HomeMy WebLinkAboutExhibit AANALYSIS OF IMPEDIMENTS
TO FAIR HOUSING CHOICE
CITY OF MIAMI
FY2020-2024
-11‘
Date Drafted
June 2020
2020-2024 Analysis of Impediments to Fair Housing Choice 1
Table of Contents
INTRODUCTION 3
Executive Summary 3
Methodology 5
JURISDICTIONAL BACKGROUND DATA 10
Social Trends 10
Education 15
Housing 33
Cost burden in Miami 52
Economic Trends 55
LEGAL STATUS EVALUATION 59
Evaluation of Current Fair Housing Legal Status 59
Compliance 60
CURRENT PROGRAMS 62
Programs 64
Affirmative fair housing efforts 80
IMPEDIMENTS 82
Private sector 82
Public sector 83
Public and private sector 84
Other findings 86
Improvements since the Last Al 88
CONCLUSIONS AND RECOMMENDATIONS 92
Identified actions and timeline for recommendations 92
actions to overcome the impediments to fair housing choice 93
2020-2024 Analysis of Impediments to Fair Housing Choice 2
INTRODUCTION
Executive Summary
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 usable 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 2019-2023 filed with U.S. HUD in 2019 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. Factors that could
restrict housing choice include, but are not limited to:
■ Discrimination based on race, color, national origin, sex, religion, familial status and disability as
defined by Title VIII of the Civil Rights Act of 1968;
1 US Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Fair Housing Guide.
2 'bid
2020-2024 Analysis of Impediments to Fair Housing Choice 3
■ 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;
■ 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 Housing and Community Development (HCD) last conducted an Al in
2014. In August 2019, it filed its most recent Consolidated Plan with U.S. HUD to span the years of 2019-
2023 incorporating population data from the 2010 Census and most recent American Community Survey
(ACS) estimates as the new decennial census is not expected to be released until 2021. 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.
The City was preparing this document as COVID-19 (novel Coronavirus) hit the country in March 2020,
with Miami -Dade County being one of the hardest hit areas in the State of Florida. As of mid -March,
emergency orders had been issued nationally, by Florida's Governor and by the City of Miami Mayor
including sheltering in place and the shutdown of businesses with the exception of those providing
essential services (pharmacies, supermarkets, hotels, etc.). Because of this, and because Miami is a tourist
destination with a high percentage of service -related jobs, much of the data noted in this document could
dramatically change during the coming months due to both the personal and economic fallout caused by
the pandemic, and at this time, its unknown duration.
PLAN PERIOD
This new Al will span from October 1, 2020 through September 30, 2025, 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 subsequent American Community Surveys 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.
It should be noted that as part of this monitoring effort, many of the actions include input provided by
Housing Opportunities Project for Excellence, Inc. (HOPE, Inc.). This entity is the City's 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, sexual orientation, or source of
2020-2024 Analysis of Impediments to Fair Housing Choice 4
income. In addition, testing is performed as well as monitoring of compliance with affordable housing
regulations.
The HCD 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 -contractors (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 and housing activities, infrastructure
needs (i.e. sidewalk and/or street improvements) and the improvement of public facilities (i.e. parks, fire
stations) among other activities 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.
The HCD 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 HCD 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 Housing and Community Development (HCD) is the lead agency
coordinating all aspects of the Al.
PARTICI PANTS
Key informant interviews were conducted with city and county officials as well as community stakeholders
and private organizations for drafting the 5-Year Consolidated Plan and the Al. 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.)
■ The Miami Realtors Association
■ Florida International University Metropolitan Center
■ 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
The Al began with a review of available social, economic, and housing data gathered from a variety of
sources including:
2020-2024 Analysis of Impediments to Fair Housing Choice 5
■ 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);
■ The 2019-2023 City of Miami 5-Year Consolidated Plan, Public Housing Authority Plan, Annual Plan
and CAPER reports;
■ 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
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 key informant dialogues of participants listed above and by additional
public input gathered at public meetings. A survey was developed in early 2020 with the intention to
gather additional input from residents as part of this process, but unfortunately the City was affected by
the COVID-19 pandemic.
The development of the Action Plan, and the Analysis of Impediments to Fair Housing Choice FY2020-2024
began in late 2019. With the gathered data, several tables and maps were also created to give context to
the issues discussed herein. All references and tables utilized most recently available data from the U.S.
Census and other sources and comparisons were made with dataset that could be compared based on
U.S. Census guidelines.
PUBLIC NOTICE AND REVIEW (NEED TO SCHEDULE)
STAGE I: Due to COVID-19 pandemic, the public notice and review process for the Analysis of Impediments
was amended following social distancing recommendations placed by the Centers for Disease Control and
Prevention (CDC). As such a Virtual Public Hearing was scheduled for July 2, 2020, which was broadcasted
on Channel 77 with close captionings to comply with ADA requirements. Following HUD's memorandum
posted on April 1, 2020, titled "Availability of Waivers of Community Planing and Development (CPD)
Grant Program and Consolidaed Plan Requirements to Prevent the Spread of COVID-19 and Mitigate
Economic Impacts Caused by COVID-19", the City posted its public notice on its website.
The following activities were carried out to ensure public participation at said hearings:
■ Posting on City of Miami website, City's public meetings webpage, and Housing and Community
Development website;
■ Advertised on the Miami Herald;
■ Utilized the Neighborhood Enhancement Team (NET) Offices to advertise and market the public
hearings to the local communities.
2020-2024 Analysis of Impediments to Fair Housing Choice 6
STAGE 2: On June 23, 2020, a public notice was posted on the City's website, following HUD's
recommendation and COVID-19 public participation waivers, advising the public of the Al's draft being
available. It also noted the start date and the end date of the 30-day comment period and how to submit
written comments. Residents had an opportunity to review and provide input for the draft Al. The same
notice also advised the public of a second Public Hearing that took place on July 23, 2020 where residents
had an additional opportunity to provide oral comments.
PUBLIC INPUT SURVEY
Although a flyer and survey (in English, Spanish and Creole) was prepared to gather feedback on general
fair housing concerns in the City, the latter coincided with the emergency orders issued by the federal,
state and local governments related to COVID-19. As such, the response rate was lackluster and does not
warrant being included here. During the life cycle of this document, and after the City is recovering from
the economic and personal fallout tied to this health emergency, the same survey will be reissued and the
results will provide an update to this document at that time.
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)
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.
2020-2024 Analysis of Impediments to Fair Housing Choice 7
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.
HCD communicates with this organization several times a year and shares information, as appropriate.
Most recently (in 2019), the realtors have held at least one training addressing the local "source of
income" protection. As one of the newest fair housing protections extended in Mami-Dade County,
awareness of it — especially amongst landlords — is lacking. To that end, Miami Realtors has been proactive
in educating its members.
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."
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:
■ Mediation
■ Employment
■ Housing
■ Public Accommodations
■ Florida's Whistle -blower's Act
■ Indigent Status
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 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 HCD also adheres to HUD's Equal Access Rule (NOTICE PIH 2014-20 HA), issued on August
20, 2014, which requires HUD's assisted and insured housing programs open to all eligible individuals
regardless of sexual orientation, gender identity or marital status, as well as the VAWA Reauthorization
Act of 2013, Final Rule, effective in Dec. 2016 ( 81 Fed. Reg. 80724) in HUD Housing Programs
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,
2020-2024 Analysis of Impediments to Fair Housing Choice 8
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 allegations of discrimination
under federal, state, and local laws. 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.
2020-2024 Analysis of Impediments to Fair Housing Choice 9
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 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, low median incomes, 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 data pulled directly from the most recent decennial
census, the 2010 Census, as well as latest updates to the ACS.
POPULATION GROWTH
The City of Miami has been experiencing significant population growth since the early 2000s. The City was
accountable for 15 percent of the County's population growth from 2000 to 2010 and from 2010 to 2017,
the City was responsible for 28 percent of the County's population growth. During this period, data
indicates that the City's population increased by 71,896 residents amounting to an 18.4 percent increase
that far surpassed Miami -Dade County's increase of 10.2 percent during the same timeframe. According
to the 2017 ACS 1-Year Estimates, the City of Miami population in 2017 was of 463,354 residents.
Table PG-1: Population Growth Change: City of Miami/Miami-Dade County 1970-2017
Decade
City of Miami Miami -Dade County Percent of County's
Growth that
% Change # Change % Change # Change Occurred within
the City
1970-1980
1980-1990
1990-2000
2000-2010
2010-2017
1970-2017
3.5%
3.5%
1.1%
10.2%
18.4%
11,822
11,967
3,822
36,987
71,896
136,494
Source: U.S. Census Bureau data Tabulation, 1970-2017
2020-2024 Analysis of Impediments to Fair Housing Choice
28.2%
19.2%
16.3%
10.8%
10.2%
357,717
311,685
316,168
243,073
255,361
1,484,004
10
Table PG-2: Demographics, City of Miami
City of Demographics 2000 2010 2017 % Change 2010-2017
Population
362,470
391,458
463,354
18.4%
Households
134,344
149,077
170,005
14.0%
Median Income
$23,483 $29,621 $40,327
Source: U.S. Census Bureau, 2017American Community Survey 1-Year Estimates (B01003, 51101, B19013)
36.1%
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 HCD believes it relates directly to the recent
massive wave of vertical development that has taken place in the City.
Table PG-3 below offers a comparison of the City's population in 2000, 2010, and 2017 amongst racial and
ethnic populations. The data makes several things clear: (a) the City mainly lost Black/African American,
Non -Hispanic population; (b) the City lost persons of two or more races (both Hispanic and non -Hispanic);
(c) there was a concise increase in the White Hispanic population (+94,632).
Table PG-3: Race and Ethnicity, 2000, 2010 Decennial vs 2017 ACS
Race/Ethnicity
City of Miami
2000 2010 2017 Change 2000-2017
Not Hispanic or Latino
124,119 34.2 120,001 30.0 131,140
28.3 +7,021
-5.9
White
Black/African American
Other Race
Two or More Races
42,897 11.8 47,622 11.9 50,704 10.9 +7,807 -0.9
-966 -3.6
2,930 0.8 4,744 1.2 6,548 1.4 +3,618 +0.6
6,102 1.7 2,642 0.7 2,664 0.6 -3,438 -1.1
72,190
19.9
64,993
16.3
71,224
15.4
Hispanic or Latino
238,351 65.8 279,456 70.0 332,214 71.8 +93,863 +5.9
White
Black/African American
Other Race
Two or More Races
198,573 54.8 242,298 60.7 293,205 67.7 +94,632 +12.9
8,668 2.4 11,887 3.0 12,187 2.6 +3,519 +0.2
20,030 5.5 17,173 4.3 19,832 4.3 -198 -1.2
11,080 3.1 8,098 2.0 6,990 1.5 -4,090 -1.6
ofd
362,470 100.0 399,457 100.0 463,354 100.0 +100,884 (x)
White
241,470 66.6 289,920 72.6 343,909 74.2 +102,439 +7.6
Black/African American
80,858 22.3 76,880 19.3 83,411 18.0 +2,553 -4.3
Other Race
22,960 6.3 21,917 5.5 26,380 5.7 +3,420 -0.6
Two or More Races 17,182 4.7 10,740 2.7 9,654 2.1 -7,528 -2.6
Source: U.S. Census Bureau, 2000, 2010 Decennial, 2017ACS 1-Year estimates (B3002)
2020-2024 Analysis of Impediments to Fair Housing Choice
11
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.orq, the
U.S. Census Bureau's pooled 2013-2017 ACS indicates that Miami -Dade County's immigrant population is
the second highest of any County in the nation with an approximate number of 1,430,900 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 fourth (of all U.S. states) after California, Texas and New York in immigrant population with
approximately 4.1 million immigrants. 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.
Miami -Dade County, Florida
Broward County, Florida
Palm Beach County, Florida
Orange County, Florida
Hillsborough County, Florida
Lee County, Florida
Pinellas County, Florida
Duval County, Florida
Collier Dourly, Florida
Polk County, Florida
Osceola County, Florida
Seminole County, Honda
1,430; 900
625:400
350:600
266:800
222:400
113,D00
111,900
94.200
86:600
65:000
64:800
55:800
According to the most recent Census estimates (Tables PG-3 and RE-1), the Hispanic population's growth
over the past seven years outpaced the growth rate of the city as a whole; the city's population grew by
13.8 percent, while the Hispanic population grew by 15.9 percent. The White Non -Hispanics population
experienced a slight decline in population percentages even as it is estimated it added over 3,000 people
making up 10.9 percent of the population. Likewise, the Black/African American population had a small
increase in individuals residing in the City yet it continue to experience losses in population percentages.
In the last seven years, Census figures indicate that the Black population in the City of Miami from, 2010
to 2017 increased by 6,531 people to now make up 18 percent of the population a decrease 1.2
percentage points. 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
2020-2024 Analysis of Impediments to Fair Housing Choice
12
significantly large and can additionally select a race in the census survey, the traditional racial categories
become skewed. For example, the 2017 ACS estimates that there is a White population of 343,909 (74.2
percent); however, 85.3 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 14.6 percent.
Table RE-1: Growth Rate by Race and Ethnicity, 2010 to 2017
Race/Ethnicity
Total population
:................................................................................................................
White
:................................................................................................................
Black or African American
Other race
Two or more races
Hispanic or Latino
:........................................................................
White
# Change
within Race
and Ethnicity
4,463
-1,086
% Change
within Race
and Ethnicity
13.8
15.7
7.8
16.9
- 11.2
52,758 15.9
50,907 17.4
Black or African American 300
Other race 2,659
Two or more races -1,108
...........................................................................................................................................................................:................................................................:
Not Hispanic or Latino 11,139
White 3,082
Black or African American 6,231
Other race 1,804
2.5
13.4
- 15.9
:. Two or more races 22.........................................................................................................................................................................................:................................................................:.............
Source: U.S. Census Bureau, 2010 Decennial, 2017ACS 1-Year estimates (B3002)
Graph RE-1: Hispanic or Latino Population by Region 2000, 2010, 2017
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
500,000
MMP
8.5
6.1
8.7
27.6
0.8
City of Miami Miami Dade County State of Florida
■ 2000 ■ 2010 In 2017
Source: U.S. Census Bureau, 2000, 2010 Decennial, 2017ACS 1-Year estimates (QT-P10, DP05)
2020-2024 Analysis of Impediments to Fair Housing Choice
13
The bar graphs above takes a closer look at the Hispanic population and its growth rates from 2000 to
2017, compared to the Miami -Dade County and the State of Florida. As noted, the City and County's
growth rates in the Hispanic population from 2000 to 2017 are both outpaced by Florida's growth rate in
this ethnic category.
POPULATION AGE
The City is also experiencing a significant shift in the distribution of its population by age. Table PA-1 shows
that, as a percentage of the population, school -aged children and younger adults are trending downward
while populations composed of individuals aged 24 and older (with the exception of the 35-44 cohort
which experienced a slight decrease) and considered to be of working -age are trending upwards,
especially the 45-54 cohort which experienced the highest increase of any group at 0.9 percent or 12,768
people.
Table PA-1: Percent Change in Age Distribution: City of Miami 2010-2017
AGE (Years)
Trend 2017 2010
of City of Miami City of Miami
Population # % # %
Total Population
Under 5 years
5-9 years
10-14 years
15-19 years
20-24 years
25-34 years
35-44 years
463,354
26,488
21,025
21,543
22,630
28,350
77,577
68,373
100%
5.7%
4.5%
4.6%
4.9%
6.1%
16.7%
14.8%
399,457
23,882
19,072
18,364
21,080
28,628
65,824
59,469
100%
6.0%
4.8%
4.6%
5.3%
7.2%
16.5%
14.9%
45-54 years +0.9% 68,835 14.9% 56,067 14.0%
55-59 years
60-64 years
64-74 years
75-84 years
85-Over years
27,521 5.9%
26,059 5.6%
38,913 8.4%
25,649 5.5%
10,391 2.2%
23,227
19,857
32,075
22,747
9,165
5.8%
5.0%
8.0%
5.7%
2.3%
Source: U.S. Census Bureau, 2010, 2017 American Community Survey 1-Year Estimates (DP05)
The table above shows that the group that experienced the highest percentage growth is the 45-54 years
cohort. Other groups with net positive percentage changes are the 25-34 and 55-59 cohorts, also working -
age cohorts. These age groups can provide an economic boost to the City and an opportunity to further
expand resources and investment.
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
2020-2024 Analysis of Impediments to Fair Housing Choice
14
area. The index score can also be interpreted as the percentage of one of the two groups included in the
calculation that would have to move to different geographic areas in order to produce a distribution that
matches that of the larger area. The index of dissimilarity can also be used as a measure of inequality. A
value of 60 (or above) is considered very high. It means that 60% (or more) of the members of one group
would need to move to a different tract in order for the two groups to be equally distributed. Values of
40 or 50 are usually considered moderate levels of segregation.
For this particular topic, the City turned to the St. Louis fed for the most updated data for our MSA as
information is not boiled down to individual jurisdicions. To begin, the black -white dissimilarity index for
our region (Miami -Fort Lauderdale -Pompano Beach MSA) sits at .639 (64%) with a range from 0 (fully
integrated) to 1 (fully segregated).3, When we pull dissimilarity between whites and non -whites in Miami -
Dade County in 2018 was 47.9, which is considered fair.4 When looking at dissimilarity between Hispanics
and non -Hispanics, the index is at it lowest 52.1%.
EDUCATION
According to 2013-2017 ACS estimates, only 16.3 percent of the City of Miami's population 25 years of
age and over have a bachelor's degree or higher. The City's population 25+ population with less than a
high school diploma is 24.4 percent. Significantly, 19.0 of the City's population 19-24 years have less than
a high school education.
