Survey (ACS)
data. Cities with high income inequality "may struggle to maintain mixed -income school
environments that produce better outcomes for low-income kids. It may have too narrow 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 to move out."9
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 $10,400 a year in 2012.
9 All Cities are Not Created Unequal, Berube, Feb. 20, 2014
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
21
0.0%
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
AGE
0116
5.0%
10.0%
15.0%
20.0%
25.0% 30.0%
Income by Household
City of Miami, 2000 & 2007-2011
Source: U.S. Census Bureau, 2000 Census & 2007-2011
ACS
■ 2000 Census ■ 2007-2011 ACS
Of large cities of 100,000 persons or more, the City of Miami ranks as the 10th place10 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 65+
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 of any 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 a diminished ability to afford
housing and a greater tendency to be in low-income categories. According to U.S. Census
Bureau, 2007-2011 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
12 months that is below the poverty level.
When looking specifically at the number of City residents who are aged 62 years and older
group, the percentage hikes up to 18.9% of the population (75,474 people) in the City of
Miami. While the City's higher age groups tend to climb in numbers, its younger age groups
have not. In fact, persons aged 5 to 9, 10 to 14, and 15 to 19 years of age all dropped in the
general population from 2000 to 2010.
Table 8: Growth Rate by Age in Miami,
2000 to 2010
Subject
# Change
Change
Total population
36,987
10.2%
Under 5 years
2,660
12.5%
10 Note: places of 100,000 or more total population. Source: U.S. Census Bureau, 2010 Census Summary File 1
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
22
5 to 9 years
-2,890
-13.2%
10 to 14 years
-3,818
-17.2%
15 to 19 years
-1,259
-5.6%
20 to 24 years
5,605
24.3%
25 to 34 years
11,560
21.3%
35 to 44 years
3,787
6.8%
45 to 54 years
11,780
26.6%
55 to 59 years
5,244
29.2%
60 to 64 years
2,099
11.8%
65 to 74 years
-158
-0.5%
75 to 84 years
1,607
7.6%
85 years and up
770
9.2%
18 years and up
42,338
14.9%
21 years and up
41,816
15.5%
62 years and up
3,292
4.6%
65 years and up
2,219
3.6%
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 between the two census in 2000 and 2010 represents a shift in the type of
households in the City of Miami. The City lost family households. It is worthy to note that the
family households did grow over the past ten years, but only modestly. On the other hand,
non -family households grew at an 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 of married 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 in the City.
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 23
City of Miami
200
0
201
0
Type of Households in the City of Miami, 2000 and
0% 20% 40% 60% 80% 100%
■ Family households ■ Nonfamily households
Source: U.S. Census Bureau, 2000 & 2010 Census, Summary File 1
Table 9: Growth Rate by
Household Type 2000 to
2010
2010
2000
Percent Change
HOUSEHOLDS BY TYPE
Number
Percent
Number
Percent
Number
Percent
Total households
158,317
100
134,198
100
24,119
18.0%
Family households (families)
90,032
56.9
83,281
62.1
6,751
8.1%
With own children under 18
years
35,903
22.7
35,277
26.3
626
1.8%
Husband -wife family
(2010)/Married-couple
family (2000)
49,610
31.3
49,139
36.6
471
1.0%
With own children under 18
years
18,515
11.7
19,741
14.7
-1,226
-6.2%
Female householder, no
husband present
28,633
18.1
25,029
18.7
3,604
14.4%
With own children
under 18 years
13,213
8.3
12,357
9.2
856
6.9%
Nonfamily households
68,285
43.1
50,917
37.9
17,368
34.1%
Householder living alone
52,644
33.3
40,834
30.4
11,810
28.9%
Householder 65 years
and over
17,812
33.2
16,723
12.5
1,089
6.5%
Households with
individuals under 18 years
43,304
27.4
42,360
31.6
944
2.2%
Households with
individuals 65 years and over
47,428
30
44,729
33.3
2,699
6.0%
Average household size
2.47
(X)
2.61
(X)
(X)
(X)
Average family size
3.15
(X)
3.25
(X)
(X)
(X)
Compared to the region, the married couple household is exceptionally low in the City of
Miami. The low growth rate (1.0%) in this household type between 2000 and 2010 signals that
this trend will most probably remain steady. It is also interesting to note that the percent of
single women households trends higher in the City than in both the County and the State.
DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
24
Table 10: Household Type by
Region, 2010
City of Miami
Miami -Dade
County
Florida
Family households (families)
90,032
100.00%
602,911
100.0%
4,835,475
100.0%
Husband -wife family
(2010)/ Married -couple family
(2000)
49,610
55.1%
380,241
63.1%
3,457,149
71.50%
Female householder, no
husband present
28,633
31.8%
162,937
27.0%
1,005,042
20.80%
PERSONS WITH DISABILITIES
The Fair Housing Act provides additional protection to those individuals that have a physical
or mental disability (including hearing, mobility and visual impairments, chronic alcoholism,
chronic mental illness, AIDS, AIDS Related Complex and 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
population), 40.6% are 65 years and over, 9.3% are aged 18 to 64, and 3.8% are ages 5 to 17.
In the 65+ age group, the bulk of persons have ambulatory (28.6%) and independent (23.3%)
living difficulty.
Table 11: Disability Characteristics
2009-2011 ACS 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 5 years
24,150
0
0
Population 5 to 17 years
49,822
1916
3.8%
With a hearing difficulty
239
0.5%
With a vision difficulty
208
0.4%
With a cognitive difficulty
1390
2.8%
With an ambulatory difficulty
198
0.4%
With a self -care difficulty
355
0.7%
Population 18 to 64 years
257,389
23841
9.3%
With a hearing difficulty
2952
1.1%
With a vision difficulty
3798
1.5%
With a cognitive difficulty
11460
4.5%
With an ambulatory difficulty
12475
4.8%
With a self -care difficulty
4200
1.6%
With an independent living difficulty
9692
3.8%
Population 65 years and over
63,105
25627
40.6%
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 25
City of Miami
With a hearing difficulty
6290
10.0%
With a vision difficulty
5437
8.6%
With a cognitive difficulty
10551
16.7%
With an ambulatory difficulty
18029
28.6%
With a self -care difficulty
9162
14.5%
With an independent living difficulty
14621
23.2%
* Note: Individuals may have 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
total dwelling units or at least one unit in a multi -family housing project, whichever is greater,
shall be made accessible for persons with mobility impairments. An additional two percent
(2%) of the units (but not less than one unit) in such a project shall be accessible for persons
with hearing or vision impairments (24 C.F.R. § 8.22.) This applies to multi -family housing
projects (containing five or more dwelling units (24 C.F.R. § 8.3.) that are designed,
constructed, or altered after July 11, 1988.
As to local requirements, the Florida Department of Business and Professional Regulation
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
received 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
accommodations," 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. A chart
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 smaller/mid-size two-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 of physical ailment.
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 26
City of Miami
Table 12: City of Miami Section 8 Mod rehab
Reasonable Accommodation Requests (Mod -
Rehab)
Year
Total
Requests
Request
Mental Health
Physical
Disability (lst
Floor)
Allergies/Interi
or Change to
Unit
2011
4
3
1
2012
1
1
2013
4
1
3
2014
5
2
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 homeownership projects, creating Chapter 17, Article XI 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 to five percent (5%) additional set 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 income
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.
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 be an ordinance prohibiting housing for persons 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 Supreme Court decision, Olmstead v. L.C., 527 U.S. 581 (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 placement 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
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 27
City of Miami
same standards applied to other residential uses occupied by a family, housing choice for the
disabled is not hindered.
In accordance to State Law (Statute 419), Miami 21 (the City's master zoning code) specifies
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 of Miami Zoning Code (Miami21) defines these community residences as:
(a) A Dwelling Unit of six or fewer 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 "resident", for the purpose of a Community Residence, may include any persons as defined
in the following statutes:
• A disabled adult or frail elder as defined in section 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
• A child as defined in section 39.01(12), Florida Statutes
Pursuant to FL Statutes Ch. 429.02(5), an assisted living facility means any building or
building's section or distinct part of a building, private home, boarding home, home for the
aged, or other residential facility, for a period exceeding 24 hours to one or more adults who
are not relatives of the owner.
The Agency for Persons with Disabilities (APD), which issues state licenses for group homes,
serves people with the following disabilities: autism, cerebral palsy, spina bifida, intellectual
disabilities, down syndrome, Prader-Willi syndrome, and children ages 3-5 who are at a high
risk of a developmental disability.
A Zoning verification approval is required in order to confirm State established distance
requirements are being satisfied. 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 and pursuant to Article 6.2 of Miami21, the location of a
facility may be denied if it results in an over concentration of Community Residences in
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 28
City of Miami
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), which monitors community homes, and with Agency for Persons with
Disabilities (APD), which monitors group homes. The State's 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
2013, 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 Homes and
Assisted Living Facilities within its boundaries that is updated monthly to reflect the latest
information from all participating state agencies (AHCA, APD). Via GIS capabilities, the
Planning & Zoning Department performs internal distance separation requirements to
analyze and monitor location, number of beds, state license expiration dates, and certificates
of use issued (when applicable) for ALFs and group homes.
The City Commission adopted Resolution 15-0155 on March 2015 urging Florida Governor
Rick Scott and the members of the Florida Legislature to adopt legislation preventing
individuals diverted from the criminal justice system from entering assisted living facilities or
community residential homes located in predominantly low -density, single-family and duplex
neighborhoods.
As of April 2015, the City had 174 community residential homes (ALFs and group homes)
within its 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 (count: 156); the remaining (count: 18) are group homes.
PERSONS WITH HIV/AIDS
The City of Miami serves as the administrator of the formula grant -funded Housing
Opportunities for Persons with AIDS (HOPWA) program for the entire geographical area of
Miami -Dade County. The Miami -Dade County metropolitan area has the fourth highest
number of living AIDS cases in the country (the top ranked in order of highest number of cases
are the metropolitan areas of New York City, Los Angeles, and Washington, D.C.). HIV/AIDS
disproportionately affects minority populations in Miami -Dade County, as is the case
nationally.
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
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 29
City of Miami
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 City also offers Short -Term Rental and Mortgage Utility Assistance (STRMU) of no more
than 21 weeks to approximately 100 persons each year who are HIV+, who are 80% AMI or
below, and who are not participants in the LTRA program. This program is administered by a
sub -recipient (non-profit) selected via an advertised, Request for Proposals process and
STRMU applicants are processed on a first -come, first -eligible basis, requiring an HIV+
diagnosis by a licensed medical professional.
Upon entrance into the HOPWA LTRA program, all clients are provided with the LTRA Client
Handbook which provides the most important information concerning the HOPWA 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 HOPWA LTRA
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 a proper authority.
The November 2014 Monthly HIV/AIDS Surveillance Report issued by the Florida Department
of Health in Miami -Dade County noted that there were a cumulative (since the year 2000)
number of 35,274 reported AIDS cases in Miami -Dade County (excluding persons in the
Department of Corrections (DOC)). Approximately 35% of the cases were Hispanic (all races);
50.4% of the cases were Black and 13% were White. A total of 14,638 cumulative (since the
year 2000) HIV (not AIDS) cases were noted in the same report, again excluding DOC cases.
Approximately 42.7% were Hispanic (all races), 42.6% were Black, and 13.3% were White.
As required by federal law and state law, a person's HIV/AIDS status is exempt from all public
record inquiries. To that end, all public materials (leases, payments, landlord packages)
associated with the City's HOPWA LTRA and/or STRMU programs make no mention of the
client's medical diagnosis of AIDS or HIV (respectively). Because of this, the City has had few
issues and no reported cases of discrimination by landlords of its tenants due to their AIDS
status.
The City of Miami HOPWA Program Policies and Procedures Manual (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;
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 30
City of Miami
ii. A record of such an impairment;
iii. Being regarded as having such an impairment;
To clarify the reference above to a 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 Chapter XV-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 of the 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 individual's disability (see
Joint Statement of the Department of Housing and Urban Development and the
Department of Justice on Reasonable Accommodations under the Fair Housing Act,
May 14, 2004);
c. and, the requested accommodation is reasonable.
In 2014, the Miami -Dade County HIV/AIDS Housing Survey & Needs Assessment was carried
out between the months of March and May 2014 for the purpose of determining the housing
needs and preferences of persons living with HIV/AIDS in the Miami -Dade EMSA in order to
establish a housing profile of this population and to assist the City in its strategic planning and
resource allocation process in consultation with the Housing Committee and the Miami -Dade
County HIV/AIDS Partnership, In total, 243 surveys were collected and analyzed at different
HIV/AIDS care provider sites. The survey found that there is a need amongst PLWAs for 10,039
subsidized rental units or rent subsidies. Close to 84% of the respondents reported that they
were NOT receiving housing assistance of any kind, compared to 59% of respondents in the
2012 survey. When asked if they were on a waiting list for housing assistance, 90% of
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
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 31
City of Miami
discrimination were HIV status (25%), alcohol or drug use, other (credit or income),
and physical disability.
HOUSING
In the last few years, the City of Miami's urban core has undergone a transformation that was
by most accounts, unexpected. When the last Al was drafted, the City had suffered the dire
after effects of the collapse of the real estate market and U.S. 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 by foreigners and out-of-
state residents who purchase investment, seasonal, and or second-, 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
additional housing is being built, this does not mean that the volume has made housing more
accessible and/or affordable to Miami's permanent residents, who both live and work here.
For the 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 ACS, 36.5% of the City's housing structures
now feature 20 or more units. This is a significant departure from the 2000 Census, where the
majority of the City's structures (30.6%) 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
of the Cities Data Systems (SOCDS) Building Permits Database (www.huduser.org), based on
unit type. As noted in the table, the bulk of the permits during the past three years have been
issued in the All Multi family category with the peak happening in 2013 (4371) and a slight
leveling off in 2014 (3507).
Table 13: Housing Unit Building Permits for Miami, FL (preliminary
data) from the SOCDS building permits database
Unit
2011
2012
2013
2014
In Single family
Structures
21
40
115
65
In All Multi -family
structure
266
911
4371
3507
In 2-unit Multi -family
structures
30
14
58
68
In 3- and 4-unit Multi-
family structures
4
0
8
0
In 5+ Unit Multi -family
structures
232
897
4305
3439
Total
287
951
4486
3572
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 32
City of Miami
Miami's trend towards vertical growth (density) is not unusual when looking at other
comparable cities, many of which have seen increased attention and focus on returning to,
and/or living in, the urban core which typically has more accessibility to public transportation
and business centers (jobs). Case in point, Downtown Miami's population has doubled in 10
years with reports indicating that as of 2014, the population was somewhere around 74,000
persons. As noted in Table 14 below, the greater Downtown Miami area is logging the greatest
number of pre -construction units in all of South Florida.
This Al's Attachment 2 provides up-to-date City maps of land use in Miami. As is evident in
the maps, there is little vacant land remaining in the City presently, with the bulk of it located
in the north/northeastern part of the City (Districts 2 & 5). 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 in Miami is
5,000-square-feet, which again compared to other cities, is not extremely large. As such, we
believe 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.
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."11 We will elaborate on the repercussions of the latter
further this document. Additional data also reinforces the prevalence of planned multi -family
developments in the Miami area. As of August 2014, 256 multi -family towers were planned
in the in the tri-county area (these include Miami -Dade, Broward, and Palm Beach Counties).
Of those towers, approximately 52% of these proposed new units (note: ultimately, not all of
these planned units may be developed) are located in Greater Downtown Miami which is
entirely within City of Miami limits.
