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HomeMy WebLinkAbout2016-58 - Adopting the Mitigated Negative Declaration No. ND2016-001 (SCH#2016031011) for the Big Canyon Habitat Restoration & Water Quality Improvement Project (PA2016-046)RESOLUTION NO. 2016-58 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF NEWPORT BEACH, CALIFORNIA, ADOPTING THE MITIGATED NEGATIVE DECLARATION NO. ND2016-001 (SCH#2016031011) FOR THE BIG CANYON HABITAT RESTORATION & WATER QUALITY IMPROVEMENT PROJECT (PA2016-046) WHEREAS, large areas of the riparian habitat of the Big Canyon Nature Park are dominated by non-native invasive species; and WHEREAS, urbanization in the Big Canyon watershed has resulted in increased peak and sustained peak storm flows which have incised the channel bed and eroded channel banks in the upper reaches of the Big Canyon Nature Park resulting in reduced floodplain connectivity and unstable embankments; and WHEREAS, Newport Bay, the receiving water for Big Canyon Creek, is listed as an impaired waterbody for metals, toxics, nutrients, and bacteria and total maximum daily loads (TMDLs) have been established to address these impairments; and WHEREAS, wet weather, roadway -related pollutants including metals, sediment, oil, and grease enter Big Canyon Creek from thoroughfares such as Jamboree Road and impact creek water quality; and WHEREAS, Big Canyon Creek is listed as an impaired waterbody for selenium and a TMDL has been established for the creek; and WHEREAS, seepages containing concentrations of selenium much higher than State water quality standards have recently been discovered in Big Canyon Creek adjacent to Jamboree Road: and WHEREAS, the 2009 Central Orange County Integrated Regional and Coastal Watershed Management Plan lists the Big Canyon Restoration Project as a key project for implementing restoration objectives in Upper Newport Bay; and WHEREAS, the proposed restoration in Big Canyon is in conformance with the guidelines of the Big Canyon Resource and Recreation Management Plan (being prepared by the Irvine Ranch Conservancy on behalf of the City), which in turn is consistent with the requirements of the Natural Community Conservation Plan/Habitat Conservation Plan (NCCP) for the Central and Coastal sub -region of Orange County in the event the City elects to incorporate the Nature Park into the NCCP; and WHEREAS, implementation of the Big Canyon Restoration & Water Quality Improvement Project will (1) restore historic riparian habitat by removing non-native vegetation and replace it with native plantings, (2) stabilize the creek and floodplain, (3) improve water quality in Big Canyon Creek and Newport Bay by diverting seeps with high concentration of selenium to the sanitary sewer, and (4) enhance public access within the Big Canyon Nature Park; and Resolution No. 2016-58 Page 2 of 3 WHEREAS, a public meeting was held by the City Council on May 10, 2016, in the City Hall Council Chambers located at 100 Civic Center Drive, Newport Beach, California. A notice of time, place and purpose of the meeting was given in accordance with the Newport Beach Municipal Code. Evidence, both written and oral, was presented to, and considered by, the City Council at this hearing; and WHEREAS, after thoroughly considering the Mitigated Negative Declaration (MND) for the Big Canyon Habitat Restoration & Water Quality Improvement Project, and the public testimony and written submissions of all interested persons desiring to be heard, the City Council finds the following facts, findings, and reasons to support adopting the MND: 1. Pursuant to the California Environmental Quality Act (CEQA), Public Resources Code Sections 21000, et seq., the CEQA Guidelines (14 Cal. Code of Regulations, Sections 15000 et seq.), and City Council Policy K-3, the proposed amendments (Project) are defined as a project and as such subject to environmental review. 2. The City caused to be prepared an Initial Study/MND in compliance with CEQA, the State CEQA Guidelines and City Council Policy K-3. 3. Notice of the availability of the draft MND was provided and the draft MND was made available for public review for a thirty -day comment period beginning on March 4, 2016, and ending April 4, 2016. Notice of the Availability of the draft MND was given in accordance with CEQA, the State CEQA Guidelines and City Council Policy K-3. Comments were received from California Department of Fish & Wildlife, Regional Water Quality Control Board — Santa Ana Region, Orange County Sanitation District. Comments were also received from the City's Planning Division. 4. Although not required pursuant to CEQA, written responses to the three comment letters received and the City Planning Division comments were prepared. The comments and responses were considered by the City Council while considering the adoption of the MND. The comments to the MND and responses to comments do not change the determinations or represent a significant departure from the original document that would warrant recirculation of the MND. 5. The Draft MND and the Final MND (which includes the Responses to Comments) are attached as Exhibits "1" and "2," respectively, and incorporated herein by reference. The documents and all related materials, which constitute the record upon which this decision was based, are on file with the Public Works Department, City Hall, 100 Civic Center Drive, Newport Beach, California. 6. On the basis of the entire environmental review record, the proposed project, with mitigation measures, will have a less than significant impact upon the environment and there are no known substantial adverse effects on human beings that would be caused. Additionally, there are no long-term environmental goals that are compromised by the project, nor cumulative impacts anticipated in connection with the project. The mitigation measures identified by the MND and incorporated in the Resolution No. 2016-58 Page 3 of 3 Mitigation Monitoring and Reporting Program are feasible and will reduce potential environmental impacts to a less than significant level. NOW THEREFORE, the City Council of the City of Newport Beach, California, hereby resolves as follows: Section 1: The Recitals provided above are true and correct and constitute, in part, the findings of the City Council for the adoption of the attached MND. Section 2: The City Council of the City of Newport Beach directs the Public Works Director to incorporate the mitigation measures contained in the Mitigation Monitoring and Reporting Program included in the Final MND included in Exhibit "2" in the plans and specifications for the project to be implemented. Section 3: The City Council of the City of Newport Beach hereby adopts MND No. ND2016-001 (SCH#2016031011) attached as Exhibits "1" and "2", which are incorporated by reference. Section 4: If any section, subsection, sentence, clause or phrase of this resolution is, for any reason, held to be invalid or unconstitutional, such decision shall not affect the validity or constitutionality of the remaining portions of this resolution. The City Council hereby declares that it would have passed this resolution, and each section, subsection, sentence, clause or phrase hereof, irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid or unconstitutional. Section 4: This resolution shall take effect immediately upon its adoption by the City Council and the City Clerk shall certify the vote adopting the resolution. ADOPTED this 10th day of May, 2016 ATTEST: Leilani I. Brown City Clerk .-J1 , :.i F- Exhibit "1" Big Canyon Habitat Restoration & Water Quality Improvement Project Mitigated Negative Declaration No. ND2016-001 State Clearinghouse Number 2016031011 BIG CANYON HABITAT RESTORATION & WATER QUALITY IMPROVEMENT PROJECT Initial Study and Mitigated Negative Declaration Prepared for February 2016 City of Newport Beach Public Works Department City of Newport Beach 100 Civic Center Drive Newport Beach, California 92660 NOTICE OF INTENT TO ADOPT PROPOSED NUTIGATED NEGATIVE DECLARATION In accordance with City of Newport Beach (City) policies regarding implementation of the California Environmental Quality Act, the City has conducted an Initial Study to determine whether the following project may have a significant adverse effect on the environment, and on the basis of that study hereby finds: The proposed project will not have a significant adverse effect on the environment, therefore, it does not require the preparation of an Environmental Impact Report. Although the proposed project could have a significant adverse effect on the X environment, there will not be a significant adverse effect in this case because the Mitigation Measures described in the Initial Study have been incorporated as part of the project. An Environmental Impact Report is therefore not required. The Initial Study provides the basis and reasons for this determination and is available in paper copy foam at the City of Newport Beach Public Works Department Counter, several public libraries, and online at the City's website, as described below. PROJECT: Title: Big Canyon Iiabitat Restoration & Water Quality Improvement Project Location: Within Big Canyon Nature Park. west and east of Jamboree Road and east of Upper Newport Bay in the City of Newport Beach Description: Project Proponent: Address: Contact Person: imRrove water quality in Big Canyon Creek and NewportBay through the addition of a water quality treatment bioretention cellextension of the We. features are functioning as originally designed City of Newport Beach 100 Civic Center Drive, Newoort Beach, California 92660 Robert Stein Telephone Number: 949.644.3322 NOTICE: The Initial Study is available for review by the general public. The Initial Study provides a detailed project description and evaluation of the potential environmental effects of the proposed project. The Initial Study can be accessed online at b#o://www.nMortbeachea.goy/index.asox?liaize=1347. Paper BIG CANYON HABITAT RESTORATION & WATER QUALITY IMPROVEMENT PROJECT Initial Study and Mitigated Negative Declaration Prepared for February 2016 City of Newport Beach Public Works Department ESA 626 Wilshire Boulevard Sufte 1160 Los Angeles. CA 90017 213.599.4300 w.wi.esassoc.com Irvine Oakland Orlando Palm Springs Petaluma Portland Sacramento San Diego San Francisco Seattle Tampa Woodland Hills 130734.00 TABLE OF CONTENTS Big Canyon Habitat Restoration & Water Quality Improvement Project Initial Study Page 1. Introduction.....................................................................................................................1-1 1.1 Statutory Authority and Requirements..................................................... ............... 1-1 1.2 Purpose ........ ........................................................................................................... 1-2 2. Project Description.........................................................................................................2-1 2.1 Introduction ............................................ .................................................................. 2-1 2.1.1 Project Background....................................................................................2-1 2.1.2 Purpose and Need for Project....................................................................2-3 2.2 Project Location and Setting...................................................................................2-5 2.3 Project Overview and Design............................................................................... 2-10 2.4 Project Components............................................................................................. 2-11 2.4.1 Creek Restoration, Creation and Riparian Habitat Enhancement.......... 2-11 2.4.2 Water Quality Improvements................................................................... 2-18 2.4.3 Infrastructure Improvements.................................................................... 2-22 2.5 Construction Activities and Schedule.................................................................. 2-23 2.6 Project Operation and Maintenance.................................................................... 2-25 2.7 Project Approvals and Discretionary Actions....................................................... 2-27 3. Initial Study Environmental Checklist..........................................................................3-1 Environmental Factors Potentially Affected.....................................................................3-2 Environmental Checklist...................................................................................................3-3 3.1 Aesthetics......................................................................................................3-3 3.2 Agricultural and Forest Resources................................................................3-5 3.3 Air Quality......................................................................................................3-8 3.4 Biological Resources.................................................................................. 3-18 3.5 Cultural Resources.....................................................................................3-26 3.6 Geology, Soils, and Seismicity................................................................... 3-31 3.7 Greenhouse Gas Emissions....................................................................... 3-35 3.8 Hazards and Hazardous Materials............................................................. 3-39 3.9 Hydrology and Water Quality...................................................................... 3-43 3.10 Land Use and Planning.............................................................................. 3-48 3.11 Mineral Resources...................................................................................... 3-50 3.12 Noise...........................................................................................................3-52 3.13 Population and Housing.............................................................................. 3-64 3.14 Public Services........................................................................................... 3-65 3.15 Recreation ..................... .............................................................................. 3-68 3.16 Transportation and Traffic........................................................................... 3-69 3.17 Utilities and Service Systems..................................................................... 3-72 3.18 Mandatory Findings of Significance............................................................ 3-75 CHAPTER11 Introduction The City of Newport Beach (City) has determined the proposed Big Canyon Creek Restoration and Water Quality Improvement Project (project) is subject to the guidelines and regulations of the California Environmental Quality Act (CEQA). This Initial Study addresses the indirect, direct, and cumulative environmental impacts associated with the proposed project. The proposed project includes the following (1) restore historic riparian habitat by removing non-native vegetation and replace it with native plantings, (2) stabilize the creek and floodplain, (3) improve water quality in Big Canyon Creek and Newport Bay, and (4) enhance public access within the Big Canyon Nature Park. The project also includes maintenance of the proposed water quality features to ensure that the features are functioning as originally designed. 1.1 Statutory Authority and Requirements In accordance with the CEQA (Public Resources Code Sections 2100-21177) and pursuant to Section 15063 of Title 14 of the California Code of Regulations (CCR), the City of Newport Beach, acting in the capacity of Lead Agency, is required to undertake the preparation of an Initial Study to determine if the proposed project would have a significant environmental impact. If the Lead Agency finds that there is no evidence that the project, either as proposed or as modified to include the mitigation measures identified in the Initial Study, may cause a significant effect on the environment, the Lead Agency must find that the project would not have a significant effect on the environment and must prepare a Negative Declaration or Mitigated Negative Declaration for that project. Such determination can be made only if, "there is no substantial evidence in light of the whole record before the Lead Agency" that such impacts may occur (Section 21080(c), Public Resources Code). The environmental documentation is intended as an informal document undertaken to provide an environmental basis for subsequent discretionary actions upon the project. The resulting documentation is not, however, a policy document and its approval and/or certification neither presupposes nor mandates any actions on the part of those agencies from whom permits and other discretionary approvals would be required. The environmental documentation and supporting analysis is subject to a public review period. During this review, public agency comments on the document should be addressed to the City of Newport Beach. Following review of any comments received, the City of Newport Beach will consider these comments as part of the project's environmental review and include them with the Initial Study documentation for consideration by the Planning Commission of the City of Newport Beach. CHAPTER 2 Project Description 2.1 Introduction The Big Canyon Restoration and Water Quality Improvement Project (proposed project) is located on a 6 -acre site in the eastern portion of the 60 -acre Big Canyon Nature Park at the downstream end of the Big Canyon Watershed in the City of Newport Beach (City), Orange County, California (Figure 1). The Big Canyon Watershed covers approximately two square miles located on the east side of Upper Newport Bay. Big Canyon Creek winds through the Big Canyon Nature Park in a general southeast to northwest direction and then discharges into Upper Newport Bay. Big Canyon is the only natural, undeveloped portion of the Big Canyon watershed and the only significant remaining natural canyon on the east side of Newport Bay. The upper 45 -acre parcel is owned by the City of Newport Beach. The lower 15 -acre portion of the Nature Park is owned the California Department of Fish and Wildlife and is a part of the Upper Newport Bay State Ecological Reserve. 2.1.1 Project Background The City has contemplated restoration efforts within Big Canyon for over a decade. Currently, the City has funding for the restoration efforts that are part of Phases IA and IB (proposed project). Potential future restoration efforts could also be proposed as a separate project, if future funding is available. The proposed project is currently being planned in coordination with a Resource and Recreation Management Plan (RRMP) being prepared by the Irvine Ranch Conservancy under contract with the City of Newport Beach for the Big Canyon Nature Park. The RRMP provides a framework for restoration and recreational improvements in the Nature Park that will be consistent with the requirements of the Natural Community Conservation Plan/Habitat Conservation Plan (NCCP) for the Central and Coastal sub -region of Orange County in the event the City elects to incorporate the Nature Park into the NCCP. Potential future restoration efforts within Big Canyon would also be coordinated with the RRMP. The potential future restoration efforts could provide benefits to Big Canyon in addition to those associated with the proposed project. These benefits could include water quality improvements in Big Canyon Creek, restoration of natural creek channels impacted by hydromodification, restoration of riparian and inland alkaline non -tidal marsh habitat, removal of non-native vegetation and replacement with native plantings, remediation of selenium -laden sediment within former freshwater ponds, creation of new transitional habitat to allow for future adaption of coastal estuarine habitat due to sea -level rise, reduction of favorable mosquito breeding habitat, and improvements and protection of public access within the natural areas of the Big Canyon Nature Park, including coastal areas that will be subject to future inundation due to sea -level rise. If funding is available, the City anticipates the preparation of a feasibility analysis to develop the least impactful and most cost-effective approach to the freshwater ponds for the future restoration efforts. These future efforts could include the protection of the biological resources within the creek and downstream estuary by addressing the sediment and reeds within these ponds and restoring the area of the future efforts. This potential future area currently contains invasive pepper trees, and the City contemplates removal of them so that the area could be restored to a transitional habitat to allow for adaptation of the coastal estuary due to sea -level rise. Based on projected sea -level rise, this area of invasive pepper trees could be inundated in about 50 years. Phases IA and IB, the current project, include the implementation of a creek and riparian habitat restoration, habitat creation and enhancement, stormwater treatment wetland, dry -weather flow diversions, culvert improvements, and trail planning in the upper portion of the Big Canyon Nature Park. Implementation is scheduled for 2016-17. 2.1.2 Purpose and Need for Project The Big Canyon Restoration Project — Phases IA and IB will: (1) restore historic riparian habitat by removing non-native vegetation and replace it with native plantings, (2) stabilize the creek and floodplain, (3) improve water quality in Big Canyon Creek and Newport Bay, and (4) enhance public access within the Big Canyon Nature Park. Restoration and water quality improvements in Phase I will proceed potential future restoration efforts in the remaining downstream areas of the watershed. 2.1.2.1 Restore Historic Riparian Habitat Big Canyon Creek has been documented as suitable for habitat restoration and enhancement due to channel incision, loss of floodplain access, unstable banks, poor water quality, and more than anything invasive species. Large portions of the riparian habitat are dominated by non-native invasive species. This in tum has impacted the habitat quality of the riparian habitat in and along Big Canyon Creek within the project area as well as in the downstream reaches of the Nature Park. 2.1.2.2 Creek and Flood Plain Stabilization Urbanization in the Big Canyon watershed has resulted in increased peak and sustained peak storm flows that have resulted in hydraulic modification of the Big Canyon Creek within the success of the planned restoration efforts as part of this phase and potential future downstream phases depends on addressing the existing water quality issues. These measures are needed for the long-term sustainability of the restoration of Big Canyon. 2.1.2.4 Public Access Enhancements Big Canyon Nature Park is used by residents and visitors for passive recreation. This is an important destination for thousands of children participating in the Orange County Department of Education Inside the Outdoors program. Inside the Outdoors provides watershed educational activities for grade school children throughout the county including disadvantage communities. As the largest undeveloped canyon adjacent to Newport Bay, it has the potential to become an integral part of the Upper Newport Bay State Ecological Preserve and to provide unique opportunities for the public to learn about the diversity of biological resources and environmental protection within a short walking distance. At present, the upper portions of the Nature Park are not attractive and rarely visited by the public. Along with habitat restoration, trail improvement and information signage will provide an enhanced experience of the different ecotones in a coastal watershed. 