Table ED-1: Educational Attainment by Age Group
Age Group
Total Percent
36,000
(x)
Less than high school graduate
6,853
19.0
Population 18 to 24 Years High school graduate (includes equivalency)
Some college or associate's degree
Bachelor's degree or higher
11,315
13,697
4,135
31.4
38.0
11.5
Population 15 years and over
327,920 (x)
Less than 9th grade 47,180 14.4
9th to 12th grade, no diploma 32,943 10.0
High school graduate (includes equivalency) 97,595 29.8
Some college, no degree 40,839 12.5
Associate's degree 22,986 7.0
Bachelor's degree 53,431 16.3
Graduate or professional degree 32,946 10.0
Total Population
Percent High school graduate or higher
(x) 75.6
Percent Bachelor's degree or higher
(x) 26.3
Source: U.S. Census Bureau, 2013-2017 American Community Survey 5-Year Estimates
3 https://www.governinq.com/qov-data/residential-racial-segregation-metro-areas.html
° https://fred.stlouisfed.orq/series/RACEDISPARITY012086
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15
Table ED-2: Educational Attainment by Race and Area
Miami %
Miami -Dade % State of Florida %
Less than high school graduate
High school degree or Higher
19.0
75.6
14.6
15.2
81.0
88.4
- -White
96.1
94.4
92.9
- -Black/African American
70.3 77.9 83.7
- -American Indian/Alaskan Native 52.3
73.7 80.1
--Asian
82.5 84.8 86.6
- -Hispanic or Latino 73.2 78.8 80.1
Associate's degree or Some College 22.5 28.5 27.7
Bachelor's degree or Higher
26.3
27.8 29.7
- -White 63.6 49.9 33.3
- -Black/African American 12.1 16.2 18.8
- -American Indian/Alaskan Native 3.5 15.9 20.8
- -Asian 56.3 50.7 50.8
- -Hispanic or Latino 22.8 25.3 24.1
Graduate or professional degree 10.0 10.0 10.8
Source: U.S. Census Bureau, 2013-2017 American Community Survey 5-Year Estimates (51501)
Education is an area of great concern in the State of Florida and in Miami as it allows for successful job
placement, development, and resident retention. In the City of Miami, close to 19 percent of the
population between 18 and 24 had less than a high school degree, much higher than the averages of both
the County and State. The data also indicates that only 26.3% of the population had a Bachelor's degree
or higher which is lower than the percentages from the State and the County.
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 ACS 2013-2017 5-Year
estimates (S0520) indicate that an astounding 55.4 percent (256,914) of Miami's population is foreign
born and 93.7 percent speak a language other than English at home (ages 5 and up).
Linguistic isolation is another thing altogether. 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." It makes
sense that in an area where many persons are foreign born, levels of linguistic isolation will be higher. In
Miami, 64.8 percent of the foreign born population speaks English less than "very well."
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
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16
opportunity if information is provided only in English. As indicated in the table below, the ACS 2013-2017
5-Year estimates indicate that 26.9% of Miami's Spanish speaking households are linguistically isolated.
Table LI-1: Household Language by Linguistic Isolation
Household Language
Miami
Households
Percent
Total Households
170,005
100.0
English only
Spanish
- -Linguistically Isolated
- -Not linguistically isolated
41,695
112,668
45,699
66,969
24.5
66.3
26.9
39.4
Other Indo-European languages 12,918
- -Linguistically Isolated 3,007
- -Not linguistically isolated 9,911
7.7
1.9
5.8
Asian & Pacific Island languages 1,870
- -Linguistically Isolated 126
- -Not linguistically isolated 1,744
1.1
0.1
1.0
Other languages 854 0.5
- -Linguistically Isolated 91 0.1
- -Not linguistically isolated 763 0.4
Source: US Census Bureau, American Community Survey 2013-2017, 5-Year estimates (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.
Because Miami is comprised of many immigrants and we are a "minority majority" City, the HCD 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 resources available to the grantee/recipient and
costs. Based on our City's population, the HCD concluded that the different, existent (already in place)
language assistance measures are sufficient for the different types of programs or activities in which the
HCD engages.
2020-2024 Analysis of Impediments to Fair Housing Choice
17
The HCD has staff members who are fluent in Spanish and Creole and makes every attempt to translate
the most vital programmatic materials for the public to both Spanish and Creole, as necessary and
reasonably requested to allow non-English speaking residents the opportunity to participate in the
different plans detailed in the Citizen Participation Plan (CPP). In public meetings, HCD staff makes sure
to have a Spanish speaker and Creole speaker on hand in the event on -the -spot translations are needed.
In late 2019, the City of Miami launched a new web platform that allows constituents to translate all web -
based information on the entire miamigov.com website to Spanish or Creole, with a quick drop down
toggle option.
RACIALLY AND ETHNCIALLY CONCENTRATED AREAS OF POVERTY (R/ECAP)
The bulk of Miami's census tracts qualify as majority -minority, where a minority will comprise a large
percentage of the tract, we must focus on poverty levels to better understand where low-income families
are concentrated. To that end, we take a current look at the City's R/ECAPs -- Racially/Ethnically-
Concentrated Areas of Poverty — as defined by US HUD. In order to qualify as a R/ECAP:
■ Census tracts must have a non -white population of 50 percent or more AND 40 percent or more
of individuals living at or below the poverty line.
■ Because overall poverty levels are substantially lower in many parts of the country, HUD
supplements this with an alternate criterion. Thus, a neighborhood can be a R/ECAP if it has a
poverty rate that exceeds 40% or is three or more times the average tract poverty rate for the
metropolitan/micropolitan area, whichever threshold is lower.
As of 2018, eighteen tracts qualify as R/ECAPs within the City. These are identified by number in Map MA-
50.1. It bears mention that nine of those tracts (exactly half) were R/ECAPs based on data from the 2010
U.S. Census. These were: 14.02, 15.01, 15.02, 18.01, 20.03, 26.00, 34.00, 36.01, and 53.02. This means
that in close to a decade, the amount of R/ECAPs has doubled and that poverty continues to further
concentrate itself in particular areas of the City, even as unemployment has dropped, income levels have
risen, and housing construction has climbed.
When looking to the map below, one can see that practically all of the R/ECAPs are located in District 5 of
the City, spanning from the northern boundary of the City towards the South.
The populations in these neighborhoods are mainly comprised of extremely low- to moderate -income
households. The housing is mainly renter -occupied and the housing structures typically 50+ years in age.
Little new affordable housing has been developed in these neighborhoods in recent years. However,
newer market -rate housing is being developed or proposed in these neighborhoods and gentrification has
become more of a concern.
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Map MA-50.1 — Racially and Ethnically Concentrated Areas of Poverty, 2018
_ WI'71ST ST
^4 arm :T HESTTHS
NW 91ST
W ISTH ST
2202
i 5302
SWFTH.5—'�-.
119p HG TH ST_ RAHP
600 2
HJTH ST
HE I3TH ST
NE9TH 9T
SE 1ST ST
SE 3119.9T
Source: https.//www.hudexchange.info/resource/4868/affh-raw-data February 2018
HOUSEHOLD INCOME AND POVERTY RATES
Despite unprecedented job growth and low unemployment, the economic well-being of most Miami
households has not significantly improved. As noted in Map HIP-1, the highest income households in the
City — with few exceptions - are found along the coastline (shaded in green and yellow), which also
coincides with those areas where land values tend to be at their highest. Map HIP-1 also displays a
significant amount of scattered red tracts, which represents where lowest median income households
($0-$18,614) comprise the majority. The bulk of these red tracts are concentrated in the middle of the
City, around the Miami River, which cuts directly through the City center.
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19
Map HIP-1 — Median Income
Legend
Median Income
- 50-518,614
- 518,615 - 527,500
® 527,501 - $38,921
530.022 - 551,976
551,077 - 565,900
565,001 - 585,909
535,001 - $123,304
I 5123, 305 - $171,094
- 5171,095 - 5250 000
Data Source: 2017 Am en ca n Fact Finder Census 2017 - 1 Year Estimate
As noted in Table HIP-1 below, the ACS 2017 1-Yr Estimates notes that close to 57.8 percent of the City's
household incomes are below $49,999. Although the City's median household income has grown, the
median household expenditure in the City averages $48,880 a year (as per the Miami -Dade Beacon
Council). This mismatch between wages and living costs could stifle a household's ability to climb the
income ladder. Most City workers are employed in low -wage service sector occupations, including retail
trade, leisure and hospitality, and educational and health services. The average wage of all City workers
is $27,250 and an estimated 40 percent of all households in the City earn 80 percent or less than the
median income.
Table HIP-1: Household Income: City of Miami, 2015 vs 2017
Income Trend
2017 ACS 2015 ACS
Less than $10,000
9L
$10,000 to $14,999
9ti
$15,000 to $24,999
4'
$25,000 to $34,999 %
$35,000 to $49,999 iJ1
12.7%
7.3%
14.5%
10.9%
12.4%
2020-2024 Analysis of Impediments to Fair Housing Choice
57.8%
17.2%
9.0%
16.8%
12.3%
11.5%
20
Income Trend 2017 ACS 2015 ACS
$50,000 to $74,999
15.0%
13.4%
$75,000 to $99,999
8.9%
7.5%
$100,000 to $149,999
8.9%
6.2%
$150,000 to $199,999
iJ1 3.9%
2.4%
$200,000 or more iJ1 5.6% 3.6%
Median Household Income
$40,327 $29,989
Source: U.S. Census Bureau, 2017 American Community Survey, 1-Year estimates (S1901); 2015 ACS 1-Year Estimates (S1901)
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 (improve economic status). To that end, an
analysis of poverty levels in the City of Miami bears mention. The U.S. Census Bureau, 2013-2017 5-Year
ACS estimates that 25.8 percent of Miami's population is below the poverty level, which is one-fourth of
its residents. The national average is 14.6 percent, while in Florida 15.5 percent of the total population is
below the poverty level. The City of Miami has the 5th highest poverty rate amongst benchmark cities in
the US.
As noted in Table HIP-2 below, the highest percentage of the population in the City determined to be
below the poverty level is Black/African American at 38.3 percent. Hispanics (of any race) comprise
approximately 25 percent of those persons in poverty.
Table HIP-2: Poverty Status in the Past 12 Months (Individuals)
Percent below
Poverty Level
Total Population for who poverty status is determined
22.8
Race and Hispanic or Latino Origin
One race
White
23.0
Black or African American
38.3
American Indian and Alaska Native
13.8
Asian
19.8
Native Hawaiian and Other Pacific Islander 22.1
Some other race
29.7
Two or more races
18.4
Hispanic or Latino (of any race) 25.0
White alone, not Hispanic or Latino 12.4
Source: US Census Bureau, American Community Survey 2013-2017, 5-Year estimates (S1701)
2020-2024 Analysis of Impediments to Fair Housing Choice
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Table HIP-3 provides data related to the family composition of those living below poverty according to the
2009-2013 ACS 5-Year estimates. As expected and as is most prevalent, poverty is most seen amongst
female -headed households with related children under 18 where approximately half of them live in
poverty.
Table HIP-3: Poverty Status in the Past 12 Months (All Families)
Percent below
Povert Level
All Families
21.7
With related children under 18 years
31.8
Married -couple families
14.8
With related children under 18 years
19.3
Families with female householder, no husband present 34.9
With related children under 18 years
48.4
Source: US Census Bureau, American Community Survey 2013-2017, 5-Year estimates (S1702)
INCOME INEQUALITY
According to Census data released in the Fall of 2019 (with the latest data for 2018), income inequality in
the US, as a whole, has hit its highest level since the U.S. Census Bureau started tracking it more than 50
years ago, even with poverty and unemployment levels at historic lows (pre-COVID-19 data). The rise in
economic inequality is tied to several factors. These include, in no particular order, technological change,
globalization, the decline of unions and the eroding value of the minimum wage.
According to a Bloomberg analysis of large American cities with a population of at least a quarter -million,
Atlanta ranked first followed by Miami in second position in the income inequality category. Bloomberg
measured the distribution of household income in 87 cities using 2018 data from the U.S. Census Bureau's
American Community Survey.' The standard measure of income inequality — the Gini coefficient — has a
scale that ranges from zero, which reflects absolute equality, to one -- complete inequality. The Gini index
closed at .485 in 2018 for the US States. For comparison purposes, the same index was at .397 in 1967.
According to the Miami Urban Future Initative (MUFI) report published in April 2019, Miami's level of
income inequality based on the Gini coefficient, is 0.508. This level of inequality is similar to that
of Colombia or Panama. Miami and New York are the only two U.S. metros with a Gini coefficient greater
than 0.500.6 See the figure below from the same report, with the black outline on the right image
containing the City of Miami. All along the shoreline, which encompass Miami's priciest neighborhoods,
the deep red dominates, indicating where inequality issues are at their worst.
With approximately 12 percent of Miami working service jobs' that depend on tourism, this stark
inequality puts many Miamians at a disadvantage should a catastrophe, health issue or unexpected
problem arise.
5 https://www.bloomberg.com/news/articles/2019-11-21/in-america-s-most-unequal-city-top-households-rake-in-663-000
6 TOWARDA MORE INCLUSIVE REGION Inequality and Poverty in Greater Miami, Richard Florida and Steven Pedigo https://carta.fiu.edu/mufi/
7US Bureau of Labor Statistics: https.//www.bls.gov/regions/southeast/news-release/areaemployment miami.htm
2020-2024 Analysis of Impediments to Fair Housing Choice
22
Income nequality:
Gini Coefficient
Source: U.S. Census American Community Survey 2017
4.0 Equal
.13 +a 49 e9
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 City of Miami's 2010-2017 population growth coincided with changes to its most common household
type (Table FS-1 below). While the 2014-2018 Consolidated Plan found a shift in the type of City
households towards non -family households from 2000 to 2010, this trend has since reverted, as non -
family households decreased by .04 percent since 2010, but still comprise 42.7 percent of all households
in the City. Recent data shows an increase in family households, which now stands at 57.3 percent of
households. Within this type, the "husband -wife family" category increased by 3.3 percent (9,158
households) and now comprises 34.6 percent of all households. The increase in family households is also
reflected in significant increases in both average household and family size.
The only household type to experience a steady decline has been the "female householder, with no
husband present" with or without children under 18 years old. Since 2010, this household type has
decreased 2.3 percent (1,716 households). This inversely correlates to the increase in "family households"
and follows a national trend where dual -income households are becoming more of a necessity to deal
with the rising costs of living in large metropolitan cities such as Miami. According to a 2015 report from
2020-2024 Analysis of Impediments to Fair Housing Choice
23
the Pew Research Center titled "Parenting in America," 60 percent of US households were dual -income
families in 2012, compared to just about 25% in 1960.
Chart FS-1: Type of Households in the City of Miami
2010
2017
-116 57.30%
43.10%
42.70%
0% 20% 40% 60% 80% 100%
• Family Households ® Non -Family Households
Source: U.S. Census Bureau, 2000, 2010, 2017
Table FS-1: Changes in Household Type 2000-2017
Household Type
Total Households
Family Households
With own children under
18 years old
Husband Wife family (2010)/
Married Couple family
(2000)
With own children under
18 years old
Female householder, no
husband present
With own children under
18 years old
Non -Family Households
2017
# %
170,005 100%
97,495 57.3%
36,537
2010
# %
158,317 100%
90,032 56.9%
21.5% 35,903
58,768 34.6%
12.9%
26,917 15.8%
22.7%
49,610 31.3%
21,929 18,515 11.7%
28,633 18.1%
11,843 7.0% 13,213 8.3%
72,510 42.7%
68,285 43.1%
2000
# %
134,198 100%
83,281 62.1%
35,277 26.3%
49,139 36.6%
19,741 14.7%
25,029 18.7%
12,357 9.2%
50,917 37.9%
Change 2010-2017
11,688 7.4%
7,463 8.3%
634 1.8%
9,158 18.5%
3,414 18.4%
-1,716 -6.0%
-1,370 -0.4%
4,225 6.2%
Householder living alone 60,182 35.4% 52,644 33.3% 40,834 30.4% 7,538 14.3%
Householder 65 years 18,871 11.1% 17,812 11.3% 16,723 12.5% 1,059 5.9/
and over
Average Household Size 2.67 2.47 2.61 (x)
Average Family Size 3.56 3.15 3.25 (x)
Source: U.S. Census Bureau, 2000, 2010, 2017
2020-2024 Analysis of Impediments to Fair Housing Choice
24
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 needs for this population.
Of the estimated 52,379 persons in the City of Miami who have a disability (12 percent of the total
population), 36.1 percent are 65 years and over, 8.3 percent are aged 18 to 64, and 5.36 percent are ages
5 to 17. In the 65+ age group, the bulk of persons have ambulatory (26.1 percent) and independent (20.2
percent) living difficulty.
Table DIS-1: Disability Characteristics
Subject
Total civilian non -institutionalized
population
Population under 5 years
....................................................................................................................
Population 5 to 17 years
..................................................................................................................................
With a hearing difficulty
..................................................................................................................................
With a vision difficulty
..................................................................................................................................
With a cognitive difficulty
..................................................................................................................................
With an ambulatory difficulty
..................................................................................................................................
With a self -care difficulty
..................................................................................................................................
Population 18 to 64 years
................................................................................................................................
With a hearing difficulty
.........................................................................................
With a vision difficulty
.........................................................................................
With a cognitive difficulty
:...........................................................................................................................
With an ambulatory difficulty
:...........................................................................................................................
With a self -care difficulty
Total
436,285
27,322
With a
disability
52,379
Percent with a
disability
12.01%
133 0.49%
51,743 2771.....,.............................................5.36%....,
608 1.18%
...................<.........................................................................,
642 1.24%
...................:.........................................................................,
1842 3.56%
........................ a.........................................................................;
685 1.32%
........................ a.........................................................................;
685 1.32%
........................ a.........................................................................;
285,878 23,751 8.31%
3499 1.22%
........................:.........................................................................,
5206 1.82%
........................ a.........................................................................;
11763 4.11%
............................ a.........................................................................;
12383 4.33%
............................:.........................................................................:
5037 1.76%
With an independent living difficulty 9833 1 3.44%
Population 65 years and over 71,342 1 25,724 1 36.06%
:.............................................................................................................................................................................:...........................................................:........................................................... a.........................................................................;
With a hearing difficulty 6584 1 9.23%
With a vision difficulty 5782 1 8.10%
With a cognitive difficulty 10007 1 14.03%
:............................................................................................................................................................................::...........................................................<...........................................................:.........................................................................:
With an ambulatory difficulty 18603 1 26.08%
With a self -care difficulty 8935 1 12.52%
With an independent living difficulty 14384 1 20.16%
:.............................................................................................................................................................................:...........................................................:...........................................................:.........................................................................:
Source: US Census Bureau, American Community Survey 2013-2017, 5-Year estimates (S1810))
2020-2024 Analysis of Impediments to Fair Housing Choice
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Under Section 504 of the Rehabilitation Act of 1973, 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 CFR 8.22) This applies to
multi -family housing projects (containing five or more dwelling units (24 CFR 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 seven formal complaints since
2015 related to the City's website, sidewalks, accessibility, and labor related issues. 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. Table DIS-2 below shows 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/handicapped, and it is not uncommon to find seniors that suffer from some type of physical
ailment.