Table 14: South Florida Pre -construction condo projects
market rankings as of August 18th 2014
Rank
Market
Towers
Floors
Units
Share of
Units
South Florida
256
5059
35132
1
Greater Downtown
Miami
61
2583
18267
52%
2
Hollywood/Hallandale
Beach
20
235
3254
9.3%
3
West Palm Beach
12
261
2122
6%
4
Aventura
13
215
2108
6%
5
Sunny Isles Beach
14
547
1924
5.5%
6
Miami Beach
27
270
1355
3.9%
7
Bal Surf Bay
30
225
1286
3.7%
8
Coral Gables
9
48
1133
3.2%
9
Fort Lauderdale
15
178
789
2.2%
10
North Bay Village
4
93
549
1.6%
11
Miami (Coconut
Grove)
7
130
435
1.2%
12
Pompano Beach
11
45
374
1.1%
11 Susan Danseyar, "Realtors push for more condo financing options," Miami Today, April 23, 2015.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
33
13
Miami (Morningside)
2
23
230
.7%
Source: CraneSpotters.com. Gray highlights indicate buildings within City of Miami limits.
HOUSING STOCK AND TENURE
Despite the market forces that have led to the increase in housing options in the City of Miami,
data shows that nearly half the city households cannot find housing that would not cost -
burden them. The high rates of cost burden indicate that the affordable housing supply is not
meeting the demands of city residents.
As previously discussed, the bulk of Miami's housing units are now in multi -family buildings —
with close to 40% of Miami's housing stock found in multi -family buildings of 20 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 26% of the city's housing stock is comprised of one -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 2009 (19.3%), no doubt fueled by the
recent wave of development. In the previous Census, the bulk of the City's housing stock had
been built between 1970 to 1979, but now that date range approximates a more modest
13.5% of the total housing stock in the City.
Table 15: MIAMI SELECTED HOUSING
CHARACTERISTICS
Estimate Percent
TOTAL HOUSING UNITS
Occupied housing units
Vacant housing units
UNITS IN STRUCTURE
1-unit detached structure
1-unit attached structure
2 units
3 or 4 units
187,938
150,974
36,964
80.3%
19.7%
48,816 26.0
18,578 9.9
9,291 4.9
9,673 5.1
5 to 9 units
10 to 19 units
20 or more units
13,939
13,624
72,879
7.4
7.2
38.8
Mobile home 1,029 0.5
Boat/RV/van etc. 109 0.1
*Source: 2009-2013 American Community Survey 5-Year Estimate
HOUSING UNIT SIZE
As noted in the table below, the majority of units in the City are two -bedrooms (38.8%)
followed by one -bedrooms (31.8%). Together, one- and two -bedroom housing comprises
close to 70% of the housing stock. This bears mention as it indicates that most households in
the City are in fact smaller -sized households, and that larger families might have a more
difficult time locating a residence that accommodates their size.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 34
City of Miami
Table 16: BEDROOMS
Estimate Percent
TOTAL HOUSING UNITS
No bedroom
1 bedroom
2 bedrooms
3 bedrooms
4 bedrooms
5 or more bedrooms
A CITY OF RENTERS
187,938
11515 6.1
59754 31.8
71991 38.3
34582 18.4
8037 4.3
2059 1.1
The City of Miami 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), 65.3% of the total
occupied housing units in Miami were made up of renters, while a lower 44.2 percent of
Miami -Dade County's occupied units were renters and an even lower 32.6 percent of the
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 any major American city, even surpassing New York City.12
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 to occupy larger units (2 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 cities of the 11 largest metro areas have more renters than homeowners, a trend that
could be attributed to the real estate bust and many persons/families losing their homes to
foreclosure, or persons being weary of owning a home given the consequences of the real
estate bust, or finally first-time homebuyers inability to purchase a home due to slow income
growth, a lack of savings, and higher -than -average rents.
The U.S Census defines gross rent as the monthly amount of rent plus the estimated average
monthly cost of utilities (electricity, gas, water, and sewer) and fuel (oil, coal, kerosene, wood,
etc.). Gross rent as a percentage of income is defined as the ratio of gross rent to household
income. It is used as a measure of housing affordability by policymakers 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,
12 NYU Furman/Capital One National Affordable Rental Housing Landscape Research Study,
www.furmancenter.ora/NationalRentalLandscape
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 35
City of Miami
data from the 2007-2011 ACS Survey indicates that the bulk of units paying rent (67.3%) were
HOUSINCiTENURE
2010 2000 Percent Change
Number Percent Number Percent Number Percent
Occupied housing units
Owne r-occu pied
Re me r-occu pied
Average HH ske of owner -occupied unit
Average HHsize of renter -occupied unit
Source: US Census Bureau, 2000ond2010 Census
Florida
(Ala m i-Dade County
City of Miami
158,317 100.0%
51,186 32.3%
107,131 653%
2.67
2.37
HetusingTenure by Region, 2010
1.111111
552%
32.3%
134,198 100.0%
46,836 34.9%
87,362 65.1%
2.79 ( X )
252 (x)
3 2.6%
44.29E
65.3%
0% 21351,
24,119
18.0%
4,350 9.3%
19,769 22.6%
40% EU% 80% 10051,
• Owner -occupied • Renter -occupied Source.: US Census tow
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 major American
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.
Table 17
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%
DRAFT- 2015-2020 Analysis of Impediments to Fair Housing Choice 36
City of Miami
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%
1.9%
Median (dollars)
910
535
$1,500 or more
$1,000 to $1,499
$750 to $999
$500 to $749
$300 to $499
$200 to $299
Less than $200
13.9%
a
26.8%
:
26.6%
18.2
%
Gross Rent
Units Paying
of Miami, 2000
36.5'
for Occupie
Rent in th
& 200i
..'
4.7k
28.5%
8.8%
d
e City
-2011
0.0% 5.0% 10.0% 15 0% 20.0% 25.0% 30.0% 35.0% 40.0%
CITY HOMEOWNERS
The state of being a City homeowner has also changed in the past decade or so. As in the
previous Al, the majority of owner -occupied housing units in the City (58%) have a mortgage
on their housing unit.
Table 20: Mortgage Status, Owner Occupied Units City of Miami
Owner -occupied units
Number Percent
Owner -occupied units 48,403 100%
Housing units with a mortgage 28,058 58%
Housing units without a mortgage 20,345 42%
Source: U.S. Census Bureau, 2011-2013 ACS 3-year estimate
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.
DRAFT- 2015-2020 Analysis of Impediments to Fair Housing Choice 37
City of Miami
Table 21: SELECTED MONTHLY OWNER
COSTS AS A PERCENTAGE OF HOUSEHOLD
INCOME (SMOCAPI), City of Miami, 2007-Number
2011 ACS
Percent
Housing units with a mortgage (excluding
units where SMOCAPI cannot be
computed)
31,783
100.0%
Less than 20.0 percent
5,022
15.8%
20.0 to 24.9 percent
3,521
11.1%
25.0 to 29.9 percent
2,557
8.0%
30.0 to 34.9 percent
2,576
8.1%
35.0 percent or more
18,107
57.0%
Table 22: SELECTED MONTHLY OWNER
COSTS (SMOC)
2007-
2011 ACS
2000
Census
Less than $300
0.0%
0.3%
$300 to $499
1.0%
2.5%
$500 to $699
1.9%
6.0%
$700 to $999
6.0%
14.6%
$1,000 to $1,499
21.3%
22.5%
$1,500 to $1,999
19.7%
9.4%
$2,000 or more
49.9%
8.2%
Median (dollars)
1,997
1,163
$2,000 or more
$1,500 to $1,999
$1,000 to $1,499
$700 to $999
$500 to $699
$300 to $499
Less than $300
.9%
5%
�1.0%
0.3%
0.0%
Selected Monthly Owner
Costs for Housing Units with
a Mortgage in the City of
Miami, 2000 & 2007-2011
0.0% 10.0% 20.0% 30.0% 40.0% 50.0%
■ 2000 Census ■ 2007-2011 ACS
DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice 38
City of Miami
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.13 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 at 65 different sites.
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. In January 2015, the Department
announced a plan to demolish the Liberty Square Apartments (known as Pork and Beans),
located within the City of Miami just off of 62nd Avenue in Liberty City and built in 1936. The
753-plus 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 as of January 2015. The plan would still require approval of
the Miami -Dade County Commission and U.S. HUD.
With regard to other subsidized housing (not including the Section 8 vouchers, Section 8
moderate 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
housing developments within the City.
Table 23: Summary Table of Assisted Housing Units, City of Miami
plot inclusive of public housing and/or Section 8 proj'rams)_
Number Number
Population Served of Percentage
projects
of units
Elderly I Elderly/Link 65 41%
Elderly I Family 4 3%
Family I Family/Link 70 44%
Family/Homeless 5 3%
Homeless 1 .5
Persons with Disabilities 1 .5
Could not confirm 13 8%
Total 159 100%
13 Miami -Dade Housing Agency PHA Five -Year and Annual Plan for FY beginning 10/2015
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
39
Source: The Shimberg Center for Housing Studies, Florida Housing Data Clearinghouse combined with the City's NSP lists.
*Note of the total assisted units noted in all categories, units currently under development are included in the listing. This
number amounts to 1,015 assisted units currently under construction. Last update 3/15.
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 a 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
2 and 4). Historically, it has been difficult to develop new housing in those areas due to the
higher costs of land, coupled with smaller vacant parcel sizes.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 40
City of Miami
City of Miami
Assisted Housing Developments, 2014
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DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
41
HOUSING CHOICE VOUCHER ADMINISTRATIVE PLAN
The most recent City of Miami Section 8 Administrative Plan "the Plan" addresses fair housing
and equal opportunity in Chapter 18 (page 177 - 184) in both the HCV Program and the
Moderate Rehabilitation Program as overseen by the DCED. 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 policy for requesting reasonable accommodations 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
disability."
Section 18.3 of the Plan addresses the City's services for persons and improving 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 City
retains the right to skip higher income families on the waiting list if necessary to meet the
statutory requirement that 75% of newly admitted families in any fiscal year be families who
are extremely low-income as defined by HUD.
The local preference for the Section 8 programs application process is for persons/families
who qualify as disabled or elderly. These preferences are defined in the Plan as follows:
Elderly family:
• A family whose head or spouse (or sole member) is 62 years or older and/or a family
that includes an elderly person(s).
Disabled family:
• A family whose member(s) include a person(s) who is under a disability as defined in
Section 223 of the Social Security Act (42 U. S. c. 423) or has a developmental
disability as defined in sectionl02(7) of the Developmental Disabilities Assistance
and Bill of Rights Act (42 U. S. C. 6001(7)); or
• A family whose member(s) include a person(s) having a physical or mental
impairment that (a) is expected to be of a long -continued and indefinite duration;
(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.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 42
City of Miami
WAITING LISTS FOR HCV AND THE MODERATE REHABILITATION PROGRAM
As the PHA, the DCED opens and closes registration periods by announcing 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 City's three main languages — English, Spanish, and Creole.
Applications were made available at all City of Miami's 13 community offices (known as the
Neighborhood Enhancement Team (NET) offices), which are spread throughout the City in 11
different neighborhoods and accessible by and to all City neighborhoods. Applications were
also made available at the Miami -Dade County MAIN library in downtown Miami, accessible
by bus, Metrorail and vehicle.
Because the DCED operates a very small program (136 vouchers) and the program's level of
attrition it extremely low, the City (via the DCED) establishes a small waitlist; the 2014 waitlist
only had 100 slots available. The City received a total of 4,091 eligible applications via U.S.
mail and a random computer lottery selected 100 from that group.
The Plan was also recently updated to include all the guidelines set forth by HUD in its final
rule on Equal Access to Housing in HUD Programs regardless of Sexual Orientation or Gender
Identity (77FR 662) which applies to all HUD -assisted and HUD -insured housing, including the
private owners who participate in housing programs funded under the U.S. Housing Act of
1937.
Table 24 provides details on the demographics of the applicants during the last Section HCV
Application period:
Table 24: Characteristics of Applicants to City of Miami
Section 8 HCV Program (2014)
Total number of eligible applicants
4,091
100%
Hispanic
2576
63%
Gender
--Female
2908
71%
--Male
1183
29%
Race
--African American
1647
40.26%
--American Indian
1
0.02%
--Asian
8
0.20%
--Other
19
0.46%
--White
2416
59.06%
American citizen
--Yes
3288
80%
--No
803
20%
Preference Identified (Elderly/Disabled)
--Yes
2097
51%
--No
1994
49%
*Note: Hispanic ethnicity is counted independently of race.
Source: City of Miami, Dept. of Community & Economic Development
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
43
No study of the rejection rate for Housing Choice Vouchers (HCV) clients has been done, but
HCV Section 8 clients do not report finding an available unit to be a problem. There were
9100/798 20,000 persons on the list for the City's Section 8 moderate rehabilitation (project -
based) program, which closed in 2003. At that 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 (LIHTC)
The Federal Low -Income Housing Tax Credit (LIHTC) program is now the major source of
federal support for affordable housing. The program provides developers with 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, the LIHTC program is administered by the 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 from 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 (TODs) across the State. TOD 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 (SW 2 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,
it also created another albeit unintended side effect -- the concentration of subsidized
housing in a particular area.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 44
City of Miami
Although TOD makes 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
Miami -Dade County, which is operated by Miami -Dade Transit (MDT), a County Department.
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 of 34 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
eleven years later in 1836. Because the bulk of early development in the area took place
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 Miami 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 opened in May 1984, the area's Metrorail system (heavy rail metro line) opened its 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 — 2015-2020 Analysis of Impediments to Fair Housing Choice 45
City of Miami
MIAMI 21 ARTICLE 4. DIAGRAM 11 TRANSIT ORIENTED DEVELOPMENT - TOD
AS ADOPTED • MAY 2014
METRORWL
nFUTURE METRORW L
MEmRMAOYER
[CIS ROUTES
STREETCAR
HEALTH DISTRICT CIRCULATOR
nHEALTH DISTRICT STOPS
FUTURE TRANSIT SHEDS
1/2 M ILE TRANSIT SHED
«I
114 M ILE PEDESTRIAN SHED
Nole: The Metal Miami 21 TOD Diagram is maintained the Office of the Oty Clerk.
IV28
More recently, the FHFC has limited Miami -Dade County to only 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 Broward
require a higher score (13.75 points) in the QAP in order to meet the "perfect" proximity
caveat, while other large Florida counties (5) only require 12.25 points. This means certain
potential applicants from the City will never meet that high score because their particular area
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.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 46
City of Miami
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
FHFC should reduce "the frequency of rule 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."
LIHTC INVENTORY
In order to have an accurate inventory of tax credit units located within City limits, the 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.
To be clear, Miami -Dade County is comprised of multiple communities - all concentrated on
the county's Eastern half, including 34 municipalities (including the City of Miami) and 16
unincorporated communities. See the Figure below for an 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 County count of 198 tax credit developments. This means that
approximately 46% of the tax credit projects in all of Miami -Dade County are 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 — 2015-2020 Analysis of Impediments to Fair Housing Choice 47
City of Miami
City of Miami
Tax Credits in Miami (Blue) and Miami -Dade County (Gray)
HOUSING MARKET
Miami's housing market grew by 24% from 2000 to 2010, adding some 35,000 units to the
City's available stock with the bulk of that activity centered in the Brickell/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 of the City's residents are in fact, renters. Qualifying that supply — its pricing and who the
end -users will be — is what becomes difficult.