2.2 Project Location and Setting The proposed project is located within the City of Newport Beach, on a 6 -acre site in the eastern portion of the 60 -acre Big Canyon Nature Park. As shown in Figure 1, the project site is east of Upper Newport Bay, west and east of Jamboree Road and includes Big Canyon Creek. Primary regional access to the project site is provided by State Route 73, which runs north -south approximately 2 miles north of the project site, and State Route 1, which runs north -south approximately 1.25 miles south of the project site. Sub -regional access is provided via Jamboree Road, Ford Road, and San Joaquin Hills Road. The project site is bounded by residential developments on the bluffs to the north and south. Land uses within the project vicinity include residential, recreational open space, golf courses, and commercial developments (Figure 2). Located on the east side of Upper Newport Bay, Big Canyon Creek winds through the Big Canyon Nature Park in a general southeast to northwest direction and then discharges into Upper Newport Bay. The Big Canyon watershed is roughly 1,300 acres extending roughly 3 miles east from Back Bay Drive into the San Joaquin Hills. Big Canyon is the only natural, undeveloped portion of the Big Canyon watershed and the only significant remaining natural canyon on the east side of Newport Bay. This 45 -acre parcel contains native and non-native habitat and an array of hiking trails, and is owned by the City of Newport Beach (Figure 3). Directly downstream of the Project Area, the lower 15 -acre portion of the Nature Park is owned by the California Department of Fish and Wildlife (CDFW) and is a part of the Upper Newport Bay State Ecological Reserve. Big Canyon Nature Park is located in the Upper Newport Bay State Marine Conservation Area (SMCA) and is part of Southern California's coastal estuarine environment. Newport Bay discharges adjacent to the Newport Coast Area of Special Biological Significance (ASBS). y f. (` c � I , Q Project Boundary / Parcel Boundary // o tso — Existing Sewer Features / Feet i SOURCE: City of Newport Beach, SSRI Big Canyon Habitat Restoration and Water quality Improvement Project. D130934 Figure 3 Project Aerial Map W - w m W n v c u o u c w w j C C W O w W O floodplain that will be graded as part of this project. Seeps that are sources of high selenium will be passively collected and diverted to the sanitary sewer. • Infrastructure Improvements — The Project will also be constructed in coordination with infrastructure improvements by the Orange County Sanitation District (OCSD). The improvements are shown on Figure 3 and include the extension and improvement of the existing access road along the toe of slope along the west side of Jamboree Road. The access road improvements will be used access and maintain the sanitary sewer manhole located to the north of the existing culvert outfall. The construction of the access road to and over the existing culvert under Jamboree Road requires the extension of the culvert as shown on Figure 3. A concrete stilling pool will be located at the end of the culvert extension to dissipate hydraulic energy as the stormwater transitions from flow in the culvert and discharges to the regraded floodplain. This stilling pool will be periodically maintained to remove sediment and vegetation Water from the stilling pool will exit via a rip rap energy dissipater. OCSD will also install a permanent dosing station and access area located to the south of the proposed habitat creation area. Community Access Improvements and Educational Opportunities — The extended access road will provide an official trail where the public can learn about and enjoy the native habitats. In addition, an 8 -foot -wide bicycle path connector will be installed to provide access directly from Jamboree Road. In addition, the maintenance road at the top of the bioretention cell will also be used as a side viewing trail with interpretive signs installed. Visitors using this trail will cross from the south to the north side of the creek via the OCSD constructed turnaround area over the culvert, and follow a footpath on the north side of the creek. The footpath on the north side of the creek will continue within the coastal sage scrub habitat, following existing ad hoc trails that will be expanded to approximately 42 -inches wide. Trails allow for educational opportunities regarding water quality and creek restoration activities, and through the installation of signage and as - needed fencing, will keep the public out of sensitive habitats. 2.4 Project Components As shown in Figure 5, the proposed project consists of habitat restoration, creation and enhancement of riparian habitat, water quality improvements, and infrastructure and trail improvements. 2.4.1 Creek Restoration, Creation and Riparian Habitat Enhancement This project consists of creek restoration and riparian habitat creation and enhancement activities including stream bank stabilization, floodplain restoration, habitat creation, and restoration of riparian habitat through invasive plant removal, soil remediation and revegetation. zb O Y a o rc f = ° LL g n a a u E�g° HNm.�H _ ®!II o��l a B a a C T U ro Ir4 Eu h .' M O � M � r � W o rn 1 m W v U O VI W K p 'D N U W h m J � O � W � � W N d N O 4` W W C n m W E 4 E N L ➢ V W W A W W C c � ; o mW 2 2 m O C m m W � u a 2 M O � M � r � W o rn 1 m would be approximately 40 square feet in size and include three chambers. The fust chamber would be designed to collect dense solids and trash (floatables); the second would collect sediment and finer solids; and the third would provide storage and delivery of dissolved phase constituents to the bioretention cell. Manhole access ports would be installed for periodic removal of trash and sediment from the three chambers. Bioietention Cell The bioretention cell is an underground, modified constructed wetland that would be designed specifically to treat the suite of transportation -related pollutants found in urban watersheds. The bioretention cell would be constructed to treat stormwater flows that discharge from the primary stormwater treatment structure. The surface area of the bioretention cell would be approximately 0.47 acres in size when measured at the top of the bioretention cell berm (see Figure 5). The bioretention cell would be designed to capture and treat the stormwater that discharges from Jamboree Road. It will treat approximately 0.75 inches of stormwater in a 24-hour period. The bioretention cell will attenuate and reduce the peak discharge rate to Big Canyon Creek during storm events. The bioretention cell will consist of (from top to bottom) layers of soil, sand, and gravel, underlain by an impermeable liner. The top of the cell will be planted with native vegetation. The soil layer would be approximately 2 to 3 feet thick and would be underlain by a 6 -inch sand filter bed located between the bioretention soil and drainage gravel layer situated in the bottom of the bioretention cell. The bottom 12 -inch gravel drainage layer will form the base layer of the bioretention cell and will be underlain by a geotextile cushion. The entire bioretention cell will be underlain by a 60 -MIL high-density polyethylene (HDPE) liner. The bioretention cell would be divided into two subcells, hydraulically separated from one another by an impermeable barrier, to enable the comparison of water quality effluent between the cells. One subcell would be designed to be free draining and the second subcell would be designed such that approximately 12 inches of treated water would remain on the liner and within the gravel drainage layer. Stormwater will flow via gravity from the primary stormwater treatment structure to the top of the subcells through a series of perforated and solid inflow PVC pipes. Pollutants would be removed from stormwater as it flows down through the treatment media. Treated water would flow from the bottom of the bioretention cell through a series of PVC pipes into a newly created wetland habitat area located to the south of the bioretention cell (see Figure 5). The wetland habitat area will be graded to allow for infiltration to groundwater and for surface flow return to Big Canyon Creek. Table 2-1 summarizes the anticipated pollutant reductions from stormwater (wet weather) anticipated from the primary stormwater treatment structure and bioretention cell. Dry weather flows with lower selenium concentrations will be diverted in a new diversion structure located on the Big Canyon Golf Course. The diversion structure will divert about 0.5 cfs and allow higher flows to pass through the diversion structure. The diversion flow line will include a valve that will enable the diverted flows to be reduced and adjusted if necessary. The diversion line will flow via gravity and will be installed along the existing southern slope of the ditch north of the golf course maintenance yard. No grading and soil disturbance is anticipated. The diversion line will be at grade on the surface of the slope and will be anchored to the slope using an anchorage system. The anchor system will be installed along the existing disturbed top of slope adjacent to the golf course maintenance yard fence. The diversion line will transition from the slope into the east side of the Jamboree Road existing culvert. The diversion line will be installed inside the existing Jamboree Road culvert and inside the new culvert extension. The diversion line will discharge dry weather flows into the restored floodplain as shown in Figure 5, to provide surface water to that area. Numerous studies and assessments on selenium loads and sources in Big Canyon Creek have been conducted. Reeder (2011) provided a comprehensive assessment of the geology, hydrology, and water quality related to selenium sources in the watershed from studies conducted as early as the 1970s through 2011. Since then, additional studies have been conducted in the watershed on flow rates (Weston 2013), water balance in the upper watershed (DBS&A 2015), and specific selenium source identification assessments in the lower portion of the watershed (City of Newport Beach, unpublished data). Based on long-term monitoring conducted in 2012 (Weston 2013), the approximate base dry weather flow rate of Big Canyon Creek at Jamboree Road is 0.420 cfs. The proposed dry weather flow diversion upstream of Jamboree Road is not anticipated to impact the natural creek function. It will divert low selenium water around a stream reach of approximately 170 feet just upstream of Jamboree Road (Figure 5) where high selenium groundwater seeps have been identified (City of Newport Beach, unpublished data). Groundwater originating in this reach is estimated to contribute less than ten percent of the dry weather baseline flow in the creek, which will be diverted to sanitary sewer. The wet weather function of the creek will not be affected by the dry weather flow diversion. To support the design of the culvert extension and stilling basin, wet weather design discharge rates were determined. The Big Canyon Watershed drains approximately 1,062 acres. The modeled 100 -year flow rate is approximately 2,510 cfs. The 10 -year flow rate is 1,680 cfs and the 2 -year flow rate 1,260 cfs. The diversion line may be extended to the bio -infiltration cell (if slopes allow) to enable irrigation of native vegetation on the surface of the bioretention cell during the plant establishment period and for persistence of the vegetation. Seep Water Flow Collection and Diversion Seeps containing high concentrations of selenium have been observed along the north and south banks along a 170 -foot reach of the creek on the east side of Jamboree Road near the existing culvert (City of Newport Beach, unpublished data). The seep flows will drain through the existing culvert and the new culvert extension and collect in a low point in the bottom the stilling basin An automatic chemical -dosing station would be constructed near the beginning of the access road extension. The dosing station consists of a 12 -foot high tower, 8 -foot diameter that would be constructed on a 20 -foot by 20 -foot pad, and a gravel access road as needed to access the station. Native plants will be planted around the facility. The station would be maintained on a monthly basis. A vehicle access path that doubles as the hiking trail would be constructed as a part of the proposed project to provide maintenance access to the infrastructure improvement components. 2.4.3.2 Community Access Improvements and Educational Opportunities Public access to the project site and surrounding environs is currently provided by existing hiking paths in Big Canyon Nature Park. The project includes providing improved and new trails for public access both on the north and south side of the creek. This new trail will allow for educational opportunities regarding water quality and creek restoration activities while keeping trails out of sensitive habitats and restored and enhanced riparian corridors. Preliminary public access and walkway signage and locations has been developed from previous efforts and will be incorporated in this project. The proposed OCSD access road will serve to connect the existing gravel path over the creek to connect with an improved trail on the north side of the creek. In addition, a bicycle path connector has been incorporated into this design to allow for direct access from Jamboree Road. Interpretive elements include key features such as a viewing area on the bio retention cell maintenance road, and informational signage. This plan is consistent with on-going efforts planned for the Big Canyon Watershed in consultation with the City, environmental organizations including the Newport Bay Conservancy and Irvine Ranch Conservancy, and the appropriate regulatory agencies. 2.5 Construction Activities and Schedule Project construction is expected to begin in Fall 2016 and will include the infrastructure components of the project, habitat restoration, and habitat mitigation implementation. Construction will be complete by March 31, 2017 to avoid impacts during the nesting season. Planting of all restoration and mitigation areas will take place once grading has been completed (see Table 2-2). Construction activities would commence with the installation of construction stormwater pollution prevention BMPs in accordance with the project Stormwater Pollution Prevention Plan (SWPPP). Following the installation of stormwater BMPs, project construction work would occur in phases for a duration of five to six months. The following schedule presents the construction phases, the activities to be completed under each phase, and the duration of the activities. Several activities will run concurrently to achieve the overall construction schedule of approximately five months. and flood damages during major wet season events. A Water Quality Management Plan (WQMP) will be developed as part of the Construction SWPPP to be implemented from the onset of the construction to post construction. Biologically sensitive area protection will be established prior to construction and periodically monitored. Water quality protection during construction will be monitored based on a pre - construction Quality Assurance Project Plan (QAPP) and Sampling and Analysis Plan (SAP), to be developed prior to construction. TABLE 2-2 PRELIMINARY CONSTRUCTION DURATION Construction Activity Approximate Duration Site preparation clearing & grubbing 1-2 weeks Excavation and grading 2-3 weeks Culvert extension 4-6 weeks Dry weather diversion structures & external piping 2-3 weeks Bioretenlion cell liner & piping 1-2 weeks Bioretention cell media placement 1-2 weeks Bioengineering structure construction 1-2 weeks OCSD dosing station installation 4-6 weeks Site vegetation restoration 34 weeks Total Construction Duration Per Component SOURCE: B&M 2.6 Project Operation and Maintenance Within the bioretention cell, sediment removal is expected only after major rainfall events. Maintenance is critical if stormwater wetland basins are to function as originally designed. A specific maintenance plan will be developed for the bioretention cell when the final design has been completed, outlining the schedule and scope of maintenance operations, as well as the documentation and reporting requirements. The following are general maintenance requirements: 1. The stormwater wetland basin should be inspected annually and inspections after major storm events are encouraged (wetland basin inspection and maintenance checklists will be developed specifically for the bioretention cell). Trash and debris should be removed as needed, but at least annually prior to the beginning of the wet season. 2. Site vegetation should be maintained as frequently as necessary to maintain the aesthetic appearance of the site and to prevent clogging of outlets, creation of dead volumes, and barriers to mosquito fish to access pooled areas, and as follows: • Vegetation, large shrubs, or trees that limit access or interfere with basin operation should be pruned or removed. 2.7 Project Approvals and Discretionary Actions The City of Newport Beach would use this IS/MND and supporting documentation in its decision to certify this IS/MND and approve the project. Regulatory Agencies would similarly use this IS/MND and supporting documentation to support additional discretionary actions, including as: • City of Newport Beach: Grading Permit • City of Newport Beach: Right of Entry Permit • U.S. Army Corps of Engineers (USACE): 404 Certification • California Department of Fish and Wildlife (CDFW): Streambed Alteration Agreement • California Coastal Commission: Coastal Development Permit • Regional Water Quality Control Board: 401 Certification CHAPTER 3 Initial Study Environmental Checklist 1. Project Title: 2. Lead Agency Name and Address: 3. Contact Person and Phone Number: 4. Project Location: 5. Project Sponsor's Name and Address: 6. General Plan Designation(s): 7. Zoning Designation(s): 7. Description of Project: 9. Surrounding Land Uses and Setting: 10. Other public agencies whose approval is required: 11. Discretionary Actions: Big Canyon Habitat Restoration and Water Quality Improvement Project City of Newport Beach 100 Civic Center Drive Newport Beach, CA 92660 Bob Stein (949) 644-3322 City of Newport Beach, Orange County, CA City of Newport Beach 100 Civic Center Drive Newport Beach, CA 92660 Open Space (City of Newport Beach) Open Space (City of Newport Beach) See Chapter 2, Project Description Recreation; Residential Army Corps of Engineers; Regional Water Quality Control Board; California Department of Fish and Wildlife; Coastal Commission City of Newport Beach: Grading Permit City of Newport Beach: Right of Entry Permit U.S. Army Corps of Engineers (USACE): 404 Permit California Department of Fish and Wildlife (CDFW): Streambed Alteration Agreement California Coastal Commission: Coastal Development Permit Regional Water Quality Control Board: 401 Certification Environmental Checklist 3.1 Aesthetics Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant impact No Impact i. AESTHETICS — Would the project: a) Have a substantial adverse effect on a scenic vista? 11 El E b) Substantially damage scenic resources, including, El F but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? C) Substantially degrade the existing visual character or El F quality of the site and its surroundings? d) Create a new source of substantial light or glare E] El E which would adversely affect daytime or nighttime views in the area? Discussion a) Have a substantial adverse effect on a scenic vista? No Impact. A scenic vista is defined as a viewpoint that provides expansive views of a highly valued landscape for the benefit of the general public. According to the City of Newport Beach General Plan Update EIR, the City does not contain any officially designated scenic vistas; however, public view points are identified within the City. The nearest public view point is located about 1,200 feet west of the project site within the western portion of Big Canyon Park. This public view point provides views of Upper Newport Bay. Project grading and construction activities as well as restoration activities on the project site would not affect views from the nearest public view point because the view point offers views to the west toward Upper Newport Bay, and the project site is located east of the view point. Therefore, implementation of the proposed project would result in no impacts on scenic vistas. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a state scenic highway? No Impact. There are no officially designated scenic highways within Newport Beach (City of Newport Beach 2006). However, the project area is approximately one mile north of State Route 1 (Pacific Coast Highway), identified by the City as "Eligible for State Scenic Highway" designation. Because no scenic highways are currently designated within the City, implementation of the proposed project would result in no impact to scenic resources within a state- or locally designated scenic highway. 3.2 Agricultural and Forest Resources Less Then Significant Potentially with Less Than Significant Mitigation Significant Issues (and Supporting Information Sources): Impact Incorporation Impact No Impact 2. AGRICULTURAL AND FOREST RESOURCES— In determining whether Impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether Impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the states inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project: a) Convert Prime Farmland, Unique Farmland, or ❑ 11 ❑ IR Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict with existing zoning for agricultural use, or a El 19 Williamson Act contract? c) Conflict with existing zoning for, or cause rezoning 0 El 19 of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Tlmbedand Production (as defined by Government Code section 51104(g))? d) Result in the loss of forest land or conversion of ❑ ❑ forest land to non -forest use? e) Involve other changes in the existing environment ❑ which, due to their location or nature, could result In conversion of Farmland to non-agricultural use or conversion of forest land to non -forest use? Discussion In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state's inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Resources California Department of Conservation: Farmland Mapping and Monitoring Program. Orange County Important Farmland 2012. January 2015. City of Newport Beach. Newport Beach Municipal Code. Title 20: Planning and Zoning. Passed November 24, 2015. <http://www.codepublishing.com/CAJNewportBeach/ ?NewportBeach20/NewportBeach20.html>. Accessed January 14, 2015. forth a comprehensive and integrated program that will lead the Basin into compliance with the federal 24-hour PM2.5 air quality standard, and to provide an update to the Basin's commitments towards meeting the federal 8 -hour ozone standards. SCAG, which is the regional metropolitan planning organization for the Southern California area, has established the assumptions for growth, in terms of demographic growth and associated air quality impacts, and these assumptions are utilized in SCAQMD's AQMP. Since the forecasted growth in SCAQMD's AQMP for the Basin relies on SCAG's regional growth forecasts, and because SCAG's growth forecasts are based upon, among other things, land uses specified in city general plans, a project that is consistent with the land use designated in a city's general plan would also be consistent with the AQMP growth projections. As discussed in Chapter 2 (Project Description), the proposed project would improve water quality through water conservation, runoff reduction and restoration. Specifically, the proposed project would include a wetland that would treat both dry and wet weather flows in Big Canyon, and would eliminate the storm drain -associated vector habitat. The proposed project would contain a pump station, and a primary treatment structure. Given that the proposed project is an infrastructure project that serves only to treat contaminated water and improve the functionality of the wetland; implementation of the proposed project would not result in any additional population or housing growth in the project area that has not been accounted for in the City of Newport Beach General Plan. Consequently, as no growth -inducing development or land use would occur under the project, implementation of the project would not conflict with or obstruct the implementation of SCAQMD's AQMP. In addition, SCAQMD regional significance thresholds were designed to assist SCAQMD in determining if a project would worsen air quality conditions in the Basin. The determination of AQMP consistency is primarily concerned with the long -tern influence of the proposed project on air quality in the Basin. As discussed under Question 3(b) below, the proposed project would not result in significant regional construction emissions and would not interfere with the attainment of air quality standards. Thus, the project's construction activities would not conflict with or obstruct implementation of the AQMP. Overall, the proposed project would result in a less than significant impact related to the AQMP. b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? Less than Significant Impact. A project may have a significant impact where project -related emissions would exceed federal, state, or regional standards or thresholds, or where project - related emissions would substantially contribute to an existing or projected air quality violation. As the proposed project consists of the installation of a surface water treatment system, culvert improvement and restoration activities, potential air quality impacts associated with the project would only occur during the construction phase as the operation of construction equipment would result in additional air emissions in the region. Once construction activities have been completed, operation of the proposed project would not involve any direct pollutant emissions sources onsite. In addition, vehicle emissions would be generated by worker trips to and from the project area for routine maintenance of the dosing station, including removal of sediment and debris from the stilling basin. These maintenance trips are anticipated to occur only once a month. As such, the appropriate dust control measures under SCAQMD Rule 403 would be implemented by the project during each phase of construction. TABLE 3-1 PROJECT PEAK DAY CONSTRUCTION EMISSIONS Pounds per Day Emissions Source ROG NOx CO sox PM10 PM2.5 Site Preparation Clearing and Grubbing Total Daily Peak Emissions 3.23 35.07 17.73 0.04 9.39 3.37 Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No Excavation and Grading Total Daily Peak Emissions 2.23 25.74 13.48 0.03 8.99 3.01 Signlficance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No Culvert Extension Total Daily Peak Emissions 1.25 15.82 8.17 0.02 1.98 0.71 Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No DryWeather Structures and External Piping Total Daily Peak Emissions 0.39 4.30 3.36 0.01 0.25 0.21 Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No Bioretention Cell Liner and Piping Total Daily Peak Emissions 1.17 15.65 8.24 0.03 5.76 1.02 Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No Sioretenlion Cell Media Placement Total Daily Peak Emissions 1.24 16.78 5.89 0.02 0.63 0.53 Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No Bioengineering Structure Construction Total Daily Peak Emissions 1.27 18.01 9.36 0.03 7.83 1.26 Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No OCSD Dosing Station Installation Total Daily Peak Emissions 2.62 31.74 15.01 0.04 9.17 3.19 Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No Site Vegetation Installation Total Daily Peak Emissions 2.46 28.10 11.82 0.03 4.04 2.56 Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No ROG = reactive organic gas; NOx= nitrogen oxides; CO =carbon monoxide; SOz=sulfur