Table DIS-2: City of Miami Section 8 Mod -Rehab Reasonable Accommodation Requests
Year Total Requests
Type of Request
Mental Health Physical Disability Allergies
2011
2012
2013
2014
2015
2016
2017
4
1
4
5
6
10
9
2020-2024 Analysis of Impediments to Fair Housing Choice
0
0
1
2
2
0
2
3
1
3
3
3
10
7
1
0
0
0
1
0
0
26
2018 5 1 4 0
2019 8 1 7 0
Source: City of Miami HCD — Section 8 program
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
same standards applied to other residential uses occupied by a family, housing choice for the disabled is
not hindered.
Section 6.2 of Miami's Zoning Code (Miami 21) addresses community residences and similar
homes/facilities. A Zoning verification is required in order to confirm State -established distance
requirements outlined in the section and all such facilities are required to provide a signed and sealed
survey to the City's Office of Zoning which demonstrates that the distance limitations pursuant to state
statutes are met.
To the extent applicable by state law, the location of a facility may be denied if it results in an over
concentration of Community Residences in proximity to the site selected such that the nature and
character of the Neighborhood would be substantially altered.
2020-2024 Analysis of Impediments to Fair Housing Choice
27
As per FL Statutes, a community residential home is defined as a dwelling unit licensed to serve residents
who are clients of the Department of Elderly Affairs, the Agency for Persons with Disabilities, the
Department of Juvenile Justice, or the Department of Children and Families or licensed by the Agency for
Health Care Administration which provides a living environment for 7 to 14 unrelated residents who
operate as the functional equivalent of a family, including such supervision and care by supportive staff
as may be necessary to meet the physical, emotional, and social needs of the residents.
The residence standards outlined in the City of Miami Zoning Code (Miami21) indicate as follows:
■ Community Residences of six (6) or fewer residents shall not be located within a radius of one -
thousand (1,000) feet of another. Such homes with six (6) or fewer residents shall not be required
to comply with the notification provisions of this section; provided that, prior to licensing, the
sponsoring agency provides the Office of Zoning with the most recently published data compiled
from the licensing entities that identifies all community residential homes within the jurisdictional
limits of the City in order to show that no other community residential home is within a radius of
one -thousand (1,000) feet of the proposed home with six (6) or fewer residents. At the time of
home occupancy, the sponsoring agency must notify the City of Miami Office of Zoning that the
home is licensed by the licensing entity. As per State law, Homes of six or fewer residents which
otherwise meet the definition of a community residential home shall be allowed in single-family
or multifamily zoning without approval by the local government, provided that such homes meet
the distance requirement noted.
■ Community Residences servicing seven (7) to fourteen (14) residents shall not be located within
a radius of twelve -hundred (1,200) feet of another. When a site for a community residential home
servicing seven (7) to fourteen (14) residents or similar assisted living facility has been selected by
a sponsoring agency in an area that allows multifamily, the agency shall notify the Planning
Director in writing and include in such notice the specific address of the site, the residential
licensing category, the number of residents, and the community support requirements of the
program. Such notice shall also contain a statement from the licensing entity indicating the
licensing status of the proposed assisted living facility or community residential home and
specifying how the home meets applicable licensing criteria for the safe care and supervision of
the clients in the home. The sponsoring agency shall also provide to the City the most recently
published data compiled from the licensing entities that identifies all assisted living facilities, adult
family -care homes, or community residential homes within the jurisdictional limits of the City. The
Office of Zoning shall review the notification of the sponsoring agency in accordance with Transect
regulations.
Pursuant to review by the Planning Department, the City may:
1. Determine that the siting of the assisted living facility or community residential home is in
accordance with this code and approve the siting. If the siting is approved, the sponsoring
agency may establish the home at the site selected.
2. Fail to respond within sixty (60) days. If the City fails to respond within such time, the
sponsoring agency may establish the home at the site selected.
3. Deny the siting of the home.
2020-2024 Analysis of Impediments to Fair Housing Choice
28
■ Adult Family -Care Homes of five (5) or fewer residents shall not be located within a radius of one -
thousand (1,000) feet of another.
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
Section 429.01 through 429.54, Florida Statutes is known as the Assisted Living Facilities Act. Pursuant to
Section 429.02, Fla. Stat. "assisted living facility" means any building or buildings, section or distinct part
of a building, private home, boarding home, home for the aged, or other residential facility, whether
operated for profit or not, which undertakes through its ownership or management to provide housing,
meals, and one or more personal services for a period exceeding 24 hours to one or more adults who are
not relatives of the owner or administrator.
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.
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. 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 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.
As of November 12, 2019, there are 139 licensed Adult Living Facilities located in the City of Miami, FL.
One -hundred and twenty-eight are under the purview of the Florida Agency for Health Care
Administration (AHCA) and eleven are under the Agency for Persons with Disabilities (APD).
2020-2024 Analysis of Impediments to Fair Housing Choice
29
Licensed Assisted Living
Facilities & Group Homes
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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.
1
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 Tenant -Based Rental Assistance (TBRA) to approximately 825 clients who have
AIDS and are 80% area median income (AMI) or below. The HOPWA TBRA application and waitlist
processes are 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
2020-2024 Analysis of Impediments to Fair Housing Choice
30
a Client Medical Eligibility Form, completed and signed by their physician, certifying that the applicant has
received an AIDS diagnosis. Said form is part of the application packet. The opening of the waitlist is
marketed through the county -wide HIV/AIDS care network to reach persons with AIDS, including but not
limited to, Ryan White Case agencies, public hospitals and clinics.
The City uses HOPWA monies to provide operational subsidies for 26 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 50 persons each year who are HIV+, who are 80% AMI or below, and who are not
participants in the TBRA program. This program is administered by a project sponsor (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 TBRA program, all clients are provided with the TBRA Client Handbook
which provides the most important information concerning the HOPWA TBRA 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. The three -page Attachment also advises the
HOPWA TBRA 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 2017 HIV/AIDS Surveillance Fact Sheet issued by the Florida Department of Health in Miami -Dade
County noted that there were 27,969 persons living with HIV, 1,195 newly diagnosed HIV cases and 502
newly diagnosed AIDS cases in 2017. Approximately 59 percent of the cases were Hispanic; 32 percent of
the cases were Black and 8 percent 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 TBRA 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 15 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:
a) A physical or mental impairment that substantially limits one or more of the major life activities
of an individual;
b) A record of such an impairment;
c) Being regarded as having such an impairment;
2020-2024 Analysis of Impediments to Fair Housing Choice
31
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 15-5, 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); and
c) the requested accommodation is reasonable.
A 2016 survey found that over 50% of all respondents had a monthly income of less than $1,000, thus
were living at the federal poverty level (2016 poverty level was $990 per month for a single household).
Based on 2016 Fair Market Rents, a single household at poverty level would be required to spend
approximately 78 percent of its household income just for an efficiency and 98 percent of their income
for a one -bedroom. Even in a roommate situation, a single person at poverty level would need to spend
63 percent of their income to afford to live in a two -bedroom unit at FMR. Individuals receiving Social
Security Income (SSI) could not afford an efficiency or a one -bedroom unit even if shared. A household of
three at the Poverty Level was required to spend approximately 74 percent of its income on housing for
a two -bedroom unit. Close to 75 percent of the 2016 survey respondents reported that they were NOT
receiving housing assistance of any kind. While benefits and wages have not significantly increased since
2016, Miami -Dade County rents have drastically increased. Based on 2020 Fair Markets compared to
those in 2016, rent for an efficiency has increased by 40 percent with one bedroom units experiencing a
32 percent rent increase and two bedroom units experiencing a 30 percent increase. The 2017 Gaps and
Needs Analysis found that there is a need amongst PLWAs for 10,116 subsidized rental units or rent
subsidies.
To recap, below is important crucial data gathered through the 2016 survey of Persons Living with
HIV/AIDS (PLWHA) and Persons Living with HIV (PLWH) for purposes of this AI:
■ There has been some improvement in finding accessible units with 11 percent reporting that it is
not easy to find housing accessible for persons with disability housing as there are only some
accessible apartments available (compared to 17.1 percent in 2014) and the same percentage
(11.1 percent) stated that is almost impossible as there are very few accessible units, compared
to 22.5 percent in 2014.
2020-2024 Analysis of Impediments to Fair Housing Choice
32
■ Respondents reported physical conditions that adversely impacted housing needs with the top
two being depression or mental illness (21 percent) and symptoms of HIV/AIDS, such as
neuropathy, fatigue or dementia (19.7 percent). Close to 11 percent reported having lost housing
they had prior to entering residential treatment or hospitalization.
■ Close to 13 percent of respondents reported having experienced discrimination. When asked of
the basis of the discrimination experienced, the top three responses were: HIV status (nearly half
of all reporting discrimination), sexual orientation and status as an ex -offender.
■ Close to 11 percent of respondents reported that they had experienced a problem with landlords
telling others of their HIV/AIDS status without consent.
Housing
According to 2017 US Census 1-Year Estimates (B25002, B25004), there are currently 201,784 housing
units in the City of Miami. The City's housing supply is mainly comprised of structures with 20 or more
units (89,589 units/44.4 percent) and 1-unit detached structures (48,663 units/24.1 percent). Structures
of 20 or more units have steadily increased since 2000 due to two waves of predominantly high -end,
multi -family construction activity during the building boom of 2005-2007 and the 2012-2017 post -
recession period. Since 2010, the City of Miami has added 14,018 units (18.5 percent increase) in 20+ unit
structures, of which, 7,678 units have been constructed since 2015. National and regional markets have
been undergoing a significant shift from owner occupancy to rental housing. In addition to the
demographic forces described above, stagnant household incomes and tightening credit requirements for
home mortgages have driven a growing number of households into rental housing. The City of Miami's
homeownership rate is now the lowest among benchmark cities in the US.
Despite significant new construction activity since 2010, the percentage of the City of Miami's occupied
housing units continues to decrease coinciding with a steady increase in both the total and percentage of
vacant housing units in the City.
Table HSG-1: Housing Occupancy 2000, 2010, 2017
Housing Occupancy
Total Housing Units
201,784 100.0%
183,994 100.0%
Occupied Housing Units
Vacant Housing Units
Homeowner Vacancy Rate
Rental Vacancy Rate
Change 2010-2017
# %
9.7%
170,005 84.3% 158,317 86.0% 134,198 90.4% 11,688 7.4%
31,779 15.7% 25,677 14.0% 14,190 9.6% 6,102 23.8%
3.8
8.3
7.2
9.2
148,388 100.0%
2.9
6.6
17,790
(X)
(X)
Source: 2014-2018 Five -Year Consolidated Plan, U.S. Census Bureau, 2017American Community Survey 1-Year Estimates (B25002, B25004)
Vacancy Rates
Vacancy rates can help determine the health of a housing market. Table HSG-2 below shows the City
having 31,779 vacant units (15.7%) which represents a high vacancy rate. This would indicate that there
is no shortage of vacant units and that market rates would need to adjust down to meet supply and
demand forces, therefore, making housing more affordable. However, if we dig deeper into census data,
2020-2024 Analysis of Impediments to Fair Housing Choice
33
we find that out of the 31,779 vacant units in the City there are 18,755 units that are not actually available
in the housing market as these are units utilized for recreational, seasonal or occasional use or that are
rented/owned but left unoccupied. The actual number of vacant units available in Miami is 13,024 or 6.5
percent, just below the 7 to 8 percent rate considered to be a healthy vacancy rate8. Low vacancy rates
contribute to poor housing affordability which is what City residents are currently experiencing.
Table HSG-2: Vacancy and Occupancy Status
Total Housing Units
Total Vacant Units
Available Units for Rent
Available Units for Sale
11,027
1,997
Vacant Units NOT available for Rent or Sale
Units
201,784
31,779
13,024
18,755
Percentage
100%
15.7%
6.5%
9.29%
Source: U.S. Census Bureau, 2017American Community Survey 1-Year Estimates (B25002, B25004)
Data pulled from the State of the Cities Data System on City of Miami permits found that as expected,
multi -family requests have dominated the market for years, with the peaks being 2006 (7,481 units
permitted), prior to the recession and housing bust, and then again in 2015, post housing recovery, when
just over 6300 units were permitted. It bears mention that after the housing market collapse, the City of
Miami was grappling with some of the highest foreclosure rates in the country and as Table HSG-3
indicates, permits for new construction drastically declined from 2008 through 2012.
The housing market report on Miami -Dade County by Reinhold P. Wolff Economic Research found a
significant increase in building permit activity since 2013 (see Table HSG-3). During this period, there were
51,334 new housing units authorized by building permits for multi -family housing and 12,572 for single-
family units. The majority of multi -family permits authorized have been in the City of Miami, including 60
percent (2,899 units) of Miami -Dade County's total since 2016. We should note, that some of this
concentration in the City could potentially be attributed to Miami's current Zoning Code, Miami 21, passed
in late 2009 and implemented in 2010, which allows for significant vertical growth — by right - in certain
portions of the City thereby facilitating multi -family development.
Table HSG-3: New Housing Units Authorized by Building Permits, Miami -Dade County 2016, 4th
Quarter, 2017
Year
Single Family Multi Family Total
2006
6,356
10,180
16,536
2007
3,691
4,240
7,931
2008
1,161
2,865 4,026
2009 565 585 1,150
2010 930 1,367 2,297
2011 973 1,684 2,657
2012 1,904 3,160 5,064
8 Vacancy: America's Other Housing Crisis - https://www.citylab.com/equity/2018/07/vacancy-americas-other-housing-crisis/565901/
2020-2024 Analysis of Impediments to Fair Housing Choice
34
Year
Single Family Multi Family Total
2013
2,092
8,087
10,179
2014
2,482
11,361
13,843
2015
2,772
13,649 16,421
2016
2,955
10,777 13,732
2017 2,271 7,460 9,731
Percentage Change
2015 us 2014 +11.7% +20.1 % +18.6%
2016 vs 2015 +6.6% -21.0% -16.4%
2017 vs 2016 -23.1% -30.8% -29.1%
Source: Reinhold Wolff Economic Research, Inc.
Graph HSG-3.1: New Housing Authorized by Building Permits, Miami -Dade County
18_000
16.000
14.000
12.000
10.000
8_000
6.000
4.000
2.000
0.000
Neu Housing Units Authorized by Building Permits
Miami -Dade County
Total Housing Units
Samar bykiP_VffEk
Table HSG-4: Multi -Family Housing Units Authorized by Building Permit by Major Areas. Miami -
Dade County and Selected Municipalities
Area
Three Month Ending
12/31/2016 9/30/2017 12/30/2017
Total Miami -Dade County
1,872
2,059
927
Unincorporated Areas
234
632
708
Miami
1,560
1,175 164
Miami Beach
0
O 0
Coral Gables
0
O 0
Cutler Bay
0
O 0
Doral
2020-2024 Analysis of Impediments to Fair Housing Choice
0
231 6
35
Area
Three Month Ending
12/31/2016 9/30/2017 12/30/2017
Hialeah
63
0
31
Hialeah Gardens
0
0
0
Homestead
0
0
0
North Miami Beach
0
O 0
North Bay Village
0
O 0
Medley Town
0
0
0
Opa-Locka
0
0
0
Other Areas
15
21
18
Total Miami -Dade County
Time Period
Percentage Change
Oct -Dec, 2017 vs Jul -Sep, 2017
-55.0%
Oct -Dec, 2017 vs Jul -Sep, 2016
-50.5%
Source: Reinhold Wolff Economic Research, Inc.
Affordable Housing Demand/Supply Analysis by Area Median Income
Housing affordability in Miami -Dade cuts across a wide range of households. The needs of households on
different rungs of the income ladder differ considerably, and is made even more complex by changing age,
household formation, family size and composition, and housing preferences. HUD's basic classification
system pegs affordable housing needs to how much money a household earns relative to the Area Median
Income (AMI), or median household income of the County or metropolitan region. HUD classifies
households into four categories relative to AMI:
• Extremely Low Income (ELI): Households with income at or below the Poverty Guideline or 30%
of AMI, whichever is higher;
• Very Low Income (VLI): Households with income between 31% and 50% of AMI;
• Low Income (LI): Households with income between 51% and 80% of AMI Middle Income (MI):
Households with income between 81% and 100% of AMI; and
• Moderate Income (MI): Households with incomes from 80% to 120% of AMI.
In May 2019, the FIU Metropolitan Center completed an analysis of housing supply and demand, at each
HUD defined income level. The analysis looks at the number of households at each income level, the rent
and purchase price affordable to each income level, and the City's supply of housing units at those
rents/prices. The analysis of affordable housing supply/demand indicates the City has a shortage of 69,465
affordable housing units.
2020-2024 Analysis of Impediments to Fair Housing Choice
36
Table HSG-5: Affordable Housing Demand/Supply Analysis — Owner Housing Analysis
Very Low
Income
Moderate
Income
Income Category
$20,163-$32,261
Total # of
Households
(Demand)
25,814
Home Purchased at Affordable
Price Levels
$61,701
$96,783
# of Owner Units
within Affordable
Price Range
Su..l
1,729 (6.7%)
Surplus/GAP
within
Affordable
Housin: Ran:e
24,085
81-120% AM I
51%AMI
80% AM I
51-80% AM I
$32,262-$48,392
Source: FIU Metropolitan Center, May 2019
23,964
$96,786
%145,176
2,749 (11.4%)
Table HSG-6: Affordable Housing Demand/Supply Analysis — Renter Housing Analysis
Extremely Low
Income
Very Low
Income
Low Income
Moderate
Income
Income Category
0-30% AM I
$0-$12,098
31-50% AM I
$12,099-$20,163
51-80% AMI
$20,164-$32,261
81-120% AMI
$32,262-$48,392
Source: FIU Metropolitan Center, May 2019
Total # of Renter
Households
(Demand)
22,680
7,764
19,067
19,003
Affordable Rent Levels
# of Renter Units
within Affordable
Price Range
(Supply)
0% AMI 30% AMI 0-30% AM I
31% AMI
$303
51% AMI
$505
51% AMI
$807
$302
50% AMI
$504
80% AMI
$806
80% AMI
$1,209
7,077 (31.2%)
31-50% AM I
3,698 (47.6%)
51-80% AM I
14,571 (76.4%)
51-80% AMI
37,720 (198%)
21,215
Surplus/GAP
within
Affordable
Housing Range
15,603
4,066
4,496
+18,716
The data collected above help explain why the City of Miami has become increasingly unaffordable and
cost -burdening to its residents —especially those seeking low -rental options. Historically, Miami has been
a boom -bust market whose volatility has not been kind to the City's low-income residents. During the
housing boom of 2005-2007, many of the City's urban core neighborhoods were rediscovered and
gentrification became prevalent in areas such as Wynwood and Coconut Grove (West). During the
recession, the volume of foreclosures and vacant buildings was highest from 2007 to 2009 and property
values dropped 50 to 60 percent, reaching their lowest levels in April 2011. The rental market in the City
of Miami was deeply affected by the foreclosure crisis too in that it pushed many middle -income
homeowners, who could no longer keep their homes, into the rental market creating a squeeze in the low
cost rental supply and pushing up rental prices.