To shed further light on the market, it is important to note that the City's current housing
market has been strongly influenced by a 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 on the major role
that non-residents (in many cases, foreigners) play in our City'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 — 2015-2020 Analysis of Impediments to Fair Housing Choice 48
City of Miami
(#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 12/31/2013), only 37% of all condominium units in the
County have a homestead exemption, which is remarkably low given that Florida law allows
for homeowners to claim a homestead exemption (tax exemption) of up to $50,000 on 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 on the 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, Sales Data 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 indicated that home prices in the
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
2008.14 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 higher than 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 area. 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 sq ft
neighborhoods Week ending Mar Dec '14 - Mar'15 price Dec '14 - Mar'15
4 Dec '14 - Mar'15
Name Amount w ° Amount y-o-y Amount y-o-y Amount y-o-y
Model City $110,642 2 0% $76,668
Allapattah $226,920
Flaciami
0.5% $115,600
$72,000 $59
4L` $104,000 $88
$234,224 0 6 $194,266 10.0°k $207,500
East Little
Havana
$241,923
4.5' $180,246
$161
21.2% $112,000 $131
14 The Miami Herald, "Miami home prices No. 1 in yearly increase," Martha Brannigan.
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 49
City of Miami
Miami Avg. listing price
neighborhoods Week ending Mar
4
Name
Amount W °
w
Avg. sales price
Dec '14 - Mar '15
Amount y-o-y
Median sales Price per sq ft
price Dec '14 - Mar '15
Dec'14 - Mar'15
Amount y-o-y Amount y-o-y
West Little
Havana
$253,106 0.2% $190,655 24.2% $199,900 34.6%
Overtown $261,597
Little Haiti $340,331
Wynwood -
Edgewater
$567,758
Coral Way $725,700
Upper East
Side
$1,195,704
$328,500
$164 29.1%
259.09 $328,500 245.8%
$240
$126,814-23.86$101,800 -7,5%
$381,162
$343,667
$581,746
150.0%
$100 2.0%
$355,000
$355
$305,000
$278
$448,250 73.1% $302
Northeast $1,801,890 $687,507 44.1% $530,000 41.3%
Coconut Grove 0.8%
Southwest $1,958,095
Coconut Grove
3.0% $769,843
16.6%
$366 16.9%
-23.4% $635,000 -29.1 % $347
Source: Trulia.com, y-o-y: year over year percentage changes, as printed on 3/17/2015
-15.4%
The Miami -Fort Lauderdale -Miami Beach, FL area's housing affordability index continues to
decline, as reported by Realtor.org, the website of the National Association of Realtors. The
higher the growth of the housing affordability index, the more affordable the metro area is
and vice versa. In 2014, there was -6.2% in growth in the area. Growth in 2013, was-21.3%.
The housing affordability index is calculated based on the sales price of the Existing Single -
Family Homes. The same negative growth is seen along most of Florida's east coast.
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% AMI 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
$214,000 for a new construction home.
Overinflated real estate prices have created what is by most 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 of low median household incomes.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 50
City of Miami
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
Assumptions based on Median HH Income in the City of Miami
Annual income
$ 29,762
Planned loan term
30 Years
Interest rate
4.55%
Monthly debt
$0
Percentage of down payment
5%
Maximum value for affordable purchase
$97,448
Affordability based on Median HH Income in the City of Miami
Single Family
Condo
Median Sales Price (2012) $ 176,950
$ 295,000
Affordable Purchase $ 97,448
$ 97,448
Affordability Gap ($79,502)
($197,552)
Sources: Median income -U. S. Census Bureau, American Community Survey, 5-YearEstimates; Percent down payment based on
Fannie Mae rates and Maximum value of affordable home purchase calculated on the Fannie Mae's Mortgage Affordability Calculator,
wvw.homepath.com; Interest Rate — Bankrate.com on 1-6-2014; Median sales price —Reinhold IV Wolff, Inc.
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 $46,640 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.ore/oor/2014/MS)
15 http://nlihc.org/oor/2014/MS
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
51
Miami/Miami Beach/Kendall
HUD Metro FMR Areas for all bedroom sizes
Studio 1-bedroom 2-bedroom 3-bedroom 4-bedroom
2014 $747 $910 $1166 $1600 $1869
2015 $745 $907 $1,162 $1,594 $1,863
Source. www.huduser.oru
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
Assumptions based on Median HH Income in the City of Miami
City of Miami Median HH Income
$ 29,762
30% of Median HH Income divided by 12 Months
$744.05
Unit Size
Monthly Rent
($)
Affordability Gap
City of Miami Median Gross Rent -
(2008-2012)
925
(180.95)
Fair Market Rent, FY 2014 0 Bedroom
747
(2.50)
1 Bedroom
910
(165.50)
2 Bedroom
1,166
(421.50)
3 Bedroom
1,600
(855.50)
4 Bedroom
1,869
(1124.50)
High HOME Rent 0 Bedroom
760
(15.50)
1 Bedroom
819
(74.50)
2 Bedroom
984
(239.50)
3 Bedroom
1,128
(383.50)
4 Bedroom
1,239
(494.50)
Low HOME Rent 0 Bedroom
602
142.50
1 Bedroom
645
99.50
2 Bedroom
773
(28.50)
3 Bedroom
894
(149.50)
4 Bedroom
997
(252.50)
Miami -Dade Affordable Rentals (Tax Credit Overall
Developments)
$819
(74.95)
0 Bedroom
$519
225.05
1 Bedroom
$711
33.05
2 Bedroom
$829
(84.95)
3 Bedroom
$943
(198.95)
4 Bedroom
$986
(241.95)
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 52
City of Miami
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%
■ 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
save for the future, leaving them with a tentative foothold on household stability in the event
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 53
City of Miami
of an unexpected setback, i.e. lay-off, injury, health issue, etc. As such, 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 severely cost -burdened households in this section.
■ Cost -burdened households: are defined as those spending 30.01 percent to 50 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 of households statewide are cost -burdened. Upon analysis of
the City's cost -burdened households, a significant majority (79%) 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% AMI) 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 of Income Paid
for Housing in the City
of Miami
■ 0-30%
■ 30-50%
50% or more
Source: Shimberg Center for Housing Studies
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 54
City of Miami
CO °,
E
ala)
J CU
>-
w
w
4J
0
0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000
17,950
Cost
Burden by
Tenure and
Type of
Household
based on
CHAS
Tables 5
and 6
Renter
Owner
Table 28: Projected Number of severely cost burdened (50%+) households with income less than 80%
AMI by tenure and income level, City of Miami (2009 to 2030)
Tenure: Owner
Household Income as
of AMI
0-30% AM
30.1-50% AMI
50.1-80% AMI
Total Severely Cost
Burdened Owners
2009 2010 2015 2020 2025 2030
3,999
2,753
2,604
9,356
4,029
2,773
2,619
9,421
4,297
2,946
2,755
9,998
4,642
3,169
2,929
10,740
5,010
3,400
3,087
11,497
5,382
3,630
3,232
12,244
# Increase
2009-2030
1,383
877
628
2,888
Household Income as % # Increase
2009 2010 2015 2020 2025 2030
of AMI 2009-2030
0-30% AM 18,903 18,984 19,887 21,098 22,314 23,458 4,555
30.1-50% AMI 6,563 6,587 6,870 7,251 7,613 7,937 1,374
50.1-80% AMI 1,199 1,201 1,243 1,303 1,361 1,410 211
Total Severely Cost 26,665 26,772 28,000 29,652 31,288 32,805 6,140
Burdened Renters
Total Severely Cost 36,021 36,193 37,998 40,392 42,785 45,049 9,028
Burdened Households
Source: Shimberg Center for Housing Studies
DRAFT- 2015-2020 Analysis of Impediments to Fair Housing Choice 55
City of Miami
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
Housing Cost Burden
Jurisdiction as a w o
White
Black/African American
Asian
Hispanic
1
i
42%
45%
30-50%
■ Total
26% 32% 100%
229I1. 26% 100% I
22% 34% 100%
62% 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
Housing Cost Burden
White
Black/African American
Asian
Hispanic
70,000
60,000
50,000
40,000
30,000
20,000
10,000
10,915
11,415
<=30%
White
<=30
100%
17%
30-50%
>50%
No /
negative
income
100% 100% 100%
12% 11% 19%
1
17% 13% 17%
29%
1% 1% 1% 1%
73% 71%
Greater Need BY Total Share:
Cost burden by Race -based on CHAS Table 17
5,260
4,835
35,200
8,245
5,640
30-50% >50%
Black/African American • Asian iii Hispanic
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 56
City of Miami
Table 31: City of Miami Housing Cost Burden
Housing Cost
Burden
<=30%
30-50%
>50%
No / negative
income (not
computed)
Jurisdiction as a
whole
65,640
39,530
49,660
3,395
White
11,415
4,835
5,640
655
Black / African
American
10,915
5,260
8,245
975
Asian
790
220
255
30
American Indian,
Alaska Native
0
0
0
0
Pacific Islander
10
0
0
0
Hispanic
42,095
28,985
35,200
1,715
Source: 2006-2010 CHAS
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 AI, 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 its allocation of State Housing Initiative Partnership (SHIP) funds for strategies
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 moderate -income and because
of particular social, economic, or health related circumstances, have a greater difficulty
acquiring or maintaining affordable housing/' as stipulated in Chapter 67-37.002 (21), F.A.C.
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 57
City of Miami
(page 8). In all cases, the persons being assisted must be very low, low or moderate income
with the latter not exceeding 120% AMI 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
and who has a 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 (SSDI) program or the Supplemental Security Income (SSI)
program or from 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-Year Estimate, Blacks have the lowest median household income in the
City of Miami followed by the Hispanic/Latino population (Table 32).
Table 32: Median Household Income by Race, City of Miami
Estimate
Inflation Adjusted
Dollars (2013)
White alone (Not Hispanic or Latino)
Black or African 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
$33,337
$38,340
$27,824
Source: U.S. Census Bureau, 2011-2013, , American Community Survey, Three -Year Estimate, Median Household Income in the
past 12 months (in 2013, Inflation adjusted dollars)
Income and employment are two essential characteristics that impact a household's
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
In Labor Force (16 years and older)
Mean travel time to work in minutes (16 years and older)
Median Household Income (dollars)
Median family income (dollars)
Per capita income (dollars)
212,997 61.9%
25.9 (X)
$30,126 (X)
$33,475 (X)
$21,416 (X)
Somme: U.S. Census Bureau, 2011-2013 ACS three-year estimates.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 58
City of Miami
INCOME
The median household income in Miami is $30,375 while Miami -Dade County's is $43,100
(ACS 2009-2013, 5-year estimate). Historically, this is usually the case — with the County's
median income averaging significantly higher than the City's median income. Keep in mind
that Miami -Dade County has significantly more households (estimated 828,031) when
compared to Miami (estimated 150,974).
When further analyzing Miami's household income brackets (see Table 34), it's easy to discern
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 units are occupied by households making $34,999
and below (ACS 2011-2013, 3-year estimate).
Table 34: Household Income by Income Brackets in the past 12 months
in 2013 inflation- adiiusted dollars): City of Miami
2011-2013 City of Miami - Financial Characteristics
(S2503)
Occupied
Housing
Owner
Occupied
Housing
Renter -
occupied
housing units
Households
152,200
48,403
103,797
Income Brackets
Estimated
Percent
Estimated
Percent
Estimated
Percent
Less than $14,999
26.9
14.9
32.4
$15,000 to $24,999
16.5
13.2
17.9
$25,000 to $34,999
12.5
12.2
12.6
$35,000 to $49,999
12.8
12.5
13.0
$50,000 to $74,999
12.5
14.1
11.8
$75,000 to $99,999
6.3
9.4
4.8
$100,000 to $149,999
6.6
11.4
4.3
$150,000 or more
6.0
12.3
3.1
Source: U.S. Census, 2011-2013 3-year Estimate ACS,
When looking at how City incomes have changed within the past decade or so, specifically
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-
income categories as much as they reveal that the landscape of the city has changed by, quite
possibly, adding more households to the higher income brackets, and, thereby changing the
share of households in these income categories.
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 59
City of Miami
0.0%
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
LABOR FORCE
5.0%
10.0%
15.0%
20.0%
25.0% 30 0%
Income by Household
City of Miami, 2000 & 2007-2011
Source: U.S. Census Bureau, 2000 Census & 2007-
■ 2000 Census ■ 2007-2011 ACS
The economic well-being of a community is largely determined by how well the residents are
connected to the labor market. Currently, 61.9 percent of the population 16 years and over
is in the labor force. The 2011-2013 Three -Year American Community Survey shows that
about 7.9% percent of the City's workforce population is unemployed. This figure most likely
does not reflect the current (actual) economic conditions. Therefore, an important proxy for
the City's current unemployment data is the Agency for Workforce Innovation's (AWI) market
statistics estimates. According to the Florida Department of Economic Opportunity's Local
Area Unemployment Statistics I, 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, Kendall, 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.
Table 35: City of Miami Employment (Labor Force) Status, 2011-2013
Population 16 years and over
344,289
100%
In labor force
212,997
61.9%
Civilian labor force
212,844
61.8%
Employed
185,503
53.9%
Unemployed
27,341
7.9%
Not in labor force
131,292
38.1%
Source: U.S. Census, ACS, 2011-2013, 3-year estimate
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 60
City of Miami
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 income are
directly correlated to economic sustainability and therefore also impact access to home
ownership. It is important to note that more than 40% of Miami's employed civilians 16 years
and over hold service and sales occupations. The bulk of individuals employed are in low end
jobs mostly related to the service industry sector.
Table 36: City of Miami Occupations by Sector 2009-2013 ACS
Civilian employed population 16 years and
over
180,453
100%
Agriculture, forestry, fishing and hunting, and
mining
484
.27 %
Construction
17,372
9.62%
Manufacturing
7,718
4.28%
Wholesale trade
6,352
3.52%
Retail trade
21,577
11.96%
Transportation and warehousing, and utilities
10,854
6.01%
Information
3,675
2.04%
Finance and insurance, and real estate and
rental and leasing
12,301
6.82%
Professional, scientific, and management,
and administrative and waste management
services
22,850
12.66%
Educational services, and health care and
social assistance
30,475
16.89%
Arts, entertainment, and recreation, and
accommodation and food services
25,711
14.25%
Other services, except public administration
16,027
8.88%
Public administration
5,057
2.80%
Sot rce: 2009-2013, 5-Year Estimates, American Community Survey
As further broken down in the Table 37, the majority of the occupations in the Miami MSA
are in retail sales with a low median hourly wage of $9.86; as of 2015, Florida's minimum
wage is $7.93 per hour. The table shows the top fifteen occupations (by count) in the Miami
MSA. The table mirrors the data collected by the 2009-2013 American Community survey
with the fact that the majority of employment is found in service, low -end income jobs. Wages
and wage growth is crucial to a household's capacity but according to the U.S. Bureau of Labor
Statistics, South Florida's wage growth was running about 2% last year.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 61
City of Miami
Table 37: Miami -Miami Beach -Kendall MSA (Miami -Dade County) Leading Selected
Occupations for 2014, based on 2013 surveys
Occupation
2013 2014
Employment Median Hr.
# of
persons Wage ($)
Retail Salespersons
Registered Nurses
Customer Service Representatives
47,220 9.86
26,220 29.09
25,650 13.77
Cashiers 25,120 9.21
Combined Food Preparation and Serving Workers,
Including Fast Food 24,670 9.01
Waiters and Waitresses 23,700 8.96
Secretaries and Administrative Assistants, Except
Legal, Medical, 22,580 14.18
Office Clerks, General 21,320 12.37
Laborers and Freight, Stock, and Material Movers,
Hand 19,640 11.46
Security Guards 18,830 10.75
Sales Representatives, Wholesale and Manufacturing,
Except Technical and Scientific Products 18,470 21.27
Stock Clerks and Order Fillers 18,110 10.57
Janitors and Cleaners, Except Maids and Housekeeping
Cleaners 16,010 9.41
Bookkeeping, Accounting, and Auditing Clerks 13,180 16.85
Accountants and Auditors 12,500 30.27
Maids and Housekeeping Cleaners 11,400 9.25
First -Line Supervisors of Office and Administrative
Support Workers 11,350 24.98
Total all occupations (not all included above) 1,023,360 $15.11
Source: Agency for Workforce Innovation, Florida Occupational Employment & Wages Miami, Miami Beach, Kendall MSA
(www floridajobs.org)
LEGAL STATUS EVALUATION
CURRENT FAIR HOUSING LEGAL STATUS EVALUATION
The Department 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
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 62
City of Miami
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 HOPWA administrators to document and collect information on the
transgender population amongst the HOPWA clients we serve This data is important to the
City, especially in relation to its operation of the Housing Opportunities for Persons with AIDS
Program (HOPWA), as the City serves as the HOPWA administrator for all of Miami -Dade
County and receives approximately $11 million dollars in HOPWA funding each year to assist
approximately 1000 low-income persons living with AIDS with Long -Term Rental Assistance
(LTRA).