dioxide: PM10 = particulate matter less than 10 microns; PM2.5 = particulate matter less than 2.5 microns; lbs/day =pounds par day NOTE: See Appendix B for CaIEEMod output. SOURCE: ESA, 2016 As shown in Table 3-1 and Table 3-2, the peak daily regional emissions generated during project construction for individual phases, as well as those that overlap, would not exceed the SCAQMD daily significance thresholds for ROG, NOx, CO, SOX, PM2.5 and PM10. Since construction emissions would not exceed the SCAQMD thresholds, the regional impacts related to air quality during project construction activities would be less than significant. c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? Less than Significant Impact. With respect to air quality, a significant impact may occur if the project would add a considerable cumulative contribution to federal or state non -attainment pollutants. Because the Basin is currently classified as a state nonattainment area for ozone, PM1o, and PM2s, cumulative development consisting of the proposed project along with other reasonably foreseeable future projects in the Basin as a whole could violate an air quality standard or contribute to an existing or projected air quality violation. With respect to determining the significance of the proposed project's contribution to regional emissions, the SCAQMD neither recommends quantified analyses of cumulative construction emissions nor provides methodologies or thresholds of significance to be used to assess cumulative construction impacts. Instead, the SCAQMD recommends that a project's potential contribution to cumulative impacts should be assessed utilizing the same significance criteria as those for project specific impacts. Furthermore, SCAQMD states that if an individual development project generates less than significant construction or operational emissions then the development project would not generate a cumulatively considerable increase in emissions for those pollutants for which the Basin is in nonattainment. As discussed under Question 3(b) above, the proposed project would not generate construction emissions that would exceed the SCAQMD's recommended thresholds. Once construction activities have been completed, operation of the proposed project would not involve any direct pollutant emissions sources onsite. ht addition, because mobile emissions generated from worker trips to and from the project area for routine maintenance of the treatment structures are anticipated to only occur once a month, the mobile emissions generated would be negligible. As such, project operations would not generate substantial pollutant emissions that would exceed SCAQMD's applicable regional thresholds. Therefore, the proposed project would not generate a cumulatively considerable increase in emissions of the pollutants for which the Basin is in nonattainment, and impacts would be less than significant. d) Expose sensitive receptors to substantial pollutant concentrations? Less than Significant Impact. A significant impact may occur if a project were to generate pollutant concentrations to a degree that would significantly affect sensitive receptors. Sensitive receptors are populations that are more susceptible to the effects of air pollution than are the population at large. The SCAQMD identifies the following as sensitive receptors: long-term health care facilities, rehabilitation centers, convalescent centers, retirement homes, residences, emissions, the emissions shown in Table 3-4 account for off-road equipment operating and fugitive dust. Table 3-4 shows the off-road equipment operating and fugitive dust emissions from those construction activities that will overlap. TABLE 3-3 LOCALIZED CONSTRUCTION POLLUTANT EMISSIONS See Appendix B for CaIEEMod output Pounds Per Day Construction Phase NOx CO PM10 PM2.5 Site Prep Clearing and Grubbing 27.12 14.28 3.93 2.67 Excavation and Grading 20.20 8.82 3.56 2.32 Culvert Extension 14.40 6.62 0.66 0.52 Dry Weather Diversion Structures 4.29 3.16 0.22 0.20 Bioretention Cell Liner and Piping 10.12 3.78 0.36 0.33 Bloretention Cell Media Placement 16.75 5.50 0.56 0.52 Bioengineering Structure Construction 10.31 3.54 0.35 0.32 OCSD Dosing Station Installation 26.19 10.35 3.74 2.49 Site Vegetation and Restoration 25.54 9.26 3.69 2.44 Peak Day Localized Emissions 27.12 14.28 3.93 2.67 City of Newport Localized Significance 197 1.711 14 9 Threshold 62.03 23.15 7.78 5.25 Exceed Threshold? No No No No See Appendix B for CaIEEMod output TABLE 3.4 LOCALIZED CONCURRENT CONSTRUCTION POLLUTANT EMISSIONS Pounds Per Day Construction Phase NOx CO PM10 PM2.5 Culvert Extension & Dry Weather Diversion 18.69 9.78 0.78 0.72 Dry Weather Diversion & Bioretention Cell Liner & OCSD 40.60 17.29 4.32 3.02 Dosing Station Bioretention Cell Media & OCSD Dosing Station 42.94 15.85 4.31 3.01 Bioengineering Structure 8& OCSD Dosing Station 36.50 13.89 4.09 2.81 Bloengineedng Structure & OCSD Dosing Station &Site 62.03 23.15 7.78 5.25 Restoration OCSD Dosing Station & Site Restoration 51.73 19.61 7.43 4.93 Peak Day Localized Emissions 62.03 23.15 7.78 5.25 City of Newport Localized Significance Threshold 197 1,711 14 9 Exceed Threshold? No No No No See Appendix B for CaIEEMod output activities at any one site would only constitute a small percentage of the total 70 -year exposure period. Thus, diesel particulates from construction activities would not be anticipated to result in the exposure of sensitive receptors to levels that exceed applicable standards, and impacts would be less than significant. e) Create objectionable odors affecting a substantial number of people? Less than Significant Impact. A significant impact may occur if objectionable odors occur which would adversely impact sensitive receptors. According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding. As the proposed project consists of the installation of infrastructure for the treatment of water and restoration of the surrounding area, the proposed project is not a type of use identified by the SCAQMD as being associated with odors. Thus, the proposed project would not result in objectionable odors during operations, and this impact would be less than significant. During construction of the proposed project, exhaust from equipment may produce discernible odors typical of most construction sites. Such odors would be a temporary source of nuisance to adjacent uses, but would not affect a substantial number of people. As odors associated with project construction would be temporary and intermittent in nature, the odors would not be considered to be a significant environmental impact. Therefore, impacts associated with objectionable odors would be less than significant. Resources South Coast Air Quality Management District (SCAQMD), Final Localized Significance Threshold Methodology, Appendix C—Mass Rate LST Look -up Tables. October 2009. South Coast Air Quality Management District (SCAQMD), Final 2012 Air Quality Management Plan. February 2013. South Coast Air Quality Management District (SCAQMD), SCAQMD Air Quality Significance Thresholds. March 2015. Website: http://www.aomd.gov/home/regulations/cega/air- quality-analysis-handbook. Accessed on February 12, 2016. No species covered by the Orange County Central -Coastal Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) were identified in the project area; therefore, the project would not affect species covered by the Orange County Central -Coastal NCCP/HCP. Three California Species of Special Concern were observed within the riparian forest habitat onsite, including yellow warbler, yellow -breasted chat, and Cooper's hawk. These species, as well as other bird species nesting in the riparian or adjacent upland habitat or in the ornamental trees just outside of the project boundary could be negatively affected by the project through temporary loss of habitat during invasive species removal, floodplain grading, replanting, and construction of water quality, infrastructure and recreational facilities. Indirect impacts from construction (e.g., noise and increased activity) could also affect nesting bird species during the breeding season by disrupting breeding behavior, resulting in nest abandonment and loss of productivity. These potential impacts to nesting birds and vegetation communities would be considered significant. Mitigation Measures BI0-1: Nesting Birds. Impacts to nesting birds would be avoided by conducting all grading and construction activities outside of the bird breeding season (February 1—August 15). If breeding season cannot be avoided, the following measures would be followed. a. During the avian breeding season, a qualified Project Biologist shall conduct a preconstruction avian nesting survey no more than 10 days prior to vegetation disturbance or site clearing. If grading or other construction activity begins in the non - breeding season and proceeds continuously into the breeding season, no surveys shall be required. However, if there is a break of 10 days or more in grading or construction activities during the breeding season, a new nesting bird survey shall be conducted before these activities begin again. b. The nest survey shall cover all reasonably potential nesting locations on and within 300 feet of the proposed construction activities areas. c. If an active nest is found during an avian nest survey, a qualified Project Biologist shall implement a 300 -foot minimum avoidance buffer for coastal California gnatcatcher, least Bell's vireo, and other passerine birds and a 500 -foot minimum avoidance buffer for all raptor species. Buffer distances for other species would be determined by the Project Biologist based on the species and its breeding or nesting requirements. The nest site area shall not be disturbed until the nest becomes inactive or the young have fledged. BI0-2: Vegetation Communities. The project would impact a total of 2.46 acres of southern riparian forest, and 0.50 acre of coastal sage scrub. These vegetation communities are both highly disturbed from a heavy infestation of non-native plants and compacted, saline soils. These low - quality habitats would be restored to provide habitats with much greater ecological function than the current conditions. A total of 2.46 acres of southern riparian forest would be mitigated onsite through substantial habitat restoration (2.03 acres), willow riparian forest habitat creation (0.25 Note that some areas of the existing southern riparian forest are not considered jurisdictional by the Corps/RWCQB and/or CDFW; therefore, refer to Table 3-7, below for detailed impact acreages of jurisdictional resources. The temporary impacts associated with construction consist of 0.43 acre of non-native grassland, 0.26 acre of low -quality southern riparian forest, 0.18 acre of low -quality coastal sage scrub, and 0.03 are of disturbed habitat. These construction -related temporary impacts include the staging area adjacent to the existing access road on the southwestern portion of the project area, the staging area adjacent to Jamboree road (the 8 -foot centerline of this area would become a permanent trail after infrastructure construction has been completed, but the surrounding slopes would be revegetated), and the slopes surrounding the bioretention cell. These temporary construction impacts would be considered significant. TABLE 3-6 SUMMARY OF IMPACTS TO VEGETATION COMMUNITIES Plant Communities/Land Cover Types Permanent Impacts (Acres) Temporary Temporary (Restoration) (Construction) Total impacts Southern Riparian Forest (SRF)' 0.43 1.77 0.26 2.46 Coastal Sage Scrub (CSS) 0.26 0.06 0.18 0.50 Non -Native Grassland (NNG) 0.63 0.14 0.43 1.20 Disturbed (Existing Access Roads and Trails) 0.08 0.02 0.03 0.13 Ornamental (ORN) 0.03 0.03 0.00 0.06 Total Acreage of Impacts 1.42 2.03 0.90 4.35 ' Corps/RWQCB/and/or CDFW and/or CCC jurisdictional habitat SOURCE: ESA, 2016 Mitigation Measures Implementation of Mitigation Measure BIO -2 is required. Significance after Mitigation With implementation of Mitigation Measure BI0-2, a total of 2.46 acres of southern riparian forest would be mitigated onsite through substantial habitat restoration (2.03 acres), willow riparian forest habitat creation (0.25 acre), and riparian habitat enhancement (0.64 acre). Impacts to coastal sage scrub would be mitigated onsite through restoration of 1.85 acres, which is 1.35 acres in excess of the required 1:1 ratio. Impacts to sensitive vegetation communities would be less than significant after implementation of Mitigation Measure BI0-2. c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Less than Significant with Mitigation Incorporated. Combined Permanent and Temporary Impacts to Jurisdictional Waters & Wetlands. The permanent and temporary impacts to jurisdictional waters and wetlands identified above are considered significant. Mitigation Measures BI0-3: Jurisdictional Wetlands. As stated previously, the project has been designed to avoid and minimize impacts to jurisdictional resources and high-quality habitat to the extent practicable. To mitigate for unavoidable permanent impacts to Waters of the United States/State, both habitat creation and enhancement activities would be conducted onsite, as summarized in Table 3-8. To offset for permanent losses to 0.24 acre of non -wetland waters of the United States (Corps/RWQCB), 0.44 acre of CDFW and 0.57 acre of CCC jurisdictional wetlands, the creation of 0.25 acre of new habitat is proposed directly to the southwest of the proposed bioretention cell. This would satisfy the federal mandate for no net loss of wetlands by the Corps. The deficit acreage (0.19 acre for CDFW and 0.33 acre for CCC) would be satisfied through the removal of non-native vegetation in adjacent riparian and seed source areas (i.e., riparian habitat enhancement). This would include removal of the Brazilian peppertrees both east of Jamboree Road and on the north slopes of the canyon west of Jamboree Road that are the primary source of invasive seeds for Big Canyon. In addition, understory invasives not mapped by Dudek, including pampas grass, periwinkle, and English ivy, are prevalent throughout the project area. These species would be removed as part of the enhancement activities. Approximately 0.64 acre of invasive removal of the 1.07 acres available would be considered mitigation for unavoidable permanent impacts. Enhancement activities are distinguished from the restoration activities proposed (not mitigation) in that restoration would require grading and extensive soil remediation to achieve full habitat functioning, and enhancement areas would not. Jurisdictional areas temporarily impacted as a result of construction of the water quality or infrastructure -related components of the project would be restored to native habitat at a 1:1 ratio. A full Habitat Restoration Plan describing the Big Canyon restoration as well as habitat mitigation activities would be submitted for review and approval as part of the environmental permitting process. TABLE 3-8 MITIGATION FOR PERMANENT IMPACTS TO JURISDICTIONAL AREAS Permanent Impacts Habitat Types (acres) Mitigation for Jurisdictional Impacts Corps/RWQCB Non-Wetlands/CDFW 0.24 0.25 acre of riparian forest habitat Riparian/CCC Wetland creation (1:1 mitigation ratio)l CDFW Riparian only 0.19 0.64 acre of habitat enhancement CCC Wetland only 0.33 (extensive invasive species removal) ' Fullfills Corps "no net loss" requirement. SOURCE: ESA, 2015 To offset for permanent losses to 0.24 acre of non -wetland waters of the United States (Corps/RWQCB), 0.44 acre of CDFW and 0.57 acre of CCC jurisdictional wetlands, the creation of 0.25 acre of new habitat is proposed directly to the southwest of the proposed bioretention cell. This would satisfy the federal mandate for no net loss of wetlands by the Corps. The deficit acreage (0.19 acre for CDFW and 0.33 acre for CCC) would be satisfied through the removal of non-native vegetation in adjacent riparian and seed source areas (i.e., riparian habitat enhancement). This would include removal of the Brazilian peppertrees both east of Jamboree Road and on the north slopes of the canyon west of Jamboree Road that are the primary source of invasive seeds for Big Canyon. In addition, understory invasives not mapped by Dudek, including pampas grass, periwinkle, and English ivy, are prevalent throughout the project area. These species would be removed as part of the enhancement activities. Approximately 0.64 acre of invasive removal of the 1.07 acres available would be considered mitigation for unavoidable permanent impacts. Enhancement activities are distinguished from the restoration activities proposed (not mitigation) in that restoration would require grading and extensive soil remediation to achieve full habitat functioning, and enhancement areas would not. Jurisdictional areas temporarily impacted as a result of construction of the water quality or infrastructure -related components of the project would be restored to native habitat at a 1:1 ratio. A full Habitat Restoration Plan describing the Big Canyon restoration as well as habitat mitigation activities would be submitted for review and approval as part of the environmental permitting process. County Central -Coastal NCCP/HCP, would be designated to meet Plan standards. The highly degraded riparian channel, floodplain, and native vegetation would be restored to better functioning riparian habitat; restoration of adjacent coastal sage scrub areas would provide higher -quality upland habitat for wildlife and wetland buffer function; and the water quality facilities would greatly improve the hydrology and water quality of the creek. Therefore, the project would not conflict with the provisions of any local policies or ordinances protecting biological resources or any NCCP/HCPs. Resources City of Newport Beach, Local Coastal Program, Coastal Land Use Plan, Amended February 2009. Website: httn://www.ngwUortbeachca. eov/PLN/LCP/Intemet°/`2OPDFs//CLUP_Cover%20and%20T able%20of1/o20Contents ndf Accessed on February 12, 2016. ESA, Biological Resources Technical Report, Big Canyon Habitat Restoration and Water Quality Improvement Project, January 2016. resources that may be encountered, and of the proper procedures to be enacted in the event of an inadvertent discovery of archaeological resources or human remains. The City shall ensure that construction personnel are made available for and attend the training and retain documentation demonstrating attendance. Archaeological monitoring shall be conducted by an archaeologist familiar with the types of archaeological resources that could be encountered within the project site. The qualified archaeologist, in coordination with the City, may reduce or discontinue monitoring if it is determined that the possibility of encountering buried archaeological deposits is low based on observations of soil stratigraphy or other factors. The archaeological monitor shall be empowered to halt or redirect ground -disturbing activities away from the vicinity of a discovery until the qualified archaeologist has evaluated the discovery and determined appropriate treatment. The archaeological monitor shall keep daily logs detailing the types of activities and soils observed, and any discoveries. After monitoring has been completed, the qualified archaeologist shall prepare a monitoring report that details the results of monitoring. The report shall be submitted to the City, the Corps, and any Native American groups who request a copy. A copy of the final report shall be filed at the SCCIC. If archaeological resources are encountered during monitoring, and if it is determined that the discovered archaeological resource constitutes a historic property under Section 106 of the NHPA or a historical resource under CEQA, avoidance and preservation in place is the preferred manner of treatment. Preservation in place maintains the important relationship between artifacts and their archaeological context and also serves to avoid conflict with traditional and religious values of groups who may ascribe meaning to the resource. Preservation in place may be accomplished by, but is not limited to, avoidance, incorporating the resource into open space, capping, or deeding the site into a permanent conservation easement. In the event that preservation in place is demonstrated to be infeasible and data recovery through excavation is the only feasible mitigation available, a Cultural Resources Treatment Plan would be prepared and implemented by a qualified archaeologist in consultation with the Corps and the City. The plan will provide for the adequate recovery of the scientifically consequential information contained in the archaeological resource. The Corps and the City shall be required to consult with appropriate Native American representatives in determining treatment for prehistoric or Native American resources to ensure cultural values ascribed to the resource, beyond that which is scientifically important, are considered. CR -2: Native American Monitoring. The City shall retain a Native American monitor to observe all ground -disturbing activities, including but not limited to brush clearance, vegetation removal, grubbing, grading, and excavation. The Native American monitor shall be selected from amongst the Native American groups identified by the NAHC as having affiliation with the project area. The Native American representative shall be allowed to participate in the cultural resources sensitivity training, discusses in Mitigation Measure CR -1, and all authorities ascribed to the archaeological monitor, including the authority to stop work in the event of the discovery of cultural resources, shall also apply to the Native American monitor. In the event that presuming the monitor is qualified in both disciplines. During ground disturbing activity, the qualified paleontologist or paleontological monitor shall conduct spot-checks of exposed sediments. The purpose would be to determine whether the project would impact the paleontologically sensitive Monterey Formation. The qualified paleontologist may institute paleontological monitoring if, based on observations of subsurface stratigraphy or other factors, he or she determines that the possibility of encountering fossiliferous deposits is high. Paleontological monitoring would be conducted by a paleontological monitor working under the supervision of the qualified paleontologist. In the event that monitoring is required, the monitor shall have the authority to temporarily halt or divert work away from exposed fossils in order to recover the fossil specimens and shall complete daily monitoring logs outlining the day's activities. The qualified paleontologist shall prepare a final monitoring report to be submitted to the City and filed with the local repository, along with any fossils recovered during construction. The qualified paleontologist shall also contribute to any construction worker cultural resources sensitivity training (see Mitigation Measure CR -1) either in person or via a training module provided to the qualified archaeologist. The training shall include information of the types of paleontological resources that may be encountered, and the proper procedures to be enacted in the event of an inadvertent discovery of paleontological resources. In the event of unanticipated discovery of paleontological resources, the City shall cease ground - disturbing activities within 100 feet of the find until it can be assessed by the qualified paleontologist. The qualified paleontologist shall assess the find, implement recovery measures if necessary, and determine if paleontological monitoring is warranted once work resumes. Significance after Mitigation The implementation of Mitigation Measure CR -3 would ensure that the project would have a less than significant impact on paleontological resources or unique geologic features. d) Disturb any human remains, including those interred outside formal cemeteries? No Impact. No human remains were identified in the project area as a result of the archival research or survey, and it is anticipated that the project would have no impact on human remains. That said, the area was known to have been used by prehistoric Native Americans. In the unlikely event that human remains are uncovered during ground disturbing activities, appropriate state law would apply. Specifically, California Health and Safety Code Section 7050.5 requires that in the event human remains are discovered, the County Coroner be contacted to determine the nature of the remains. In the event the remains are determined to be Native American in origin, the Coroner is required to contact the NAHC within 24 hours to relinquish jurisdiction. Further, California PRC Section 5097.98, as amended by Assembly Bill 2641, provides procedures in the event human remains of Native American origin are discovered during project implementation. PRC Section 5097.98 requires that no further disturbances occur in the immediate vicinity of the discovery, that the discovery is adequately protected according to generally accepted cultural and archaeological standards, and that further activities take into 3.6 Geology, Soils, and Seismicity Less Than Significant Potentially with Less Than Significant Mitigation Significant Issues(andSupporting Information Sources): Impact Incorporation Impact No Impact 6. GEOLOGY, SOILS, AND SEISMICITY— Would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as ❑ IR delineated on the most recent Alquisl-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? (Refer to Division of Mines and Geology Special Publication 42.) II) Strong seismic ground shaking? iii) Seismic -related ground failure, including El El liquefaction? iv) Landslides? b) Result In substantial soil erosion or the loss of topsoil? El C) Be located on a geologic unit or soil that is unstable, 0 E ® E] or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? e) Have soils incapable of adequately supporting the use El EJ of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? Discussion a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? (Refer to Division of Mines and Geology Special Publication 42.) No Impact. Based on a review of the City of Newport Beach General Plan, Safety Element, the City is located in the northern part of the Peninsular Ranges Province which is an area that is exposed to risks from multiple earthquake fault zones. The nearest earthquake that contains an Alquist-Priolo Earthquake Fault Zone is the Newport - Inglewood fault zone. This fault is located offshore from the City of Newport Beach. Based on a review of the Special Studies Zones map prepared by the California Division of Mines and Geology, there are no Alquist-Priolo Earthquake Fault Zones on the project The erosion control best management practices (BMPs) such as scheduling, preservation of existing vegetation, hydroseeding, sandbags, fiber rolls, and silt fences would prevent the exposure of soil to wind and water and reduce the threat of erosion during construction to less than significant. Once constructed, the potential for erosion or loss of topsoil is substantially reduced. The project would include creek restoration activities that would include floodplain restoration, streambank stabilization and habitat restoration. Floodplain restoration and streambank stabilization activities would result in flood flow attenuation, stabilization of the north bank of the main channel, and creation of an active sinous riparian floodplain. The north creek bank at the inlet would be stabilized using natural bioengineering techniques. Riparian habitat would be restored directly downstream of the floodplain restoration area through the removal of invasive trees, soil remediation to reduce plant -limiting sodium levels, and replacement with native riparian species. The proposed project would reduce the potential for soil erosion or loss of topsoil to less than significant. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? Less than Significant Impact. As described above, the development of the proposed structures would be required to adhere to the CBC and City requirements. These requirements would ensure that appropriate engineering techniques are implemented to reduce any potential for landslides, lateral spreading, subsidence, liquefaction or collapse to less than significant. d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? Less than Significant Impact. Although the west side of Big Canyon contains previously dredged materials from Upper Newport Bay that could contain expansive soils, it is unknown if the project site contains expansive soil. As stated above, the proposed structures would be required to comply with the CBC and the City requirements for stable soils. Compliance with these requirements would reduce the potential impacts to less than significant. e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? No Impact. The proposed project does not include septic tanks or alternative waste disposal systems. As a result, there is no potential for soil failure associated with the installation of septic tanks or alternative waste disposal systems. Resources California Division of Mines and Geology (CDMG), State of California Special Studies Zones, Newport Beach Quadrangle, 1986. Website: 3.7 Greenhouse Gas Emissions Gases that trap heat in the atmosphere are referred to as greenhouse gases (GHGs) because they capture heat radiated from the sun as it is reflected back into the atmosphere, much like a greenhouse does. The accumulation of GHGs has been implicated as a driving force for global climate change. Definitions of climate change vary between and across regulatory authorities and the scientific community, but in general can be described as the changing of the earth's climate caused by natural fluctuations and anthropogenic activities, which alter the composition of the global atmosphere. Prominent GHGs contributing to the greenhouse effect are carbon dioxide (CO2), methane (CH4), nitrous oxide (N20), hydrofluorocarbons (HFCs), chlorofluorocarbons (CFCs), perfluorocarbon (PFCs), and sulfur hexafluoride (SF6). Carbon dioxide is the "reference gas" for climate change, meaning that emissions of GHGs are typically reported in "carbon dioxide -equivalent" (CO2e) measures. There is international scientific consensus that human -caused increases in GHGs have and will continue to contribute to global warming, although there is uncertainty concerning the magnitude and rate of the warming. Potential global warming impacts in California may include, but are not limited to, loss in snow pack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years. Secondary effects are likely to include global rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity. In 2005, in recognition of California's vulnerability to the effects of climate change, Governor Schwarzenegger established Executive Order S-3-05, which sets forth a series of target dates by which statewide emissions of GHG would be progressively reduced, as follows: • By 2010, reduce GHG emissions to 2000 levels; e By 2020, reduce GHG emission to 1990 levels; and e By 2050, reduce GHG emissions to 80 percent below 1990 levels. In 2006, California passed the California Global Warming Solutions Act of 2006 (Assembly Bill No. 32; California Health and Safety Code Division 25.5, Sections 38500, et seq., or AB 32), which requires CARB to design and implement emission limits, regulations, and other measures, Less Than Significant Potentially With Less Than Issues (and Supporting Information Soumesf: Signi(ecent Impact Mitigation Incorporation Significant Impact No Impact 7. GREENHOUSE GAS EMISSIONS — Would the project: a) Generate greenhouse gas emissions, either directly or El indirectly, that may have a significant Impact on the environment? b) Conflict With an applicable plan, policy or regulation E] ❑ CK adopted for the purpose of reducing the emissions of greenhouse gases? Discussion Gases that trap heat in the atmosphere are referred to as greenhouse gases (GHGs) because they capture heat radiated from the sun as it is reflected back into the atmosphere, much like a greenhouse does. The accumulation of GHGs has been implicated as a driving force for global climate change. Definitions of climate change vary between and across regulatory authorities and the scientific community, but in general can be described as the changing of the earth's climate caused by natural fluctuations and anthropogenic activities, which alter the composition of the global atmosphere. Prominent GHGs contributing to the greenhouse effect are carbon dioxide (CO2), methane (CH4), nitrous oxide (N20), hydrofluorocarbons (HFCs), chlorofluorocarbons (CFCs), perfluorocarbon (PFCs), and sulfur hexafluoride (SF6). Carbon dioxide is the "reference gas" for climate change, meaning that emissions of GHGs are typically reported in "carbon dioxide -equivalent" (CO2e) measures. There is international scientific consensus that human -caused increases in GHGs have and will continue to contribute to global warming, although there is uncertainty concerning the magnitude and rate of the warming. Potential global warming impacts in California may include, but are not limited to, loss in snow pack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years. Secondary effects are likely to include global rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity. In 2005, in recognition of California's vulnerability to the effects of climate change, Governor Schwarzenegger established Executive Order S-3-05, which sets forth a series of target dates by which statewide emissions of GHG would be progressively reduced, as follows: • By 2010, reduce GHG emissions to 2000 levels; e By 2020, reduce GHG emission to 1990 levels; and e By 2050, reduce GHG emissions to 80 percent below 1990 levels. In 2006, California passed the California Global Warming Solutions Act of 2006 (Assembly Bill No. 32; California Health and Safety Code Division 25.5, Sections 38500, et seq., or AB 32), which requires CARB to design and implement emission limits, regulations, and other measures, construction -related GHG emissions would be 3.47 COZe MT/yr. With respect to operational emissions, the only GHG emissions generated by the proposed project would be periodic maintenance on-site. This maintenance would include maintenance of the water dosing station, monitoring the bioretention cell for any debris buildup and maintenance of any invasive or dead vegetation removal. The periodic maintenance would not be expected to result in higher GHG emissions than produced by construction activities. Therefore, a conservative estimate of the operational GHG emissions was chosen as 20% of the annual construction GHG emissions. TABLE 3-9 ESTIMATED PROJECT CONSTRUCTION GHG EMISSIONS Proposed Project Emission Source Emission ie (MT/yr) Construction Annual Project Construction (Amortized over 30 yrs)a 3.47 Operation 20.79 Total Annual Emissions 24.26 CAPCOA Screening Threshold 3000 Significant Impact? No NOTES: CO,e= carbon dioxide equivalent MT/yr= metric tons per year. see Appendix B for CalEEMod model outputs. ' The total project construction GHG emissions vrere derived by summing the annual construction emissions (MT/yr) for all nine phases. Total project construction GHG emissions= 103.97 Cole MT/yr. Amortized over 30 years, annual project construction GHG emissions = 3.47 COye MT/yr. As shown in Table 3-9, the proposed project's total annual GHG emissions resulting from construction activities and project operation would be approximately 24.26 MT COZe per year. Thus, the project's total annual GHG emissions would not exceed the 3,000 MT Of COze per year screening threshold recommended by SCAQMD. Therefore, the proposed project would not result in the generation of substantial levels of GHG emissions and would not result in emissions that would adversely affect the statewide attainment of GHG emission reduction goals of AB 32. This impact would be less than significant. b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? No Impact. The proposed project would generate temporary construction -related GHG emissions and minimal GHG emissions during operations. Because the proposed project only involves the installation of surface water treatment infrastructure, culvert improvements and restoration activities, implementation of the project would not result in, or induce, growth in the project area that has not been accounted for by the City of Newport Beach. Consequently, no growth -inducing development or land use that would generate GHG emissions would occur under the project. The proposed project would not conflict with any adopted plan's goals of reducing GHG emissions. 3.8 Hazards and Hazardous Materials Less Than Significant Impact No Impact b) Create a significant hazard to the public or the ❑ Less Than ® ❑ Significant Potentially with Significenf Mitigation Issues (and Supporting Information Sources): Impact Incorporation a. HAZARDS AND HAZARDOUS MATERIALS— Would the project: G) Emit hazardous emissions or handle hazardous or a) Create a significant hazard to the public or the ❑ ❑ environment through the routine transport, use, or acutely hazardous materials, substances, or waste disposal of hazardous materials? Less Than Significant Impact No Impact b) Create a significant hazard to the public or the ❑ ❑ ® ❑ environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials Into the environment? G) Emit hazardous emissions or handle hazardous or ❑ ❑ ® ❑ acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of ❑ ❑ ❑ hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land use plan ❑ ❑ ❑ or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? b For a project within the vicinity of a private airstrip, ❑ ❑ ❑ would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically Interfere with ❑ ❑ ❑ an adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of loss, ❑ ❑ ❑ injury or death involving wildland fires, Including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? Discussion a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Less than Significant Impact. Construction activities associated with the proposed project would involve site clearing, excavation, grading, and other ground -disturbing activities. Construction activities would be required for the installation of the project facilities, including the culvert extension, the bioretention cell liner and piping, and the bioengineering structure construction. Construction activities would occur for approximately five months within the project site. The proposed construction activities would require the use of equipment, such as loaders, excavators, trucks, and other powered equipment, and would therefore use fuels (gasoline or diesel) and lubricants (oils and greases). All construction equipment would be housed within the staging area of the project site. The construction equipment on site may require minor construction is completed. Operation of the proposed project would not introduce any hazardous emissions or materials into the project site. Therefore, the proposed project would result in less than significant hazardous material -related impacts to schools within a quarter -mile of the project. d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? No Impact. Pursuant to Government Code 65962.5, environmental regulatory database lists were reviewed to identify and locate properties with known hazardous substance contamination within the proposed project area (California Government Code, Section 65960 et seq.) (see Appendix D). A review of the Department of Toxic Substances Control's (DTSC) Hazardous Waste and Substances List — Site Cleanup (Cortese List) indicates that identified hazardous material sites are not located within the project area (DTSC, 2007). There was a formerly leaking underground storage tank across the street at Big Canyon Country Club, but the case has closed as of May 15, 2001 (EDR, 2016). A review of the DTSC EnviroStor and the State Water Resources Control Board GeoTracker online databases did not indicate any open cleanup sites or hazardous waste facilities within the vicinity of the project area. Therefore, since the project is not located on a list associated with hazardous materials, no impacts would occur. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? No Impact. The nearest public airport to the project site is John Wayne Airport (JWA), approximately 2.5 miles north of the site. The John Wayne Airport Safety Compatibility Zones are defined in the Airport Environs Land Use Plan for JWA (ALUC, 2013). The proposed project is not located within any Safety Compatibility Zones for JWA. No impacts to safety hazards for people residing or working in the project area would occur. f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? No Impact. The proposed project is not located within the vicinity of a private airstrip. The nearest private airstrip to the project site is the L.A. Times Costa Mesa Heliport approximately 5 miles northwest of the project site (www.tollfreeairline.com). No airstrip related hazard impacts would occur. g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? No Impact. The Newport Beach Fire Department prepared an Emergency Operations Plan (EOP) that was adopted by the City of Newport Beach in September 2011. The purpose of the EOP is to provide guidance for the City's response to extraordinary emergency situations associated with natural disasters, technological incidents, and national security emergencies in or affecting the 3.9 Hydrology and Water Quality Discussion a) Violate any water quality standards or waste discharge requirements? No Impact. The proposed project would not violate any water quality standards or waste discharge requirements because the project includes treatment facilities that would improve surface water quality in the project area. Less Than Significant Potentially with Less Than Issues fandSupporting lnrormation Sources): Significant Impact Mitigation Incorporation Significant Impact No Impact 9. HYDROLOGY AND WATER QUALITY— Would the project: a) Violate any water quality standards or waste ❑ ❑ El requirements? b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the ❑ ❑ production rate of pre-existing nearby wells would ® ❑ drop to a level which would not support existing land uses or planned uses for which permits have been granted)? c) Substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that ❑ ❑ ® ❑ would result in substantial erosion or siltation on. or off-site? d) Substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, substantially increase the ❑ ❑ ® ❑ rate or amount of surface runoff in a manner that would result In flooding on- or off-site? e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater ❑ ❑ drainage systems or provide substantial additional ❑ IK sources of polluted runoff? f) Otherwise substantially degrade water quality? ❑ ❑ ❑ g) Place housing within a 100 -year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood E] El Rate Map or other flood hazard delineation ElInsurance map? h) Place within a 100 -year flood hazard area structures that impede ❑ El ® ❑ would or redirect flood flows? 1) Expose people or structures to a significant risk of loss, injury or death Involving flooding, including ❑ ❑ ❑ flooding as a result of the failure of a levee or dam? j) Expose people or structures to a significant risk of loss, injury or death involving inundation by seiche, ❑ ❑ ❑ tsunami, or mudflow? Discussion a) Violate any water quality standards or waste discharge requirements? No Impact. The proposed project would not violate any water quality standards or waste discharge requirements because the project includes treatment facilities that would improve surface water quality in the project area. the bioretention cell that would retain and filter these flows. Following treatment of the stormwater, the flow would be discharged through an outlet structure that would control the rate of discharge. Therefore peak storm flows that can impact downstream sections of the creek would be attenuated. The proposed project would therefore reduce peak flows that may impact the sensitive habitat of the site, and potential flooding impacts associated with the project would be less than significant. e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? No Impact. Surface flow rates that currently discharge to the site from Jamboree Road would be measurably reduced by the bioretention cell. The project includes a new permanent access that would include adequately design stormwater drainage features to accommodate the proposed flows and not impact downstream areas. In addition, the project would not add additional sources of polluted runoff, but would improve downstream surface water quality through the implementation of the proposed surface water quality improvements. The proposed project would result in no impacts to the capacity of the existing stormwater drainage system and no impacts to downstream surface water quality. f) Otherwise substantially degrade water quality? No Impact. The Project would result in positive water quality improvement for both stormwater and dry weather surface flows. Storm Flows — The purpose of the stormwater treatment system is to reduce transportation - related constituent concentrations currently discharged to Big Canyon Creek during storm events and to attenuate stormwater peak -flow discharge rates from the contributing Jamboree Road drainage area. The transportation -related pollutants are currently conveyed to the receiving waters in Big Canyon Creek from a variety of sources, including vehicles, road maintenance, maintenance facility runoff, and landscaping maintenance. Vehicles are known to produce a variety of pollutants that can have a negative impact on water quality in the receiving waters to which they drain. Metals such as copper and zinc can build up on road surfaces through brake and tire wear; other metals such as cadmium, chromium and sometimes lead can be deposited on road surfaces from paint on vehicles and streets. Metals often bind to sediments, trash, and debris on road surfaces; these can be carried into waterways during storm events. In addition to pollutants associated with vehicles, landscaped areas associated with or adjacent to streets (e.g., median, parkway, and residential landscaping) can be sources of pollutants such as pesticides, nutrients (particularly nitrate and phosphorus), and fecal -indicator bacteria (all of which are known to be associated with urban landscaping, which is found throughout the 11.1 -acre Jamboree Road drainage area). These pollutants can be transported to receiving waters during storm events. Finally, in addition to direct deposition to the road surface, street surfaces and adjacent walkways and landscaped areas can be impacted from vehicle emissions through atmospheric deposition of pollutants such as the dissolved fraction of metals and organics (e.g., polynuclear aromatic hydrocarbons (PA -Hs). i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? No Impact. No risk associated with property loss or life threatening conditions would result from the proposed project as no significant changes in site hydrology would occur as a result of the project. Hydraulic analysis of the proposed flood control conveyance show that velocities in the conveyance would be below erosive levels due to the 2% longitudinal slope and heavily vegetated side slopes. The proposed project would not increase the risk of people or structures to loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam. The watershed is heavily urbanized and the Upper Newport Bay is protected against ocean waves. Therefore, the proposed project would result in no impacts related to flooding. P Expose people or structures to a significant risk of loss, injury or death involving inundation by seiche, tsunami, or mudflow? No Impact. No risk associated with property loss or life threatening conditions would result from the proposed project as no significant changes in site hydrology would occur as a result of the project. Hydraulic analysis of the proposed flood control conveyance show that velocities in the conveyance would be below erosive levels due to the 2% longitudinal slope and heavily vegetated side slopes. The proposed project would not increase the risk of the project area or surrounding land to be inundated as a result of seiche, tsunami, or mudflow. The watershed is heavily urbanized and the Upper Newport Bay is protected against ocean waves. Therefore, the proposed project would result in no impacts related to seiche, tsunami or mudflow. Resources California Stormwater Quality Association, Stormwater Best Management Practice Handbook, New Development and Redevelopment, January 2003. Website: httns://www.casga.ore/sites/default/files/BMPHandbooks/BMP NewDevRedev Comulete pddf. Accessed on February 12, 2016. City of Newport Beach, City of Newport Beach General Plan, Chapter 11: Safety Element. Adopted July 25, 2006. County Central -Coastal NCCP/HCP, will be designated to meet Plan standards. The highly degraded riparian channel, floodplain, and native vegetation will be restored to better functioning riparian habitat; restoration of adjacent coastal sage scrub areas will provide higher -quality upland habitat for wildlife and wetland buffer function; and the water quality facilities will greatly improve the hydrology and water quality of the creek. Therefore, the project will not conflict with the provisions of any local policies or ordinances protecting biological resources or any NCCP/HCPs. Resources City of Newport Beach, City of Newport Beach General Plan, Chapter 3: Land Use Element. Adopted July 25, 2006 City of Newport Beach, Local Coastal Program, Coastal Land Use Plan, Amended February 2009. Website: htto://www.nMortbeachca.gov/PLN/LCP/Intemet%2OPDFs//CLUP Cover%20and%20T able%20of%2OContems.ndf. Accessed on February 12, 2016. City of Newport Beach. Newport Beach Municipal Code. Title 20: Planning and Zoning. Passed November 24, 2015. <http://www.codepublishing.com/CA/NewportBeach/ ?NewportBeach20/NewportBeach20.htm1>. Accessed on January 14, 2015. City of Newport Beach, City of Newport Beach General Plan EIR. Mineral Resources. July 25, 2006. in units of A -weighted decibels (dBA). A -weighting follows an international standard methodology of frequency deemphasis and is typically applied to community noise measurements. An individual's noise exposure is a measure of noise over a period of time. While a noise level is a measure of noise at a given instant in time, community noise varies continuously over a period of time with respect to the contributing sound sources of the community noise environment. Community noise is primarily the product of many distant noise sources, which constitute a relatively stable background noise exposure, with the individual contributors unidentifiable. The background noise level changes throughout a typical day, but does so gradually, corresponding with the addition and subtraction of distant noise sources such as traffic. What makes community noise variable throughout a day, besides the slowly changing background noise, is the addition of short -duration, single -event noise sources (e.g., aircraft flyovers, motor vehicles, sirens), which are readily identifiable to the individual. These successive additions of sound to the community noise environment change the community noise level from instant to instant, requiring the measurement of noise exposure over a period of time to legitimately characterize a community noise environment and evaluate cumulative noise impacts. This time -varying characteristic of environmental noise is described using statistical noise descriptors. The most frequently used noise descriptors are summarized below: Leq: The Leq, or equivalent sound level, is the energy -mean