Front and center to the change in the City's housing market is household mobility and income trends.
According to the US Census, ACS, 2017 1-Year Estimates, 68.1 percent of the occupied households in the
City of Miami moved into their unit in 2010 or later. In other words, over half of the City's households
have moved into their current unit within the past decade. If one takes into consideration the figures from
2000 to present, a total of 143,685 or 85 percent of the City's households moved into their unit during
this time frame. 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 Table HIP-1, which is a comparison between the
ACS 2015 and the ACS 2017 1-Yr. estimates, the City's share of households earning less than $10,000 fell
from 17.2 percent to 12.7 percent. In fact, during this same period, the share of every low-income
category fell while higher income households rose. It is important to understand that these figures do not
necessarily indicate that the City "lost" residents in low-income categories, but perhaps because the City's
landscape has changed, it quite possibly has added more households to the higher income brackets.
2020-2024 Analysis of Impediments to Fair Housing Choice
37
This information, combined with census demographic data that illustrated a dramatic change in
population growth, household wealth, household mobility, and household type towards non -family help
us make the assumption that much of the new housing supply developed in the City over the last decade
was not intended to meet the demands of its residents, but instead has attracted wealthier individuals,
perhaps professionals without families, interested in living in the urban core and what the revitalization
of the City's central business district and surrounding neighborhoods like Brickell, Mid -town, Wynwood,
and the Design District has to offer. A simple fact remains: despite the market forces that increased the
supply of housing options in the City of Miami, nearly half the City households cannot find housing that
would not cost -burden them. Perhaps more ominous in a City of renters that has experienced a robust
injection of multi -family units over the past decade: a staggering 62.8% of the City's renter households
are cost -burdened. The high rates of cost burden indicate that the available affordable housing stock is
not meeting the needs of City residents. The demand for low-cost rental options in Miami is corroborated
by an article in Bloomberg Business Week in which a private affordable housing developer stated that,
especially near the job core and transit lines, there is an insufficient supply of low-cost rental options
compared to the demand. The article quoted that the demand "is so large that even if developers had the
resources to build five times as many units per year in the area, thousands would still be in need."
Therefore, the following broad statement can be made - Miami's housing market does not provide
sufficient:
Affordable housing options —especially low-cost rental units: Over half the City of Miami is cost -
burdened and a staggering segmentof the cost -burdened (62.8 percent) and severely cost -burdened (35.4
percent) households in the City of Miami are renters. Considering the majority of the City's households
rent, there is a general need for affordable rental options for households across income brackets.
Small multi -family unit structures ideal for affordable rental: While the City experienced an increase in
housing units, there were notable decreases in small multi -family structure types. Of particular note was
the loss of small multi -family units in structures containing two to nine units. These structure types
traditionally support affordable rental housing in older urban neighborhoods and are often considered
ideal affordable rental communities.
Affordable rental units with three or more bedrooms large families: Occupancy data by tenure illustrated
that the smaller the unit size, the greater the chance it will be occupied by a renter. Therefore, families
that require more than two bedrooms may have trouble finding rental opportunities in the City of Miami —
the choices are even more limited if the family is cost -burdened.
Affordable rental options are needed to accommodate small families: Small households have a greater
need than the other population sub -categories. Approximately, 35,585 small households are cost -
burdened or severely cost -burdened in the City of Miami the greatest majority of these households are
renters, especially in the low-income categories.
Affordable rental and single-family rehabilitation programs for the City's elderly population: According
to the US Census, 16.7 percent of City residents are 65 years and over9. These statistics are important to
consider in light that the growth rate of the elderly population is low comparatively to the workforce age
residents in the City, but make up a significant share of the City's population comparatively to other large
9 US Census, 2013-2017 ACS, 5-Near Estimates (S0103)
2020-2024 Analysis of Impediments to Fair Housing Choice
38
cities. The CHAS data analyzed in the Needs Assessment found that a significant portion of the population
in the lowest income category are made up of elderly households and, thus, elderly renter and
homeowner households experience high rates of housing problems due to high costs — this group is the
only household type in the City with a significant number of homeowners experiencing cost -burden.
Tenant -based HOPWA rental assistance to help meet the need of persons living with HIV/AIDS in Miami -
Dade County in need of housing assistance: A large number of persons living with HIV/AIDS in Miami -Dade
County have limited income due to their disability and, thus, there is a need for more safe and affordable
housing options. The 2017 Miami -Dade HIV/AIDS Housing Gap Analysis found that 10,116 persons living
with HIV/AIDS in Miami -Dade County are in need of housing assistance.
Expansion of Permanent Housing Options and Homeless Prevention and Diversion Resources: The CoC
is focused on rapidly re -housing homeless individuals and families into permanent housing. The CoC has
identified the need to add up to 200 units of permanent housing for homeless households to its inventory
each year, with a particular focus on chronically homeless persons, seniors (62+), unaccompanied youth
(18-24), families and veterans. The CoC is also increasingly focused on diversion and prevention strategies.
Diversion prevents homelessness for people seeking shelter by helping them identify immediate,
alternate housing arrangements and, if necessary, connecting them with services and financial assistance
to help them return to permanent housing. Prevention uses rent and utility assistance along with
supportive services to help households that would otherwise become homeless regain stability and
remain housed. Together, these strategies are being utilized to promote system flow, making
homelessness rare, brief and one-time. By enhancing strategies to prevent and divert homelessness,
while also adding permanent housing strategies to enhance exit opportunities, crisis housing (emergency
shelter) can be more readily available when needed.
HOUSING STOCK AND TENURE
According to Table HST-1, owner -occupied housing units comprise 28.9 percent (49,202 units) down from
32.3 percent (51,186 units) in 2010. Renter -occupied units comprise 71.1 percent (120,803 units) of
occupied units up from 65.3 percent (107,131 units) in 2010. The percentage of renter -occupied units in
the City of Miami far exceeds both Miami -Dade County (48.9 percent) and the State of Florida (34.8
percent). Significantly, the average household size (3.07 persons) of owner -occupied units and renter -
occupied (2.50 persons) have increased since 2010.
Table HST-1: Housing Tenure 2000, 2010, 2017
Housing Tenure
2017 2010 2000 Change 2010-2017
Estimate Percent Estimate Percent Estimate Percent Estimate Percent
Occupied Housing Units
Owner -Occupied
Renter -Occupied
Average HH Size of
Owner -Occupied Unit
Average HH Size of
Renter -Occupied Unit 2.50 2.37 2.52
Source: 2014-2018 Five -Year Consolidated Plan, U.S. Census Bureau, 2017 American Community Survey 1-Year Estimates (CP04)
100.0% 158,317 100.0% 134,198 100.0% 11,688 7.4%
49,202 28.9% 51,186 32.3% 46,836 34.9% -1,984 -3.9%
120,803 71.1% 107,131 65.3% 87,362 65.1% 13,672 12.8%
3.07
2.67
2020-2024 Analysis of Impediments to Fair Housing Choice
2.79
(X)
(X)
39
Table HST-2: Housing Tenure by Region, 2017
Housing Tenure by Region, 2017
2017
Owner- Renter -
Occupied Occupied
State of Florida
5,010,187
2,679,777
Miami -Dade County
445,138
427,357
City of Miami 49,202 120,803
Source: U.S. Census Bureau, 2017 American Community Survey 1-Year Estimates (CP04)
Housing choice and opportunity are characterized by several factors including affordability, location, type
and bedroom distribution. The number of bedrooms in a community's rental housing supply is particularly
important as most low- and moderate -income families rent their housing units.
Table HST-3: Housing Unit Size by Tenure, 2017
Housing Tenure
OWNERS
RENTERS
TOTAL
Estimate Percent Estimate Percent Estimate Percent
No bedroom
1 bedroom
2 bedrooms
3 or more bedrooms
Total
901 5.9% 14,466 94.1% 15,367 100.0%
4,927 10.2% 43,388 89.8% 48,315 100.0%
17,959 29.1% 43,675 70.9% 61,634 100.0%
25,415 56.9% 19,274 43.1% 44,689 100.0%
49,202 28.9% 120,803 71.1% 170,005 100.0%
Source: U.S. Census Bureau, 2017 American Community Survey 1-Year Estimates (B25042)
Despite the market forces that have led to the increase in housing options in the City of Miami, data shows
that over 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.
Table HST-4: Miami Selected Housing Characteristics
Total Housing Units
Occupied housing units
Vacant housing units
Units in Structure
2009-2013
2013-2017
Estimate Percent Estimate Percent
187,938 196,618
150,974 80.3 164,734 83.8
36,964 19.7 31,884 16.2
1-unit detached structure 48,816 26.0 48,740 24.8
1-unit attached structure 18,578 9.9 19,742 10.0
2 units 9,291 4.9 8,299 4.2
3 or 4 units 9,673 5.1 9,271 4.7
5 to 9 units 13,939 7.4 14,163 7.2
10 to 19 units 13,624 7.2 14,965 7.6
20 or more units 72,879 38.8 80,511 40.9
Mobile home 1,029 0.5 903 0.5
2020-2024 Analysis of Impediments to Fair Housing Choice
40
Estimate Percent Estimate Percent
Boat/RV/van etc. 109 0.1
Source: 2009-2013 ACS 5-Year Estimates vs 2013-2017 ACS 5-Year Estimates (DP04)
24
0.0
HOUSING UNIT SIZE
As noted in the table below, the majority of units in the City are two -bedrooms (37.8%) followed by one -
bedrooms (31.2%). 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.
Table HUS-1: Miami Selected Housing Characteristics by Unit Size
Total Housing Units
No bedroom
1 bedroom
2 bedrooms
3 bedrooms
4 bedrooms
5 or more bedrooms
2009-2013
187,938
11,515
59,754
71,991
34,582
8,037
2013-2017
6.1 14,628 7.4
31.8 61,421 31.2
38.3 74,299 37.8
18.4 36,003 18.3
4.3 8,586 4.4
1,681 0.9
2,059
1.1
Source: U.S. Census Bureau, 2009-2013 ACS 5-Year Estimates vs 2013-2017 ACS 5-Year Estimates (B25041)
A CITY OF RENTERS
The City of Miami has long been a city of renters. One can especially understand the extent of this when
comparing local data to the region. According to the 2013-2017 ACS 5-Year estimates, 69.8 percent of the
of the total occupied housing units in the City of Miami were made up of renters, while a lower 47.8
percent of Miami -Dade County's occupied units were renters and an even lower 35.2 percent of the State
of Florida's residents were renters.
Table CR-1: Tenure of Housing Units
Renter Households
Home Owner Households
Total Households
114,911
49,823
69.8
30.2
164,734 100.0
Source: U.S. Census Bureau, 2013-2017 ACS 5-Year Estimates (B25003)
2020-2024 Analysis of Impediments to Fair Housing Choice
41
Comparing statistical figures from a recent report (2017) from New York University's Furman Center and
Capital One Financial Corp, the City of Miami's housing rental market would rank first in the nation with
69.8 percent renter households surpassing Los Angeles, CA10 by a large margin.
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.
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 CR-2 analyzes gross rent as a percentage of
household income. As indicated, approximately 66.2% (an increase from 62.8% reported on 2011-2015
ACS 5-Year estimates) 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 CR-2: Gross Rent as a Percentage of Household Income
Occupied Units Paying Rent
Less than 15.0 percent
15.0 to 19.9 percent
20.0 to 24.9 percent
25.0 to 29.9 percent
30.0 to 34.9 percent
35.0 percent or more
2007-2011
2013-2017
Number Percent
92,656 100.00 108,245 100.0
5,004 5.4 6,921 6.4
6,394
6.9
7,835
7.2
8,797 9.5 1 10,374 9.6
10,388 11.2 1 11,428 10.6
9,388 10.1 1 10,418 9.6
52,685 56.9 1 61,269 56.6
Source: U.S. Census Bureau, 2007-2011 ACS 5-Year Estimates vs 2013-2017 ACS 5-Year Estimates (B25070)
Estimated No. of Units not computed in 2013-2017 ACS = 6,666 units
Table CR-3 below shows how rents for occupied units have changed from the 2007-2011 ACS 5-Year
Estimates to the 2013-2017 ACS 5-Year Estimates. A noticeable change occurred in households paying
$500-$749 which shows an approximate 6 percentage point decrease or 3,767 units. The bulk of the rents
being paid remain in the higher side or the rental scale paying $750 or more, however, the percentage of
households paying higher rents has increased from 67.3 percent to 76.6 percent. The spike in rental
amounts coincides with the increase in the number of renters combined with a decline in rental housing
stock.
According to NYU Furman Center's study titled "Renting in America's Largest Metropolitan Areas," which
was released in March, 2016, Miami experienced a 10 percent decline in rental housing stock from 2006
to 2014. The renter population in Miami grew more quickly than the rental stock creating a rising demand
for rental housing forcing rental costs to increase. The report points out, "The Miami metro area, where
the median rent was more than $150 higher than the national benchmark while the median renter's
10 NYU Furman/Capital One National Affordable Rental Housing Landscape
Research Study, www.furmancenter.orq/NationalRentalLandscape
2020-2024 Analysis of Impediments to Fair Housing Choice
42
income was over $1,000 lower than that figure among metros nationwide, pops out as a troubling
exception —a high -cost city without high incomes."
Table CR-3: Renter -Occupied Housing Units
Occupied Units Paying Rent
Median Gross Rent
Less than $200
$200 to $299
$300 to $499
$500 to $749
$750 to $999
$1,000 to $1,499
$1,500 or more
2007-2011
95,225
100.0
$910
2013-2017
Number Percent
112,324
100.0
$1,056
4,111 4.3 2,500 2.2
4,432 4.7 5,590 5.0
5,296 5.5 4,645 4.1
17,349 18.2 13,582 12.1
25,328 26.6 25,250 22.5
25,520 26.8 32,344 28.8
13,189 13.9 28,413 25.3
Source: U.S. Census Bureau, 2007-2011 ACS 5-Year Estimates vs 2013-2017ACS 5-Year Estimates (B25063)
Estimated No. of Units not computed in 2013-2017ACS = 2,587 units
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 (54%) have a mortgage on their housing unit.
Table CH-1: Mortgage Status, Owner Occupied Units City of Miami
Owner -occupied units
Number Percent
Owner -occupied units 49,823 100%
Housing units with a mortgage 26,873 54%
Housing units without a mortgage 22,950 46%
Source: U.S. Census 2013-2017 ACS 5-Year Estimates (B25081)
When looking at the selected monthly homeowner costs as a percentage of household income, these have
experienced a minimal decline. The bulk (49.6%) of City homeowners are paying more than 30% of their
income towards their monthly owner costs, a reality that is concerning, as noted in Table CH-2
Table CH-2: Selected Monthly Owner Costs as a Percentage of Housing Income
Number
Housing Units with a Mortgage
Less than 20.0 percent
20.0 to 24.9 percent
25.0 to 29.9 percent
:.............................................................................
30.0 to 34.9 percent
26,530
7,475 28.1
3,054 11.5
100.0
2,8641 10.8
2,035 7.6
2020-2024 Analysis of Impediments to Fair Housing Choice
43
35.0 percent or more
11,1021 42.0
Source: U.S. Census Bureau, 2013-2017 ACS 5-Year Estimates (B25091)
Table CH-3 indicates that the bulk of homeowners with a mortgage continues to be at the $2,000 and up
cost category (26 percent). While there has been a small decrease from the 2009-2013 ACS, it is still the
group with the highest percentage in owner cost.
Table CH-3: Percent of Selected Monthly Owner Cost
Less than $300
5300 to $499
$500 to $699
5700 to $999
$1,000 to $1,499
$1,500 to $1,999
$2,000 or more
:.................................................................
Source: U.S. Census Bureau, 2013-2017 ACS 5-Year Estimates (B25094)
2009-2013
ACS
7.8
2013-2017
ACS
8.6
12.1 13.2
9.7 9.2
11.0 11.9
17.2 17.0
PUBLIC AND SUBSIDIZED HOUSING
The HCD does not administer Public Housing within its jurisdiction. The latter is managed by another
entitlement, the Public Housing & Community Development (PHCD) Department of Miami -Dade County.
Nonetheless, the HCD gathers statistics on the quantity and age of public housing stock within the City of
Miami's limits, along with some of the characteristics of that housing. Of special note is the fact
that about 70% of the County's public housing stock, of 9,506 units total, is within our jurisdiction(Miami)
primarily because Miami is the oldest of Miami -Dade County's 34 incorporated municipalities, established
in July 1896. Due to the age of many of these buildings (average being over 40 years) and the limited
capital funding available to the PHCD (presently around $12 million annually) to make repairs and
renovations, the PHCD has been steadily working for several years to rehabilitate/upgrade existing public
housing units, removing and replacing those that were obsolete, and increasing the number of income -
restricted units on underutilized sites with private sector partners via the Rental Assistance
Demonstration (RAD) program.
Some of these renovations have taken place at sites located within the City. The RAD program allows for
the conversion of a public housing subsidy platform to a Project Based Voucher subsidy platform, which
is a more stable funding source.. In December, 2018, PHCD submitted applications to HUD to achieve a
RAD portfolio award for a total of 6,426 units, and subsequently received approval from HUD in March,
2019. As part of PHCD"s Plus, an additional 6,000 to 10,000 affordable and workforce units are potentially
projected for construction on top of the 6,400 units referenced. The RAD rent structure allows for
increased subsidy over time compared to the public housing funding model.