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 AI,
specifically with the execution of a testing component. During the preparation of this AI, 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 AI, 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.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 63
City of Miami
FAIR HOUSING COMPLAINTS
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
attributing to persons in one of our City zip codes, might in fact fall within a neighboring
community. Nonetheless, analyzing HOPE Inc.'s data allows the City's DCED to better
understand any trends or concentrations of discrimination allegations/complaints within 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 from the same zip codes —these are 33125, 33138, 33142, and 33147. With
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 darker blue sections
again illustrate the zips with the highest reported number of complaints (based on three-year
average).
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 64
City of Miami
City of Miami
Fair Housing Complaints 3 year average (2012-2014) by Zip Code
33134
Legend
— 3-10
E 11-20
▪ 21-30
- 31 -100
When looking at the category of inquiries on any given year, the overwhelming 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 laws. 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 as "Disability," followed by "Race."
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 65
City of Miami
Table 38: HOPE, Inc. Intake Reports — for City Zip Codes
City Zip Code
33125
33126
33127
33128
33129
33130
33131
33132
33133
33134
33135
33136
33137
33138
33139
33142
33144
33145
33146
33147
33149
33150
Total cases in
City zips
Total cases in 263
County zips
*The most recent fiscal year reported is incomplete, as 5 months remain.
4/1/2014- 4/1/2013- 4/1/2012-
10/31/2014* 3/31/2014 3/31/2013
13 16 11
2 4 3
Total per zip
code
40
9
11 3 13 27
4 3 7
2 1 1 4
4 7 7 18
1 1
1 2 3
3 3 3 9
7 3 10
2 6 8
9 6 13 28
2 3 3 8
12 15 6 33 ,
1 5 5 11
17 22 17 56 ,
3 2 5
1 2 3
2 2
9 18 11 38 A
0
8 11 4 23
451
283
Table 39: HOPE, Inc.
Basis of Discrimination for City zip code
Based on intake reports
Disability
Familial Status
National Origin
Other
Race
Sexual Orientation
Blank
Rental
Total
4/1/2014- 4/1/2013- 4/1/2012-
10/31/2014* 3/31/2014 3/31/2013
9 14 17
1 2 0
1 0 1
80 106 93
3 7 3
0 0 2
0 3 0
0 0 1
94 132 117
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 66
City of Miami
NATIONAL TRENDS
According to the National Fair Housing Alliance's (NFHA) 2014 Fair Housing Trends report,
"Expanding Opportunity: Systematic Approaches to Fair Housing," fair housing complaints
(amounting to 27,352 filed in 2013, nationwide) have remained relatively 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 information outlining the actions taken since the last Al to
address the fair housing complaints identified in the City of Miami.
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 20 for a complete listing of workshops. Specialized workshops
for housing providers, including Community & Economic Development Block Grants
(CDBG)/Home Investment Partnerships Program (HOME) funded Community & Economic
Development Corporations (CDCs), and Community & Economic Development Housing
Organizations (CHDOs), 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 city's 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 (1680 AM). Fair Housing materials
were distributed at city related events as well as included in the Department's quarterly
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 67
City of Miami
newsletter and posted on the city's Community & Economic Development website. In
addition, the City has issued proclamations for the last two years (2014, 2013) during National
Fair Housing Month (April) further reinforce its commitment to upholding the Fair Housing
Act and affirmatively furthering fair housing.
It should be noted that fair housing marketing materials (in English and Spanish) are available
at all of the city's NET offices, which are located in all five city commission districts and
accessible to city residents.
Table 40: Fair Housing Education and Outreach Activities,
Date
Description
Address
# Attendees
February 19/20, 2013
Staff training on Affirmatively
Furthering Fair Housing
Training offered by the
National Community
Reinvestment Coalition
60 South Ivanhoe Blvd.
Orlando, FL 32804
2 City
employees
September 4, 2013
Training for HOPWA agencies
including fair housing review
and working with the
transgender community
Lummus Park
404 NW 3 Street
40
January 24, 2014
HOPE FHC: Fair Housing &/or
Predatory Lending Sessions
(Creole)
Haitian American CDC
(Little Haiti)
Varies
February 11, 2014
HOPE FHC: Housing Provide
Presentation
South Florida
Community
Development Coalition
Varies
March 8, 2014
HOPE FHC: Community Fair
Participation
ConnectFamilias Fair:
Miami -Dade College
Interamerican Campus
Varies
March 11, 2014
HOPE FHC: Fair Housing &/or
Predatory Lending Sessions
Chapman Partnership
families meeting
Varies
March 20, 2014
HOPE FHC, Fair Housing &/or
Predatory Lending Sessions
Accion Community
Service Center
Varies
March 22, 2014
HOPE FHC, Fair Housing &/or
Predatory Lending Sessions
Neighborhood Housing
Services
Varies
April 1, 2014
HOPE FHC: Fair Housing &/or
Predatory Lending Sessions
(Community Meeting)
ConnectFamilias (Little
Havana)
Varies
April 2, 2014
HOPE FHC, Fair Housing &/or
Predatory Lending Sessions
Miami Workers Center
Varies
April 9, 2014
HOPE FHC: Housing Provider
Presentation
Miami -Dade County
Homeless Trust
Varies
May 5, 2014
HOPE: Housing Provider
Presentation
Miami Rescue Mission
Varies
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
68
May 20, 2014
HOPE FHC, Fair Housing &/or
Predatory Lending Sessions
Wynwood Community
Advisory Committee
Varies
May 21, 2014
Letter to all 100+ Section 8
HCV landlords including fair
housing brochure and
reminder
Multiple
N/A
May 23, 2014
HOPE FHC, Fair Housing &/or
Predatory Lending Sessions
(Creole)
Haitian American CDC
Varies
May 30, 2014
Periodic mailings to funded
developers reminding them of
alerting HUD (90 days prior)
to initiation of rental marketing
activities.
Multiple developers
@ 5-7
June 6, 2014
HOPE FHC: Community,
Cultural, Health & Job Fairs
Folk Life Friday
(Overtown)
Varies
July 18, 2014
HOPE FHC: Community Fair
Hosanna Community
Baptist Church
(Resource Fair)
Varies
July 19, 2014
HOPE FHC: Fair Housing &/or
Predatory Lending Sessions
Nieighborhood Housing
Services
Varies
July 24, 2014
HOPE FHC: Community Fair
Association of Agencies
at Miami -Dade College
Wolfson Campus/Miami-
Dade County
Commission on
Disabilitiy Issues (ADA
25th anniversary
celebration)
Varies
July 25, 2014
HOPE FHC: Community Fair
Miami Rescue Mission
Varies
July 29, 2014
HOPE FHC: Fair Housing &/or
Predatory Lending Sessions
Hadley Park
Homeowners
Association (Liberty City)
Varies
August 2, 2014
HOPE FHC: Community Fair
54t" Street Medical Plaza
Community Fair
Varies
August 6, 2014
HOPE FHC: Community Fair
Fanm Ayisyen nan
Miyami (FANM)
Community Fair— Little
Havana
Varies
August 7, 2014
HOPE FHC: Housing Provider
Presentation
Haitian American CDC
Varies
September 24, 2014
HOPE FHC: Community Fair
Dade County Bar
Association Young
Lawyers Division
(Hadley Park, Liberty
City)
Varies
September 27, 2014
HOPE FHC: Community Fair
CNC Community Fair,
Marlins Park (Little
Havana)
Varies
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
69
September 19, 2014
HOPE FHC: Community fair
Miami -Dade College
Wolfson Campus
(Downtown Miami)
Varies
October 25, 2014
HOPE FHC: Fair Housing &
Predatory Lending
Presentation (Creole)
Haitian American CDC
Varies
November 8, 2014
HOPE FHC: Community,
Culture, Health and/or Job
Fair
ConnectFamilias at
Miami Dade Colllege
Interamerican Campus
Varies
November 12, 2014
HOPE FHC: Fair Housing &
Predatory Lending
Presentation
Liberty City Community
Revitalization Trust
Varies
November 22, 2014
HOPE FHC: Fair Housing &
Predatory Lending
Presentation
NHS at Coconut Grove
Collaborative
Development Corp.
Varies
November 24, 2014
Public Forum for Interested
Miami Realtors addressing
housing impediments of
concern in the real estate
market
Miami City Hall,
Commission Chambers
15
December 19, 2014
HOPE FHC: Community,
Culture, Health and/or Job
Fair (Holiday)
Jessie Trice Community
Health Center
Varies
January 26, 2015 thru
March 26, 2015
Survey for the public on fair
housing matters issued to
over 1,000 stakeholders and
posted on Department web
site for 45 days
Via e-mail mailing
57
April 25, 2015
Assistant Director of Policy
attended HOPE, Inc.'s Fair
housing luncheon and
presented City Proclamation
declaring April 2015, Fair
Housing Month in the City of
Miami.
Jungle Island, City of
Miami, FL
100+
May 14, 2015
Meeting with City Manager's
staff and Economic Specialist
concerning the draft of the Al
DCED offices, City of
Miami
4
May 21, 2015
Meeting with Spanish
speakers from the Little
Havana area and The
Workers Center to discuss the
draft Al's impediments in
Spanish
Iglesia del Espiritu
Santo, 150 SW 13th
Ave, Miami, FL
May 28, 2015
DCED meeting with HOPE,
Inc. concerning the Al draft
DCED offices, City of
Miami
Source: Any event descriptions labeled HOPE, Inc. above are based on In
Inc.
orm
ion provided by HOPE,
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
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 70
City of Miami
■ The Miami Herald
■ Homes By -Owner
■ The New Times
■ Harmon Homes
■ Casas Harmon South Florida
■ Coldwell Banker Real Estate Buyer's Guide
■ Greater Miami Apartment Guide
■ The Flyer
■ For Rent Magazine
■ South Florida Senior Outlook
■ El Flyer
■ New Times
■ El Clarin
■ Apartment Magazine and Street
■ Para Rentar
DISCRIMINATION SUITS FILED
HOPE, Inc. also conducts independent testing of advertised rental or sales properties to
determine whether landlords, realtors or sellers comply with their responsibilities under the
Fair Housing Act. Upon consulting with HOPE, three fair housing cases could be identified
that have been litigated in the City of Miami since the last Al. Below is a brief description of
these:
1. Wells Fargo— In early2012, 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 America for failing to maintain its REO properties in minority neighborhoods
. Evidence showed homes in predominately white neighborhoods received far more
regular maintenance and efforts to sell than vacant homes in minority communities.
More than 2400 REO properties in thirty 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 Color."
2. Design Place in November 2012 and again in December 2014, 5175 NE 2 Ct. — HOPE,
Inc. sued SPV Realty (property owner) of a 500 unit apartment complex, alleging that
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 African -American renters were quoted higher rental rates
than their Anglo counterparts. A settlement was reached. A second lawsuit against
the same property was filed in December 2014 after recent testing found that the
same discriminatory practices were still in place. HOPE is seeking financial damages
for both the wrongdoing and because the site is a repeat offender.
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 71
City of Miami
3. Elite River View Apartments May 2014 — — HOPE, Inc. sued Elite River View
Apartments for race -based discrimination at this apartment complex located at 1750
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 African -Americans.
The rental complex settled the case out of court in November 2014.
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 Dimitrouleas of United States District Court for the
Southern District of Florida had dismissed two of the lawsuits.
5. In April 2015, HOPE, Inc. filed a lawsuit against two South Florida apartment buildings,
one which is located in the City of Miami neighborhood of Allapattah (1434 NW 19
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.16
CURRENT PROGRAMS
A BRIEF SUMMARY OF CURRENT PROGRAMS AND ACTIVITES TO
AFFIRMATIVELY FUTHER FAIR HOUSING IN THE CITY OF MIAMI
This chapter briefly summarizes the current programs and activities carried out by the City
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 & Economic Development Block Grant Entitlement Program (CDBG): As an
entitlement City, Miami receives an annual CDBG grant on a formula basis. The formula takes
into account total population, overcrowding, and poverty. CDBG funds must be used for
16 The Miami Times, "Blacks turned away from housing — again," Jose Cassola, April 8, 2015.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
72
activities that benefit low- and moderate -income persons. Eligible activities include
affordable housing, public service, and economic development activities.
The City (via the DCED) allocates most of its CDBG grant funding on a competitive basis,
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 to address any questions related to the RFP. All RFPs submitted
are reviewed and scored and the DCED makes funding recommendations to the City of Miami
Commission.
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 CDBG RFP competitive cycle (for FY 14-15), approximately 30 non -profits were
awarded CDBG funds.
Home Investment Partnerships Program (HOME): The purpose of the HOME Program is to
increase the supply of safe, decent, sanitary, and affordable housing for low and very -low-
income households. HOME also seeks to expand the capacity of nonprofit housing providers
through CHDOs. Jurisdictions can use HOME funds to carry out a wide variety of housing
activities for low- and very low-income families, including:
• Homebuyer programs, which may include down payment and closing costs
assistance, construction loans, rehabilitation, or new construction or soft
cost pre -development.
• Rental housing programs, consisting of construction loans, permanent
mortgage loans, bridge loans, or loan guarantees for acquisition,
rehabilitation, new construction, and refinancing.
• 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
on funding availability and recommends RFPs 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 in January 2014. In said RFP, an
additional 20 points (out of a total 100 points) were awarded to any projects that were to be
developed in District 2 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— 2015-2020 Analysis of Impediments to Fair Housing Choice 73
City of Miami
have historically seen the least amount of affordable housing development. The City believes
in furthering fair housing choice whenever possible and saw this RFP 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 in one of those two districts.
All HOME related contracts require an Affirmative 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 of Miami/DCED.
Each recipient of HOME funds must comply with several requirements including, but not
limited to:
• Describe proposed method of advertising to be used to market to those
least likely to apply
• Display a Fair Housing Poster in any location where the sale/rental of
assisted units (more than 5) takes place
• Ensure that a City of Miami (standard) project site sign is displayed in a
conspicuous position with the HUD -approved Equal Housing Opportunity
logo included during the construction or renovation of the project including
the amount of assistance provided to the site; the City provides all housing
developers with uniform specifications for said sign which is an exhibit to
their loan agreement/contract (exhibit)The developer must submit
notification of intent to begin marketing to the Office of Housing in the HUD
Office servicing the locality in which the proposed housing will be located no
later than 90 days prior to the initiation of rental marketing activities
Emergency Solutions Grant Program (ESG): The ESG program is a formula grant program that
allocates monies to assist persons who are homeless or at -risk of homelessness via a variety
of funding mechanisms including operating/improving emergency homeless shelters. The City
utilizes its ESG allocation to aid in providing important street outreach and referral services
via a City Department known as the Miami Homeless Assistance Program (MHAP), and
funding rapid re -housing or homelessness prevention assistance for very low-income persons
(30% AMI), which is managed by a sub -recipient. The latter recommendation/award is based
on an RFP process. ESG provides a foundation for homeless people to begin moving towards
independent living. The current level of funding is based on the yearly homeless assistance
appropriation, as well as the demand of HUD's other McKinney-Vento Act programs. The City
of Miami does not operate homeless shelters, as this is a function of the County — although
one of the major shelters in the County is located in downtown Miami. The City uses ESG
funds to provide outreach services to the homeless and to fund rapid re -housing and
homelessness prevention activities which are both operated by a sub -recipient who is vetted
via a Request for Proposal process.
Housing Opportunities for Persons with AIDS (HOPWA): The City of Miami serves as the
administrator of the formula grant -funded Housing Opportunities for Persons with AIDS
(HOPWA) program for the entire geographical area of Miami -Dade County. The goal and
intent of the local HOPWA Program is to ensure that a continuum of housing options and
related housing services are available to low income persons with Acquired
Immunodeficiency Syndrome (AIDS) or related diseases to prevent homelessness of such
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 74
City of Miami
individuals and their families. We address this population in further detail elsewhere in this
document.