dBA during a measured time interval. It is the "equivalent" constant sound level that would have to be produced by a given source to equal the acoustic energy contained in the fluctuating sound level measured. L,,,e,,: The maximum, instantaneous noise level experienced during a given period of time L,,,;,,: The minimum, instantaneous noise level experienced during a given period of time. Ldp: Also termed the DNL, the L& is defined as the A -weighted average sound level for a 24- hour day with a 10 -dB penalty added to nighttime sound levels (10:00 p.m. to 7:00 a.m.) to compensate for increased sensitivity to noise during usually quieter evening and nighttime hours. CNEL: CNEL, or Community Noise Equivalent Level, is defined as the A -weighted average sound level for a 24-hour day. It is calculated by adding a 5 -dB penalty to sound levels in the evening (7:00 p.m. to 10:00 p.m.) and a 10 -dB penalty to sound levels at night (10:00 p.m. to 7:00 am.) to compensate for increased sensitivity during such time periods when a quiet environment is expected. An important way of predicting a human reaction to a new noise environment is the way it compares to the existing environment to which one has adapted (i.e., comparison to the ambient noise environment). In general, the more a new noise level exceeds the previously existing TABLE 3-10 GENELAN PLAN POLICY N1.8 DBA INCREASE Existing CNEL (dBA) dBA Increase 55 3 60 2 65 1 70 1 75+ Any increase is considered significant SOURCE: City or Newport Beach General Plan Policy N5.1 describes that the limited hours of construction activity is enforced. The limited construction hours are based on the municipal code. City of Newport Beach Municipal Code Section 10.28.040 limits construction hours between 7:00 a.m. and 6:30 p.m. on any weekdays and between 8:00 a.m. and 6:00 p.m. on any Saturdays. It also prohibits construction activities on any Sundays and any federal holidays. a) Exposure of persons to or generation of noise levelS in excess of standards established in the local general plan or noise ordinance, or applicable standards or other agencies? Less than Significant Impact. A significant impact may occur if the proposed project would generate excessive noise that exceeds the noise level standards set forth in the respective General Plan Noise Elements and Noise Ordinances of the City of Newport Beach. Potential project noise impacts were assessed for 1) project construction to the adjacent noise sensitive receivers, 2) off- site noise impacts due to the project operation, and 3) on-site noise impact to the project site. It is concluded the impact would be less than significant. See details below. Construction Noise With regard to construction noise, the City's noise ordinance, Section 10.28.040 limits construction hours between 7:00 a.m, and 6:30 p.m. on any weekdays and between 8:00 a.m. and 6:00 p.m. on any Saturdays. It also prohibits construction activities on any Sundays and any federal holidays. It is assumed that construction would not occur outside of indicated hours and considered less than significant. Off -Site Noise After the completion of the project, there would be no noise generated sources in the project site. The potential noise generated activities would be occasional maintenance and repair activities throughout a year. It is assumed that maintenance and repair activities would occur within the includes, but is not limited to, electron microscopes, high-resolution lithographic equipment, and normal optical microscopes. Category 2 refers to all residential land uses and any buildings where people sleep, such as hotels and hospitals. Category 3 refers to institutional land uses such as schools, churches, other institutions, and quiet offices that do not have vibration -sensitive equipment, but still have the potential for activity interference. The vibration thresholds associated with human annoyance for these three land -use categories are shown in Table 3-12. TABLE 3-12 GROUNDBORNE VIBRATION IMPACT CRITERIA FOR GENERAL ASSESSMENT Occasional Land Use Category Frequent Events" Events" Infrequent Events` Category 1: Buildings where vibration would 65 VdB° 65 VdB" 65 VdB" interfere with Interior operations. Category 2: Residences and buildings where 72 VdB 75 VdB 80 VdB people normally sleep. Category 3: Institutional land uses with 75 VdB 78 VdB 83 VdB primarily daytime use. a "Frequent Events" is defined as more than 70 vibration events of the same source per day. b "Occasional Events" is defined as between 30 and 70 vibration events of the same source per day. o 'Infrequent Events' is defined as fewer than 30 vibration events of the same kind per day. d This criterion is based on levels that are acceptable for most moderately sensitive equipment such as optical microscopes. SOURCE: FTA, 2006. The various peak particle velocity (PPV) expressed in inches per second (in/sec) and root mean square (RMS) velocity expressed in VdB levels for the general construction equipment that would operate during the construction of the proposed project are identified in Table 3-13. Note that it is assumed that impact activities, such as pile driving, would not be used for this project. TABLE 3-13 VIBRATION SOURCE LEVELS FOR CONSTRUCTION EQUIPMENT Approximate PPV Approximate RMS Equipment (intsec) at 25 feet (VdB) at 25 feet Large Bulldozer 0.089 87 Loaded Trucks 0.076 86 Jackhammer 0.035 79 Small Bulldozer 0.003 58 r Vibratory roller would be used only for Pond Lining/Miscallaneous phase SOURCE: FTA, 2006. Significance after Mitigation With the implementation of Mitigation Measure N0I-1, vibration impacts from operational activities associated with maintenance would be reduce to less than significant. c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? Less than Significant Impact. After the completion of the project, there would be no noise generated sources in the project site. The potential noise generated activities would be occasional maintenance and repair activities throughout a year. It is assumed that maintenance and repair activities would occur within the hours indicated in the City's noise ordinance, Section 10.28.040. Therefore, the impact would be less than significant. d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? Less than Significant with Mitigation Incorporation. The project would temporary increase noise levels during construction phases. Construction of the proposed project would occur in multiple phases within a project boundary and is expected to last approximately five months. Construction phases and activities are presented in Table 3-14. TABLE 3-14 CONSTRUCTION SCHEDULE Phase Activity Duration Months Site preparation/ Mobilization &Earthwork clearing/Grubbing 1-2 weeks Month 1 Excavation and grading 2-3 weeks Months 1 and 2 Culvert extension 4-6 weeks Months 2 and 3 Drainage Structures and Piping Construction Dry weather diversion structures and external piping 2-3 weeks Month 3 Bioretention cell liner and piling 1-2 weeks Months 3 and 4 Water Quality System Construction Bloretention cell media placement 1-2 weeks Month 4 Bioengineering structure construction 1-2 weeks Month 4 OCSD Scope OCSD dosing station installation 4-6 weeks Months 3, 4, and 5 Restoration Site vegetation restoration 3-4 weeks Month 5 Construction activities occurring under each of these phases would require the use of heavy equipment (e.g., excavators, bacichoes, loaders, tractors, etc.) along with the use of smaller power tools, generators, and other sources of noise. During each construction phase there would be a different mix of equipment operating and noise levels would vary based on the amount of equipment in operation and the location of each activity. As such, construction activity noise levels during each phase would fluctuate depending on the particular type, number, and duration of use of the various pieces of construction equipment. TABLE 3-15 CONSTRUCTION EQUIPMENT USAGE AND NOISE LEVELS Maximum Noise Equipment Hours Estimated Noise Equipment° Level at 50' (dBA)° Quantity' per day' Level at 50' (dBA) OCSD Dosing Station Installation Loader 80 1 8 86 Back Hoe 80 1 8 Dozer 85 1 8 Compactor 80 1 8 Site Vegetation Restoration Dozer 85 1 8 68 Water Truck 84 1 2 Soil Disc/ Tractor 84 1 8 Hydroseeder Truck 84 1 8 'Bums & McDonnell 2016. ° maximum noise levels are derived from Federal Highway Administration's (FHWA) Roadway Construction Noise Model User's Guide. Noise levels for those equipment not included in this User's Guide are estimated based on similar equipment SOURCE: ESA 2016. During the project's construction activities, the nearest and most notable off-site sensitive receptors to the construction site would be the existing multi -family residential uses to the north, which would be as close as 10 feet from the project boundary. Due to the use of construction equipment during the construction phases, the project would expose these sensitive receptors to increased exterior noise levels. Over the course of a construction day, the highest noise levels would be generated when multiple pieces of construction equipment are being operated concurrently. The City's noise ordinance, Section 10.28.040 limits construction hours to between 7:00 a.m. and 6:30 p.m. on any weekdays and between 8:00 a.m. and 6:00 p.m. on any Saturdays. It also prohibits construction activities on any Sundays and any federal holidays. Thus, the construction activities associated with the proposed project would be required to adhere to the applicable permitted hours of operation established under the City of Newport Beach's Noise Ordinance. However, although the proposed project's construction activities would only occur under the permitted hours allowed under the City of Newport Beach's Noise Ordinance, the proposed project would still expose the existing sensitive receptors located in proximity to the project site to increased exterior noise levels above existing ambient noise levels. It should be noted, however, that any increase in noise levels at the off-site sensitive receptors during project construction would be temporary in nature, and would not generate continuously high noise levels, although occasional single -event disturbances are possible. Nonetheless, because the temporary noise nuisance generated by the project's construction activities would constitute a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project, this noise impact is considered to be potentially significant. Federal Highway Administration (FHWA), Roadway Construction Noise Model User's Guide, 2006. Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment, 2006. County of Orange, Airport Environs Land Use Plan for John Wayne Airport, April 17, 2008. 3.14 Public Services Less Than Significant Potentially with signincant Mitigation Issues (and Supporting Information Sources): Impact Incorporation 14. PUBLIC SERVICES— Would the project: a) Result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental facilities, the construction of which could cause significant environmental Impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the following public services: 1) Fire protection? ii) Police protection? ii) Schools? iv) Parks? ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Less Than Significant Impact No Impact v) Other public facilities? ❑ ❑ ❑ Discussion Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: a) Fire protection? No Impact. The Newport Beach Fire Department (NBFD) provides fire protection services for the entire City. The nearest NBFD fire station is Fire Station #3 located approximately 0.4 miles south of the project site at 868 Santa Barbara Drive. The proposed project would restore habitat, provide water quality features, and provide enhanced access to the project site for trail users. The proposed project could increase the use of the project area by increasing access and providing educational opportunities through the installation of interpretive signs along the trail. The project site could also provide learning opportunities for community and school groups. Although the project may increase the use of the project area, this increase would not result in a substantial number of trail users such that the fire department's service would be substantially affected. In addition, the enhancement of onsite access would allow the fire department improved access within the project site for emergencies. Because the proposed project is not altering the use of the project site (i.e., provision of trails), and the project would not substantially alter the number of trail users, the proposed project would not require the NBFD to provide new or physically altered facilities to serve the project site. Therefore, the implementation of the proposed project would result in no environmental impacts to new or physically altered fire department facilities because changes to these City facilities would not be required. e) Other public facilities? No Impact. The proposed project would introduce no new residents that would directly increase the City's population, and thus the project would result in no increase in the demand for other public services, such as libraries or hospitals. Therefore, the implementation of the proposed project would result in no environmental impacts to new or physically altered public facilities such as libraries and hospitals. Resources City of Newport Beach, Fire Stations. Website: http://newportbeachca.gov/government/departments/fire-department/fire-operations- division/fire-stations. Accessed on February 12, 2016.. City of Newport Beach, City of Newport Beach General Plan. General Plan Land Use Overview Map, November 2006. Website: htip://www.newi)ortbeachca.gov/PLN/General Plan/Fi res/FigLU01 GeneralPlanOvervi ewMap 11x17color web.pdf. Accessed on February 12, 2016. City of Newport Beach, Police Department. Website: h!W://www.nbpd.org/. Accessed on February 12, 2016. 3.16 Transportation and Traffic Less Than Significant Potentially with Less Than Significant Mitigation Significant Issues (and Supporting Information Sources): Impact Incorporation Impact No Impact 16. TRANSPORTATION AND TRAFFIC — Would the project: a) Conflict with an applicable plan, ordinance or policy ❑ ❑ ® ❑ establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non -motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? b) Conflict with an applicable congestion management ❑ ❑ ® ❑ program, including, but not limited to, level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including ❑ ❑ ❑ either an increase in traffic levels or a change in location, that results in substantial safety risks? d) Substantially increase hazards due to a design feature ❑ ❑ ❑ (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? ❑ ❑ ❑ D Conflict with adopted policies, plans, or programs ❑ ❑ ❑ regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? Discussion a) Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non -motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Less than Significant Impact. The project site is assessable from Back Bay Drive and Jamboree Road by trail users as well as maintenance personnel. The implementation of the proposed project would result in an increase in traffic during construction activities and may result in minor increases in maintenance personnel trips during the operation of the project. During construction, approximately 8 employees will travel to the project site during the morning peak hour traffic period (i.e., prior to 9 am). Construction activities will require the use of haul trucks for vegetation and soil removal. The haul trucks would be used during the non -peak hours (i.e., after 9 am and prior to 4 pm). A maximum of 40 trucks per day during 6 hours each day would result in a maximum average of 7 trucks per hour. Trucks arriving to the site would travel along Jamboree Road, San Joaquin Hills Drive, and Back Bay Drive to the access road within Big posted along Back Bay Drive regarding the construction activities and duration. Therefore, the proposed project would not result in increasing hazards due to a design feature. e) Result in inadequate emergency access? No Impact. Project construction activities would be located on the project site and would not require any lane closures. In addition, project operational activities will not require lane closures or impact emergency access. The provision of additional trail segments on the project site would provide greater access to the project area, but would not adversely affect emergency access. Therefore, the project would not impact emergency access to the project site or areas in the vicinity of the project site. I) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? No Impact. The implementation of the proposed project would not conflict with policies, plans or programs related to public transit, bicycle or pedestrian facilities. Back Bay Drive currently has public transportation facilities, including a one way vehicular pathway. The project construction vehicles would use the one-way vehicular pathway and limit their speeds to the existing 15 miles per hour limit. Resources Orange County Transportation Authority, Congestion Management Program, 2015. Website: htty://www.octa.net/pdf/Final%202015%20CMP.pdf. Accessed on February 16, 2016. Orange County Transportation Authority, Congestion Management Program Preparation Manual, 2011. Website: http://www.octa.net/pdf/cmRprepmanual.i3. Accessed on February 16, 2016. b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? No Impact. The proposed project would not require the construction of a new water or wastewater treatment facility or expansion of the existing treatment facilities serving the project vicinity. The project requires no potable water supply for the project site. The project would involve the extension of an existing sewer conveyance within the project site, but would not require the extension of any existing water or wastewater facilities off the project site. Therefore, the proposed project would result in no impact requiring the construction of water or wastewater treatment facilities. c) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? No Impact. The proposed project would not require the construction of new stormwater drainage facilities. The project itself includes the construction of a primary stormwater treatment structure to trap and pretreat contaminants prior to conveyance to the bioretention cell. The project would not require the addition of a storm drain conveyance or the expansion of any stormwater drainage facilities since the project aims to restore the natural habitat and improve water quality within the creek. With the implementation of these features, the proposed project would not require the construction of new storm water drainage facilities or expansion of existing facilities off site. Therefore, the project would result in no environmental effects from new storm water drainage facilities or expansion of existing facilities to serve the proposed project. d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? No Impact. The City of Newport Beach's water supply is provided by the Municipal Water District of Orange County. The construction and operation of the proposed project requires no use of imported water supply from existing water resources. Thus, the project would result in no need for new or expanded water supply entitlements, and no impacts would occur. e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? Less than Significant Impact. Wastewater collected by the Sanitary District is sent to the County Sanitation Districts of Orange County (County Sanitation) plants for treatment and disposal. Wastewater is treated at County Sanitation's treatment plants in Fountain Valley and Huntington Beach. According to County Sanitation's treatment plant operational data, the combined effluent treated at both plants is approximately 200 million gallons daily (average). County Sanitation operates under an NPDES ocean discharge permit issued by the California Regional Water Quality Control Board (OCSD, 2016). The project's increase in selenium 3.18 Mandatory Findings of Significance Less Than Significant Potentially with Less Than significant Mitigation Significant Issues (and Supporting Information Sources): Impact Incorporation Impact No Impact 18. MANDATORY FINDINGS OF SIGNIFICANCE Would the project: a) Have the potential to degrade the quality of the ® ❑ environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory? b) Have impacts that are individually limited, but ❑ ® F-1 ❑ cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? c) Have environmental effects that would cause ❑ ❑ ® ❑ substantial adverse effects on human beings, either directly or indirectly? Discussion a) Have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory? Less than Significant with Mitigation Incorporated. Construction activities associated with the proposed project could impact nesting birds, vegetation communities such as riparian and wetland habitat and could temporarily disrupt wildlife movement. These potential impacts to these biological resources would be significant. Construction activities could also impact historical or prehistorical resources. Although no resources are (mown to occur on the project site, there is a potential for unknown historical or prehistorical resources to be located on the project site based on resources found in the project vicinity. These potential unknown resources could be significantly affected. Mitigation Measures Implementation of Mitigation Measures BI0-1 through BIO -3, CR -1 and CR -2 is required. Less than Significant with Mitigation Incorporated. The implementation of the proposed project could result in temporary noise increases during construction as well as vibration impacts during construction. These noise and vibration impacts could represent significant adverse effects on human beings. Mitigation Measures Implementation of Mitigation Measures NOI-I through NOI-5 is required. Significance after Mitigation The implementation of the above mitigation measures would reduce the potential vibration impacts as well as the construction noise level on the adjacent residents. This reduction in impact would result in a less than significant noise and vibration impact. i Attachment A Analysis of Impediments to Fair Housing Choice City of Newport Beach City of Anaheim City of Buena Park City of Costa Mesa City of Fountain Valley City of Fullerton City of Garden Grove City of Huntington Beach City of La Habra City of Lake Forest City of Mission Viejo City of Newport Beach City of Orange City of Rancho Santa Margarita City of San Clemente City of Santa Ana City of Tustin 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table of Contents EXECUTIVE SUMMARY.............................................................................................. i A. WHAT IS THE ANALYSIS OF IMPEDIMENTS.................................................................. ii B. DEFINING FAIR HOUSING............................................................................................. ii C. COMMUNITY PARTICIPATION...................................................................................... ii D. SUMMARY OF Al FINDINGS AND CONCLUSIONS......................................................... v E. RECOMMENDED ACTIONS TO ADDRESS IMPEDIMENTS ............................................ vi 1. INTRODUCTION............................................................................................... 1 A. PURPOSE OF THE ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE ...............1 B. LEAD AGENCIES AND GEOGRAPHIC AREA COVERED...................................................1 C. FAIR HOUSING LEGAL FRAMEWORK............................................................................3 D. ORGANIZATION OF THE REGIONAL Al .........................................................................4 E. DATA SOURCES............................................................................................................ 5 2. COMMUNITY PARTICIPATION.......................................................................... 7 A. COMMUNITY WORKSHOPS..........................................................................................7 B. FAIR HOUSING SURVEY................................................................................................8 C. AGENCY CONSULTATION............................................................................................. 9 D. PUBLIC REVIEW............................................................................................................9 3. COMMUNITY AND REGIONAL PROFILES........................................................ 10 A. DEMOGRAPHIC PROFILE............................................................................................10 B. HOUSEHOLD PROFILE................................................................................................22 C. INCOME PROFILE.......................................................................................................26 D. SPECIAL NEEDS HOUSEHOLDS...................................................................................33 E. HOUSING PROFILE......................................................................................................41 F. HOUSING ISSUES PROFILE..........................................................................................48 G. PUBLIC AND ASSISTED HOUSING............................................................................... SO H. RESIDENTIAL CARE FACILITIES....................................................................................S3 I. ACCESSIBILITY TO PUBLIC TRANSPORTATION............................................................ S5 TABLE OF CONTENTS 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 4. MORTGAGE LENDING PRACTICES.................................................................. 