2020-2024 Analysis of Impediments to Fair Housing Choice
44
The County also oversees approximately 1,955 mod -rehab units in its Section 8 program and 15,368
Section 8 vouchers (with an average of 13,800 active on a monthly basis)." Their average Housing
Assistance Payment is just under $940. The County's Waitlists for Project Based Units and Tenant Based
Units were both established in 2014.
As to City of Miami, we can only address the assisted housing we administer, which includes 158 Section
8 Housing Choice Vouchers (HCV) and 268 mod -rehab units. The latter units are in 16 privately owned
buildings, located primarily in the Little Havana and Liberty City neighborhoods. The buildings' combined
inventory totals 15 studios, 215 one -bedroom units, and 38 two -bedroom units. Ten of these
buildings were built on or before 1930. Due to their significant age, there are limitations as to the
renovations possible at these sites, such as an inability to accommodate elevators. The age of the
properties is obviously of concern to HCD, as there is already a shortage of landlords interested in taking
on project -based units, given the Miami market's high demand for rental units and escalating rental rates.
The City has two separate waitlists for these programs. The City's waitlist for HCV's vouchers last opened
for pre -applications for two days in Oct. 2014 (with a preference of Elderly or Disability) during which
4,000 persons applied. A random, computerized waitlist was established of 100 names which is still being
worked through. The City's Section 8 moderate rehabilitation program waitlist was established in 2003
and 20,000 persons applied.
In the last waitlists established for the City of Miami's Section 8 programs, specific information on race
and ethnicity was NOT requested in the application itself. As such, the City cannot provide
certain demographic information on said waitlists at this time. The City has noted HUD's expectations as
to identifying particular characteristics of Section 8 applicants, and will request this type of data (ethnicity,
race, etc.) when establishing future waitlists.
Table PSH-1: Public Housing Total Number of Units
Certificate
Mod- Public
Rehab Housing
# of Units/
Vouchers
Available
# of
Accessible
Units
*includes Non -Elderly Disabled, Mainstream Five -Year, and Nursing Home Transition
Source: PIC (PIH Information Center)
Total
Vouchers
Special Purpose Voucher
Project- Tenant- Veterans Family
Based Based Affairs Unification
Supportive
Housing Program
9,219 14,742
0
Because of the age of the public housing stock, the County estimates its redevelopment needs at
approximately $1.9 billion agency -wide. Generally, they indicate that their older stock has inherent
deficiencies tied to the age of the property, noting that mechanical, electrical, and plumbing upgrades are
needed, as well as security systems, building envelopes (hurricane resistance), fire safety, windows and
doors.
As of 2019, 13 Public Housing redevelopment projects have been completed: Total number of units are
1,622 Units (1,222 Public Housing and 400 Non -Public Housing/Affordable). As of 2019, four (4) Public
P 5-YEAR PHA PLAN (2015-2020) Miami -Dade County, effective 10/2018
2020-2024 Analysis of Impediments to Fair Housing Choice
45
Housing development projects are under construction: total number of units are 614 Units (321 Public
Housing and 293 Non -Public Housing/Affordable). As of 2019, one Public Housing Site is projected to close
in next three months: total number of units is 204 Units (73 Public Housing and 131 Non -Public
Housing/Affordable).
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 in both the HCV Program and the Moderate Rehabilitation Program as overseen
by the HCD. 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. If an applicant or
participant indicates that an exception, change, or adjustment to a rule, policy, practice, or service is
needed because of a disability, HUD requires that the PHA treat the information as a request for
reasonable accommodation, even if no formal request is made [Joint Statement of the Departments of
HUD and Justice: Reasonable Accommodations under the Fair Housing Act].
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
2020-2024 Analysis of Impediments to Fair Housing Choice
46
■ 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.
WAITING LISTS FOR HCV AND THE MODERATE REHABILITATION PROGRAM
As the PHA, the HCD 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 HCD operates a very small program (143 vouchers) and the program's level of attrition is
extremely low, the City (via the HCD) 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 includes 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 WL-1 below provides details on the demographics of the applicants during the last Section HCV
Application period:
Table WL-1: Characteristics of Applicants to the City of Miami Section 8 HCV Program (2014)
Total number of eligible applicants 4,091 100.0%
:.................................................................................................................................................................................................... d.............................................................:.......................................................:
Hispanic 2576 63.0%
:....................................................................................................................................................................................................:.............................................................:........................................................
Gender
--Female
.......................................
--Male
Race
......................
--African American
--American Indian
--Asian
...........................
--Other
:.....................................................................
--White
:.....................................................................
American citizen
--Yes
--No
2020-2024 Analysis of Impediments to Fair Housing Choice
2908
1183
1647
8
19
2416
803
71.0%
............................ .
29.0%
40.3%
0.0%....,
20.0%
47
Preference Identified (Elderly/Disabled)
--Yes 2097 51.0%
--No 1994 49.0%
Source: City of Miami, Dept. of Housing & Community Development
*Note: Hispanic ethnicity is counted independently of race.
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 given that Florida's counties are diverse and each
have their own set of challenges.
To this end, we feel is crucial 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
2020-2024 Analysis of Impediments to Fair Housing Choice
48
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.
Map LIHTC-1: Metrorail System
Mara I. WC4wv+.niwLI44+'" n feoCRina n QM VALI ana c.q LAA
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
2020-2024 Analysis of Impediments to Fair Housing Choice
49
the City's total LIHTC project count sits at 95. Please note, that some of the assisted developments are
RAD (public housing) projects.
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 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 157 projects have been funded
and are still in the program, leaving a total County count of 63 tax credit developments. This means that
approximately 94 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).
City of Miami - Low Income Housing Tax Credit
•
•
•
•
•
efti
•
t•
k•
.,I,.•;i
• •.j.a •
Re
• al
•
Data Source: Shimiberg Center University of Florida 2019
•
RENTS
The Fair Market Rents in Miami -Dade County are noted below. A recent analysis prepared by the National
Low Income Housing Coalition (NLIHC), Out of Reach 2019, 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 in the Miami -Miami Beach -Kendall HUD Metro
2020-2024 Analysis of Impediments to Fair Housing Choice
50
FMR Area based a rent amount of $1,454 was $27.9612. If this formula is adjusted to today's figures, with
an updated FY2020 FMR for a two -bedroom unit of $1,625 in Miami, a household must earn
approximately $5,416 monthly or $64,992 annually. Assuming a 40-hour work week, 52 weeks per year,
this level of income translates into an hourly housing wage of $31.25. As per the report, this would require
at least 2.7 full-time jobs at minimum wage. However, the estimated hourly wage in for City of Miami
residents is $19.39.
Table HM-3: Fair Market Rents
Miami/Miami Beach/Kendall
HUD Metro FMR Areas for all bedroom sizes
Studio 1-bedroom 2-bedroom 3-bedroom 4-bedroom
2019 $951 $1,147 $1,454 $1,934 $2,354
2020 $1,084 $1,285 $1,625 $2,164 $2,621
Source: www.huduser.orq
Utilizing 2019 FMRs, the HCD ran a brief analysis to try and pinpoint the affordability gap in our
marketplace based on unit sizes, and assuming $40,327 as the median household income. The graph
below shows the gap in multiple categories including Fair Market Rents (FMR) and HOME assisted units.
Table HM-4: Rental Affordability Gap by Unit Size, City of Miami
ssumptions b c '
"ty of Miami
City of Miami Median HH Income
$ 40,327
30% of Median HH Income divided by 12 Months
$1,008
City of Miami Median Gross Rent
(2013-2017)
Unit Size
-
Monthly Rent
($)
$1,056
Affordability
Gap
($48)
Fair Market Rent, FY2019
0 Bedroom
951
1 Bedroom
1,147
($139)
2 Bedroom
1,454
($446)
3 Bedroom
1,934
($926)
4 Bedroom
2,354
($1,346)
High HOME Rent
0 Bedroom
944
-
1 Bedroom
1,013
($5)
2 Bedroom
1,217
($209)
3 Bedroom
1,398
($390)
4 Bedroom
1,540
($532)
Low HOME Rent
0 Bedroom
741
-
1 Bedroom
794
-
z http://nlihc.org/oor
2020-2024 Analysis of Impediments to Fair Housing Choice
51
2 Bedroom 953
3 Bedroom
1,101 ($93)
4 Bedroom
1,228 ($220)
Sources: City Gross rent and Median Household Income, US Census Bureau American Community Survey;
Fair Market Rent, US HUD; High/Low HOME Rent, Miami Dade Affordable Rental from Tax Credit
Developers, Reinhold P Wolff Economic Research.
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.
Table CB-1: Percent of Cost -Burdened Renter Households
Total Number of Renter Households
108,612
(x)
Paying on Ren E`
# of Households % of Households
Less than 15 percent of Income
6,210
5.7%
15-19.9 percent of Income
7,027
6.5%
20-24.9 percent of Income
9,675 8.9%
25-29.9 percent of Income
11,015 10.1%
30-49.9 percent of Income (Cost -Burdened) 29,750 27.4%
35 percent or more of Income (Severely Cost -Burdened) 38,480 35.4%
Not computed 6,455 5.9%
Cost -Burdened
68,230 62.8%
Source: U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates (B25070)
Table CB-2: Percent of Cost -Burdened Home Owner Households
Total Number of Owner Households
48,735
(x)
Paying on Mortgage or Without a Mortgage: # of Households % of Households
Less than 15 percent of Income
13,000
26.7%
15-19.9 percent of Income
5,549
11.4%
20-24.9 percent of Income
5,000 10.3%
25-29.9 percent of Income
4,335 8.9%
30-49.9 percent of Income (Cost -Burdened)
8,385 17.2%
35 percent or more of Income (Severely Cost -Burdened)
11,260 23.1%
Not computed
1,206 2.5%
Cost -Burdened
19,645 40.3%
Source: U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates (B25091)
2020-2024 Analysis of Impediments to Fair Housing Choice
Not Cost -
Burdened
Cost -
Burdened
Not Cost -
Burdened
Cost -
Burdened
52
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 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.
■ Severely Cost -burdened households: As per HUD, Households spending more than 50 percent are
considered to be "severely cost -burdened." Of the City's 55 percent of cost -burdened households,
more than half (31 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 (62.8%) of the severely cost -burdened
households in the City are renters.
Table CB-3: Housing Cost Burden — Owners & Renters
Race or Ethnicity
<=30% of
Income toward
Housing Cost
(Not Cost -
Burdened
30-50% of
Income toward
Housing Cost
(Cost- Burdened)
>50% of Income
toward Housing
Cost
(Severely Cost -
Burdened
Cost -Burdened
Not Available
Total
Jurisdiction as a whole
66,430
42%
White
13,475
37,060
24%
48,435
31%
4,395
5,015
15,409 I=1 157,334
(x) (x)
770
57% 19% 21% (x)
23,655
(x)
Black/African American
8,665 5,330 7,185 1,665 22,845
38%
23%
31%
(x)
(x)
Asian
980 385 270 65
58% 23% 16% (x)
1,700
(x)
American Indian, Alaska Native
105 45 30 15
54% 23% 15% (x)
195
(x)
Pacific Islander
0
0 0 0 0
0% 0% 0% (x) (x)
Hispanic
42,660 26,640 35,745 2,840 105,045
41% 25% 34% (x) (x)
Other Non -Hispanic
Source: 2011-2015 CHAS
0
0%
250
51%
190
38%
54
(x)
494
(x)
With 55.8 percent cost -burdened households, the City of Miami is one of the most unaffordable cities in
the nation. The City's share of cost -burdened renters as a proportion of all households is 1.8 times the
national average. In fact, more Miamians living in larger households may be masking the true scale of the
problem.
The City of Miami's high rate of cost -burdened households has become a near permanent feature of the
local economy. Since 2000, the percentage of cost -burdened households in the City has consistently run
2020-2024 Analysis of Impediments to Fair Housing Choice
53
at 1.5 times the national average. The most significant difference between Miami and the rest of the
nation has been the rate of growth in cost -burdened renter households since 2000. At the national level,
cost -burdened renter households grew from 14.3 to 17.5 percent of all households from 2000 to 2015. In
Miami, rather than peaking and receding, the composition of cost -burdened renter households has been
steadily growing without interruption since 2000, increasing from 41.8 percent of all households (owner
and renter households) in the City to its current peak of 55.8 percent of all households.
Table CB-4: Percent of Cost -Burdened Households
Total Households Cost -Burdened Household
Renter Households
108,612
68,230
Home Owner Households
48,735
19,645
Total Households
157,347
87,875
Total % of Households that are cost -burdened
55.89,
Source: U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates — Derived from Table B25091
Forecasting a significant decline in the City's cost -burden rate without aggressive intervention is probably
unrealistic, for three reasons. First, the dynamics driving housing affordability in the City of Miami have
been moving in the wrong direction — housing prices and rents increasing faster than wages, slow higher -
wage job creation or absorption, tightening vacancy rates, and increasing speculative investment that
permanently removes more units each year from the local market.
Second, increasing household size may be suppressing the City's cost -burden rate. The small increase in
median household incomes at the middle of Miami's income ladder may simply be that more people are
living together. The fastest way to increase total household income is to add a roommate, even if they are
employed part-time or move in with other family members.
Lastly, the City's upward housing price trends typically move much faster than wages and income.
Historically, housing prices and rents in the City have demonstrated considerable rates of increase over
short time periods. Conversely, the City would need to undergo a monumental change in its industrial and
occupational structure in order to create higher wage jobs and significantly impact its affordability
indicators (affordable housing cost and income gaps). Historically, the City of Miami's and Miami -Dade
County's economy have shown they can shed high -wage jobs very quickly, but struggle in adding new
high -skill, high -paying jobs. The City has historically not had many large scale employers (100+ employees)
either, and the bulk of its businesses (68%) feature four employees or less (source: Miami -Dade Beacon
Council).
The Miami area has one of the most cost -burdened middle -income households in the nation
Although the numbers clearly show that Miami's poorest residents are severely cost -burdened, there is
growing evidence that the middle class is also being squeezed. According to a report from the Joint Center
of Housing Studies of Harvard University "The State of the Nation's Housing 2018," which evaluated the
100 largest U.S. metropolitan areas for middle class cost -burden, the Miami metropolitan area ranked as
the thirteenth metropolitan area in this category with 38.6 percent of middle-class households in the
$45,000 to $74,999 income range and 66.1 percent in the $30,000 to $44,999 income range being cost -
burdened. Housing costs outpace income growth in the area due in part to foreign investment and rapid
population growth.
2020-2024 Analysis of Impediments to Fair Housing Choice
54
HOMEBUYER AFFORDABILITY FOR SPECIAL NEEDS POPULATION
Several mechanisms have been in place for about a decade, 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 10% of the total units for which they
are applying for Extremely Low Income (ELI) households. Starting in 2009, Florida Housing began requiring
Applicants commit to reserving 50% of their 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 serve
as coordinators to assist special needs households with supportive services. Meanwhile, the tax credit
developer and referral agency create a Memorandum of Understanding (MOU) which 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.Based on data provided to us by the Florida
Housing Finance Corp. As of January 2020, there were 427 units in Miami -Dade under the LINK Program;
210 of thse units were located in the City of Miami.
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) filed by the HCD 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.
(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 Table ET-1 below, The Black/African American population has
the lowest median household income in the City of Miami and it is also the Race group that has
experienced the least increase in median household income in the past 4 years (+$2,114). The
Hispanic/Latino population also did not fare much better either since it reported the second lowest
median household income with small increases in comparison to Asians who had an average increase of
$22,717 in just the past 4 years. This increase is more than the median household income of the
Black/African American population.
2020-2024 Analysis of Impediments to Fair Housing Choice
55
Table ET-1: Median Household Income by Race, City of Miami
Race / Ethnicity
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)
:.............................................................................................................................................................................
Source: U.S. Census Bureau, 2009-2013 ACS 5-Year Estim
Estimate
Inflation Adjusted
Dollars (2013)
$66,210
....................................:
$20,436
....................................
$55,833
....................................:
$34,422
....................................:
$37,266
....................................:
$27,873
Estimate
Inflation Adjusted
Dollars (2017)
es vs. 2013-2017 ACS, 5-Year Estimates (B19013)
Change
+$15,986
+$2,114
+$22,717
+$1,110
+$8,028
+$3,723
Income and employment are two essential characteristics that impact a household's sustainability and
economic growth.
INCOME
The median household income in Miami is $40,327 while Miami -Dade County's is $49,930. Historically,
this is usually the case - with the County's median income averaging significantly higher than the City's
median income. When further analyzing Miami's household income brackets (see Table HI-2 below), 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 under 60% of the renter -occupied units are occupied by households making $34,999
and below.
Table HI-1: Household Income: City of Miami vs Miami -Dade County
City of Miami Miami -Dade Count
Median Household Income
$40,327
$49,930
Per Capita Income
$27,250
$25,996
Persons in Poverty, Percent* 25.8% 19.0%
Source: U.S. Census Bureau, 2017American Community Survey 1-Year Estimates (B19013, B19301)
* U.S. Census Bureau, 2013-2017American Community Survey 5-Year Estimates
Table HI-2: Percentage of Household Income in the Past 12 Months (In 2017 Adjusted $)
Subject
Occupied
Housing Units
Owner -Occupied Renter -Occupied
Housing Units Housing Units
Occupied Housing Units
164,734
49,823
114,911
Income Brackets
Percent
Percent
Percent
Less Than $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 or more
13.1
11.7
10.2
10.5
14.9
11.3
12.7
15.5
Source: U.S. Census Bureau, 2017American Community Survey 5-Year Estimates (S2503)
23.4
15.4
12.2
13.0
13.5
7.6
7.5
7.5
2020-2024 Analysis of Impediments to Fair Housing Choice
27.9
17.0
13.0
14.0
12.8
6.1
5.2
4.1
56
When looking at how City incomes have changed within the past decade or so, specifically when
comparing the 2010 ACS to that of the 2017 ACS, 5-Year Estimates, 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 this data, the City's share of household earnings less than $10,000 fell from
26.5% to 15.0%. 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
continues to evolve, quite possibly, adding more households to the higher income brackets, and, thereby
changing the share of households in these income categories.