Neighborhood Stabilization Program (NSP): On July 30, 2008, the Housing and Economic
Recovery Act of 2008 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 or foreclosed 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 of Florida, the City of Miami was awarded approximately
$12.06 million. All activities funded by NSP must benefit low- and moderate -income persons
whose income does not exceed 120% of area 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
(Miami21) 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 Better Bonds: The Miami -Dade County General Obligation Bonds (GOB Program),
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 Miami
boundaries - one in the Southeast Overtown Park West neighborhood, and a second in the
OMNI. Both are independent government agencies established by the City of Miami and
Miami Dade County in the 1980s, pursuant to the Community Redevelopment Act of 1969.
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
CRA funds its programs and projects primarily through Tax Increment Financing, which uses
the increased property tax revenues collected by the City of Miami 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
projects.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 75
City of Miami
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 -downs, matching dollars for federal housing grants and programs, and
homeownership counseling. After a freeze on SHIP allocations for several years related to the
national and state economic downturn, the City received @ $500,000 in FY2013-2014 and just
over $1 million in 2014-2015. The program is funded by a documentary stamp program made
possible by the State's Sadowski Act.
Miami -Dade County Documentary Stamp Surtax Program: Under Section 201.02 and
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 incomes of up to 140% AMI. 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
County.
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 (HAC) 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&B funds are awarded via a Request for Proposal
(RFP) process. Approximately $18.4 million was collected in 2014, through October.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 76
City of Miami
ACTIVITIES
The City of Miami stated in its FY 2015-2016 Action Plan that the current activities would focus
on implementing policies that advance housing preservation and neighborhood revitalization,
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 on the following activities:
■ Affordable housing preservation through single-family rehab and residential code
compliance assistance, supportive fair housing activities, downpayment assistance,
and funding affordable housing developments.
■ Neighborhood revitalization through supporting economic development activities in
the Commercial Business Corridors (CBCs) and concentrating 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 rental assistance, namely low-, very -low-, and low
to moderate income residents. Below is a description of the activities.
Multi -Family Rental New Construction: To increase the inventory of affordable rental
housing in the Model Blocks and the NDZs, the City of Miami encourages the construction of
new rental units by partnering with non-profit and for -profit housing developers. The City
provides construction loans, permanent mortgage loans, bridge loans, or loan guarantees for
acquisition, rehabilitation, new construction, and refinancing.
Multi -Family Rental Rehabilitation: To preserve the affordable rental housing inventory, the
City of Miami provides multi -family rental rehabilitation loans and/or grants for the
preservation of affordable rental housing available to extremely low-, very low-, and low to
moderate -income residents.
Housing Choice Voucher Assistance: The City of Miami provides rental subsidies to 136 low -
and very -low, and moderate -income households through the Section 8 Program. Participants
in the HCV program are free to choose any qualified housing in the 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 — 2015-2020 Analysis of Impediments to Fair Housing Choice 77
City of Miami
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 8 Moderate Rehabilitation Program (Rental Assistance): The city's 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 City's five districts. The bulk of the
units in this program are one -bedrooms (227), 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 2003. At that time, data on applicant's race, sex, ethnicity, was not logged so we cannot
address the characteristics of that waitlist at this time.
PRESERVE EXISTING AFFORDABLE HOUSING - HOMEOWNER
RETENTION 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 Program and Code Enforcement Assistance: The City of Miami
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 its 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 to 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
on any given year.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 78
City of Miami
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 to afford 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 of New Homeownership Units: The City of Miami promotes affordable
homeownership opportunities for low and moderate income families by financing new
construction. The City also provides hard and soft construction financing and permanent
financing for affordable housing units.
Provide Homeownership Financing: To assist homebuyers in the purchase of a home, the City
of Miami provides down payment, closing cost, and/or second mortgage financing assistance
to eligible persons and households who are first time homebuyers. Although this assistance
is available to anyone who wants to purchase a home in the City of Miami, City residents have
access to the maximum allowable subsidy.
STIMULATE HOUSING DEVELOPMENT — OTHER NON -HUD ACTIVITIES
In addition to the activities listed above, it has been important for the City of Miami to provide
incentives to stimulate housing development. Such incentives help to off -set the barriers that
make it difficult to undertake affordable housing projects. The following is a list of the
incentives that the City of Miami provides in order to facilitate the development of affordable
housing.
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 Permitting for Affordable Housing Projects.
■ Review of Legislation, Policies and Plans that Impact Affordable Housing.
■ Impact Fee Waiver/Deferral.
■ Reduction of Parking and Setback Requirements - Miami 21 allows for parking
reduction for Low -Income Housing by process of exemption -- only up to fifty
percent (50%) of the spaces generally required.
■ Lien Removals for Affordable Housing properties
Training/Workshops for Developers on City Programs and Regulations: The Community &
Economic Development Department seeks opportunities to work with other City 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 on the permitting
process, zoning, and environmental clearances.
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 79
City of Miami
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 CDCs to partner with private developers by
giving developers extra credit points in their RFP applications if they have a 51 percent partner
that is a non-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
with HIV/AIDS, and persons with disabilities who are within the very low to moderate
income range. The activities for special needs populations are described below.
Housing Opportunities for the Elderly: The City continues to seek opportunities to fund
rehabilitation and new construction of residential projects that are Section 202 Supportive
Housing.
Housing Opportunities for People with AIDS: Through the HOPWA Long Term Rental
Assistance (LTRA) program, the City of Miami works to expand housing opportunities for
county residents that are low to moderate income and have been diagnosed with AIDS with
approximately 1,000 clients assisted per year. The City has also operated a Short Term Rental
and Mortgage Utility (STRMU) program for the last 3 years for low- to moderate -income
persons with AIDS —who are not HOPWA LTRA clients — and whom have had some emergency
situation that has set them back in related housing expenses, STRMU assists approximately
100 households a year for a maximum of 21 weeks and helps stabilize their housing so they
are not at risk of losing their place of residence.
Homeless Program: The DCED continues its efforts in the prevention of homelessness by
supporting the City of Miami's Homeless Program and its street outreach programs via
Emergency Solutions Grant (ESG) funding. The City's Homeless Office provides outreach
services in the form of referrals for a myriad of social services, including behavioral, mental,
health, and supportive housing. The City also funds a sub -recipient to provide homelessness
prevention and rapid re -housing assistance to very low-income persons and families who are
homeless and/or at risk of homelessness (with a court ordered eviction notice). Operated
under the programmatic name HAND, the City's funding assists some 110 households a year.
AFFORDABLE HOMEOWNERSHIP OPPORTUNITIES
An FHA mortgage is a loan provided by an FHA approved lender but backed by the Federal
Housing Administration (providing additional security to the lender). 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 3.5% down payment program is highly desirable to people that have the income
to buy a home, but may not have much of a 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 20 percent, rather than the FHA's customary 3.5 percent.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 80
City of Miami
After the real estate collapse, and the tightening of FHA rules, many communities saw a sharp
decline in the number of FHA approved condominium buildings and Miami was no exception.
After conversations with the MIAMI 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 50% 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 party to a pending legal action. Getting FHA approved also
requires extensive documentation — both financial and insurance documents (hazard, floor,
liability, fidelity bond/insurance) and many developers opt to not go through 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 60% of homebuyers use an FHA Loan.
This too can create a "stigma" tied to FHA loans amongst condo owners (associations) who
can opt to avoid the complicated FHA review/approval process altogether. Besides this,
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 condominiums 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
companies.
As already explained, the bulk of Miami's housing stock is comprised of condominium 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
property).
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 3 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 of 3-5
percent are actually quite similar to the default rates on loans with down payments of 5-10
percent.
Upon pulling a list from the HUD website for all FHA approved condominiums in Miami -
Dade County as of January 2015, the table below indicates that only FIVE locations are
eligible in the City. We also note the average price points of those locations for reference.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 81
City of Miami
Table 41: FHA Approved Multi family
buildings in the City of Miami
Project Name
Project Address
Description
Start
End Date
Average
Price
point
(1/15)
BRICKELL ON THE
RIVER NORTH
31 S.E. 5TH ST,
MIAMI, FL 33131
404 units- 384 residential units, 20
commercial units, 1 building
4/22/2014
4/22/2016
$374,900
(2/2)
BRICKELL PLACE
PHASE II
1925 BRICKELL
AVENUE, MIAMI, FL
33129
Three Buildings, two towers and
townhomes: Bldg 1-1915 Brickell
Avenue -Tower C(198); Bldg 2-1925
Brickell Avenue -Tower D(257); Bldg 3-
1915 Brickell Avenue-Townhomes(12)
7/23/2013
7/23/2015
$530,000
(2/2)
CORAL WAY
GARDENS
2160 SW 16TH AVE,
MIAMI, FL 33145
Consists of 80 units
10/29/2013
10/29/2015
$132,900
(1 /2/)
COSTA BELLA
CONDOMINIUM
1450 BRICKELL BAY
DR., MIAMI, FL
33131
High -Rise 19 story bldg consisting of
213 units; Missing all condominium
legal documents, mgmt agreement,
FEMA Flood map information and
special assessment information.
8/7/2013
8/7/15
$359,000
(2/2)
KEYSTONE
VILLAS, A
CONDOMINIUM
3590 CORAL WAY,
MIAMI, FL 33145
1 Nine Story Building, 60 residential
units, 1 commercial units.
4/14/2014
4/14/16
$349,000
(2/2)
As listed on www.hud.gov (1/12/2015)
*Providing lowest price on record for a 2/2 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 Miami -
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
of 5%, i.e., 478 of its 9,543 total housing units to comply with section 504, title ii of the ADA,
the uniform federal accessibility standards (UFAS), 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 restrooms), laundry room mail delivery, trash
disposal, meeting rooms, recreation rooms, community center (including restrooms) and day
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 82
City of Miami
care centers (including restrooms).The county shall complete accessibility modifications to its
central office, private rental housing division offices and administrative offices housing its
ADA coordinator. (3) the County must meet all the terms and conditions of the VCA within six
(6) years from the date it is executed. Based on a report dated February 5, 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 FY 2015. Based on PHCD's current schedule, 94
additional units are to be completed in FY 2013; 75 units are to be completed in FY 2014; 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 (CFP) funds.
THE HOME MORTGAGE DISCLOSURE ACT - HMDA
HMDA was enacted by Congress in 1974 and 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 race and income, 2) the type,
purpose, and amount of the loan, 3) the loan application decision, and 4) the census tract of
the property to be financed. The loan data discussed in this section was pulled directly from
the Federal Financial Institutions Examination Council's website www.ffiec.gov.
HUD recommends that HMDA data be included in an Al as an analysis of mortgage
applications and their outcomes 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
distinct from 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 available for our general area encompasses what the FFIEC reports
refer to as the Miami -Miami Beach -Kendall MSA. The data included in this analysis
encompasses data for the last three available years (2012-2014) across this entire MSA. To be
clear, Miami is one of several municipalities within this area and as such, the data noted here
encompasses a geographic area much wider and larger than that of our City alone. A more
careful analysis of loans that would have solely 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 to the primary applicant only.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 83
City of Miami
In order to address HMDA data accurately within our MSA, we would also need to stress the
higher -than -average amount of real estate cash transactions the Miami MSA has experienced
for several years, which would obviously not be reflected in the HMDA data below. For
reasons already stated, Miami sees a large amount of foreign capital and many investors from
outside the U.S. have elected to purchase property here, either for rental purposes or for
second/third home purposes. These cash sales are difficult to track by a municipality (and our
Department) and so we must rely on industry reports for some type of general data to better
understand their role in our marketplace.
Because South Florida had one of the largest foreclosure rates in the nation, there was a large
supply of bank 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 low 60% levels. According to a recent release by CoreLogic as recently as October 2014,
"of the nation's largest 100 Core Based Statistical Areas (CBSAs) measured by population,
Miami -Miami Beach -Kendall, Fla. had the highest share of cash sales at 56.6 percent."17
In the tables that follow, we look at conventional loans followed by FHA loans between 2011
and 2013. In comparing at Tables 42, 43, and 44, we first make some general observations.
To begin, the largest number of loan applications received for our MSA in the conventional
loan category was in the Refinancing category, with approximately 106,910 received in
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
a three-year average of 67% denials.
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 in 2013 up to approximately 59%. The percent denied has also remained pretty steady,
oscillating somewhere in, or around 24%.
CONVENTIONAL LOAN THREE-YEAR BREAKDOWN
Table 42: Results
of Conventional (Home Purchase)
Loans
in Miami
-Dade
Reporting Year: 2013
Race /Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
30
17
56.7%
2
9
30.0%
2
0
Asian
383
212
55.4%
16
99
25.8%
43
13
1- "Cash Sales Continue to Decline in US, Miami Still Top Market," World Property Journal, Michael Gerrity.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
84
Black or African
American
612
338
55.2%
24
169
27.6%
56
25
White
13872
8192
59.1%
836
2880
20.8%
1519
445
Other
169
94
55.6%
9
37
21.9%
22
7
Unknown
2243
1310
58.4%
142
456
20.3%
239
96
Total by Race
17309
10163
59.3%
1029
3650
24.4%
1881
586
Hispanic*
9427
5591
59.3%
563
2005
21.3%
977
291
Reporting Year: 2012
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
23
8
34.8%
3
9
39.1%
1
2
Asian
291
163
56.0%
18
66
22.7%
33
11
Black or African
American
509
251
49.3%
39
143
28.1%
55
21
White
10507
6242
59.4%
776
2135
20.3%
1047
307
Other
116
62
53.4%
10
32
27.6%
9
3
Unknown
1829
1050
57.4%
125
356
19.5%
232
66
Total by Race
13275
7776
51.7%
971
2741
26.2%
1377
410
Hispanic*
7006
4157
59.3%
479
1473
21.0%
690
207
Reporting Year: 2011
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
22
14
63.6%
1
5
22.7%
2
Asian
265
131
49.4%
18
66
24.9%
36
14
Black or African
American
524
246
46.9%
53
158
30.2%
50
17
White
9315
5151
55.3%
718
2099
22.5%
1027
320
Other
96
46
47.9%
11
22
22.9%
13
4
Unknown
1677
957
57.1%
114
327
19.5%
187
92
Total by Race
11899
6545
53.4%
915
2677
23.8%
1315
447
Hispanic*
6146
3388
55.1%
431
1479
24.1%
649
199
Source: FFIEC;
*Hispanic ethnicity is counted independent of race.
HOME REFINANCE LOANS
There has also been a steady increase in the amount of applications submitted for home
refinance loans (Table 43) from 2011 to 2013. Even though the amount of applications in
2013 was more than double the amount submitted in 2011, the percent issued in 2013 was
just slightly above (46%) that of 2011's percentage (42%). The popularity of home 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.
DRAFT- 2015-2020 Analysis of Impediments to Fair Housing Choice 85
City of Miami
Table 43: Results of Home Refinance Loans
in Miami -Dade
Reporting Year: 2013
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
119
45
37.8%
12
38
31.9%
15
9
Asian
815
429
52.6%
79
195
23.9%
59
53
Black or African
American
3123
1367
43.8%
238
986
31.6%
312
220
White
32327
16781
51.9%
2558
8211
25.4%
2886
1891
Other**
522
261
50.0%
45
118
22.6%
58
40
Unknown(Race
not available)
7387
3118
42.2%
509
2108
28.5%
949
703
Total by Race
44293
22001
46.4%
3441
11656
27.3%
4279
2916
Hispanic*
22917
11700
51.1%
1887
6059
26.4%
1954
1317
Reporting Year: 2012
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
75
40
53.3%
5
19
25.3%
8
3
Asian
775
425
54.8%
41
185
23.9%
75
49
Black or African
American
2567
1256
48.9%
164
768
29.9%
245
134
White
30441
16850
55.4%
1857
7428
24.4%
2779
1527
Other**
468
222
47.4%
32
138
29.5%
42
34
Unknown(Race
not available)
6309
2971
47.1%
406
1705
27.0%
743
484
Total by Race
40635
21764
51.2%
2505
10243
26.7%
3892
2231
Hispanic*
20299
11166
55.0%
1240
5181
25.5%
1673
1039
Reporting Year: 2011
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
53
19
35.8%
2
23
43.4%
6
3
Asian
402
169
42.0%
33
132
32.8%
41
27
Black or African
American
1281
469
36.6%
83
493
38.5%
160
76
White
16230
7863
48.4%
1093
4696
28.9%
1749
829
Other**
261
127
48.7%
15
88
33.7%
20
11
Unknown(Race
not available)
3755
1471
39.2%
220
1139
30.3%
500
425
Total by Race
21982
10118
41.8%
1446
6571
34.6%
2476
1371
Hispanic*
10182
4825
47.4%
658
3101
30.5%
1033
565
Source: FFIEC
*Hispanic ethnicity is counted independent of race.
DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
86
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
what they are worth. According to CoreLogic, negative equity continues to be an issue for
nearly a third of Miami -Dade homeowners.18 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 Miami -Dade
Reporting Year: 2013
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
33
8
24.2%
5
18
54.5%
2
0
Asian
63
16
25.4%
4
41
65.1%
2
0
Black or African
American
563
83
14.7%
12
449
79.8%
13
6
White
2484
681
27.4%
176
1460
58.8%
119
48
Other**
47
12
25.5%
1
33
70.2%
1
0
Unknown(Race
not available)
458
132
28.8%
42
247
53.9%
31
6
Total
3648
932
24.3%
240
2248
63.7%
168
60
Hispanic*
2030
486
23.9%
134
1308
64.4%
74
28
Reporting Year: 2012
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
40
6
15.0%
1
33
82.5%
0
0
Asian
37
9
24.3%
2
23
62.2%
3
0
Black or African
American
491
63
12.8%
9
402
81.9%
15
2
White
2001
551
27.5%
109
1240
62.0%
82
19
Other**
43
4
9.3%
2
35
81.4%
2
0
Unknown(Race
not available)
552
114
20.7%
53
359
65.0%
21
5
Total
3164
747
18.3%
176
2092
72.5%
123
26
Hispanic*
1667
376
22.6%
76
1153
69.2%
49
13
18The 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
87
Reporting Year: 2011
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
32
7
21.9%
1
23
71.9%
0
1
Asian
18
3
16.7%
1
13
72.2%
1
0
Black or African
American
302
53
17.5%
8
234
77.5%
6
1
White
1315
344
26.2%
63
828
63.0%
53
27
Other**
33
13
39.4%
4
13
39.4%
2
1
Unknown(Race
not available)
247
49
19.8%
11
156
63.2%
23
8
Total
1947
469
23.6%
88
1267
64.5%
85
38
Hispanic*
1130
258
22.8%
46
771
68.2%
38
17
Source: FFIEC
*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 MSA from 2011
to 2013, data differs. First, the amount of applications has steadily declined with only 7,002
applications submitted in 2013. In this same year, the number of applications 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 of 23.2% or so. Approval rates
during those years have also remained fairly steady - in the mid-50% range.
Table 45 : Results of FHA, FSA/RHS,
and VA
Home Purchase Loans
in Miami -Dade
Reporting Year: 2013
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
10
7
70.0%
1
2
20.0%
0
0
Asian
48
32
66.7%
3
6
12.5%
2
5
Black or African
American
878
446
50.8%
41
245
27.9%
118
28
White
5650
3508
62.1%
275
1084
19.2%
628
155
Other**
70
35
50.0%
6
19
27.1%
8
2
Unknown (Race
not available)
346
147
42.5%
20
113
32.7%
50
16
Total
7002
4175
57.0%
346
1469
23.2%
806
206
Hispanic*
4975
3051
61.3%
236
989
19.9%
563
136
Reporting Year: 2012
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
8
4
50.0%
0
1
12.5%
3
0
DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
88
Asian
72
45
62.5%
7
14
19.4%
5
1
Black or African
American
976
511
52.4%
55
246
25.2%
135
29
White
6199
3912
63.1%
262
1193
19.2%
664
168
Other**
73
44
60.3%
2
18
24.7%
7
2
Unknown(Race
not available)
438
167
38.1%
33
118
26.9%
100
20
Total
7766
4683
54.4%
359
1590
21.3%
914
220
Hispanic
5517
3447
62.5%
233
1061
19.2%
623
153
Reporting Year: 2011
Race / Ethnicity
Total
Applications
Number
Issued
Percent
Issued
Approved
Not
Accepted
Number
Denied
Percent
Denied
With-
drawn
Closed
Incomplete
American Indian
or Alaskan
23
15
65.2%
5
2
8.7%
1
0
Asian
75
39
52.0%
7
23
30.7%
3
3
Black or African
American
1155
556
48.1%
72
313
27.1%
180
34
White
6636
3863
58.2%
433
1445
21.8%
752
143
Other**
84
38
45.2%
8
26
31.0%
9
3
Unknown(Race
not available)
563
255
45.3%
29
149
26.5%
111
19
Total
8536
4766
52.3%
554
1958
24.3%
1056
202
Hispanic*
5779
3328
57.6%
382
1277
22.1%
657
135
Source: FFIEC
*Hispanic ethnicity is counted independent of race.
**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 HOME/CDBG-assisted housing units. Furthermore, the City's policies are consistent
with Davis -Bacon and Section 3 protocols.
Affirmative marketing consists of providing information and attracting eligible persons in the
housing market area to available housing without regard to race, color, national original,
sex, religion, familial status or disability. 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 Program's affirmative
marketing policy may include, but are not limited to, using the Equal Opportunity
logo OR slogan in relevant printed materials, project signage, posting this
DRAFT - 2015-2020 Analysis of Impediments to Fair Housing Choice 89
City of Miami
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 and/or Community Outreach:
In order to meet the obligations towards the City's/DCED's affirmative marketing
policy requirements as required by 24CFR92.351, each property owner/developer
who receives federal funding from the City/DCED must submit a completed and
signed AFHMP Plan (HUD 935.2A/2B), as an exhibit to their executed contract with
the DCED, 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 of any possible printed material (brochures, leaflets, etc.) This final AFHMP plan
must also be submitted by the developer/owner with the local Fair Housing & Equal
Opportunity Office and serves to satisfy the requirements of 24 CFR 200.620 which
indicates that all FHA subsidized or unsubsidized 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 a manner calculated to inform
eligible persons who may otherwise be least likely to apply for the unit.
3. Recordkeeping:
The City of Miami requires recipients to maintain records that describe efforts taken
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 demographics or local housing
market area).
4. Limited English 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/developers 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 unit will assess the 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 — 2015-2020 Analysis of Impediments to Fair Housing Choice 90
City of Miami
IMPEDIMENTS
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 of Miami combined with
stagnant wages.
A high percentage of City of Miami residents both homeowners and
renters are paying more than 30 percent of their income for housing,
defining them as cost burdened. This increased housing burden must be
addressed on a City-wide level to prevent further loss of homeownership,
increases in foreclosures, evictions, bankruptcies, and potential
homelessness.
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 extremely low, very low, and low -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 at 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 fund the Single -Family Rehabilitation and Replacement programs to aid in preservation of
homeownership, as well as the first-time 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.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 91
City of Miami
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 2014, 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 FHA loan cannot purchase a unit (primary residence) in the
majority of Miami's multi family buildings, even when approximately 36% of the City's
entire housing stock is comprised of units in multi family buildings.
Recommendations:
- The DCED will 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.
- The DCED will 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.
PUBLIC SECTOR
Impediment FH3: Scarcity of Developable Vacant Parcels Diminishing the
new construction of single-family and/or smaller apartment developments
thereby housing choice.
There is a land shortage in the City of developable, residentially zoned vacant
tracts and many of the available vacant parcels are scattered and situated in
the City's most economically distressed neighborhoods, requiring development
on an in fill basis. A property is determined to be developable for a single
family dwelling if it meets the minimum lot criteria of 5,000 square feet, plus
a minimum of 2 parking spaces per home are required. In addition, the city
needs to consider how the application of zoning regulations and parking
requirements can be "tweaked" to encourage the development of single-family
homes and smaller -scale buildings (20 units or less) on these smaller parcels.
Recommendation
- The DCED will 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.
- 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,
thereby 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.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 92
City of Miami
- DCED will continue to prepare request for lien removals for eligible affordable
housing properties
Impediment FH4:
There is a lack of adequate federal funding for rental assistance programs.
Federal funding vehicles for low-income housing creation/preservation continue
to be cut. Demand for Section 8 vouchers in all Miami -Dade communities,
along with demand for public housing units, is startling. Unfortunately, for
those who are not randomly selected for waitlists, there is no funding available
to be able to assist them in meeting their monthly rental obligations. In addition,
the latest HIV/AIDS Housing Needs Assessment conducted in 2014 estimated
that there are approximately 10,000 individuals living with HIV/AIDS in
Miami -Dade County in need of housing assistance.
Recommendations
- The DCED will continue to accommodate as many HOPWA clients as fiscally possible
in the City's Long -Term Rental Assistance (LTRA) Program.
- The DCED will continue to fund the HOPWA Short Term Rental Mortgage & Utility
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 DCED will continue to fund private developers to build 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.
The number of affordable housing units in a project is based on the amount of
subsidy provided by the City.
Impediment FHS:
There is a lack of adequate federal funding for the preparation of a
comprehensive Analysis of Impediments.
Presently, any monies spent on testing, studies, and/or potential
consultant work related to an AI must come from the CDBG Program's
Administration allowance. The latter is already stretched thin due to the
overall CDBG funding cuts the City has suffered in the past five years.
Consequently, less money is available to contract sub -recipients to conduct
important research and testing related to the rental and/or sale of housing
in the Miami market, in order to identify any disparities.
Recommendation
- 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
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice 93
City of Miami
jurisdictions could be utilized for testing and more specific studies, which tend to
be costly.
PUBLIC AND PRIVATE SECTOR
AFFORDABLE ORKFO CE HOUSING
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 for
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 larger 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.
F R HOUSING RCENIENT
Impediment FH7:
Housing Discrimination on the Basis of Race, Color, National Origin,
Religion, Sex, Familial Status, and Disability continues to take place.
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City of Miami
According to HOPE, Inc. there were 343 fair housing inquiries/complaints over
a 31 month -period that originated in zip codes within (or partially within) the
City of Miami'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
- Commence (DCED) to track race and ethnicity of holders of Section 8 vouchers 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 (PSAs), web site) are available in in the City's official
languages (including Spanish and Creole); 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 to include fair housing information during the Section 8 and HOPWA
intake process and at the time of annual recertification.
- Continue to make fair housing collateral available in a variety of location (i.e.
Neighborhood Enhancement Team (NET) offices, public places such as libraries,
and/or social agencies such as the welfare office).
- Conduct an annual public informational campaign during the Fair Housing Month
each April.
Impediment FH8:
Absentee Landlords in Low -Income Neighborhoods Disregard Code
Violations and Fines, Leaving Tenants in Buildings/Units with Poor Living
Conditions.
Several absentee landlords (especially in low-income neighborhoods in the City) do not
pay and/or ignore multiple code and building fines related to their privately owned rental
buildings. Tenants claim that complaints to landlords about living conditions lead to
targeted evictions.
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- 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 including solid waste and code enforcement issues and it is pursuing
action against them
- The City should research how other communities attempt to correct said issues with
an aim to pass necessary legislation to ban said landlords with possible measures
including permit denial for habitual offenders, asset attachment to allow a
municipality to garnish property owner's wages if building is deemed a danger, and
potential threat of property seizure.
OTHER FINDINGS
The barriers listed below are beyond the scope of this plan, but were deemed important
enough to mention as comments.
State/local building codes increase the cost of affordable housing 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
public. Unfortunately, the more stringent building codes, especially in relation to hurricane -
proofing, increase the costs of affordable housing production.
The 50 percent rule increases the cost of affordable rehab: Another impediment includes a
regulatory barrier known as the "50-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 of the units. This is particularly a concern with multifamily structures
that do not have funds set aside, except for tax credits, to offset the cost of bringing the
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 on both the owner (developer/general contractor) and city sides, which also
increases housing costs. While the objective of the prevailing wage requirements is to protect
workers, developers often complain that the increased cost results in higher housing
construction expenses. A cost analysis would be necessary to determine how much costs are
truly impacted by the Davis -Bacon Prevailing Wage.
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Absentee Landlords - Absentee landlords, especially in several low-income City
neighborhoods, have become a serious issue in Miami, a trend seen in other big cities
nationwide. Many reside out-of-state and take little to no action to correct serious code
violations that lead to poor living conditions. In many situations, the landlords are difficult to
locate and create various shell companies to avoid being fined or held accountable for
damages and repairs on their structures, all while low income tenants continue to live there
and pay rent because they allege they cannot find few - if any - buildings where they can
relocate, paying comparable rental rates. Meanwhile, the City is limited in its role in landlord -
tenant issues which are governed by Florida law (Chapter 83, Part II, Florida Statutes) and
must be resolved in civil court. If however, buildings within City boundaries meet certain
criteria as outlined by Miami's City Code of Ordinances, they can be condemned in accordance
to the law. City administrators are looking closely at this serious issue and attempting to best
address it (please see Impediment # 9).
NIMBYism - As a large, high -density City, the Department generally does not experience
public dissent to funded housing projects and/or NIMBYism (not in my backyard attitudes). In
recent years, one particular development in Liberty City met with some public resistance from
park conservationists given that one of the project's parcels had originally been zoned as a
pocket park and was being re -zoned to become part of the development's build out.
Ultimately, developers — who needed the small parcel to develop a multi -family project —
purchased a nearby lot as a "swap" to preserve a 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 of the City.
Past credit problems - Credit problems lead to a person's/family's inability to secure a bank
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 (DCED) does not fund credit
counseling services at this time.
Past criminal history - Many LIHTC developments in Miami have strict criminal background
policies which prohibit admission for persons who have been charged with a felony — with no
restrictions as to how far back that charge goes. Sadly, this type of policy prevents ex -
offenders — whose incident might have happened years ago -- from accessing publically
funded housing.
Service/supportive 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 is funded by the State of Florida and overseen by the 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 leading the pack in foreclosures amongst the 20 largest
metro areas in the U.S., with foreclosure filings including default notices, scheduled auctions
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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 (Associated Press, January 19,
2015).
Property Insurance — Recent reports indicate that Florida homeowners now pay more than
double the national average for homeowners insurance, with coastal areas — including many
parts of South Florida -- paying the highest rates. Data released by the National Association
of Insurance Commissioners indicates that the most common type of policy 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 $1742. The national average is $1034, which makes
Florida's premiums 102% 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 or to persons looking at purchasing a home.
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
on to renters through rent increases. In 2014, the City of Miami had a millage rate of
7.6435.There were seven other municipalities in Miami -Dade County with higher millage
rates. The millage rates (also called tax rates) and taxes are determined by each of the taxing
authorities such as Miami -Dade County, the School Board, City and Regional authorities. The
Tax Collector -- part of Miami -Dade County's Finance Department -- collects 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 military exemption; the institutional exemption; and 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. 1 each year, these values are
"established by nationally accepted valuation methods, which are sales comparison, cost, and
income valuation approaches. Adjustments are made for size, condition and extra features of
a property."
IMPROVEMENTS SINCE THE LAST AI
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
New Urbanism and Smart Growth — known as Miami 21— was approved by the City of Miami
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.
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Miami 21 did not include any inclusionary zoning regulations, neither voluntary nor
mandatory. Presently, it specifically 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, Article 3, Section 3.14). These
specified programs are as follows: Affordable/workforce housing, Public Parks and Open
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
Affordable/Workforce Housing, Public Parks and Open Space, and Green Building certification
shortfall penalty made under this section of the Zoning Code. 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 by the Commission to
support affordable/workforce housing shall be deposited in the Affordable Housing Trust
Fund for expenditures pursuant to the guidelines adopted by the City Commission. All cash
contributions thus allocated by the Commission to support Parks and Open Space shall be
deposited in the Parks and Open Space Trust Fund. For a cash contribution to the Miami 21
Public Benefit Trust Fund, the development shall be allowed additional Floor Area up to the
bonus Height and FLR described in Section 3.14.1. The cash contribution shall be determined
based on a percentage of the 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 a land value per saleable or rentable square foot within
market area to equate to between 10 (ten) to 15 (fifteen) percent of market 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 of every year.