60 A. LENDING LAWS AND REGULATIONS..........................................................................60 B. OVERALL LENDING PATTERNS...................................................................................64 C. LENDING PATTERNS BY RACE/ETHNICITY AND INCOME LEVEL.................................68 D. LENDING PATTERNS BY CENSUS TRACT CHARACTERISTICS.......................................80 E. LENDING PERFOMANCE BY LENDER..........................................................................82 F. SUB -PRIME LENDING MARKET...................................................................................86 G. PREDATORY LENDING................................................................................................88 H. FORECLOSURES..........................................................................................................89 5. PUBLIC POLICIES AND PRACTICES.................................................................. 91 A. GENERAL PLAN POLICIES AFFECTING HOUSING DEVELOPMENT..............................91 B. ZONING ORDINANCE..................................................................................................94 C. BUILDING CODES AND OCCUPANCY STANDARDS.....................................................99 D. AFFORDABLE HOUSING DEVELOPMENT..................................................................101 E. OTHER LAND USE POLICIES, PROGRAMS AND CONTROLS ......................................103 F. ZONING REGULATIONS FOR PERSONS WITH DISABILITIES......................................107 G. LOCAL HOUSING AUTHORITIES................................................................................108 H. COMMUNITY REPRESENTATION AND PARTICIPATION............................................112 6. FAIR HOUSING PROFILE................................................................................11", A. FAIR HOUSING PRACITICES IN THE HOMEOWNERSHIP MARKET ............................114 B. FAIR HOUSING PRACTICES IN THE RENTAL MARKET...............................................118 C. FAIR HOUSING SERVICES..........................................................................................120 D. FAIR HOUSING STATISTICS AND TRENDS.................................................................122 E. TENANT -LANDLORD SERVICES.................................................................................124 F. HATE CRIMES...........................................................................................................126 I��:Z�Z�i:T����i�L�I�►Zi7� �� >F�:3 A. STATUS OF 2010-2015 ORANGE COUNTY REGIONAL Al ACTIONS ..........................128 B. STATUS OF 2010-2015 SUB -REGIONAL Al ACTIONS ................................................135 8. FAIR HOUSING PLAN....................................................................................142 A. REGIONAL IMPEDIMENTS CARRIED OVER FROM 2010 REGIONAL AND SUBREGIONAL AI...........................................................................................142 B. PUBLIC SECTOR IMPEDIMENTS................................................................................145 TABLE OF CONTENTS 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS APPENDIX A: COMMUNITY PARTICIPATION APPENDIX A-1: FAIR HOUSING WORKSHOPS APPENDIX A-2: FAIR HOUSING SURVEYS APPENDIX A-3: PUBLIC REVIEW NOTICES APPENDIX R: PUBLIC TRANSIT AND MAJOR EMPLOYMENT CENTERS r_ • • ► .:4-1- fD �rrr�e����r_���i►ne�r•1:»► r��•�-r►•rx��i.� ��r��� _l'11�i>•:I>�1�:+[���iL•I3%�Tal���f�711[. • • � :�r•L�� APPENDIX C-1: HOME PURCHASE LOAN ACTIVITIES 2008-2013 APPENDIX C-2: PERCENT OF DENIED PURCHASE LOANS - BY CENSUS TRACT - APPLICANT RACE/ETHNICITY APPENDIX D: HUD WORKSHEET APPENDIX D: HUD WORKSHEET TABLE OF CONTENTS 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS LIST OF TABLES 3-1. Population Growth 2000-2015...................................................................................................11 3-2. Age Distribution of Population 2013...........................................................................................12 3-3. Age Characteristics 2013.............................................................................................................14 3-4. Racial and Ethnic Composition of Population 2000 and 2013 ....................................................16 3-5. Growth in Racial/Ethnic Group Populations 2000-2013.............................................................18 3-6. Limited English Speaking Households 2013................................................................................21 3-7. Household Growth 2000-2015....................................................................................................22 3-8. Household Tenure...................................................................................................................... 23 3-9. Average Household Size by Tenure.............................................................................................24 3-10. 2015 State Income Limits for Orange County.............................................................................26 3-11. Median Household Income.........................................................................................................27 3-12. Family Households Below Poverty Level, 2013...........................................................................29 3-13. Income Levels by Tenure 2012................................................................................................... 31 3-14. Household Characteristics 2013.................................................................................................34 3-15. Persons Per Owner and Renter Households, 2013..................................................................... 35 3-16. Disability Characteristics of Seniors and Working -Age Adults 2013 ...........................................37 3-17. Homeless Point in Time Count 2013 and 2015...........................................................................40 3-18. Housing Growth 2000-2015........................................................................................................41 3-19. Housing Stock by Type 2015.......................................................................................................42 3-20. Housing Stock by Year Built, 2013..............................................................................................44 3-21. Cost of Housing, 2015.................................................................................................................45 3-22. Maximum Affordable Housing Prices and Rents by Income Groups 2015 .................................46 3-23. Future Housing Needs by Income Level, 2014-2021..................................................................47 3-24. Overpayment by Tenure 2012....................................................................................................48 3-25. Overcrowding by Tenure 2013...................................................................................................50 3-26. Orange County Housing Authority Section 8 Program Recipients by City .................................. 52 3-27. Licensed Community Care Facilities............................................................................................54 3-28. OCTA Bus Fare Structure 2015....................................................................................................56 3-39. OCTA Cost of Bus Passes 2015.................................................................................................... 57 4-1. Status of Home Purchase Loans 2013.........................................................................................65 4-2. Status of Home Refinance Loans 2013....................................................................................... 66 4-3. Status of Home Improvement Loans 2013.................................................................................67 4-4. Status of Home Purchase Loans by Applicant Race - 2013 ........................................................ 69 4-5. Home Purchase Loans - Completed Loan Applications Percent of Total, 2008 to 2013............ 70 4-6. Home Purchase Loans - Comparisons, Completed Loan Applications and Percentof City, 2013....................................................................................................... 72 TABLE OF CONTENTS 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 4-7. Denied by Race — Purchase Loans — 2013................................................................................... 73 4-8. Home Purchase Loans — Denial Rate Percentages, 2008 to 2013 ............................................... 74 4-9. Purchase Loans — Denied by Race/Ethnicity — Per Census Tract — 2013 ..................................... 75 4-10. Status of Home Purchase Loans by Applicant Income 2013 .......................................................77 4-11. Denied Home Purchase Loans by Applicant Income 2013.........................................................79 4-12. Purchase Loans — Denied by Income — Per Census Tract — 2013 ................................................ 81 4-13. Top 10 Lenders —All Home Loan Applications, 2013..................................................................83 4-14. Top 10 Lenders — Market Share and Income and Minority Categories - All Home Loan Applications, 2013......................................................................................................................85 4-15. Home Purchase Loans — Rate Spread, 2011 to 2013..................................................................86 4-16. Home Purchase Loans — Rate Spread —Top Orange County Lenders, 2011 & 2013 .................. 87 4-17. All Types of Loans — High Cost Loans (HOEPA), 2011 to 2013 ....................................................88 4-18. Foreclosures, September 2015...................................................................................................89 4-19. Foreclosures and Market Sales Prices, September 2014 & 2015 ...............................................90 5-1. Typical Residential Land Use Designations.................................................................................93 5-2. Zoning for a Variety of Housing Types........................................................................................ 95 5-3. Affordable Rental Units.............................................................................................................101 5-4. Development Fees....................................................................................................................102 5-5. Density Bonus Concessions.......................................................................................................103 5-6. Community Outreach by Cities.................................................................................................113 6-1. Discrimination Cases by Protected Class: 2012/13 — 2014/15 .................................................123 6-2. Tenant/Landlord Complaints and Inquiries 2012/13 — 2014/15 ..............................................125 6-3. FBI Hate Crime Statistics 2010-2014.........................................................................................127 8-1. Fair Housing Action Plan 2015/16 — 2019/20...........................................................................148 LIST OF FIGURES 1-1. 16 Orange County Participating Cities.......................................................................................... 2 3-1. Age Distribution 2013.................................................................................................................13 3-2. Population by Race/Ethnicity 2013.............................................................................................17 3-3. Minority Group Population by Census Tracts 2013....................................................................20 3-4. Household Size............................................................................................................................25 3-5. Household Distribution by Income 2013....................................................................................28 4-1. Minority Population - Purchase Loan Denials by Census Tracts 2013 ........................................76 TABLE OF CONTENTS 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS TABLE OF CONTENTS 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Executive Summary The U.S. Department of Housing and Urban Development (HUD) requires entitlement jurisdictions -- HUD grant recipients -- to develop an Analysis of Impediments to Fair Housing Choice and evaluate its fair housing issues as an individual jurisdiction and within the context of a larger region. In Orange County, 16 entitlement cities have elected to prepare a regional Analysis of Impediments to Fair Housing Choice, referred to as the Al, to fulfill their HUD requirement and remove barriers to fair housing choice for all their residents. A. What is the Analysis of Impediments This Analysis of Impediments to Fair Housing Choice, which is referred to as the Al, examines policies, procedures, and practices within a community that may limit a person's ability to choose their residence free from discrimination. This Al provides an overview of laws, regulations, conditions or other possible obstacles that may affect an individual or a household's access to housing in a community. It also presents local and regional demographic profiles, assesses the extent of housing needs among specific groups, identifies existing barriers or impediments that may limit housing choice, and proposes actions to overcome those barriers. Participating Cities The 16 participating cities within Orange County that have collaborated in the preparation of this regional Al include: ■ Anaheim ■ Buena Park ■ Costa Mesa ■ Fountain Valley ■ Fullerton ■ Garden Grove ■ Huntington Beach ■ La Habra Current Al Process ■ Lake Forest ■ Mission Viejo ■ Newport Beach ■ Orange ■ Rancho Santa Margarita ■ San Clemente ■ Santa Ana ■ Tustin This Al is consistent with the current HUD requirements, and follows the guidelines according to HUD's Fair Housing Planning Guide. However, in July 2015, HUD announced the release of a final rule to Affirmatively Further Fair Housing (AFFH), which will replace the existing Al with a new Assessment of Fair Housing (AFH). The key differences between the current Al and the new AFH are EXECUTIVE SUMMARY 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS that HUD will provide data and an AFH Assessment Tool Template for conducting the fair housing analysis; grantees will be required to incorporate fair housing planning into their Consolidated Plans; and HUD will review assessments upfront as part of the planning process. The due date for the first AFH is 270 days prior to the program year that begins on or after January 1, 2017 (or January 1, 2018, depending on grantee type) for which a jurisdiction submits a new Consolidated Plan. Since the Orange County participating cities have recently submitted their Consolidated Plans for the 2015/16- 2019/20 period, the AFH will not be required until 270 days before the start of the next five-year cycle in 2020/21.1 Therefore, this Regional Analysis of Impediments to Fair Housing Choice for 16 Orange County Cities is prepared under the current HUD Al requirements. B. Defining Fair Housing Fair housing are rules that protect a person from being discriminated against during the sales, rental or leasing of housing. According to HUD's Fair Housing Planning Guide, and based within the legal framework of federal and state laws, impediments to fair housing choice are: ■ Any actions, omissions or decisions taken because of race, color, ancestry, national origin, religion, sex, disability, age, marital status, familial status, source of income, sexual orientation or any other arbitrary factor that restricts housing choices or the availability of housing choices, or ■ Any actions, omissions or decisions that have the effect of restricting housing choices or the availability of housing choices on the basis of race, color, ancestry, national origin, religion, sex, disability, age, marital status, familial status, source of income, sexual orientation or any other arbitrary factor. In California, this also includes discrimination based on one's citizenship or immigration status. HUD also distinguishes between housing affordability and fair housing. Economic factors that affect a household's housing choices are not fair housing issues per se. Only when the relationship between household income, household type, race/ethnicity and other factors create misconceptions, biases and differential treatment would fair housing concerns arise. C. Community Participation In order to identify factors that could indicate impediments to fair housing choice, this Al incorporated a community outreach effort that included five community meetings, an on-line fair housing survey, consultation with fair housing and other service providers, and . Community Workshops During the preparation of this Al, residents, businesses, and public and private agencies were invited to participate in the discussion of fair housing issues in Orange County. The five community workshops were conducted on the following dates and at five different locations: 1 The City of San Clemente adopted a five year Consolidated Plan for the 2013/14-2017/18 period, and therefore its first AFH will be due by October 1, 2017. EXECUTIVE SUMMARY 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ September 22, 2015 — Assembly Hall, Downtown Anaheim Community Center, 250 E. Center, Anaheim, 6:00 p.m. ■ September 23, 2015 — Professional Training Center, Tustin Library, 345 E. Main Street, Tustin, 6:00 p.m. ■ September 24, 2015 – City Hall Council Chambers, 10200 Slater Avenue, Fountain Valley, 6:00 p.m. ■ September 30, 2015 – Santa Ana Police Community Room, 60 Civic Center Plaza, Santa Ana, 6:00 p.m. ■ October 1, 2015 – City Hall, Community Room, 25550 Commercentre Drive, Lake Forest, 6:00 p.m. The meetings provided the opportunity for the community to gain awareness of fair housing laws, and for residents and service agencies to share fair housing issues and concerns. To ensure that the fair housing concerns of low- and moderate -income and special needs residents were addressed, individual invitation letters were distributed via mail and email, if available, to agencies and organizations that serve the low- and moderate -income and special needs community. A notice of the Fair Housing Workshops was available in English, Spanish, and Vietnamese and published in the Orange County Register, La Opinion, and the Viet Bao Daily News. In addition, community workshop notices were posted on the various City websites. Copies of the Fair Housing Workshop notices and each City's outreach mailing list to housing agencies and organizations are included in Appendix A-1 of this Al. As a result of an extensive outreach effort, attendance at the public meetings included several service providers and citizen groups that work with residents considered a protected class according to HUD's definition. A summary of key comments from the community workshops included: ■ Affordable Housing: Increasing rents coupled with low vacancies have made it difficult to find affordable rental units. Some feel that landlords use the strong market to discriminate among potential renters. ■ Information on Housing Discrimination: Many residents lacked information on tenant rights, such as when landlords asked for immigration documents. Residents did not know where to get help when they felt they had been discriminated against. ■ Mothers with Children: A common complaint was the difficulty of families, especially mothers with children, in finding housing. ■ Overcrowding: Problem was brought up by both residents and property managers. ■ Special Needs Housing: Need for affordable rental housing units for seniors, persons with disabilities, and veterans. EXECUTIVE SUMMARY iii 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Fair Housing Survey To supplement the community meetings and to assist in further understanding fair housing issues in the region, a Fair Housing Survey was made available to Orange County residents at the City Halls of the 16 -Cities and via each City's website. In addition, surveys were provided to service providers by request. The Fair Housing Survey was also available in Spanish, Vietnamese, and Korean. During the four-week survey period in September and October 2015, 188 surveys were completed online or in hardcopy by Orange County residents. Of the total, 59 percent were Spanish-speaking, 40 percent English-speaking, and one percent Vietnamese -speaking respondents. Samples of the Fair Housing surveys in the four languages are included as Appendix A-2 of this Al. The survey consisted of questions designed to gather information on a person's experience with fair housing issues and perception of fair housing issues in their community. A summary of the key survey results included: ■ Almost 60 percent of respondents completed the survey that was translated in Spanish. ■ 57 percent of respondents have encountered housing discrimination, and of those, 88 percent felt landlord/property managers were responsible. ■ 82 percent of the discrimination occurred in an apartment complex. ■ One-half of those discriminated felt it was because of family status (families with children). ■ Over 90 percent did not report the discrimination incident. ■ 14 percent have been denied reasonable accommodation. ■ Three-quarters of respondents felt they had little to no information on housing discrimination law, and one-third would not know what to do when discriminated. Agency Consultation A Working Group was formed with key staff representing each of the 16 cities participating in the development of this Al. The Working Group provided valuable information and insight into their community housing needs and fair housing issues. Monthly meeting were held in various participating cities to discuss the data needs, the community outreach effort, the Al approval process, the action plan recommendations, and the review of the Al. In addition to information gained through the workshops and survey, numerous phone interviews were conducted with agencies such as the Fair Housing Foundation, the Fair Housing Council of Orange County, and the Orange County Housing Authority. Public Review During a 30 -day public review period from March 9 to April 7, 2016, the draft Al document was made available at city halls and on websites of the 16 -participating cities. During this review period, no written comments were received on the draft Al. EXECUTIVE SUMMARY iv 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Public review notices were published in the Orange County Register, La Opinion, and Viet Bao Daily News on March 8, 2016. Published copies of the public review notices are included in Appendix A-3. D. Summary of Al Findings and Conclusions The following is a summary of the key findings from the Al: ■ The number of fair housing cases opened by the Fair Housing Foundation and the Fair Housing Council of Orange County in the 16 participating cities total 85 over the last three years, with the leading bias based on disability (physical and mental), followed by familial status, national origin and race. ■ The racial and ethnic distribution of Orange County's population appears diverse, with 56 percent of the total population comprised of Hispanics, Asians, African Americans, and other non-white groups. However, within the County there are areas of racial/ethnic concentrations, such as in Santa Ana where over three-quarters of the population is Hispanic and ten percent Asian. Approximately ten percent of households in the County are considered to be limited English-speaking households. ■ Denial of reasonable modification or reasonable accommodation is a continuing impediment to fair housing choice. ■ Incidents of discriminatory advertising that have potentially discouraged a certain type of renter or buyer have occurred. ■ An average of 35 hate crimes are committed annually within the 16 participating cities. The highest number of hate crimes have occurred in the Cities of Huntington Beach, Santa Ana, Newport Beach and Garden Grove. ■ Disparities exist in the home purchase loan denial rates experienced by Hispanic and Black/African American applicants within the 16 cities, with these groups evidencing loan denial at rates 1.5 to 1.6 times greater than White applicants. Cities with a large Hispanic population have a disproportionately smaller number of home purchase loans. ■ Fifteen of the 16 Housing Elements are in compliance with state Housing Law. The City of San Clemente's draft 2014-2021 Housing Element was submitted for State review in early 2016. ■ Zoning regulations related to second units, single -room occupancy housing (SRO), and transitional/supportive housing in a few cities should be amended to improve access to housing choice for all populations. ■ Although all jurisdictions have adopted local density bonus ordinances, the recent addition of anti -displacement provisions under AB 2222 and modified parking standards for transit - accessible projects under AB 744, will require updates to local density bonus ordinances. EXECUTIVE SUMMARY V 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS E. Recommended Actions to Address Impediments The following actions are recommended to address the impediments to fair housing choice in the 16 - city Regional Al: Regional Impediments Carried Over from 2010 Regional and Subregional Al A-1. Housing Discrimination Recommendations for All Jurisdictions: ■ In partnership with each city's fair housing provider, conduct multi -faceted fair housing outreach to tenants, landlords, property owners, realtors, and property management companies. Methods of outreach should include workshops, informational