Chart HI-1: Percentage of Household Income Comparison 2010 vs 2017
$200,000 or more 11
$150,000 to $199,999
$100,000 to $149,999
$75,000 to $99,999
$50,000 to $74,999
$35,000 to $49,999
$25,000 to $34,999
$15,000 to $24,999
$10,000 to $14,999
Less than $10,000
0.0% 2.0% 4.0% 6.0% 8.0% 10.0% 12.0% 14.0% 16.0% 18.0%
1N 2017 ACS ■ 2010 ACS
Source: U.S. Census Bureau, 2010 & 2017 American Community Survey 5-Year Estimates (51901)
LABOR FORCE
The economic well-being of a community is largely determined by how well the residents are connected
to the labor market. Currently, 61.8 percent of the population 16 years and over is in the labor force.
Table LB-1 below shows that about 5 percent of the City's workforce population is unemployed. However,
according to the Florida Department of Economic Opportunity's Local Area Unemployment Statistics'
Local Area Unemployment Statistics (LAUS) data, in December 2017 the State of Florida had a 3.8 percent
unemployment rate; a 4.3 percent 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.
2020-2024 Analysis of Impediments to Fair Housing Choice
57
Table LB-1: Labor Force
Number Percent
Population 16 years and over
371,805
100.0
In Labor Force (16 Years and older)
229,792
61.8
Civilian Labor Force
229,640 56.8
Employed
211,126 56.8
Unemployed
Not in Labor Force
Source: 2013-2017 ACS, 5-Year Estimates (DP03)
18,514 5.0
142,013 38.2
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
50% 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 WK-1: Industry by Occupation for the Civilian Employed Population 16 Years and Over
Number Percent
Civilian employed population 15 years and over
Agriculture, forestry, fishing and hunting, and mining
Construction
Manufacturing
Wholesale Trade
Retail Trade
Transportation and warehousing and utilities
Information
Finance and insurance, and real estate and rental
211,126
784
20,661
8,012
6,958
23,560
14,075
3,976
16,501
Professional scientific, and management, and
administrative and waste management services
29,019
Educational services, and health care and social assistance 34,148
Arts, entertainment, and recreation, and accommodation
and food services
32,056
Other services, except public administration
100.0
0.4
9.8
3.8
3.3
11.2
6.7
1.9
7.8
13.7
16.2
15.2
16,037 7.6
Public Administration
5,339 2.5
Source: 2013-2017 ACS, 5-Year Estimates (S2405)
2020-2024 Analysis of Impediments to Fair Housing Choice
58
LEGAL STATUS EVALUATION
Evaluation of Current Fair Housing Legal Status
The Department of Housing and Community Development is actively engaged in promoting fair housing
for City of Miami residents through the monitoring of fair housing complaints and promoting and securing
compliance with fair housing regulations. The City's fair housing program is designed to affirmatively
further fair housing objectives of Title VI of the Civil Rights Act of 1964, Title VIII of the Civil Rights Act of
1968, as amended, and other relevant federal, state, and local fair housing laws.
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.
The City retains the private, not -for -profit Housing Opportunities Project for Excellence, Inc. (HOPE, Inc.)
to carry out trainings, workshops, and monitoring fair housing activities, specifically with the execution of
a testing component. 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). HOPE, Inc. is a private fair housing
not -for -profit organization dedicated to eliminating housing discrimination and promoting fair housing in
South Florida. HOPE, Inc. employs a three -tiered system of private enforcement, education outreach, and
counseling to achieve its mission to affirmatively further fair housing. Its programs are designed to ensure
that residents, including those living in the City of Miami, are offered the right to select housing of their
choice without discrimination based on race, religion, color, national origin, sex, disability, marital or
familial status, or such other protected classes as may be conferred by federal, state, or local laws.
FAIR HOUSING 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. 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 complainant. 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 HCD 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.
Looking at the category of inquiries on any given year, the overwhelming majority of the cases fall under
Landlord/Tenant Issues. The assumption that discrimination did or did not take place should not be made.
The second largest number of inquiries falls under Public Housing Assistance complaints. The table does
show, however, a declining trend on the number of complaints received in all categories.
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Table LS-1: Basis of Complaint
Protected Class / Complaint
Disability
Disability (Emotional Support Animal)
Disability (Reasonable Accommodation)
Familial Status
National Origin
Marital Status
Race
Sexual Orientation
Source of Income
Religion
Other
Rental (Landlord/Tenant Issues)
Public Assistance (Housing)
Financial Assistance
Homeowner Association
First Time Homebuyer
Foreclosure
Homeless
Total
Data provided by HOPE, Inc.
4/1/2016- 10/1/2017- 10/1/2018-
3/31/2017 9/30/2018 9/30/2019
3 1 -
3 - 2
1 2 -
3 - -
3 - -
1 - -
4 7 2
2 1 -
3 1
2
14 6 2
52 43 11
19 20 7
7 2
1 3 1
6 2 -
1 1 1
10 4 1
133 95 28
NATIONAL TRENDS
According to the National Fair Housing Alliance's (NFHA) 2018 Fair Housing Trends report, "Making Every
Neighborhood a Place of Opportunity," fair housing complaints (amounting to 29,031 filed in 2017,
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 in 2017 were disability
related (56.7 percent), followed by 18.5 percent of complaints reported that were race -related. This was
followed by familial status as the third most frequent basis for discrimination, with 2,675 cases (or 9.3
percent of all cases of housing discrimination). The fourth most frequent basis of discrimination was
national origin, with 1,951 reported cases (or 6.8 percent of all complaints), and the fifth most frequent
basis was sex, with 6.7 percent, or 1,917 complaints. Color was a basis of discrimination for 422 complaints
(1.5 percent), and religion was the basis of 383 complaints, or 1.3 percent of all complaints nationwide.
Housing discrimination occurs most often in the rental market, and the complaints reported in 2017 were
overwhelmingly rental -related complaints. The prevalence of discrimination in the rental market over
other types of transactions is because it is the most common and frequent type of housing transaction
and also because it is easier to detect discrimination due to the simplicity of the transaction itself. Testing
for rental discrimination is far more straightforward than testing for a real estate sales or mortgage
lending case, for example. In 2017, there were 17,981 complaints reported by private fair housing
organizations. This is consistent with the number in the past few years but represents 87.4 percent of all
transactions types, down from 91.4 percent last year and in 2015.
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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 departmental activities. In addition, the city distributes
free fair housing material at different city locations and at city sponsored events relevant to affordable
housing.
In addition, 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 refer to Table EOM-1 below 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.
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 EOM-1: Fair Housing Education and Outreach Activities FY2018-2019
• Date
Description
Location
Attendees
10/27/2018
10/27/2018
12/15/2018
12/15/218
1/26/2019
2/9/2019
Fair Housing Workshop (Creole)
Fair Housing Workshop (Spanish)
Fair Housing Workshop (Spanish)
Fair Housing Workshop (English)
Fair Housing Workshop (Spanish)
Fair Housing Workshop (Spanish)
Haitian American CDC
Cuban American National Council
Cuban American National Council
Neighborhood Housing Services
Cuban American National Council
Neighborhood Housing Services
10
5
4
17
6
43
2/16/2019 Fair Housing Workshop (English)
Neighborhood Housing Services 21
2/23/2019 Homebuyer's Workshop (Spanish)
Cuban American National Council 26
3/16/2019 Homebuyer's Workshop (English)
Neighborhood Housing Services 29
3/23/2019 Fair Housing Workshop (Spanish)
Cuban American National Council 25
4/5/2019
HOPE, Inc. 26th Annual Miami -Dade County Fair
Housing Month Celebration
Double Tree Biscayne Bay 93
4/26/2019 Homebuyer's Workshop (Creole)
Haitian American CDC 16
4/27/2019 Fair Housing Workshop (Spanish)
Cuban American National Council 12
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7/20/2019 Fair Housing Workshop (Spanish)
Cuban American National Council 6
7/27/2019 Fair Housing Workshop (English)
Neighborhood Housing Services 21
8/24/2019 Fair Housing Workshop (Spanish)
Cuban American National Council 12
9/14/2019 Fair Housing Workshop (Spanish)
Neighborhood Housing Services 37
9/21/2019 Fair Housing Workshop (Spanish)
Source: HOPE, Inc.
Cuban American National Council 14
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, the following case(s) were identified that have been litigated in the City of Miami
or that are of interest to the City of Miami since the last Al. Below is a brief description of these:
1. Royal House Apartments May 2019 — HOPE, Inc. joined a family in a federal housing lawsuit
against the owner of Royal House Apartments located at 4410 W. Flagler St for discriminating
against families with children. Once aware that the couple became pregnant, the property
manager advised them that there were no available apartments to lease when their current lease
expired, including the unit they were occupying under the excuse that the owner wanted to
renovate the facility, a process that would only take 3 days. The family asked to stay in a hotel
during the renovation period, but they were denied their request. After receiving the complaint,
HOPE Inc. sent multiple testers who found out discriminatory practices against families with
children.
2. In March 2018, the National Fair Housing Alliance (NFHA), Fair Housing Council of Greater San
Antonio (FHCGSA), Fair Housing Justice Center of New York (FHJC), and Housing Opportunities
Project for Excellence, Inc. collectively "Fair Housing Groups", settled a lawsuit against Facebook
that alleged that Facebook's advertisement platform enabled landlords and real estate brokers to
exclude people of color, families with children, women, people with disabilities and other
protected groups from receiving housing ads. The Fair Housing Group conducted investigations
that confirmed Facebook's alleged discriminatory practices. As part of the settlement agreement,
Facebook will work with NFHA to develop an in-house fair housing training program for Facebook
leadership and staff. Furthermore, Facebook will work with the Fair Housing Group to support
programs that expand fair housing opportunities throughout the country.
3. In March and October 2017, two separate individuals filed lawsuits alleging the miamigov.com
website was not accessible to persons with hearing disabilities and visual disabilities, respectively.
The City migrated to a new web platform in 2019 that accommodates disabilities.
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. These lawsuits were dismissed in 2014 in a decision
that later was overturned by the US Court of Appeals for the 11th Circuit and on May 2017, by a
vote of 5-3, the US Supreme Court stated that the City has standing to proceed to sue Wells Fargo
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over charges that predatory lending in minority communities damaged the city and its
homeowners. In January 2020, the City of Miami voluntarily dropped these fair housing lawsuits.
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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 FY2019-2020 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 Development Block Grant (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 activities that benefit low- and moderate -income persons. Eligible activities
include affordable housing, public service, and economic development activities.
The City (via the HCD) 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 the City of Miami. Different districts have
different priorities and workshops are held to address any questions related to the RFP. All RFPs submitted
are reviewed and scored and the HCD 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. In the manual, 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).
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.
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■ 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 HCD) 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 HCD
addresses any priority housing needs the City may have based on its current Consolidated Plan. The HCD
issued its last RFP in February 2019, a Request for Proposals for the construction/rehabilitation and
permanent financing for multifamily rental development and multifamily and single family
homeownership projects. The intent of the RFP was to make HCD aware of all of the potential housing
developments planned in different areas of the City in order to provide the widest range of affordable
housing opportunities. The RFP produced 29 applications. The City is providing assistance to 7
developments located in all districts in the City, fulfilling the City's goal.
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/HCD.
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
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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
individuals and their families. We directly address this population in further detail elsewhere in this
document.
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 HCD'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.
The Miami Forever Bond: Voted on and approved by City residents, is a $400M general obligation bond
that will fund projects that protect property from sea level rise and flooding, increase affordable housing,
improve parks and cultural facilities, improve roadways and enhance public safety. Out of the $400M,
$100M is for affordable housing and economic development activities. The City has issued a request for
applications for multi -family affordable housing developments, where bond funding can potentially be
used.
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.
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
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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. 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.
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.
ACTIVITIES
The City of Miami stated in its FY2019-2023 Consolidated 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, down payment 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
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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
Housing and Community Development is encouraging the construction of new rental units, especially
within target areas, as specified in the FY2019-2023 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, 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 HCD 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 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 focuses 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
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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 Housing and Community 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.
Homeownership Preservation Program (HPP): Expected to roll out by the end of 2020, and funded
through the Miami Forever Bond with an initial $4 million allocation, this will help homeowners who are
retired or cash strapped "harden" the exterior envelope of sing;e-family, owner -occupied homes, with a
maximum assistance amount of $50,000 per home. ten-year deferred loan for households up to 140%
AMI and a tax assessed market value that does not excceeed $400,000. Work can encompass the
replacement or repair of roofs, replacement of windows and/or window hurricane shutters and doors
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
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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.
■ Under 3.15 and 3.16 of the Zoning Code (Miami 21) developers are provide with additional density
if they agree to dedicate a certain percentage of their project units to specific income households
(via a restrictive covenant).
■ Impact Fee Deferrals.
■ 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: HCD 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.
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:
2020-2024 Analysis of Impediments to Fair Housing Choice
70
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.
Senior Rental Assistance Program: Funded with general funds for the 19-20 Fiscal Year, this program
provides assistance to income -eligible (40% AMI) senior households (ages 62 and up) who spend more
than 50% of their household income on housing costs AND who live in City -assisted rental housing or
subsidized buildings within City of Miami limits. The program provides up to $100 a month toward rental
housing assistance, for up to a year, for qualifying households.
Housing Opportunities for People with AIDS: Through the HOPWA Tenant -Based Rental Assistance
(TBRA) 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 850 clients assisted per
year. The City has also operated a Short Term Rental and Mortgage Utility (STRMU) program for the last
few years for low- to moderate -income persons with HIV/AIDS — who are not HOPWA TBRA clients — and
whom have had some emergency situation that has set them back in related housing expenses, STRMU
assists approximately 50 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 HCD 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 for 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.
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, and 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 low-income households although statistics
indicate that some 60% of homebuyers use an FHA Loan. This too can create a "stigma" tied to FHA loans
2020-2024 Analysis of Impediments to Fair Housing Choice
71
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.
Reports indicate that in the County's entire roster of 4,760 condo projects, only 7 are approved as of
March 202013, and not one is located within City of Miami limits This comes even after the FHA issued
new condominium approval rules that became effective in October 2019 (Docket #: FR-5715-F-02), hoping
to promote affordable and sustainable homeownership. The rules established a new condominium
process that supposedly allow certain individual condominium units to be eligible for FHA mortgage
insurance even if the condominium project is not FHA approved. The new rules included that (1) for
condominium projects with 10 or more units, no more than 10 percent of individual condo units can be
FHA -insured; and projects with fewer than 10 units may have no more than two FHA -insured units and (2)
FHA will insure mortgages for selected single -unit approval that is located in a completed project that is
not approved and has at least five dwelling units.
Below is a snapshot of the FHA map as of March 31, 2020 which shows the low concentration of projects
(five) and units in an area where there are thousands of condominium offerings. Perhaps it will take more
time for the new FHA guidelines to settle into the marketplace and catch on, given that these were only
issued a few months ago or perhaps the process continues to be too laborious for potential
buyers/condominium projects.
Map Satellite
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W fdFle
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Lauaeraale
Hollytd
avenwre
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Palmetto Bay
CWIa�'
Miami Beach
Miami
Key Biscayne
Biscayne
National Park
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 buildings 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
1s https://entp.hud.gov/idapp/html/condol.cfm
2020-2024 Analysis of Impediments to Fair Housing Choice
72
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 an 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.
Based on conversations with the MIAMI Realtors Association, the main issue is the reserve requirements
of the Rule. Generally, the proposed reserve requirement would be at least 10 percent of the monthly
unit assessments. A lower amount could be deemed acceptable by HUD based on a reserve study
completed not more than 24 months before a request for a lower reserve amount is received
(§ 203.43b(d)(6)(x)). Due to widespread issues with Condominium Associations across the State of Florida
related to theft, many associations purposefully opt to NOT have large amounts in reserves. Data
indicates that the State has more than 47,000 community associations. In Florida, HOA's are governed by
Chapter 720 of the Florida Statutes but there is no agency that enforces the Florida HOA statutes,
meaning that potential fraud by member(s) of associations would place the burden of proof on the
homeowners interested in pursuing a cas through the courts, including what can be expensive legal
counsel. Florida's Division of Florida Condominiums, Timeshares, and Mobile Homes under the State's
Department of Business and Professional Regulation deals only with administrative issues such as
elections and recalls. The HCD 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
Public Housing (PH) in our area is operated/managed by the Public Housing and Community Development
(PHCD) Department of Miami -Dade County. HUD's provided pre -populated data from the Public Housing
Information Center (PIC) in the charts below include both Miami-Dade's PH and Section 8 (S8) programs
combined with the City's Section 8 program. We have elected to use a combination of the pre -populated
data with other credible data sources to further refine this narrative and analyze the PH units within our
jurisdiction. The data shows (Table PH-1) that there are 8,077 Public Housing units in use and 13,516
Section 8 units, the bulk of these tenant based (13,184). The County's Housing Choice Voucher Section 8
units are spread throughout the 30+ municipalities. Data indicates that 6,800 of the public housing units
are located within City limits at 65 different sites.
When looking at the age of the PH sites in the City, more than half (35) were built on or before 1973
making them at least 40 years old. Given the age of the PH stock within our jurisdiction, the City supports
the implementation of the PHCD's FY2018 5-Year Plan and the Annual Capital Fund Program (CFP) to
renovate or modernize public housing units so that occupancy is maximized and current stock is
preserved, especially given the demand for these units. During an application cycle that ran from July 7-
2020-2024 Analysis of Impediments to Fair Housing Choice
73
31, 2008, PHCD received 71,376 applications for the waitlist for its project -based (Public Housing and
Moderate Rehabilitation), Assisted Living Facilities, and tenant -based (Section 8 Housing Choice Voucher)
programs, an obvious sign of the overwhelming demand for income -restricted housing County -wide.
Table PH-1: Public Housing Totals in Use
Program Type
Certificate
Mod- Public
Rehab Housing
# of
Units in
Use
97
2,339
8,077
Total
13,516
Project- Tenant -
Based Based
51
13,184
*includes Non -Elderly Disabled, Mainstream Five -Year, and Nursing Home Transition
Source: PIC (PIH Information Center)
Table PH-2: Public Housing Characteristics of Residents
Number of
Homeless at Admission
•
Elderly Program
Participants (>62)
Disabled Families
Families Requesting
Accessibility Features
HIV/AIDS Program
Participants
DV Victims
Certificate
2
12
Source: PIC (PIH Information Center)
Mod -
Rehab
Program Type
Public
Housing
15 0
1,536 3,772
Total
Vouchers
Special Purpose Voucher
............