For purposes 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 any
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
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 /workforce
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. As discussed above.
B. Public parks, open space or park improvements, the development project in a T6 zone
may provide any of the following or combination 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 be allowed two times the development Floor Area of provided land up to the bonus
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Height and FLR as described in Section 3.14.1. The Open Space may be a Park, Green or
Square, as more fully described in Article 4, Table 7 of this Code.
(b) Park improvements shall be valuated and for said value the development project shall
be allowed additional Floor Area up to the bonus Height and FLR described in Section
3.14.1 and shall for all applicable purposes be treated as a Trust Fund contribution
pursuant to Section 3.14.4, b, (3).
(c) Park improvements for Public Parks in area below 50% median income threshold shall
be allowed two times the valuation credit.
d) Donations must meet all City requirements for design, equipment specifications,
construction, warranties, etc. Park improvements are subject to review and approval by
the City Manager or designee in accordance with Miami 21.
2. Public Open Space provided on -site in a location and of a design to be approved by the
Planning Director. For each square foot of dedicated public Park or Open Space provided,
the development shall be allowed an equivalent amount of development Floor Area up to
the bonus Height and FLR as described in Section 3.14.1.
3. Trust fund contribution. As discussed above.
C. Historic Preservation. Bonus Floor Area to the maximum bonus Height and FLR as
described in Section 3.14.1 shall be allowed for additional square footage qualified under the
city Transfer of Development Rights program established in Chapter 23, City Code.
D. Green Building. In a T6 zone, additional Height and FLR shall be allowed for Buildings
certified by the U.S. Green Building Council as Silver, Gold or Platinum.
E. Brownfields. One additional Story of Height shall be permitted for redevelopment on a
Brownfield Site as defined in the 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, it should be noted that the Public Benefits Trust Fund is
presently at its 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 facilitating/incentivizing overall
housing development — and furthering housing choice — in the City include the following:
• In May 2011, 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 of facility development costs and
rents, and are typically passed on to the resident.
• In Feb. 2014, the 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 removed from the
major employment centers of the urban core of the City and the City Commission was
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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 as 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 set forth 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
bonus. City administrators hope this will encourage the development of much -
needed workforce 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 a 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,
or to make cash contributions to the Miami 21 Public Benefits Trust.
• The City of Miami Planning Department has been actively engaged in the
development of a new zoning overlay, called a Neighborhood Revitalization District
(NRD-1). The stated intent of this overlay district is to transition an industrial district
into a mixed use, walkable neighborhood. A key component of the NRD-1 is a reduced
parking requirement for residential units under 650 square feet, dropping from 1.5
per unit to 1 per unit, and allowing that one space to be paid into a parking trust fund
in lieu of physically providing the space. This results in substantial cost savings for
developers, and incentivizes small unit construction. These units are anticipated to be
more affordable than the typical residential product currently being offered in the
City of Miami.
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 of housing available to low- and very -low income persons (50%
AMI and below). As mentioned, there are no inclusionary zoning 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 a share of newly developed housing
incorporates — by law — 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.
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Finally, the Planning Department has recently researched and suggested upzoning in
particular parts of the City. Although upzoning could lead to additional housing stock
(density), the DCED 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 at coupling a neighborhood's potential upzoning with a 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.
CONCLUSIONS AND RECOMMENDATIONS
IDENTIFIED ACTIONS AND TIMELINE FOR RECOMMENDATIONS
This chapter provides the City of Miami's strategy to address fair housing from FY2015 to
FY2020. In the first section, the City's fair housing program's strategy to maintain records to
support the AFFH certification will be discussed. Afterwards, a table is provided that identifies
the actions that the City plans to implement to overcome 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) CERTIFICATION
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 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.
■ 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.
■ The City will continue to educate the general public through communication
vehicles available to it on Fair Housing laws and rights, and how/where to report
alleged discrimination.
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■ The City will continue to monitor the developers with which it has contracts
(federal, state assistance) to assure that they are following their signed AFHMP
plans.
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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
City of
#
FH1: Increased Housing (Cost) Burden
Miami combined with stagnant wages.
Recommendation
for 46% of City households due to
Action Steps
the rising costs
Timeline
of housing in the
Measurable Results
FH 1.1
Seek additional funding opportunities for the
creation of additional affordable housing beyond
LIHTC funded projects (i.e., Promise 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 affordable and workforce
housing development by engaging and informing Cit
officials of the 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 fund the Single -Family Rehabilitation
and Replacement programs to aid in preservation of
homeownership, as well as the first-time homebuye
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
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104
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 approval, leaving potential buyers seeking to
purchase a home with an FHA loan with fewer housing options.
Recommendation
Action Steps
Timeline
Measurable Results
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.
Support and join the MIAMI Association of
Realtors' efforts to have more developments
offer FHA units
2015-2020
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
single-family homes and/or smaller apartment
# Recommendation
Vacant Parcels in the City Diminishing the construction
developments thereby limiting housing choice.
Action Steps Timeline
of new,
Measurable Results
FH 3.1
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
city -owned vacant parcels;
2015-2020
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
105
IMPEDIMENT
#
FH4: There is a lack of adequate federal
Recommendation
funding for rental assistance programs.
Action Steps
Timeline
Measurable Results
FH 4.1
DCED will continue to accommodate as many HOPWA
clients as fiscally possible in the City's Long -Term Rental
Assistance (LTRA) Program and to assist HIV+ persons
who are income eligible via the HOPWA funded STRMU
program (based on funding availability)
1) Continue to conduct rent comparables to
ensure that rent paid corresponds to the on-
going market rent.
2) Educate clients about looking for more
affordable rental options.
3) Continue to market the availability of the
STRMU program
2015-2020
All clients must have rent
comparables in file and rents
must be equal or below the
fair market rent for any given
year.
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
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.
The department will continue to issue Request for
Proposals to provide gap financing that will allow
housing projects to include affordable housing
units.
2015-2020
Bringing additional affordable
housing units to the market
IMPEDIMENT FH5: There is a lack of adequate federal funding for the preparation of a comprehensive Analysis of
Impediments.
Recommendation
Action Steps
Timeline
Measurable Results
FH 5.1
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.
Contact Miami -Dade County
Explore opportunities for joint efforts to plan and
draft a comprehensive Analysis of Impediments
2015-2020
Join Analysis of Impediments
to Fair Housing Choice
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
106
IMPEDIMENT
#
FH6: There are not Enough Affordable/Workforce
Recommendation
Housing Units in the City To
Action Steps
Meet The Needs
Timeline
Of City Residents.
Measurable Results
FH 6.1
The City should explore options to create workforce
housing opportunities/incentives/bonuses to encourage
private developers to build housing to serve the
workforce (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
#
FH7: Housing Discrimination On The Basis Of Race,
Recommendation
Color, National Origin, Religion, Sex, Familial
Action Steps
Status, And
Timeline
Disability Continues.
Measurable Results
FH 7.1
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
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
107
IMPEDIMENT FH8: Absentee Landlords in Low -Income Neighborhoods Disregard Code Violations and Fines, Leaving Tenants in Buildings/Units
with Poor Living Conditions.
Recommendation
Action Steps
Timeline
Measurable Results
FH 8.1
Pursue legal action/recourse so that bad landlords are
banned from operating within City limits
- 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.
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 108
City of Miami
Appendix
Attachment 1:
Geographical Information System (GIS) Maps based on U.S. Census analyzing different groups
65 years old and up
Commission Di sIC and Cammesbnsls Mime
Nano guene
POWLA7ICs1$ VEAPL CLOANOAEOVE
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
109
Black Population 2010
CITY OF MIAMI
BLACK POPULATI9N-2010
-BY-CENSUS-BLOCKS WITH COMMISSION DISTRICT OVERLAY
tit
fl[I•111 l ■tdi 1i114h
whir ,� olrl u�IIII�rIrl�iUl(�i11f1iElelE;! &a i°i!
I eF_S IF ![llfi { dl 11.N
� rEi=� ,t
�'
III. Il1II[i! �=
ca.n,nysiw. PIFVk1 and Can rnNam.
umaka
!LAC% POPULATION PERCENTAGE
I♦'
I=� .
Jf.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
110
Hispanic Population 2010
CITY OF MIAMI
HISPANIC POPULATION2010-
8Y C-ENSUS-BLOC-ICS WITH COMMISSION DISTRICT OVERt_
0
MANIC POPULATION PERCENTAGE
eef
1025 0.5 1 Wet
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
111
White, Non -Hispanic Population, 2010
CITY OF MIAM1
NOT HISPANIC WH1T-E-POPULATION 2010
-BY CENSUS -BLOCKS -WITH COMMISSION DISTRICT O ERLAY
Cemm.sefn'Aletee[Mln Ca,Nllleuenen N.m.
CGM7IS11P
0, ••,,,,,,,,,,,wy,C.1
a. KmlY u
clew aleoa..1,-05
Y OT HISPANIC W MIE POPULATION
1,2514.
•
� -,
G a 25 J 5 1 Miles
DRAFT— 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
112
Racial Dot Map — from the Cooper Center
Axle Chiefty
2010 Census Block Data
1 Dot =1 Person
• White
• Black
• Asian
• Hispanic
•
ome�Alname
amFri�n (M�In.aclal
what am R looking at.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 113
City of Miami
.. _.... _..
Attachment 2: Land Use Maps
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 114
City of Miami
2. Single-family housing
City of Miami
Land Use - Single Family Housing
Source: City of Miami, ARC GIS, as of 2015
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 115
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 116
City of Miami
Appendix 3
Fair Housing Proclamations — City of Miami
Flll elog ll
TFIF CITY OF MIAMI, FLORIOA
q�rq i_q�.e4 W e' oa kig46 (atop! l ru l
eyeuGlr
N 676 p s�1 .fir
a -deal sikhn�e pnei.ip�11e# nm�ju�Tioa tav e11�
writ
rf" ,.� ena:l =ae6$•
6.1� Trv+if^i �°�u."'dI .�kkp
t _
s@l; ply n(. �,in }rlimmh, t ! .s4 1.fu .lFwr
i���1I.°Mk� �vlln�fIo"(,G'k�PJ"Jr�� a. si c�.l �i ee-apepµ "r�q�.��,ry4 p
4h pu6, 4 ll 4• bj P V, Y tYkkq {fiat u[v lot:
ii
WLLHHE t# F� J L. I
F 6
Ci
,` 4 Y '
pyr�yatqse aa � etf..y . .W� p�{<4, tntl r" (y�
1� 1 IkaF q! {�u I�naL.¢ I.
y
aie,..7/atisifig
"[.seta n¢ t`a, Con“,.nn,rk.. Rio.L 6y 810.6
HE�itt l�t9EAaFCa FUN-Fewa p upon,
pon, �� market*: of the City of
..ppoc6er "ry,iu ii iee lhu odr6n Finof imy r[aol ar iq
uEy�,e[ :,l goal !v`,ieeukq npprortunifuy.
ilwii�lly� 1' 4n � ii.t :�W�W..{ my L.rrd ae.J w,... lLe *.,I
/Hem. In f},. {iaa nr the Mayo, of are C*-y °I 11„6de.
, ,J 4. 261.4
glands ,�#laypr
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
THE CITY OF MIAMI
5frm&ian
yal laitE.nt In th �a a&rfa pranore is rltuognsian m s e rt wil 'a a
prMra4e 8°equaQi ftr3.'j� ca G l pn �yy e� a(�r
WHJ -�{e 0 F,it iZel�iRlat n �,��ye�s an m1 3erua � the Frlah�
'm min sra clan arniinla6`rg� scnminaFion agakrUgiin ` i"- rro a was an
►IVY iFe z�tTO city. lltac g��m nnn��tnpamffigm11 irl mAmem to {ri,,rrtth�a�fnp1ar4ouµ9-�p
a1I Pt u .osig IBS rd to grin NOY r al sTyrn np 0[,rktl morr1 i Slaa%ver
r
��Ip1aery)p p un a'Io-'t"ro-s h". IpiO[OQCRafllranmS GJaM Prie�`annps
n Ine yuPiiC a hghl�o c9 alh�ioua+ng erg
W HERF.4 It i rttln a rognalsthgt of he Cis e W r
j€[ aeNee. ott,pp,ro n wig
WV; ra o-r cel canted r rA n +ri
a'rid'qq Sv''�n�`"r`��gtarirpen pia 7.r�V ({ep,l i4af y a Pion g n iscryn n
eitehv procfa m remHnn tt k of Mnf in Ehep r 2et Ss of the Crty Of Miami. Florida, do
Fair Housing Month
"Restoring Our Communities Block by Block"
[he caelebfa to al lFois HenV k [all In sSoU equal ha n9 gP girern me m
Vpip'E ile ►3 HEHY.OVs I hereunto net my hand and Cause the seal of the City of
zmi to a
110,04 In the dhice of the Meryor of the City cf Miaml, FWrida.
April 17, 2015
Tomas Regale Mayor
—a
..ilea. .. <
117
Appendix 4
Spanish brief/translation about the main impediments identified in the DRAFT of the Analysis of Impediments to Fair
Housing as requested by the Miami Workers Center presented at a meeting held on May 21, 2015.
Reunion Publica — The Workers Center
Ciudad de Miami, Departamento de Desarrollo Comunitario y Economico
21 de mayo del 2015
Iglesia del Espiritu Santo, 150 SW 13th Ave, Miami, FL
c,QUE ES UN ANALISIS DE IMPEDIMENTOS PARA LA ELECCION DE VIVIENDA EQUITATIVA? WHAT IS AN ANALYSIS OF
IMPEDIMENTS (Al) TO FAIR HOUSING?
El Analisis de Impedimentos para la Eleccion de Vivienda Equitativa (Al) revisa las politicas publicas y privadas, las
practicas y los procedimientos para identificar las posibles barreras a la eleccion de vivienda equitativa en una
comunidad. El Departamento de Vivienda y Desarrollo Urbano de los Estados Unidos (conocido como HUD por sus siglas
en ingles) requiere que los concesionarios locales que reciben subsidios federales, tales como la Ciudad de Miami,
presenten una version actualizada del Al cada cinco aiios como parte del proceso del Plan Consolidado del
concesionario/la jurisdiccion local. El Al sirve como base para la planificacion de vivienda equitativa por el suministro de
informacion sobre los obstaculos y las maneras de disminuir las barreras para finalmente promover la eleccion de
vivienda equitativa en la ciudad de acuerdo a las !eyes locales, estatales y federales sobre este mismo tema.
La Ciudad de Miami toma alrededor de un ario en preparar un documento borrador tomando en cuenta las condiciones
que HUD dicta y que deben incorporarse a todo Al. Estas condiciones son indicadas en un documento creado y
transmitido por ellos (HUD) Ilamado el Fair Housing Planning Guide, accesible por Internet en la
http://www.hud.gov/offices/fheo/images/fhpg.pdf. Tras analizar los datos mas recientes distribuidos por la Oficina del
Census de los Estados Unidos y tras consultar con grupos locales tales como la Asociacion local de agentes de bienes
raices, los administradores de la Ciudad, las organizaciones locales que se especializan en las !eyes de vivienda equitativa,
urbanizadores, arrendadores, y residentes, el borrador se prepara, se le avisa al publico sobre la disponibilidad del
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 118
City of Miami
borrador por medio de un anuncio en el periodico, extendiendole al publico en general 30 dias para someter comentarios
al borrador del Al. Todos los comentarios que se reciban seran incorporados a la version final del AI, y este documento
sera presentado a la Comision de la Ciudad para su consideracion, cambios y/o aprobacion antes de ser sometida a HUD
para la evaluacion final del documento.