booths, presentations to civic leaders and community groups, staff trainings, and distribution of multi-lingual fair housing literature. ■ Conduct focused outreach to small property owners/ landlords; conduct property manager trainings on a regular basis; promote fair housing certificate training. ■ Provide general counseling and referrals to address tenant -landlord issues, and provide periodic tenant -landlord walk-in clinics at City Halls and other community locations. ■ Include testing/audits within the scope of work for each city's fair housing provider. Support enforcement activity and publicize outcomes of fair housing litigation. A-2. Racial and Ethnic Segregation Recommendations for All Jurisdictions: ■ Coordinate with fair housing providers to focus fair housing services, education/outreach, and/or additional testing in areas of racial/ethnic concentrations. ■ Offer a variety of housing opportunities to enhance mobility among residents of all races and ethnicities. Facilitate the provision of affordable housing throughout the community through: 1) available financial assistance; 2) flexible development standards; 3) density bonuses; and 4) other zoning tools. ■ Promote equal access to information on the availability of affordable housing by providing information in multiple languages, and through methods that have proven successful in outreaching to the community, particularly those hard -to -reach groups. ■ Affirmatively market first-time homebuyer and/or housing rehabilitation programs to low and moderate income areas, and areas of racial/ethnic concentration. ■ Work collaboratively with local housing authorities to ensure affirmative fair marketing plans and de -concentration policies are implemented. EXECUTIVE SUMMARY Vi 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS A-3. Denial of Reasonable Modifications/ Reasonable Accommodations Recommendations for All Jurisdictions: ■ Through each city's fair housing contractor, continue to provide fair housing education and information to apartment managers and homeowner associations on why denial of reasonable modifications/accommodations is unlawful. ■ Provide information on the unlawful practice of denying reasonable modifications/ accommodations at fair housing seminars conducted by the Apartment Association of Orange County. A-4. Discriminatory Advertising Recommendations for All Jurisdictions: ■ Through each city's fair housing contractor, periodically monitor local newspapers and online media outlets to identify potentially discriminatory housing advertisements. When identified, make contact with the individual or firm and provide fair housing education. ■ Take steps to encourage both the Los Angeles Times and Orange County Register to publish a Fair Housing Notice and a "no pets" disclaimer that indicates rental housing owners must provide reasonable accommodations, including "service animals" and "companion animals" for disabled persons. A-5. Hate Crimes Recommendations for All Jurisdictions: ■ Continue to monitor FBI data to determine if any hate crimes are housing -related and if there are actions that may be taken by the City or its fair housing service provider to address potential discrimination linked to the bias motivations of hate crimes. ■ Continue to coordinate with various City and County housing, building and safety, health and sanitation, law enforcement and legal aid offices to maintain a comprehensive referral list of support services for victims of hate crimes or other violent crimes —inclusive of housing resources. A-6. Unfair Lending Recommendations for All Jurisdictions: ■ As resources permit, monitor HMDA data annually using the 2013 HMDA analysis as a benchmark. ■ As resources permit, monitor the top 10 lenders in Orange County to compare and contrast loan denial rates and percentage of loans completed to minority populations. EXECUTIVE SUMMARY Vii 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ Both of the Orange County fair housing service contractors should assist in identifying potential issues regarding redlining, predatory lending and other illegal lending activities. In addition, each city should review their agreements annually to make sure that increased and comprehensive services are being provided, and that education and outreach efforts are expanded and affirmatively marketed in low and moderate income and racial concentrated areas. ■ Each city should explore ways to collaborate with local lenders and support lenders' efforts to work with community groups to help minority households purchase their homes. Collaborative efforts should ensure that minority groups have access and knowledge of City programs, supportive services, and provide for networking opportunities with these groups. ■ Coordinate with local lenders to expand outreach efforts to first time homebuyers in minority neighborhoods. ■ Affirmatively market first-time homebuyer and/or housing rehabilitation programs in neighborhoods with high denial rates, high minority population concentrations and limited English speaking proficiency to help increase loan approval rates. Public Sector Impediments B-1. Housing Element Compliance Recommendations for Specific Jurisdictions: ■ The City of San Clemente should pursue State certification of its Housing Element. B-2. Housing for Persons with Disabilities Recommendations for Specific Jurisdictions: ■ The City of San Clemente should adopt formal Reasonable Accommodations policy and procedure in 2016. ■ The Cities of Anaheim, Tustin and La Habra should consider eliminating the processing fee for reasonable accommodation requests. ■ The City of Newport Beach should consider amending its Reasonable Accommodation procedures to eliminate the requirement for a public hearing, and to approve administratively. B-3. Zoning Regulations Recommendations for Specific Jurisdictions: ■ The City of Newport Beach should consider pursuing a Zoning Code amendment to eliminate the current age restriction on second units and establish a ministerial review process. EXECUTIVE SUMMARY viii 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ The Cities of Buena Park, Orange and Santa Ana should amend their Zoning Codes to specify provisions for SRO units. ■ The Cities of Fountain Valley and Orange should amend their Zoning Codes to regulate transitional and supportive housing as a residential use, subject to the same standards as other residential uses of the same type in the same zone. B-4. Density Bonus Incentives Recommendations for All Jurisdictions: ■ All 16 jurisdictions should amend their Zoning Codes to reflect current State density bonus law. EXECUTIVE SUMMARY ix 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 1. Introduction Equal access to housing is fundamental to each person in meeting essential needs and pursuing personal, educational, employment or other goals. In recognizing equal housing access as a fundamental right, the federal government and the State of California have both established fair housing choice as a right protected by law. A. Purpose of the Analysis of Impediments to Fair Housing Choice The purpose of an Analysis of Impediments to Fair Housing Choice is to examine policies, procedures, and practices within a community that may limit a person's ability to choice their residence free from discrimination. This Al provides an overview of laws, regulations, conditions or other possible obstacles or impediments that may affect an individual or a household's access to housing in a community. HUD defines impediments to fair housing choice as: ■ Any actions, omissions or decisions taken because of race, color, ancestry, national origin, religion, sex, disability, age, marital status, familial status, source of income, sexual orientation or any other arbitrary factor that restricts housing choices or the availability of housing choices; or ■ Any actions, omissions or decisions that have the effect of restricting housing choices or the availability of housing choices on the basis of race, color, ancestry, national origin, religion, sex, disability, age, marital status, familial status, source of income, sexual orientation or any other arbitrary factor. Once the impediments to fair housing have been identified, the Al presents actions to overcome those barriers. B. Lead Agencies and Geographic Area Covered The following 16 Orange County entitlement cities have collaborated in the preparation of this regional Al: ■ Anaheim 0 Huntington Beach 0 Rancho Santa Margarita ■ Buena Park 0 La Habra ■ San Clemente ■ Costa Mesa 0 Lake Forest ■ Santa Ana ■ Fountain Valley ■ Mission Viejo ■ Tustin ■ Fullerton 0 Newport Beach ■ Garden Grove ■ Orange The geographic area covered by this Al is shown in Figure 1-1. INTRODUCTION 1 Nus, INTRODUCTION 2 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Figure 1-1 :ounty Participating Cities I€h4 Santa largpriW nente 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS C. Fair Housing Legal Framework Federal The federal Fair Housing Act of 1968 and the Fair Housing Amendments Act of 1988 (42 U.S. Code §§ 3601-3619, 3631) are federal fair housing laws that prohibit discrimination in all aspects of housing, such as the sale, rental, lease or negotiation for real property. The Fair Housing Act prohibits discrimination based on race, color, religion, sex and national origin. In 1988, the Fair Housing Act was amended to extend protections based on familial status and to persons with disabilities (mental or physical). The Amendments Act requires landlords to provide "reasonable accommodations" (exceptions) to their rules, policies and operations to allow tenants with disabilities equal access to housing. The Act also requires landlords to allow disabled tenants to make reasonable access -related modifications at their own expense. In 2012, HUD published the Final Report on "Equal Access to Housing In HUD Programs Regardless of Sexual Orientation or Gender Identity." The new rule prohibits considering a person's marital status, sexual orientation, or gender identity in making homeless housing assistance available. In July 2015, HUD announced the release of a final rule to Affirmatively Further Fair Housing (AFFH), which will replace the existing Al with a new Assessment of Fair Housing (AFH). The new AFH will incorporate data provided by HUD and use an AFH Assessment Tool Template for conducting the fair housing analysis. Grantees will incorporate fair housing planning into the Consolidated Plans and HUD will review assessments upfront as part of the planning process. The first AFH will be required of entitlement jurisdiction beginning 270 days prior to the program year that begins on or after January 1, 2017 (or January 1, 2018, depending on grantee type) for which a jurisdiction submits a new consolidated plan. As mentioned in the Executive Summary of this Al, as the 16 Orange County participating cities have recently submitted their Consolidated Plans for the 2015/16-2019/20 period, the AFH will not be required until 270 days before the start of the next five-year cycle in 2020/21.1 Therefore, this Al for the 16 Orange County Cities is prepared under the current HUD Al requirements. California The California Department of Fair Employment and Housing (DFEH) enforces California laws that provide protection and monetary relief to victims of unlawful housing practices. The Fair Employment and Housing Act (FEHA; Part 2.8 of the California Government Code, Code Sections 12900-12996) prohibit discrimination and harassment in housing practices. 1 The City of San Clemente adopted o five year Consolidated Plan for the 2013/14-2017/18 period, and therefore its first AFH will be due by October 1, 2017. INTRODUCTION 3 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS The Unruh Act (California Government Code Section 51) protects Californians from discrimination in public accommodations and requires equal access to the accommodations. The Unruh Act provides broad protection and has been held by the courts to prohibit any arbitrary discrimination on the basis of personal characteristics or traits, and applies to a range of types of housing. The Ralph Civil Rights Act (California Civil Code Section 51.7) prohibits violence and threats of violence and specifies that housing situations are protected under this Act, including houses, apartments, hotels, boarding housing and condominiums. Violators of the Ralph Act can be sued for actual or emotional damages, in addition to civil penalties. The Bane Civil Rights Act (California Civil Code Section 52.1) provides another layer of protection for fair housing choice by protecting all people in California from interference by force or threat of force with an individual's constitutional or statutory rights, including a right to equal access to housing. The Bane Act also includes criminal penalties for hate crimes. However, convictions under the act are not allowed for speech alone unless that speech itself threatened violence. In addition to these acts, California Government Code Sections 111135, 65008 and 65589.5 prohibit discrimination in programs funded by the state and in any land -use decisions. Government Code Section 65583, which governs preparation of the Housing Element, requires jurisdictions to include programs in their Elements to promote housing opportunities for all persons, regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability. The Housing Element must also address any zoning or land use laws or practices that either expressly discriminate against a group protected by the fair housing laws, or have the effect of discriminating against such a group. D. Organization of the Regional Al The Analysis of Impediments to Fair Housing Choice includes the Executive Summary, eight chapters and appendices. Chapter 1: Introduction explains the purpose of this Al, defines fair housing and identifies the 16 participating cities that collaborated in the preparation of the Al. Chapter 2: Community Participation describes the community outreach effort to receive input on the housing needs and fair housing issues faced by the community and housing service providers. This chapter also summarizes the input received from the five community meetings and responses from the fair housing survey. Chapter 3: Community and Regional Profiles presents the demographic, socioeconomic, housing, employment characteristics and public services available to the residents of the 16 participating cities and Orange County. Chapter 4: Mortgage Lending Practices analyzes lending activities and practices that could impede fair housing choices in the 16 participating cities. INTRODUCTION 4 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Chapter 5: Public Policies and Practices evaluates various local public policies and actions that could impede fair housing choice. Chapter 6: Fair Housing Profile evaluates the fair housing services available to residents and identifies fair housing complaints and violations in the 16 cities. Chapter 7: Progress Since 2010 summarizes the private and public sector impediments identified in the prior Al and the region's progress in implementing actions to address these impediments. Chapter 8: Fair Housing Plan provide conclusions about fair housing issues and recommends actions to address impediments in the 16 cities. E. Data Sources The following data sources were used to complete this Al. Sources of specific information are identified in the text, tables and figures. ■ U.S Census Bureau, 2000 and 2010 Census ■ U.S. Census Bureau, American Community Survey (ACS), 2009-2013 Five -Year Estimates ■ U.S. Department of Housing and Urban Development (HUD) website ■ U.S. Department of Housing and Urban Development Comprehensive Housing Affordability Strategy 2012 (CHAS) ■ Federal Bureau of Investigation (FBI) Uniform Crime Reporting Program ■ California Department of Finance (DOF), 2015 Estimates ■ California Department of Social Services (DSS), Community Care Licensing Division ■ Orange County Transportation Authority (OCTA) website ■ Orange County Community Services, Orange County Homeless Count and Survey Report, 2015 ■ Orange County Housing Authority (OCHA) Section 8 Program information, 2015 ■ Anaheim Housing Authority (AHA) Section Program information, 2015 ■ Garden Grove Housing Authority (GGHA) Section 8 Program information, 2015 ■ Santa Ana Housing Authority (SAHA) Section 8 Program information, 2015 ■ Fair Housing Council of Orange Quarterly Reports, 2012/13 - 2014/15 ■ Fair Housing Foundation Annual Reports, 2012/13 - 2014/15 ■ Housing Mortgage Disclosure Act (HMDA) data on lending patterns, 2011-2013 INTRODUCTION 5 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ Documents from the 16 participating cities: General Plan 2014-2021 Housing Elements 13 Zoning Ordinances 13 Consolidated Annual Performance and Evaluation Report (CAPERS) 13 2015-2020 Consolidation Plan INTRODUCTION 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 2. Community Participation In order to identify factors that could indicate impediments to fair housing choice, this Al incorporated a community outreach effort that included five community meetings, an on-line fair housing survey, coordination with fair housing service and housing providers, and a public review of the Draft Al. A. Community Workshops During the preparation of this Al, residents, businesses, and public and private agencies were invited to participate in the discussion of fair housing issues in Orange County. Five community workshops were conducted in late September and early October 2015 at five different locations. The five locations were selected to enable residents easier access to the workshops. The community workshops were held on the following dates: ■ September 22, 2015 — Assembly Hall, Downtown Anaheim Community Center, 250 E. Center, Anaheim, 6:00 p.m. ■ September 23, 2015 — Professional Training Center, Tustin Library, 345 E. Main Street, Tustin, 6:00 p.m. ■ September 24, 2015 — City Hall Council Chambers, 10200 Slater Avenue, Fountain Valley, 6:00 p.m. ■ September 30, 2015 — Santa Ana Police Community Room, 60 Civic Center Plaza, Santa Ana, 6:00 p.m. ■ October 1, 2015 — City Hall, Community Room, 25550 Commercentre Drive, Lake Forest, 6:00 p.m. The meetings provided the opportunity for the community to gain awareness of fair housing laws, and for residents and service agencies to share fair housing issues and concerns. To ensure that the fair housing concerns of low- and moderate -income and special needs residents were addressed, individual invitation letters were distributed via mail and email, if available, to agencies and organizations that serve the low- and moderate -income and special needs community. Notices of the Fair Housing Workshops were available in English, Spanish, and Vietnamese. The workshop notices were published in the Orange County Register, La Opinion (Spanish) and the Viet Bao Daily News (Vietnamese) weeks prior to the meetings. Thanks to the participating Cities' efforts to publicize the workshops through posts on their websites, mailings to local service providers, and communications with local stakeholders and public officials, a total of 54 individuals participated in the five workshops. In addition, as a result of the extensive outreach effort, the workshops were attended by several service providers that work with residents considered a protected class COMMUNITY PARTICIPATION 7 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS according to HUD's definition. The Fair Housing Workshop notices (English, Spanish and Vietnamese), workshop sign -in sheet, presentation material, city mailing lists, and a summary of workshop attendee comments are included as Appendix A-1 of this Al. Summary of key comments from the community workshops included: ■ Affordable Housing: Increasing rents coupled with low vacancies have made it difficult to find affordable rental units. Some have indicated that landlords use the strong market to discriminate among potential renters. ■ Information on Affordable Housing Discrimination: Many residents lacked information on tenant rights, such as when landlords asked for immigration documents. Residents did not know where to get help when discriminated. ■ Mothers with Children: A common complaint was the difficulty of families, especially mothers with children, in finding housing. ■ Overcrowding: The problem of overcrowding was brought up by both residents and property managers. ■ Special Needs Housing: There is a need for affordable rental housing units for seniors, persons with disabilities, and veterans. B. Fair Housing Survey To supplement the community workshops and to assist in further understanding the fair housing issues in the region, a Fair Housing Survey was made available to residents at the 16 city halls and online via the City's website. The surveys, both hardcopy and on-line, were available in English, Spanish, Vietnamese, and Korean to reflect the diversity of Orange County residents. The survey consisted of questions designed to gather information on a person's experience with fair housing issues and perception of fair housing issues in his/her neighborhood. During the four-week survey period in September and October 2015, 188 surveys were completed online and on hardcopies. Of the total, 59 percent were Spanish-speaking, 40 percent English-speaking, and one percent Vietnamese -speaking respondents. A summary of the key questions and responses were the following: The survey consisted of questions designed to gather information on a person's experience with fair housing issues and perception of fair housing issues in their community. A summary of the key survey results included: ■ Almost 60 percent of respondents completed the survey that was translated in Spanish. ■ 57 percent of respondents have encountered housing discrimination, and of those, 88 percent indicated that landlord/property managers were responsible. ■ 82 percent of the discrimination occurred in an apartment complex. COMMUNITY PARTICIPATION 8 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ One-half of those discriminated responded that it was because of family status (families with children). ■ Over 90 percent did not report the discrimination incident. ■ 14 percent have been denied reasonable accommodation. ■ Three-quarters of respondents indicated they had little to no information on housing discrimination law, and one-third would not know what to do when discriminated. Copies of the survey in four languages and a summary of the results are included in Appendix A-2 C. Agency Consultation A Working Group was formed with key staff representing each of the 16 cities participating in the development of this Al. The Working Group provided valuable information and insight into their community housing needs and fair housing issues. The first meeting of the Working Group was held in June 2015 and hosted by the City of Garden Grove. Monthly meeting were held in various participating cities to discuss the data needs, the community outreach effort, the Al approval process, the action plan recommendations, and the review of the Al. In addition to information gained through the workshops and survey, numerous phone interviews were conducted with agencies such as the Fair Housing Foundation, the Fair Housing Council of Orange County, and the Orange County Housing Authority. D. Public Review During a 30 -day public review period from March 9 to April 7, 2016, the draft Al document was made available at the following locations: ■ City Halls of 16 -participating Cities ■ City websites During this review period, no written comments were received on the draft Al. Public review notices were published in the Orange County Register, La Opini6n, and Viet Bao Daily News on March S, 2016. Published copies of the public review notices are included in Appendix A-3. In addition, all persons that attended the community workshops were emailed or faxed the location of the public review document on the City's website and asked to provide any further comments for incorporation into the final Al. COMMUNITY PARTICIPATION 9 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 3. Community and Regional Profiles Chapter 3 provides analysis of the demographic, socioeconomic and housing characteristics of the 16 Orange County cities participating in this regional Analysis of Impediments to Fair Housing Choices. chapter presents a demographic profile, assesses the extent of housing needs among specific income groups and evaluates the availability of a range of housing choices for residents. Major employers and transportation access to job centers are identified, and community social services offered by licensed care facilities are discussed. Data -based analysis of demographic, economic, and housing conditions within a city or other jurisdiction is integral for evaluating housing demands and potential fair housing issues for the studied area. Key data sources for Chapter 3 include: U.S. Census Bureau (Census), American Community Survey (ACS), HUD Comprehensive Housing Affordability Strategy (CHAS) Data, California Department of Finance (DOF), California Department of Social Services Community Care Licensing Division, and the California Employment Development Department (EDD). A. Demographic Profile Population Growth In 2015, the population of the 16 cities participating in this regional Al totals approximately 2.1 million, which represents two-thirds of the total number of residents in Orange County. Table 3-1 details the number and growth rate of the residential populations of the 16 cities, Orange County, and California between 2000 and 2015. In general, there was consistent positive growth on the city, county, and state levels during both the 2000-2010 and 2010-2015 time periods. The sole exception is the City of Santa Ana, which experienced a decrease in population by four percent between 2000 and 2010. During the last five years, the City of Tustin experienced the highest percentage increase in population growth at 5.4 percent, larger than both the County rate of 4.6 percent and the State rate of 3.9 percent. However, over the 15 -year period, the City of Lake Forest had the largest percentage increase in population, with an increase of 36.4 percent growth'. The next fastest growing cities for this 15 -year period were San Clemente (31.0%), Newport Beach (24.6%), Tustin (17.9%), and Fullerton (11.9%). No other cities experienced population growth in excess of ten percent. In comparison, the population of Orange County increased by 10.6 percent while California grew by 14.3 percent between 2000 and 2015. Although the City of Santa Ana rebounded over the last five years with a population increase of 3.3 percent, the overall 15 -year growth was still a negative 0.8 percent. Other low -growth cities included Fountain Valley (3.7%), Mission Viejo (3.8%), Rancho Santa Margarita (4.0%), Costa Mesa (4.4%), and Huntington Beach (4.6%). 