Veterans
Affairs
Supportive
Housing
0
Family
Unification
Program
41
Vouchers
Project- Tenant -
Based Based
4,524 23
84 399 1,127 2,561
97 2,339 8,077
0
Table PH-3: Public Housing Race of Residents
Race
White
Black/African American
Asian
American Indian/
Alaskan Native
Pacific Islander
Other
:......____.
Source: PIC (PIH Information Center)
Certificate
31
0
1
Public
Housing
2020-2024 Analysis of Impediments to Fair Housing Choice
3,705
13,516 51
0
0 0
Total
10
1
Disabled*
52
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
0
0
2,480
0
13,184
0
0
0
0
0
Vouchers
Special Purpose Voucher
Project- Tenant- Veterans
Based Based Affairs
Supportive
Housing
Family
Unification
Program
0
7
0
1
0 0
13
0
Family
Unification
Program
0 13
0 0
0
0
0
0
0
74
Table PH-4: Public Housing Ethnicity of Residents
Program Type
Ethnicity
Certificate
Mod- Public
Rehab Housing
Hispanic
23 1,854 3,867
Vouchers
Special Purpose Voucher
Veterans
Total Project- Tenant- A airs Family
Based Based ff Unification
Supportive
Housing Program
6,391 30 6,235 0 12
Not -Hispanic
74 485 4,210 7,125 21 6,949 0 29
Source: PIC (PIN Information Center)
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 (2016-2018) 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.
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
2020-2024 Analysis of Impediments to Fair Housing Choice
75
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.
In the tables that follow, we look at conventional loans followed by FHA loans between 2016 and 2018. In
comparing Tables HMDA-1, HMDA-2, and HMDA-3, 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 81,745 received in three years. That was followed up by the
number of Home Purchase loans, which amounted to some 70,334 applications in three years. Finally, the
fewest number of applications received was in the Home Improvement category with a total of some
19,663 in the last three years. Conversely, the highest denial rates are seen in the Home Improvement
category with a three-year average of 57.2 percent denial rate.
When focusing on Table HMDA-1 (Conventional Home Purchases), the amount of applications has steadily
increased since 2016 as well as the percentage of loans issued which was 63.5 percent in 2018. The
percent denied has remained pretty steady though, oscillating somewhere in, or around 17.5%.
Conventional Loan Applications (Latest 3 years of data available)
Table HMDA-1: Home Purchase Loan Applications in Miami -Dade County
Reporting Year - 2018
# of
Race/Ethnicity Applica
tions
# of Loans %
Originated Issued
Approved
but Not
Acce•ted
Denied Denied Withdrawn
Closed for
Incomplet
eness
American Indian/Alaska
Native
62
27 43.5
3 17 27.4
14
1
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
583
1,319
21,662
344
2,288
26,258
22,635
357
706
14,031
205
1,358
16,684
15,218
61.2
53.5
64.8
59.6
59.4
63.E
67.2
13
45
525
9
71
666
441
91
322
3,448
87
510
4,47.E
3,491
15.6
24.4
15.9
25.3
22.3
17.0
15.4
96
193
2,898
40
301
3,542
2,772
26
53
760
3
48
891
713
Reporting Year - 2017
# of
Race/Ethnicity Applica
tions
# of Loans %
Issued Issued
Approved
but Not
Accepted
Denied Denied Withdrawn
Closed for
Incomplet
eness
American Indian/Alaska
Native
32
18 56.3
0
1
3.1
4
0
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
573
1,032
18,296
248
2,244
22,42.E
14,159
# of
Race/Ethnicity Applica
tions
350
534
11,742
148
1,233
14,02.E
9,103
61.1
51.7
64.2
59.7
54.9
62..E
64.3
# of Loans %
Issued Issued
13 98
36 256
402 2,987
4 44
63 534
518 3,920
2,351
293
Approved
but Not
Acce•ted
17.1
24.8
16.3
17.7
23.8
17..E
16.6
4
152
2,504
34
342
3,133
1,886
Denied Denied Withdrawn
0
54
661
18
72
820
526
Closed for
Incomplet
eness
American Indian/Alaska
Native
31 19 61.2
0 8 25.8
4
0
Asian
433
253 58.4
15 101 23.3
47
17
Black/African American 1,006 518 51.5 33 250 24.9 164 41
2020-2024 Analysis of Impediments to Fair Housing Choice
76
White 17,302 11,018 63.7 470 2,985 17.3 2,273 556
Other 194 135 69.6 5 31 16.0 19 4
Race not Available 2,685 1,637 61.0 110 535 19.9 303 100
Total by Race 21,651 13,580 62.7 633 3,910 18.1 2,810 718
Hispanic* 13,050 8,371 64.1 347 2,264 17.3 1,642 426
Source: https://www.ffiec.qov/hmdaadwebreport/aggwelcome.aspx
*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)
Conventional - Home Refinance Loans (Latest 3 years of data available)
There has also been a considerable decrease in the amount of applications submitted for home refinance
loans (Table HMDA-2) from 2016 to 2018. There were 39,887 applications submitted in 2016 but only
13,856 in 2018. The lack of popularity of home refinance loans makes sense, given that interest rates
dropped to low levels below 4 percent in 2016 and have remained low to present. Most households that
wanted to refinance jumped on their opportunity early in 2016. With industry insiders predicting that
interest rates will remain steady, this trend might continue.
Table HMDA-2: Home Refinance Loan Applications in Miami -Dade County
Reporting Year - 2018
# of
Race/Ethnicity Applica
tions
American Indian/Alaska
Native
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
129
191
884
7,363
144
5,145
13,856
6,221
# of Loans
Originated Issued
7 5.4
57 29.8
250 28.3
2,899 39.4
50 34.7
2,101 40.8
5,364 38.7
2,399 38.6
Approved
but Not
Acce.ted
# % #
Denied Denied Withdrawn
2 114 88.4
5
37
230
3
198
47.E
195
67
341
2,240
54
1,452
4,268
1,935
35.1
38.6
30.4
37.5
28.2
30.8
31.1
3
46
174
1,432
30
989
2 674
1,210
Closed for
Incomplet
eness
3
16
82
562
7
405
1,07.E
482
Reporting Year - 2017
# of
Race/Ethnicity Applica
tions
# of Loans %
Originated Issued
Approved
but Not
Acce•ted
# % #
Denied Denied Withdrawn
Closed for
Incomplet
eness
American Indian/Alaska
Native
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
Reporting Year - 2016
89
399
2,984
18,688
338
5,504
28,002
15,179
24 27.0
147
969
7,833
129
1,953
11,0.6.E
6,317
36.8
32.5
41.9
38.2
35.5
39.E
41.6
0 30 33.7
12
106
647
9
217
991
532
# of # of Loons Approved
Race/Ethnicity Applica but Not
Originated Issued
tions Acce.ted
109
979
4,757
96
1, 655
7,626
3,914
27.3
32.8
25.5
28.4
30.1
27.2
25.8
23
78
640
3,875
68
1,163
5,847
3,144
Denied Denied Withdrawn
12
53
290
1,576
36
516
2,483
1,272
Closed for
Incomplet
eness
American Indian/Alaska
Native
138
41 29.7
5 46 33.3
29
17
Asian 647 225 34.8 35 214 33.1 119 54
Black/African American 3,744 1,035 27.6 114 1,529 40.8 713 353
White 27,703 11,232 40.5 918 8,461 30.5 4,701 2,391
Other 412 140 34 12 149 36.2 72 39
Race not Available 7,243 2,580 35.6 343 2,505 34.6 1,097 718
Total by Race 39,887 15,253 38.2 1,427 12,904 32.4 6,731 3,572
Hispanic* 21,393 8,509 39.8 739 6,609 30.9 3,606 1,930
Source: https.//www. f fiec. qov/hmdaadwebreport/apgwelcome. aspx
2020-2024 Analysis of Impediments to Fair Housing Choice
77
*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)
Home Improvement Loans (Latest 3 years of data available)
In relation to home improvement loans, although the applications for these have steadily climbed in the
past three years, denial percentages continue to be very 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 an article in The Real Deal, Miami leads the
nation with the highest percentage of mortgaged homes with negative equity of any major metropolitan
area. As of the end of Q2 of 2017, 14.7 percent of homes had a negative equity. However, it is good news
to know that this trend has been slowly decreasing in comparison to previous years.
Table HMDA-3: Home Improvement Loan Applications in Miami -Dade County
Reporting Year - 2018
#of #of Loans
Race/Ethnicity Applica Originated
tions
°sb
Issued
Approved # # Closed for
%but Not Denied Denied Withdrawn Incomplet
Acce•ted eness
American Indian/Alaska
Native
71
8 11.3
0 55 77.5
4
4
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
210
712
6,611
150
1,030
8,784
5,403
47
129
1,745
47
325
2,301
1,262
22.4
18.1
26.4
31.3
31.6
26.2
23.4
5
18
139
0
8
170
106
133
476
4,041
91
504
5,300
3,530
63.3
66.9
61.1
60.7
48.9
60.3
65.3
17
62
375
7
132
597
281
8
27
311
5
61
416
224
Reporting Year - 2017
# of
Race/Ethnicity Applica
tions
# of Loans %
Originated Issued
Approved
but Not
Acce•ted
Denied Denied Withdrawn
Closed for
Incomplet
eness
American Indian/Alaska
Native
35
4 11.4
0 26 74.3
3
2
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
Reporting Year - 2016
73
655
3,864
56
980
5,663
3,328
# of
Race/Ethnicity Applica
tions
14
151
1,217
11
297
1,694
982
19.2
23.1
31.5
19.6
30.3
29.9
29.5
# of Loans
Originated Issued
3
12
98
0
25
138
77
Approved
but Not
Accepted
46
428
2,020
36
491
3,047
1,837
63.0
65.3
52.3
64.3
50.1
53.8
55.2
7
42
376
6
111
545
306
# % #
Denied Denied Withdrawn
3
22
153
3
56
239
126
Closed for
Incomplet
eness
American Indian/Alaska
Native
53
14 26.4
1
33 62.3
3
2
Asian 51 17 33.3 2 27 52.9
Black/African American 652 128 19.6 13 462 70.9
White 3,575 1,166 32.6 75 1,955 54.7
Other 71 19 26.8 1 43 60.6
Race not Available 814 214 26.3 17 487 59.8
Total by Race 5,216 1,558 29.9 109 3,007 57.6
Hispanic* 3,050 897 29.4 62 1,805 59.2
Source: https.//www. f fiec. qov/hmdaadwebreport/aqqwelcome. aspx
*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)
2020-2024 Analysis of Impediments to Fair Housing Choice
3
36
233
6
62
343
171
2
13
146
2
34
199
115
78
FHA Loans (Latest 3 years of data available)
When looking at the trends in applications for FHA loans in the Miami -Dade MSA from 2016 to 2018, it is
clear that the amount of applications has steadily increased with 16,182 applications submitted in 2018.
However, in this same year, the number of applications for conventional home purchase loans was 10,000
higher than the amount of FHA loans - 26,258 total. Denial rates for the FHA loans varied from year to
year showing a slight decline in the past year at 24.2 percent. Approval rates during those years have also
varied with an only 47.2 percent issuance rate in 2018. A number that is concerning as approval rates for
FHA loans have oscillated in the mid-60 percentage range since 2014.
Table HMDA-4: FHA Loan Applications in Miami -Dade County
Reporting Year - 2018
# of
Race/Ethnicity Applica
tions
#of Loans %
Originated Issued
Approved
but Not
Accepted
Denied Denied Withdrawn
Closed for
Incomplet
eness
American Indian/Alaska
Native
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
Reporting Year - 2017
31 12 38.7
185
2,035
11,200
46
2,685
16,182
7,493
# of
Race/Ethnicity Applica
tions
American Indian/Alaska
Native
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
14
50
1,123
7,724
19
2,685
11,615
7,316
38
834
5,104
8
1,637
7,633
4,700
20.5
41.0
45.6
17.4
61.0
47.2
62.7
# of Loans %
Originated Issued
8 57.1
26
675
5,415
13
1,637
7,774
5,117
52.0
60.1
70.1
68.4
61.0
66.9
69.9
7 8 25.8
31
512
1,499
0
110
2,159
135
Approved
but Not
Acce•ted
101
251
2,998
31
535
3,924
1316
54.6
12.3
26.8
67.4
19.9
24.2
17.6
3
11
300
1,238
3
303
18,958
1030
Denied Denied Withdrawn
0 5 35.7
1
31
112
0
110
633
109
14
219
996
3
535
3,910
972
28.0
19.5
12.9
15.8
19.9
33.7
13.3
0
7
159
1,014
3
303
2,810
939
1
4
138
361
4
100
608
312
Closed for
Incomplet
eness
1
2
39
187
0
100
718
179
Reporting Year - 2016
# of
Race/Ethnicity Applica
tions
# of Loans %
Originated Issued
Approved
but Not
Acce•ted
# % #
Denied Denied Withdrawn
Closed for
Incomplet
eness
American Indian/Alaska
Native
Asian
Black/African American
White
Other
Race not Available
Total by Race
Hispanic*
8
5 62.5
0 1 12.5
51 31 60.8 0 12
1,259 762 60.5 29 252
8,310 5,795 69.7 114 1,179
151 100 66.2 2 29
466 238 55.1 7 128
10,245 6,931 67.7 152 1,601
7,736 5,400 69.8 98 1,109
Source: https://www.ffiec.qov/hmdaadwebreport/aqqwelcome.aspx
*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)
2
0
2020-2024 Analysis of Impediments to Fair Housing Choice
23.5
20.0
14.2
19.2
27.5
15.6
14.3
7
176
1,013
20
78
1,296
937
1
40
209
0
15
26.E
192
79
Affirmative Marketing 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 address 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 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/HCD's affirmative marketing policy requirements
as required by 24 CFR 92.351, each property owner/developer who receives federal funding from the
City must submit a completed and signed AFHMP Plan (HUD 935.2A/2B), as an exhibit to their
executed contract with the City, 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. City ordinance #13491 also requires that any developer with a project that
receives affordable or workforce housing incentives or benefits from the City, its departments,
instrumentalities, or Community Redevelopment agencies, including but not limited to financing,
grants, impact fee waivers or deferrals, parking waivers or reductions shall provide notice to the
Department of Housing & Community Development AND the Zoning Department at least 60 days prior
to the initial leasing/sales period of the assisted/incentivized unit so that elected officials can notify
their residents of the availability of these units. Upon receipt of the developer's written notification,
the Department then issues a formal memorandum (via e-mail) advising the elected officials' office
and shares the project details.
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
2020-2024 Analysis of Impediments to Fair Housing Choice
80
updating the AFHMP if the property's circumstances change (changes to area demographics or local
housing market area).
4. Limited English Proficiency (LEP) Requirements:
Although LEP individuals are not a protected class, housing owners/developers must take reasonable
steps to ensure meaningful access to the information and services they provide for persons with 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. Additional
guidance was issued by HUD in September 2016 (by the Office of General Counsel Guidance on Fair
Housing Act Protections for Persons with Limited English Proficiency), noting that a lack of English
proficiency can be a proxy for national origin, and practices that restrict access to housing on the basis
of LEP can have a discriminatory effect based on national origin, race, or other protected
characteristic, even when the housing provider has no intent to discriminate.
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 to the HCD for inclusion in the project file. Marketing efforts typically begin as indicated
on the submitted AFHMP form, with the standard being usually three to six months prior to the
completion of the project's construction. The HCD's Housing unit assesses the owner's affirmative
marketing plan and the results of these efforts, communicating any concerns and/or requesting
adjustments. Should an owner fail to follow these affirmative marketing efforts, the HCD will refer to
the matter to the local FHEO office and to the local FHIP.
NIP
2020-2024 Analysis of Impediments to Fair Housing Choice
81
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
REAL ESTATE MARKET
Impediment FH1:
Increased Housing (Cost) Burden for approximately 55.8% of City households (renters and homeownes
combined) due to the rising costs of housing in the City of Miami along 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 and
evictions, bankruptcies, and potential homelessness.
■ Leverage Miami Forever Bond allocation ($80 million for affordable housing development) with a
20:80 ratio between Forever Bond and Other Public/Private sources via an RFP pipeline process.
This means that for every dollar the City invests, it will be requiring a leverage of $4 dollars from
public and private sources.
■ Engage, inform, and work with City leadership (elected officials) to retain and 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.
■ Continue to implement the actions to increase affordable housing as identified in the 2019-2023
Consolidated Plan and the recommendations of the draft Affordable Housing Master Plan, at the
discretion of the City Commission.
■ Continue funding 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.
■ Explore the potential of establishing a local tenant protection law, upon review of other
municipalities' best practices.
2020-2024 Analysis of Impediments to Fair Housing Choice
82
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 March 2020, there are no
buildings in the entire City of Miami that are FHA approved. 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 any of Miami's multi -family buildings, even when just over 50%14 (104,448)
of the City's entire housing stock is comprised of multi -family buildings of ten or more units.
Recommendations:
■ The HCD will continue to work with the Miami Realtors Association to further their efforts on a
local, state and federal level.
■ The HCD will draft marketing materials targeting multi -family condominium associations, with
information on how to become an FHA approved building, including the Miami Realtors
Association's rack brochure on this topic.
Public sector
LAND USE, ZONING, AND SITE SELECTION
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 HCD 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 HCD 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.
■ HCD will continue to prepare request for lien removals for eligible affordable housing properties.
14 (B25024, ACS 2017, 1-yr estimate)
2020-2024 Analysis of Impediments to Fair Housing Choice
83
PUBLIC ASSISTED HOUSING
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 Gap Analysis conducted in 2019 estimated that there were 9,556 individuals/
households living with HIV/AIDS in Miami -Dade County in need of housing assistance.
Recommendations
■ The HCD will continue to accommodate as many HOPWA clients as possible in the City's Tenant -
Based Rental Assistance (TBRA) Program.
■ The HCD will continue to fund the HOPWA Short Term Rental Mortgage & Utility Assistance
Program (STRMU) to assist HIV+ persons who are not TBRA recipients remain housed in the event
of a valid emergency.
■ The HCD 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.
■ The HCD will support the PHCD in their efforts to develop HUD approved RAD projects within City
of Miami limits.