La ley federal de equidad de vivienda (y sus modificaciones), prohibe a traves de la nacion la discriminacion en la yenta,
alquiler, y financiamiento de viviendas, y en otras transacciones relacionadas con la vivienda, basada en •raza •color
•nacionalidad •religion •sexo •tipo de familia (por ejemplo, tener hijos) •discapacidad
Las !eyes del estado de la Florida proveen protecciones adicionales para •personas embarazadas *personas con VIH
Las !eyes locales del Condado Miami -Dade proveen protecciones adicionales para •edad •linaje •victimas de violencia
domestica •expresion de genero y/o identidad •estado civil •orientacion sexual •fuente de ingresos
A continuacion elaboramos sobre los ocho impedimentos (barreras) que hemos identificado en la Ciudad de Miami, tales
como se describen en el borrador en ingles.
Impedimento #1: Aproximadamente el 46% de los hogares de la Ciudad de Miami estan viviendo con sobrecargos en
gastos de vivienda dado a los costos crecientes para comprar y/o rentar viviendas dentro de la Ciudad, combinado con
salarios locales estancados. HUD define a hogares viviendo con sobrecargos en gastos de vivienda como residentes—sean
duenos de vivienda o inquilinos — que paguen mas del 30% de sus ingresos hacia los gastos de vivienda.
Impedimento #2: Muy pocos edificios en la Ciudad de Miami se registran para ser aprobados para aceptar prestamos
del Federal Housing Administration (FHA). Un prestamo de la FHA permite que el comprador de una vivienda ponga
menos deposito hacia la compra de una unidad ya que la gran cantidad de bancos requieren un deposito inicial de 20%,
que tipicamente no esta al alcance de las personas de ingresos bajos y/o moderados. Los datos indican que en el mes de
diciembre del 2014, solamente habian cinco edificios en toda la Ciudad que estan aprobados para aceptar prestamos
FHA.
Impedimento #3: Hay poca tierra vacante y disponible en la Ciudad para desarrollar la construction de nuevas viviendas
unifamiliares y/o edificios de apartamentos mas pequenos (de menos unidades). Esta deficiencia limita la variedad de
viviendas que se encuentran en el mercado. Existe una escasez de tierra disponible para la construccion dentro de la
Ciudad y muchas de las tierras que existen estan disperses en areas empobrecidas. Una propiedad tipicamente se puede
desarrollar dentro de la Ciudad si el tote mide 5,000 pies cuadrados y puede tambien acomodar un minimo de dos espacios
de estacionamiento, tat como es requerido por los codigos de la Ciudad. La Ciudad tiene que considerar como la aplicacion
de regulaciones de zonificacion y los requerimientos de estacionamiento pueden modificarse en zonas especificas para
estimular el desarrollo de viviendas unifamiliares y de edificios mas pequenos (de 20 unidades o menos), ya que muchos
de los totes vacantes son muy pequenos en tamano.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 119
City of Miami
Impedimento #4: Hay una deficiencia (escasez) de fondos federales pars administrar programas de asistencia pars
ayudar a pagar la rents. La demanda para vales del Plan 8 en toda la comunidad de Miami -Dade, tanto como la demanda
para viviendas publicas, es alarmante. Desafortunadamente, para las personas de bajos recursos que no hayan aplicado
y/o que no hayan sido seleccionadas al azar para ninguna lista de espera, no existe ningun otro fondo publico disponible
para poder asistirlas con sus obligaciones de renta mensual. Tambien, un estudio efectuado en el condado indica que hay
aproximadamente 10,000 individuos viviendo con VIH+/SIDA en el Condado de Miami -Dade que necesitan ayuda con la
vivienda.
Impedimento #5: Falta de fondos federales disponibles pars preparar el anolisis de impedimentos pars la eleccion de
vivienda equitativa. En los ultimos cincos anos el gobierno federal ha cortado los fondos que distribuye a la Ciudad de
Miami que se pueden utilizar para esfuerzos tales como la preparacion requerida de este documento (Al). A consecuencia,
hay menos fondos disponibles para conseguir una agencia que se especialice en hacer pruebas anonimas, visitando a
edificios de renta a traves de la Ciudad, para poder identificar violaciones a las leyes de vivienda equitativa.
Impedimento #6: No hay suficiente viviendas costeables/de trabajadores pars satisfacer la necesidad de los residentes
de la Ciudad de Miami. Estudios recientes indican que muchas familias con ingresos medianos no pueden razonablemente
pagar para vivir en las comunidades en donde trabajan. Los gastos de vivienda estan fuera de su alcance, basondose
sobre la definicion de 30% de ingresos totales que recomienda el gobierno. El mercado inmobiliario de la Ciudad de Miami
ha sido seriamente afectado por factores de demanda que han contribuido hacia la escalacion continua de rentas.
Impedimento #7: La discriminacion de vivienda a base de raza, color, nacionalidad, religion, sexo, estatus familiar y/o
discapacidad existe y continua ocurriendo. De acuerdo a HOPE, Inc., una organizacion sin fines de lucro que monitorea
las violaciones de equidad de vivienda a traves de los Condados Miami -Dade y Broward, hubieron 343 consultas/quejas
durante 31 meses, de personas que residen en codigos postales dentro de la Ciudad de Miami. Estas consultas/quejas
representan aproximadamente 34% de las quejas totales recibidas y evaluadas por HOPE, Inc., a traves del Condado
Miami -Dade.
Impedimento #8: Varios arrendadores ausentes de edificios de rents privados en barrios de personas de bajos ingresos
ignoran violaciones de codigos dejando a muchos inquilinos en edificios/unidades con condiciones pobres. La Ciudad
esta activamente intentando corregir este problema y le ha planteado una demanda a seis arrendadores dentro de la
Ciudad que deben mos de $2 millones de dolares en multas por violaciones de codigo y otras razones.
eTiene comentarios, ideas, opiniones sobre posibles impedimentos?
-*Si usted tiene comentarios que le gustaria entregar acerca de la informacion relatada en el borrador del Analisis De
Impedimentos Para La Eleccion De Vivienda Equitativa de la Ciudad de Miami, por favor mande esos comentarios por
escrito, incluyendo su nombre y apellido, y una forma de contactarlo (numero de telefono o correo electronico) a la
atencion de Roberto Tazoe, rtazoe@miamigov.com, o por escrito a la siguiente direccion: City of Miami, Dept. of
Community & Economic Development, 444 SW 2 Ave., Second Floor, Miami, FL 33130.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
120
—)Si usted siente haber sido discriminado(a) bajo una de las clases protegidas bajo la ley local, estatal o federal, a
donde usted puede recurrir para presentar una queja?
Puede recurrir a UNA de las agencias indicadas aqui. Por favor tenga en cuenta que toda queja por discriminacion de
vivienda es revisada por un especialista de vivienda justa para determinar si en ella se alegan hechos que podrian violar
la Ley de Equidad de Vivienda o la ley estatal o local sobre el mismo tema.
Local — Housing Opportunities Project
for Excellence, Inc., HOPE, Inc.
Miami -Dade Location
Bill Thompson Building
11501 NW 2 Ave.
Miami, FL 33168
Telefono: 305-651-HOPE (4673)
Fax: 305-759-2440
Website: http://www.hopefhc.com
Estatal — Comision de Relaciones Humanas de le
Florida
2009 Apalachee Parkway
Suite 200, Oakland Building
Tallahassee, FL 32301-4857
http://FCHR.state.fl.us
Telefono: 850-488-8170
Correo de Voz: 1-800-342-8170
Appendix 5
Comments to the DRAFT of the Al
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
City of Miami
Local - Condado Miami -Dade - Office of
Human Rights and Fair Employment Practices
Stephen P. Clark Center
111 NW 1st Street 22nd Floor
Miami, Florida 33128
Telefono: 305-375-2784
Fax: 305-375-2114
Correo electronico: OFEP@miamidade.gov
Federal — El Departamento de Vivienda y
Desarrollo Urbano de los Estados Unidos (HUD)
Para someter una queja por Internet:
http://portal.hud.gov/hudportal/HUD?src=/topi
cs/housing discrimination
Para mas informacion sobre las !eyes federales:
www.espanol.hud.gov/offices/fheo/
Telefono (800)669-9777
TTY (800)927-9275
121
V,f1�1�A
Miami Ceollition terthe Homeless.hC.
140 West Flagler SM..
Saiie t05
H3ian,i, FL33130
Telephone: 786469.2060
Fax: 305372.6337
info ralamlhomelese.arg
BOARD OF DIRECTORS
Jason Pittman
neeiseni
Touching tiarri wen tog
Marla Crisliina Barron
VIIM Preaderit
!Materiel* TrO ,rmr o
Vance Ample
Secretary
The ChidRn'e %MOW N ei Fgrkle
Anthony Brunson
Treasurer
shaven Brunson 1C repaey. PA.
Monica Vigues-Pltan
Itraadrihe Past Primitive.
Legal Sa+ksn d riser Were!
Ana Castilla
Totem
Judge Cindy Lederman
11. Judcial Gnarl Coln
Barbara L. Romani
CtarerA
Curtis Taylor
Camksr 9ucportte liousie
Beni' Power
McKenzie Ceos&uctiec
Dr. Luther Brewster
FU Herbal weoeirn 091 }e er
Itadlahe
Rev. Grey Magglane
TrnityCancerai
Donnovan Maginley, CPA
McGladrey. LIP
Alison Austin, P.A.
6/B/2014
Assistant Director Roberto Tazoe
City of Miami Department of Community and Economic Development
444 SW 2.4 Avenue, Suite 2
Miami, FL 33130
Re: Comments on the City of Miami's AT FY2015.2020
Dear M. Tazoe:
After thoroughly reviewing the draft FY2015-2020 City of Miami
Analysis of Impediments, the Kam Coalition for the Homeless (MCH) world
like to submit the following comments.
C. impediment FH1: Increased Housing (Cost) Burden for 46°% of City
households due to the rising costs of housing in the City of Miami
combined with stagnant wages.
MCH agrees that the City of Miami's high percentage of cost -burdened
households is the primary impediment for fair housing choice, particularly
among the City's lowest income households. According to the Center for
Horsing Policy, the Miami memo area is the most expensive lousing market in
the US for renters. The mismatch betweea local wages and housing costs is so
high that a household earning the average center income of household in Miami
would need 1.5 full-time minimum wage jobs to afford a 2-bedroom rental.
This situation is particulady difficult for extremely low-income (ELI) renter
households in the City of Miami.
The Urban Institute indicates there are only 24 units available and
affordable in Miami for every 100 ELI tenter households. Due to this
significant shortage and limited household income, most of D iruni`s
renters are spending more than half of their income on housing costs.
According to the Shimberg Center for Housing Studies, there are roughly
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 122
City of Miami
51,000 ELI households in the City of Miami Of which 36,500 (71%u) are
severely cost burdened Furthernare, the Shimberg Center also anticipates that
l'.iA households in the City of Mianni will significantly increase by 2030. To meet
this growing need, the City and County must explore creative solutions to
expand the supply of affordable rental housing for Miami's lowest -income
households.
Recommendation FN 1.9: Seek additional funding opportunities for the creation of additional
housing beyond LIHTC innded projects.
MCH recommends that the City of Miami provide stronger leadership on creating new
public/private partnerships that use innovative financing for affordable housing development
like the City of Denver's metal impact bond program or the New York City Aequi rest fund.
The City should explore best practices of successful partnerships between City governments,
major foundations, nonprofits, and commercial lending institutions that have created additional
fonts of capital for affordable housing development.
Locally, the Miami Coalition for the Homeless has launched its affordable housing
initiative, Miami Homes for All (MHFA). This initiative ores private capital to leverage public
resources to increase the development of mixed -income rental housing with a percentage of the
units set -aside for ELI households- MHFA anticipates producing between 530-1,000 units within
a ten-year period by developing low -interest, flexible loan products that are responsive to the
Miami market and meet the capital needs of local non-profit and for -profit and for -profit
developers. The 1-2% interest nn MHFA loans will be used to replenish the loan pool. Brrielrr e
Cif01114Barad Ptarsier Zone, the Deparfwrni of Cemarnai0 sad Ewnetmk Deertepmrat (l3C D) !hosed also
colon pm aul:1g with ore-1iag initiarie Me MFIFA ar mating mow of rhw protxershipr bdurea for CO,
wnrmnaity detrlopmeaf orgaeielraat, and fandatiosr to rest nay tattainable funding appommities for
eartiabk Ian-aola r}rod,,penet.
Recommendation FH 1.9: Better delineate Departmental housing related Proposals by providing
higher point consideration through City RFP processes for: developerslprojecls that provide a
greater percentage of units aimed of serving incomes at 35% AV in comparable rental projects.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice
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123
MCH agrees that the additional points should be added to the rating table for newly
issued housing -related RFPs that serve households at 35% f4MI. Hoavaer; then additional points
must also iodide ;macho:* at or %a /has 33% AMI. Miami -Dade County's recently released "2015
Surtax/SHIP RFA" increased the minimum thresholds for ELI households and MCH
recommends the City also adopt this practice.
II. Impediment FH3: There is a scarcity of developable vacant parcels in the City
diminishing the construction of new, single-family homes and/or smaller apartment
developments thereby limiting housing choice.
Recommendation FH 3.1: 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.
MCH agrees that exempting or reducing the parking requirements of smaller multifamily
buildings is a viable Action Step to increasing housing affordability. The City will effectively
encourage the development of much -needed infiill affordable housing development as well as
decrease construction -related hard costs by exempting smaller buildings near public transit from
the minimum parking requirements. Affordable mid -scale infill development near transit will also
help to lower Miami's high combined housing/transportation cast burden.
Ill. Impediment FH6: There are not enough affordable/workforce housing units in the
City to meet the needs of City residents.
On May 6 2015, MCI1 hosted a "Housing Summit" to bring together leaders in
government, housing development, philanthropy, and advocacy to discuss how to address the
current housing crisis through unique public/private partnerships and other creative solutions.
The event had over 175 attendees, including the City of Miami Mayor Tomas Regalado and
County officials, all of which discussed the high level of need of affordable/workforce units in
Miami. The Housing Summit concluded with a list of policy recommendations for stakeholders
to implement. A key policy recommendation presented by attendees was to establish a cross -
sector taskforce to focus on creative responses to affordable housing development. This suggestion
is u14 aligned milk Rrrsmmendatian FH 6.3 M0-I would aelemet the opportunity to csnist the t:iiy in
the cocain, of this trskfere.
DRAFT — 2015-2020 Analysis of Impediments to Fair Housing Choice 124
City of Miami
wrens taalHWl1nr Ise Homeless. kW.
MCH aLro suggests that DCED meet with the CR, [s located is the CO to dinars itnptnted
partnershep to immerse the srrppij of ajjordabk rental Lousing la the urban core. The Cry should also further
explore the use of linkage fees and impact fee daferrals to stimulate affordabk housing drado/went
Fll 6.2 Continue to support the City's Affordable Housing Trust Fund (AHTF)
Housing Summit attendees also recommended that the City explore making a percentage
of the Miami 21 Public Benefit Trust Funds be distributed automatically to the Affordable
Housing Trust Fund to finance the development of much -needed affordable housing. MCH
supports DECD's recommended Action Step to continue advocating city officials to consider
having monies be distributed automatically into the Affordable Housing Trust Fund_ The City
mart consider adding idcturionary zoning regulations to Miami 21, ineluding the possibilipy of making the
program mandatory to sigeriFcandy expand the snpp'y of affordable rental housing.
Conclusion
The Housing Summit also identified increased code enforcement (Impediment FH 8) as
well as the transfer of publically owned buildings to developers (Impediment FH 3.2) as
important policy tools to mitigate existing housing needs. Overall, MCH congratulates the City
for the draft recommendations which we believe am viable and full responses to the City's
housing needs. We hope that you will take out comments and suggestions into account while
working on updating the FY2015-2020 Analysis of Impediments to Fair Housing Choice.
We are happy to provide any additional information if necessary.
Sincerely,
(Bobbie) Ibarra, SPHR
Executive Director
DRAFT — 2015-20.
City of Miami
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City of Miami
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/estimates/
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City of Miami