Public and private sector
AFFORDABLE WORKFORCE HOUSING
Impediment FHS:
There are 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 low -and middle-class working citizens cannot afford to live in the
communities where they live without be$ing considered cost -burdened. 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 international demand factors that have contributed to the
escalation of property values and sales and rental rates even when the area median income based on the
most recent ACS stood at $40,327. In 2018, the City hired the Jorge M. Perez Metropolitan Center at
Florida International University (FIU) to prepare a draft Affordable Housing Master Plan, based on an
analysis of the most up-to-date City demographic, economic and housing -related data, while making
suggestions on how to create additional affordable/workforce housing options responsive to that data.
2020-2024 Analysis of Impediments to Fair Housing Choice
84
Recommendations
■ The City should continue to 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 any efforts that can create a dedicated revenue source for the City's
Affordable Housing Trust Fund. At this time, there is none.
■ Workforce housing, currently defined in Miami 21 as those City of Miami households with
incomes that range between 60% to 140% AMI with the Area Median Income being issued by
HUD, should be studied and redefined. Presently, the category spans a very broad spectrum of
income ranges. Even thought the County's median income sits at around $49,930, while the City's
is $40,327. That gap has concerned some City of Miami Commissioners who feel that the
workforce definition needs to be adjusted to make sure that the incentive is helping the average
City of Miami household.
FAIR HOUSING ENFORCEMENT
Impediment FH6:
Housing Discrimination on the Basis of Race, Color, National Origin, Religion, Sex, Familial Status, and
Disability continues to take place.
According to HOPE, Inc. there were 256 fair housing inquiries/complaints over a 36 month -period that
originated within City of Miami's boundaries. 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.
■ 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.
2020-2024 Analysis of Impediments to Fair Housing Choice
85
■ 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).
■ Conduct an annual/biennial public informational campaign during the Fair Housing Month each
April.
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 latter, combined with recent changes in costs tied to steel tariffs, also adds variable costs
to the construction process.
Davis -Bacon prevailing wages increase 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.
Landlord -tenant issues — The Department, as well as the local FHIP mentioned in this document, receives
numerous calls a year from tenants seeking assistance with landlord -tenant issues, which are spelled out
in the Florida Statutes, Part II, Chapter 83, which is better known as the Florida Residential Landlord
Tenant Act. Amongst the general public there seems to be a lack of awareness of these laws and how to
work through disputes via the Court system and frequently constituents feel they are fair housing
violations, even though the issue has nothing to do with a protected class. The Department routes these
requests to Legal Services of South Florida given that most tenants cannot incur the costs of hiring a
private attorney. The Department believes an awareness campaign — under the State's purview — would
make sense, especially in parts of the State with high amounts of foreign born persons/immigrants who
are not as knowledgeable about landlord/tenant law.
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). 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
2020-2024 Analysis of Impediments to Fair Housing Choice
86
matter and are attempting to purchase a home, the City refers them to local associations that offer low-
cost credit counseling. The City (HCD) 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 publicly funded housing.
Foreclosures —According to RealtyTrac as of December 2019, there are 4,872 properties in some stage of
foreclosure (default action or bank owned) while the homes listed for sale are 4,020. The number of
properties that received a foreclosure filing was 7 percent higher than November 2019 and 26 percent
higher than the same time in 2018.
FORECLOSURE STATUS DISTRIBUTION FOR MIAMI, FL December 2019
The current distribution of foreclosures based on the number of active foreclosure homes in Miami, FL.
• Pre Foreclosures
Prior Month
Prior Year
t 28.1%
t 34.2%
• Auction
Prior Month
Prior Year
i 2.8%i
4 31.0 %
• Bank Owned
Prior Month
Prior Year
i 13.4+H,
4 I.
Pre -For closure Auction MI Bank -Owned
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 in January 2019 by the National Association of Insurance
Commissioners (NAIC) indicates that Florida's average home owner's insurance premium is $1,993, the
most expensive in the nation. The national average is $1,192, making Florida's average premium 67
percent higher. Combine this with flood insurance requiements, given that Florida is home to more flood
insurance policies than any other state by a factor of three. Almost two million properties in the state
carry flood insurance and one of every eight such policies in the nation covers a property in South Florida
with an average premium of $750 a year.15 These costs are an additional burden to homeowners or to
persons looking to purchase a home.
Permitting process - During numerous workshops held in 2019 towards the preparation of the FIU
Affordable Housing Master Plan Draft, more than a dozen small and large developers expressed a genuine
frustration with the stumbling blocks associated with the permitting process in the City, as well as the
different levels of review needed to get projects approved — Building, Planning & Zoning, Fire, etc.
Developers complained that the delays cost them money given the fluctuating costs of construction, labor,
https://www. wlrn. org/post/south-floridas-flood-maps-are-being-updated-will-you-get-hit-paying-insurance#stream/0
2020-2024 Analysis of Impediments to Fair Housing Choice
87
etc., especially when dealing with affordable housing where the overall project cost simply cannot absorb
unexpected additions to the bottom line (lot maintenance, taxes, water/sewage hook ups). In Oct. 2018,
the City of Miami launched the ePlan (short for Electronic Plan Review) process to help digitize the
Building/Permitting process in order to streamline it. Some developers feel the latter has helped matters,
but also expressed an interest in the City considering a joint review of Plans, and a dedicated staff person
that walks them through the process, especially for the small builders who cannot afford to keep a plan
runner on the payroll.
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 2019,
the City of Miami had a millage rate of 7.5665.There were five 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."
Short term rental regulations — After litigation with Airbnb in 2018, the City has not yet codified short
term rental regulations. Although short term rentals can help a homeowner offset housing costs, an
abundance of short term units in a touristic location such as Miami, could also inadvertently raise rents
for residents by reducing the inventory of available housing stock (rental units) indirectly raising rents.
Sometimes, short term rentals are also owned by persons who reside outside of the State and/or country
and are difficult to track down, especially in relation to code enforcement issues and violations (party
houses, illegal activities) affecting the quality of life of neighboring residents.
Improvements since the Last Al
Approved in May 2010, the City of Miami's form -based Zoning code - Miami 21 - allows for varied
residential types which reduces potential impediments to housing choice by members of the protected
classes. The code did not include any inclusionary zoning regulations, neither voluntary nor mandatory
but addressed 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 what are known as public benefits (Miami
21, Article 3, Section 3.14).
These specified programs are as follows (A through F):
2020-2024 Analysis of Impediments to Fair Housing Choice
88
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 Afford-
able/Workforce housing priced at or below eighty percent (80%) area median income (including
pertaining shared space such as parking and circulation) provided on site, the development shall
be allowed three (3) square feet of additional area up to the bonus Height and FLR as described
in Section 3.14.1. For each square foot of Affordable/Workforce housing priced above eighty
percent (80%) area median income (including pertaining shared space such as parking and
circulation) provided on -site, 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.
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. 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.
8. 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' Assesment Report.
i. 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
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.
ii. 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).
iii. Park improvements for Public Parks in areas below 50% median income threshold shall be
allowed two times the valuation credit.
2020-2024 Analysis of Impediments to Fair Housing Choice
89
iv. 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. The project shall maintain the Frontage requirements of the
Transect Zone. The Open Space may be a Courtyard, Plaza, or Thoroughfare or Pedestrian Passage
through the site connecting two (2) Thoroughfares, such as a segment of the Baywalk or FEC
Greenway. See Article 4, Table 7.
3. Trust Fund contribution. For a cash contribution to the Miami 21 Public Benefits Trust Fund, the
development project 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.
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, most 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. The most popular public benefits option in the past few years has been the transfer
of development rights.
Sections 3.15 and 3.16 of Miami 21 address the zoning incentives available to developers who opt to --
■ As of March 2015, the City Commission passedan amendment to Ordinance #13114 by
establishing a new zoning sub -classification known as T6-24(B) that will have a higher floor lot
2020-2024 Analysis of Impediments to Fair Housing Choice
90
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 HCD 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 HCD
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. However, the latter would have to fall within the parameters specified under
Section 166.04151 of Florida Statutes, passed in July 2019 (known as HB 7103), which states that "an
inclusionary housing ordinance may require a developer to provide a specified number or percentage of
affordable housing units to be included in a development or allow a developer to contribute to a housing
fund or other alternatives in lieu of building the affordable housing units. However, in exchange, a county
must provide incentives to fully offset all costs to the developer of its affordable housing contribution. Such
incentives may include, but are not limited to: (a) Allowing the developer density or intensity bonus
incentives or more floor space than allowed under the current or proposed future land use designation or
zoning; (b) Reducing or waiving fees, such as impact fees or water and sewer charges; or (c) Granting other
incentives.
2020-2024 Analysis of Impediments to Fair Housing Choice
91
CONCLUSIONS AND RECOMMENDATIONS
Identified actions and timeline for recommendations
This chapter provides the City of Miami's strategy to address fair housing from FY2020 to FY2024. 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 Housing and Community 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.
■ 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.
2020-2024 Analysis of Impediments to Fair Housing Choice
92
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
of Miami
#
FH 1.1
FH1: Increased Housing (Cost) Burden for
combined with stagnant wages.
Recommendation
Leverage Miami Forever Bond funding on a 20:80
ratio through an RFP process. For every dollar the
City Invests it should get an average return of $4
dollars from other public/private sources.
55.8% of City households due to the
Action Steps
Issue a Miami Forever Bond RFP for Multi
family development of affordable housing.
rising costs
Timeline
2020-2024
of housing in the City
Measurable Results
Acceptance of qualified
proposals to develop
affordable housing.
FH 1.2
Continue advocating for affordable and workforce
housing development by engaging and informing
City 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
administration whenever possible.
Continue implementing actions to increase
affordable housing as identified in the 2019-
2023 Consolidated Plan and the
recommendations of the draft Affordable
Housing Master Plan.
2020-2024
Bringing additional
affordable housing units
for city residents
FH 1.3
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.
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
2020-2024
Single Family Rehab: 10
Households;
Households;
Down Payment Assistance:
40 Households
IMPEDIMENT FH2: Very Few Multi -Family Buildings in
# Recommendation
the City Seek FHA approval
Action Steps
Timeline
Measurable Results
FH 2.1
Work with the Miami Realtors Association to
further their efforts on a local and state level to
address this issue on a local, state, and federal level.
Support and join the Miami Realtors
Association's efforts to have more
developments offer FHA units
2020-2024
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
Draft and develop marketing material
2020-2024
Mailing of marketing
material; Departmental
2020-2024 Analysis of Impediments to Fair Housing Choice
93
how to become an FHA approved building, including
Create a link in the department's website that
website updated to reflect
the Miami Realtors rack brochure on this topic.
provides more information on this topic for
multi -family condo associations
this information
IMPEDIMENT
family homes
#
FH 3.1
FH3:There is a scarcity of Developable
and/or smaller apartment developments
Recommendation
HCD 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.
Vacant Parcels in the City Diminishing
thereby limiting housing choice.
Action Steps
Continue developing affordable housing units
on city -owned vacant parcels;
the construction
Timeline
2020-2024
of new, single-
Measurable Results
Bringing additional
affordable housing units to
the market
FH 3.2
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.
Work with Miami -Dade County Water &
Sewer Dept. (WASD) to work towards the
creation of a program that offsets WASD
hook-up costs that are passed onto
developers.
2020-2024
Bringing additional
affordable housing units to
the market
FH 3.3
HCD to continue to prepare request for lien
removals for eligible affordable housing properties
Have a dedicated staff person at HCD to
expedite the review and approval of these
lien removals.
2020-2024
Bringing additional
affordable housing units to
the market
IMPEDIMENT
#
FH4: There is a lack of adequate federal
Recommendation
funding for rental assistance programs.
Action Steps
Timeline
Measurable Results
FH 4.1
HCD will continue to accommodate as many
HOPWA clients as possible in the City's Tenant-
Based Rental Assistance (TBRA) Program and to
assist HIV+ persons who are income eligible via the
HOPWA funded STRMU program (based on funding
availability)
Continue to conduct rent comparables to
ensure that rent paid corresponds to the on-
going market rent.
Educate clients about looking for more
affordable rental options.
Market the availability of the STRMU
program
2020-2024
Continue marketing the
STRMU program through
the Miami -Dade HIV/AIDS
Partnership and other
proper channels.
FH 4.2
HCD 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
HCD will continue to issue Request for
Proposals to provide gap financing that will
2020-2024
Bringing additional
affordable housing units to
the market
2020-2024 Analysis of Impediments to Fair Housing Choice
94
portion of the total cost of the project, the
allow housing projects to include affordable
developer provides a pre -determined number of
housing units.
affordable rental housing units to be rented to low -
to -moderate income families.
IMPEDIMENT
#
FH5: There are not Enough Affordable/Workforce
Recommendation
Housing Units to Meet the Needs of City Residents
Action Steps
Timeline
Measurable Results
FH 5.1
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%)
Continue discussions with City management
and elected officials related to the
development of affordable housing, inclusive
of workforce housing options.
2020-2024
Bringing workforce
housing units to the
market
FH 5.2
Continue to support the creation and/or
establishment of dedicated funding for 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
2020-2024
Number of affordable
housing units assisted with
AHTF
FH 5.3
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
2020-2024
Bringing additional
affordable housing units to
the market
FH 5.4
Continue to implement the actions to increase
affordable housing identified in the current
Consolidated Plan
Implement affordable housing objectives
identified in the 2019-2023 Consolidated Plan
2020-2024
Meet the goals and
measurable results
identified in the
Consolidated Plan.
IMPEDIMENT FH6: Housing Discrimination On The Basis Of Race, Color, National Origin, Religion, Sex, Familial Status, And Disability Continues.
Recommendation
Action Steps
Timeline
Measurable Results
FH 6.1
Continue fair housing rights campaign for City
residents that will help them identify and
challenge discrimination including material during
the Section 8 and HOPWA TBRA 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 TBRA clients at time of
intake/ recertification.
2020-2024
Approximately 420 Section
8 and 800 HOPWA TBRA
clients receiving the
newest fair housing
material
2020-2024 Analysis of Impediments to Fair Housing Choice
95
FH 6.2
Conduct fair housing testing at least twice within
Contract the services of an agency to
2020-2024
Testing results and follow
the span of this Al.
perform housing discrimination testing
concentrating our efforts on multifamily
rental properties
up
FH 6.3
Continue to provide fair housing education and
Organize/host community workshops for
2020-2024
A workshop a year hosted/
training to housing providers to ensure compliance
residents and developers or other target
led by HCD, besides those
with fair housing laws.
audience as deemed appropriate by the city.
led by the area FHIP year-
round
2020-2024 Analysis of Impediments to Fair Housing Choice
96
Appendix
Attachment 1:
Geographical Information System (GIS) Maps based on U.S. Census analyzing different groups
65 years old and up
Census Data: ACS 5-Year Estimates 2014-2018
2020-2024 Analysis of Impediments to Fair Housing Choice
97
Black Population
Census Data: ACS 5-Year Estimates 2014-2018
2020-2024 Analysis of Impediments to Fair Housing Choice
98
Hispanic Population
Census Data: ACS 5-Year Estimates 2014-2018
2020-2024 Analysis of Impediments to Fair Housing Choice
99
White Population
Census Data: ACS 5-Year Estimates 2014-2018
2020-2024 Analysis of Impediments to Fair Housing Choice
100
Racial Dot Map
Miami/on
Public seeev I aerereece oaa ey stamen Design
University of Virginia — Racial Dot Map (latest available)
2020-2024 Analysis of Impediments to Fair Housing Choice
2010 Census Block Data
1 Dot =1 Person
• White
• Black
• Asian
• Hispanic
• a[ a xaceJna
Amevl[an(Mulrt�ve[{al
What ern I looking at..?
101
Land Use Maps
Vacant Properties
City of Miami, Planning and Zonning Department
2020-2024 Analysis of Impediments to Fair Housing Choice
102
Single Family Housing
City of Miami, Planning and Zonning Department
2020-2024 Analysis of Impediments to Fair Housing Choice
103
Multi Family Housing
City of Miami, Planning and Zonning Department
2020-2024 Analysis of Impediments to Fair Housing Choice
104
Attachment 2:
Affordable Housiing Proclamations:
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Attachment 3:
Spanish brief/translation about the main impediments identified in the DRAFT of the Analysis of
Impediments to Fair Housing.
ZQUE 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
anos 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 alio 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 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 leyes 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 55.8% 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
2020-2024 Analysis of Impediments to Fair Housing Choice
106
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). Los datos indican que en el mes de marzo
del 2020, no hay ningun edificio 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 construccion de
nuevas viviendas unifamiliares y/o edificios de apartamentos mas pequehos (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.
Impedimento #4: Hay una deficiencia (escasez) de Tondos federates para administrar programas de
asistencia para ayudar a pagar la renta. 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 9,556 individuos viviendo con VIH+/SIDA en el Condado de Miami -Dade que necesitan
ayuda con la vivienda.
Impedimento #5: La historia de los vecindarios, su demografia, y las recomendaciones de los residentes
deben de ser consideradas en la planificacion y zonificacion relacionadas a solicitudes de desarrollo
residencial.
Impedimento #6: No hay suficiente viviendas costeables/de trabajadores para satisfacer la necesidad
de los residentes de la Ciudad de Miami. Estudios recientes relacionados al costo de la renta indican que
muchas familias con ingresos medianos no pueden razonablemente pagar para vivir en las comunidades
en donde trabajan. 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 troves de los
Condados Miami -Dade y Broward, hubieron 256 consultas/quejas durante 36 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 troves del Condado
Miami -Dade.
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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 Housing & Community Development, 14 NE 1st
Avenue, Second Floor, Miami, FL 33132.
—)Si usted siente haber sido discriminado(a) bajo una de las closes 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
2020-2024 Analysis of Impediments to Fair Housing Choice
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 leyes federales:
www.espanol.hud.gov/offices/fheo/
Telefono (800)669-9777
TTY (800)927-9275
108
Attachment 4:
Comments to DRAFT Analysis of Impediments
2020-2024 Analysis of Impediments to Fair Housing Choice
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Disclaimer Related to Census Comparisons:
CAUTION:
The Census Bureau cautions when comparing 2010 decennial census to Amercian Community Survey data.
Differences in the universe, question wording, residence rules, reference periods, and the way in which
the data are tabulated can impact comparability with Census 2010.
The strength of the American Community Survey is in estimating characteristic distributions. We
recommend users compare derived measures sucha as percent, mean, median, and rates rather than
estimates of population totals.
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