1 The large population growth in Lake Forest is attributed to annexation that occurred in late 2000. COMMUNITY AND REGIONAL PROFILES 10 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Sources: U.S. Census 2000 and 2010; CA Dept of Finance E-5 Est., January 2015 *Growth attributed to the annexation of Foothill Ranch and Portola, which occurred in late 2000. Age Composition Analyzing the age distribution is important because it affects the future need for jobs, housing and other social services. For cities that have a majority share of the population under the age of 35 years, future growth planning may need to include additional schools, entry-level jobs, and starter homes. This age group typically consists of young children, students, recent graduates, or adults just entering the job market. This indicates that the provision of smaller, affordable housing opportunities, particularly in the rental market, is needed in the near future to allow this group to remain in the community. Residents ages 35 to 64 years tend to drive the market demand for moderate to relatively high cost condominiums and single-family homes. People over 65 years of age tend to generate demand for low to moderate cost apartments and condominiums, group quarters, and mobile homes; senior residents may also balance their housing options with the proximity to social services. COMMUNITY AND REGIONAL PROFILES 11 Table 3-1: Population Growth 2000-2015 % Change to 201012010 % Change to 2015 -MMMiii Anaheim 328,014 336,265 351,433 2.5% 4.5% Buena Park 78,282 80,530 82,767 2.9% 2.8% Costa Mesa 108,724 109,960 113,455 1.1% 3.2% Fountain Valley 54,978 55,313 57,021 0.6% 3.1% Fullerton 126,003 135,161 141,042 7.3% 4.4% Garden Grove 165,196 170,883 174,774 3.4% 2.3% Huntington Beach 189,594 189,992 198,389 0.2% 4.4% La Habra 58,974 60,239 62,079 2.1% 3.1% Lake Forest 58,707 77,264 80,070 31.6%* 3.6% Mission Viejo 93,102 93,305 96,652 0.2% 3.6% Newport Beach 70,032 85,186 87,249 21.6% 2.4% Orange 128,868 136,416 140,094 5.9% 2.7% Rancho Santa Margarita 47,214 47,853 49,125 1.4% 2.7% San Clemente 49,936 63,522 65,399 27.2% 3.0% Santa Ana 337,977 324,528 335,264 -4.0% 3.3% Tustin 67,504 75,540 79,601 11.9% 5.4% Orange County 2,846,289 3,010,232 3,147,655 5.8% 4.6% California 33,873,086 37,253,956 38,714,725 10.0% 3.9% Sources: U.S. Census 2000 and 2010; CA Dept of Finance E-5 Est., January 2015 *Growth attributed to the annexation of Foothill Ranch and Portola, which occurred in late 2000. Age Composition Analyzing the age distribution is important because it affects the future need for jobs, housing and other social services. For cities that have a majority share of the population under the age of 35 years, future growth planning may need to include additional schools, entry-level jobs, and starter homes. This age group typically consists of young children, students, recent graduates, or adults just entering the job market. This indicates that the provision of smaller, affordable housing opportunities, particularly in the rental market, is needed in the near future to allow this group to remain in the community. Residents ages 35 to 64 years tend to drive the market demand for moderate to relatively high cost condominiums and single-family homes. People over 65 years of age tend to generate demand for low to moderate cost apartments and condominiums, group quarters, and mobile homes; senior residents may also balance their housing options with the proximity to social services. COMMUNITY AND REGIONAL PROFILES 11 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 3-2 details the age distribution in 2013 of the residential populations of the 16 cities, Orange County, and the State. The age groups are designated as follows: Under 5 years (young children), 5- 17 years (minors), 18-34 (young adults), 35-54 (middle -age adults), 55-64 (future elderly), 65-74 (elderly), and 75 years and older (frail elderly). These divisions are intended to give an overview of the percent of populations at different age ranges which tend to have similar needs in terms of housing and social services. In general, the 35-54 years of age group represented the largest share of the population. The exceptions were the cities of Costa Mesa, Fullerton, La Habra, and Santa Ana, where the 18-34 age group was the largest proportion. Figure 3-1 illustrates the 2013 age distribution by the 16 cities. Source: ACS 2009-2013 5 -Yr Est. Tables DP05 and 50101 COMMUNITY AND REGIONAL PROFILES 12 Table 3-2: Age Distribution of Population 2013 Anaheim 7.7% 19.4% 26.0% 27.4% 9.6% 5.4% 4.4% Buena Park 6.3% 18.2% 24.5% 29.0% 10.5% 6.2% 5.3% Costa Mesa 6.5% 14.5% 30.8% 29.6% 9.7% 4.7% 4.1% Fountain Valley 4.3% 15.2% 19.8% 29.0% 13.5% 10.4% 7.8% Fullerton 6.4% 16.9% 27.5% 27.4% 9.8% 6.0% 6.0% Garden Grove 6.1% 18.9% 24.1% 29.1% 10.5% 6.2% 5.2% Huntington Beach 5.0% 15.0% 22.5% 30.1% 12.4% 8.4% 6.4% La Habra 7.5% 18.5% 27.0% 26.7% 10.1% 4.7% 5.4% Lake Forest 5.9% 18.0% 21.1% 32.7% 12.3% 6.2% 3.9% Mission Viejo 5.1% 17.2% 18.2% 30.3% 14.1% 8.2% 6.9% Newport Beach 3.9% 13.4% 21.6% 27.4% 14.3% 10.6% 8.7% Orange 6.5% 15.9% 26.7% 29.5% 10.2% 6.3% 4.8% Rancho Santa Margarita 6.0% 22.2% 21.5% 34.1% 9.8% 3.8% 2.5% San Clemente 6.6% 18.7% 17.1% 30.6% 13.1% 8.1% 5.8% Santa Ana 8.7% 21.5% 28.7% 27.0% 7.3% 4.0% 2.9% Tustin 7.5% 19.1% 26.3% 29.8% 9.1% 4.7% 3.5% Orange County 6.3% 17.7% 24.0% 28.9% 11.0% 6.5% 5.5% California 6.7% 17.8% 24.9% 27.7% 11.1% 6.4% 5.4% Source: ACS 2009-2013 5 -Yr Est. Tables DP05 and 50101 COMMUNITY AND REGIONAL PROFILES 12 Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Tustin Orange County California United States 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Figure 3-1: Age Distribution 2013 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% ■ Under 18 ■ 18-34 35-54 ■ 55-64 65+ Source: ACS 2009-2013 5 Yr Est. Tables DP05 and 50101 Table 3-3 contains summary age indicators for the 16 cities, Orange County, and California. In each jurisdiction, the median age of the residential population has increased between 2000 and 2013, indicating a general trend towards a "greying" of the population. The highest median age in 2013 was seen in Newport Beach (43.7), followed by Fountain Valley (43.4), Mission Viejo (43.0), Huntington Beach (40.6), and San Clemente (40.1). The lowest median age in 2013 was Santa Ana's 29.2 years, followed by Anaheim (32.8), La Habra (33.2), Tustin (33.3), and Costa Mesa (33.8). In comparison, the median age in 2013 was 36.4 years for Orange County, and 35.4 years statewide. COMMUNITY AND REGIONAL PROFILES 13 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 3-3: Age Characteristics 2013 Median Age • P.. Depend.Depend. Depend. P.. City/Areaiii iRatio Ratio Ratio Yrs Yrs Anaheim 30.3 32.8 58.4 15.6 42.9 27.1% 9.8% Buena Park 32.0 35.5 56.4 18.0 38.4 24.5% 11.5% Costa Mesa 32.0 33.8 42.5 12.5 30.1 21.0% 8.8% Fountain Valley 38.1 43.4 60.4 29.2 31.2 19.5% 18.2% Fullerton 32.9 34.4 54.6 18.6 36.0 23.3% 12.0% Garden Grove 32.3 35.6 57.2 17.9 39.3 25.0% 11.4% Huntington Beach 36.0 40.6 53.6 22.8 30.7 20.0% 14.8% La Habra 31.5 33.2 56.6 15.9 40.7 26.0% 10.1% Lake Forest* 35.1 38.4 52.8* 15.1* 37.7* 23.9% 10.1% Mission Viejo 37.5 43.0 59.5 24.0 35.5 22.3% 15.1% Newport Beach 41.6 43.7 57.7 30.4 27.3 17.3% 19.3% Orange 33.2 35.4 50.7 16.8 33.9 22.4% 11.1% Rancho Santa Margarita 31.9 35.2 52.6 9.7 42.9 28.2% 6.3% San Clemente 38.0 40.1 64.4 22.9 41.6 25.3% 13.9% Santa Ana 26.5 29.2 58.8 10.8 48.0 30.2% 6.9% Tustin 31.8 33.3 53.4 12.6 40.9 26.6% 8.2% Orange County 33.3 36.4 56.4 18.8 37.6 24.0% 12.0% California 33.3 35.4 57.1 18.6 38.6 24.5% 11.8% Source: ACS 2009-2013 5 -Yr Est. Tables DP05 and S0101 * 2012 value from ACS 2008-2012 Table 50101 The dependency ratio, which is the ratio of the population under 18 and over 65 years of age to the population 18 to 64, is an indicator of the reliance of children and senior citizens on the working age population. The range of the dependency ratio is measured from 0 (low) to 100 (high); the lower the dependency ratio, the lesser the "burden" is on a community's working age residents. The dependency ratio is an important indication of the demand for social services and senior housing. According to Table 3-3, the dependency ratio in 2013 was 56.4 in Orange County, and 57.1 in California. Cities with notably higher dependency ratios included San Clemente (64.4), Fountain Valley (60.4), and Mission Viejo (59.5). In addition to the composite age dependency ratio, Table 3-3 includes the proportion of minor -age dependency versus elderly dependency, as well as the percentages of the total populations that are under 18 years and 65 years or older, respectively. The old age dependency ratio and the child COMMUNITY AND REGIONAL PROFILES 14 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS dependency ratio can inform with greater detail the types of services and housing options needed in a particular jurisdiction. For example, the dependency ratios of Santa Ana (58.8) and Newport Beach (57.7) indicate similar degrees of the social burden on working age residents. However, Newport Beach has an old -age dependency ratio of 30.4 and a child dependency ratio of 27.3, indicating a great demand for senior housing and social service targeted for the elderly. With an old age dependency ratio of 10.8 and a child dependency ratio of 48.0 in Santa Ana indicates the types of housing and social services needed would skew more towards childcare and other youth -targeted amenities, with relatively less demand for senior services. Age and fair housing intersect when managers or property owners make housing decisions based on the age of residents or the familial status (families with children). For example, managers and property owners may prefer to rent to mature residents, limit the number of children in their complex or discourage older residents due to their disabilities. Although a housing provider may establish reasonable occupancy limits and set reasonable rules about the behavior of tenants, those rules cannot single out children for restrictions that do not also apply to adults. Race and Ethnicity The race and ethnic composition of a population influence fair housing issues to the extent that certain racial and ethnic groups may experience discrimination. These influences are due to factors such as color, language spoken, or other cultural factors. Table 3-4 presents the racial and ethnic characteristics of the 16 cities and Orange County residents. It shows that the County experienced major shifts in racial and ethnic composition since 2000. In 2000, over one-half of the countywide population was non -Hispanic White, but by 2013 the proportion of the non -Hispanic White population decreased to 43.5 percent. During the same period, the Hispanic population increase from 30.8 percent to 33.8 percent. The largest shift occurred in the non -Hispanic Asian/Pacific Islander group, which accounted for 13.8 percent of the total County population in 2000 and increased to 18.5 percent in 2013. Table 3-4 and Figure 3-1 show the racial/ethnic composition by the 16 cities. The City of Santa Ana had the highest proportion of Hispanic residents in the County at 78.5 percent in 2013. Other cities with high representation of Hispanic residents included La Habra (60.3%), Anaheim (52.6%), Buena Park (38.5%), and Orange (38.4%). The other key minority group was non -Hispanic Asian/Pacific Islander residents. The city with the highest proportion of non -Hispanic Asian residents was the City of Garden Grove (38.8%). This was followed by the Cities of Fountain Valley (33.8%), and Buena Park (28.7%). The city that experienced the largest percent change of the minority population between 2000 and 2013 was Newport Beach. Although the number of Hispanic and non -Hispanic Asian residents in the city was relatively small (7,189 Hispanic and 6,008 non -Hispanic Asian), these two racial/ethnic groups in Newport Beach more than doubled in size during the 13 -year period. COMMUNITY AND REGIONAL PROFILES 15 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: Census 2000 SF1 Table P004, ACS 2009-2013 5Vr Est. Table DP05 NH: Non -Hispanic COMMUNITY AND REGIONAL PROFILES 16 Table 3-4: Racial and Ethnic Composition of Population 2000 and 2013 HispanicCity/Area % • 2000 46.8% 35.9% 2.4% 12.3% 2.8% Anaheim 2013 52.6% 27.4% 2.4% 15.6% 2.1% 2000 33.5% 38.2% 3.6% 21.3% 3.4% Buena Park 2013 38.5% 26.3% 4.3% 28.7% 2.2% 2000 31.8% 56.8% 1.2% 7.4% 2.8% Costa Mesa 2013 35.2% 51.6% 1.2% 9.7% 2.4% 2000 10.7% 58.5% 1.1% 26.2% 4.1% Fountain Valley 2013 15.8% 46.6% 1.2% 33.8% 2.6% 2000 30.2% 48.7% 2.1% 16.2% 2.8% Fullerton 2013 34.5% 36.1% 2.5% 23.9% 2.9% 2000 32.5% 32.5% 1.1% 31.4% 2.5% Garden Grove 2013 36.8% 21.3% 1.0% 38.8% 2.0% 2000 14.7% 71.9% 0.7% 9.5% 3.3% Huntington Beach 2013 18.7% 66.1% 0.7% 11.3% 3.1% 2000 49.0% 41.4% 1.4% 6.0% 2.3% La Habra 2013 60.3% 28.7% 1.6% 7.5% 1.9% 2000 18.6% 66.7% 1.7% 9.8% 3.2% Lake Forest 2013 23.5% 56.9% 1.6% 14.5% 3.6% 2000 12.1% 76.0% 1.1% 7.8% 3.1% Mission Viejo 2013 15.8% 70.9% 1.5% 8.0% 3.8% 2000 4.7% 89.0% 0.5% 4.1% 1.7% Newport Beach 2013 8.4% 81.6% 0.6% 7.0% 2.4% 2000 32.2% 54.6% 1.4% 9.4% 2.4% Orange 2013 38.4% 45.9% 1.0% 12.8% 2.0% 2000 13.0% 74.4% 1.7% 7.5% 3.5% Rancho Santa Margarita 2013 18.8% 66.8% 1.1% 10.7% 2.7% 2000 15.9% 78.4% 0.6% 2.7% 2.4% San Clemente 2013 17.5% 75.4% 0.7% 3.5% 3.0% 2000 76.1% 12.4% 1.3% 9.0% 1.2% Santa Ana 2013 78.5% 9.6% 1.1% 10.1% 0.7% 2000 34.2% 44.8% 2.6% 15.1% 3.2% Tustin 2013 39.4% 32.3% 2.3% 23.2% 2.8% 2000 30.8% 51.3% 1.5% 13.8% 3.1% Orange County 2013 33.8% 43.5% 1.5% 18.5% 2.6% Source: Census 2000 SF1 Table P004, ACS 2009-2013 5Vr Est. Table DP05 NH: Non -Hispanic COMMUNITY AND REGIONAL PROFILES 16 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Other cities with a significant change in the Hispanic population between 2000 and 2013 included the Cities of Lake Forest (68.2%) Fountain Valley (50.3%), and Rancho Santa Margarita (48.1%). For the non -Hispanic Asian population, the Cities of Lake Forest (96.7%), Tustin (74.4%), and San Clemente (66.1%) also experienced large percentage changes between 2000 and 2013. Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Tustin Orange County California United States Figure 3-2: Population by Race/Ethnicity 2013 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% ■ NH White ■ Hispanic NH Asian/Pacific Islander ■ NH Black Other/Multiracial Source: ACS 2009-2013 5 Yr Est. Table DP05 COMMUNITY AND REGIONAL PROFILES 17 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: Census 2000 SF1 Table P004, ACS 2009-2013 5Yr Est. Table DP05 COMMUNITY AND REGIONAL PROFILES 18 Table 3-5: Growth in Racial/Ethnic Group Populations 2000-2013 NH Asian/Pacific Islander Other •. Cit /Area Anaheim 153,374 178,723 16.5% 117,607 93,099 -20.8% 7,939 8,174 3.0% 40,182 53,204 32.4% 8,912 6,881 -22.8% Buena Park 26,221 31,406 19.8% 29,885 21,417 28.3% 2,826 3,481 23.2% 16,696 23,396 40.1% 2,654 1,822 31.3% Costa Mesa 34,523 39,018 13.0% 61,778 57,223 -7.4% 1,313 1,278 -2.7% 8,022 10,731 33.8% 3,088 2,621 -15.1% Fountain Valley 5,870 8,823 50.3% 32,144 26,031 -19.0% 584 669 14.6% 14,302 18,891 32.1% 2,249 1,497 -33.4% Fullerton 38,014 47,230 24.2% 61,420 49,371 -19.6% 2,675 3,476 29.9% 20,381 32,657 60.2% 3,513 3,968 13.0% Garden Grove 53,608 63,617 18.7% 53,735 36,826 -31.5% 1,873 1,803 -3.7% 51,798 67,121 29.6% 4,182 3,418 -18.3% Huntington Beach 27,798 36,204 30.2% 136,237 127,779 -6.2% 1,383 1,332 -3.7% 17,976 21,850 21.6% 6,200 6,032 -2.7% La Habra 28,922 36,748 27.1% 24,399 17,507 -28.2% 808 949 17.5% 3,432 4,537 32.2% 1,324 1,157 -12.6% Lake Forest 10,913 18,351 68.2% 39,161 44,521 13.7% 998 1,236 23.8% 5,760 11,330 96.7% 1,875 2,815 50.1% Mission Viejo 11,266 14,856 31.9% 70,735 66,870 -5.5% 1,032 1,412 36.8% 7,244 7,588 4.7% 2,825 3,585 26.9% Newport Beach 3,301 7,189 117.8% 62,342 70,174 12.6% 354 541 52.8% 2,844 6,008 111.3% 1,191 2,089 75.4% Orange 41,434 52,967 27.8% 70,292 63,298 -9.9% 1,798 1,353 -24.7% 12,166 17,613 44.8% 3,131 2,768 -11.6% Rancho Santa Margarita 6,139 9,094 48.1% 35,132 32,281 -8.1% 787 519 -34.1% 3,530 5,166 46.3% 1,626 1,295 -20.4% San Clemente 7,933 11,174 40.9% 39,155 48,232 23.2% 320 448 40.0% 1,355 2,250 66.1% 1,173 1,890 61.1% Santa Ana 257,097 257,998 0.4% 41,984 31,466 -25.1% 4,309 3,750 -13.0% 30,405 33,047 8.7% 4,182 2,458 -41.2% Tustin 23,110 30,139 30.4% 30,264 24,690 -18.4% 1,785 1,739 -2.6% 10,194 17,775 74.4% 2,151 2,154 0.1% Source: Census 2000 SF1 Table P004, ACS 2009-2013 5Yr Est. Table DP05 COMMUNITY AND REGIONAL PROFILES 18 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Residential Segregation The racial and ethnic distribution of Orange County's population appears diverse with 56 percent of the total population composed of Hispanic, non -Hispanic Asian, non -Hispanic Black/African American, and other. However, within the County there are areas of racial/ethnic concentrations. For example, the City of Santa Ana's population is over three-quarters Hispanic and ten percent non - Hispanic Asian. Areas of racial/ethnic minority concentration are neighborhoods with a disproportionately high number of minority (non-White) residents. To illustrate areas of minority "concentration" on a geographic level, census tracts that exceed the countywide average of minorities, measured at 56 percent in 2013 was mapped. Figure 3-3 displays the Orange County census tracts with the minority population representing more than 56 percent of the total population of the census tract. As the map illustrates, concentrations of minorities are most prevalent in central and northern Orange County in cities such as Santa Ana, Garden Grove, Anaheim, and Buena Park. Linguistic Isolation Table 3-6 details the percent of total households in 2013 that were considered to be limited English- speaking households. The Census defines a limited speaking household as a household "in which no member 14 years old and over: 1) speaks only English; or 2) speaks a non-English language and speaks English 'very well."' In other words, all household members 14 and older have at least some difficulty with English proficiency. According to Table 3-6, 9.6 percent of Orange County households and 9.9 percent of California households fall under this definition. The Cities with larger percentages than the County and State were Santa Ana (23.1%), Garden Grove (18.5%), Buena Park (17.8%), Anaheim (14.2%), La Habra (11.8%), and Tustin (10.1%). The table also lists the prevalence of limited English proficiency among households whose primary spoken language is not English. For example, among all Buena Park households whose primary spoken language is Spanish, 29.2 percent were considered to be limited English-speaking households. In general, households speaking Asian/Pacific Islander languages display the largest degree of linguistic isolation. As presented in the table, 40.5 percent of Santa Ana's households whose primary language was Asian/Pacific Islander had limited English-speaking proficiency. Other cities that exhibited similar linguistic isolation among Asian/Pacific Islander -speaking households included Garden Grove (38.1%), and Buena Park (35.2%). Language barriers can serve as an impediment to fair housing accessibility. Residents who lack proficiency with the English language may have difficulties accessing services and information pertaining to fair housing, or may be obstructed by reluctance on the part of landlords to rent units to non-English speaking tenants. Another fair housing concern could arise if foreign -born owners of rental housing advertise only in their native languages, thus restricting choice in the renter market. Limited English proficiency may also hinder access to social services, or affect a resident's employment opportunities and educational attainment. COMMUNITY AND REGIONAL PROFILE 19 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS COMMUNITY AND REGIONAL PROFILES 20 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: ACS 2009-2013 5Yr Est. Table 51602 COMMUNITY AND REGIONAL PROFILES 21 Table 3-6: Limited English Speaking Households 2013 % of HH by Primary Language Limited English Speaking as % of Other Total MMM Anaheim 14.2% 22.9% 17.5% 30.9% 26.0% Buena Park 17.8% 29.2% 14.2% 35.2% 33.9% Costa Mesa 5.8% 19.2% 7.3% 17.1% 2.9% Fountain Valley 8.4% 9.9% 11.4% 26.1% 13.2% Fullerton 9.6% 14.9% 11.5% 29.6% 11.7% Garden Grove 18.5% 16.7% 11.5% 38.1% 15.0% Huntington Beach 4.0% 13.1% 8.4% 23.1% 26.9% La Habra 11.8% 22.7% 17.7% 30.3% 7.4% Lake Forest 4.9% 12.8% 19.6% 16.7% 26.5% Mission Viejo 3.1% 7.8% 13.2% 17.5% 12.4% Newport Beach 1.8% 6.9% 5.2% 19.2% 1.2% Orange 9.0% 22.0% 7.7% 28.5% 19.2% Rancho Santa Margarita 4.5% 18.6% 13.9% 13.2% 45.0% San Clemente 1.7% 12.7% 4.9% 10.6% 0.0% Santa Ana 23.1% 27.8% 9.4% 40.5% 10.1% Tustin 10.1% 21.4% 12.4% 18.4% 47.4% Orange County 9.6% 20.6% 12.0% 29.8% 17.7% California 9.9% 23.1% 17.2% 28.3% 18.9% Source: ACS 2009-2013 5Yr Est. Table 51602 COMMUNITY AND REGIONAL PROFILES 21 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS B. Household Profile Household Growth Table 3-7 details the number and growth rate of households within the 16 cities, Orange County, and the State of California between 2000 and 2015. In general, there was consistent positive growth on the city, county, and state levels during both the 2000-2010 and 2010-2015 time periods. During the last five years, the City of Tustin experienced the largest percent increase number of household at 3.0 percent -- larger than the 2.0 percent growth rate for both Orange County and California. Over a 15 -year period (2000-2015), the City of Lake Forest witnessed the largest percentage increase in households, with an increase of 32.9 percent. The only other cities to experience double-digit growth during the 15 -year period were San Clemente (24.0%) and Newport Beach (17.3%). In comparison, total households within Orange County increased by 8.2 percent and within California by 11.5 percent between 2000 and 2015. The City of Garden Grove had the lowest overall household growth rate, with a 0.5 percent increase between 2000 and 2015, followed by La Habra (0.9%), Santa Ana (1.0%), and Buena Park (2.0%). Sources: Census 2010 Redistricting Data, CA Dept of Finance E-5 Est., January 2015 *Growth attributed to the annexation of Foothill Ranch and Portola, which occurred in late 2000. COMMUNITY AND REGIONAL PROFILES 22 Table 3-7: Household Growth 2000-2015 City/Area % Change % 2000-2010 2010-2015 Change Anaheim 96,969 98,294 100,406 1.4% 2.1% Buena Park 23,332 23,686 23,788 1.5% 0.4% Costa Mesa 39,206 39,946 40,404 1.9% 1.1% Fountain Valley 18,162 18,648 18,785 2.7% 0.7% Fullerton 43,609 45,391 45,978 4.1% 1.3% Garden Grove 45,791 46,037 46,020 0.5% 0.0% Huntington Beach 73,657 74,285 76,028 0.9% 2.3% La Habra 18,947 18,977 19,108 0.2% 0.7% Lake Forest 20,008 26,224 26,580 31.1%* 1.4% Mission Viejo 32,449 33,208 33,596 2.3% 1.2% Newport Beach 33,071 38,751 38,779 17.2% 0.1% Orange 40,946 43,367 43,528 5.9% 0.4% Rancho Santa Margarita 16,253 16,665 16,714 2.5% 0.3% San Clemente 19,395 23,906 24,049 23.3% 0.6% Santa Ana 73,002 73,174 73,765 0.2% 0.8% Tustin 23,831 25,203 25,956 5.8% 3.0% Orange County 935,287 992,781 1,012,422 6.1% 2.0% California 11,502,871 12,577,498 12,830,035 9.3% 2.0% Sources: Census 2010 Redistricting Data, CA Dept of Finance E-5 Est., January 2015 *Growth attributed to the annexation of Foothill Ranch and Portola, which occurred in late 2000. COMMUNITY AND REGIONAL PROFILES 22 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 3-8 shows the distribution of total occupied housing units by tenure in 2000 and 2013. In general, the percentage of renter households increased more than owner household in most of the 16 cities, a trend also displayed on the county and state levels. The exceptions were the Cities of Fullerton, San Clemente, and Tustin where the percentage of renters declined from 2000 to 2013. For example, renters in the City of San Clemente represented 37.6 percent of all households in the city in 2000, but declined to 34.4 percent by 2013. The city with the highest percentage of renters in 2013 was Costa Mesa, where nearly 60 percent of total households were renters. Other cities with large percentages of renter households in 2013 were Santa Ana (54.0%), Anaheim (52.2%), and Tustin (49.4%). The cities with low percentages of renter households in 2013 were Mission Viejo (21.6%), Rancho Santa Margarita (28.2%), Fountain Valley (29.0%), and Lake Forest (29.9%). Anaheim Table 3-8: Household Tenure •••2013 • • Renter 50.0% 50.0% 47.8% 52.2% Buena Park 57.1% 42.9% 56.1% 43.9% Costa Mesa 40.5% 59.5% 40.3% 59.7% Fountain Valley 74.7% 25.3% 71.0% 29.0% Fullerton 53.9% 46.1% 54.4% 45.6% Garden Grove 59.6% 40.4% 55.8% 44.2% Huntington Beach 60.6% 39.4% 59.2% 40.8% La Habra 56.6% 43.4% 55.3% 44.7% Lake Forest 72.0% 28.0% 70.1% 29.9% Mission Viejo 81.4% 18.6% 78.4% 21.6% Newport Beach 55.7% 44.3% 55.4% 44.6% Orange 62.6% 37.4% 59.5% 40.5% Rancho Santa Margarita 78.3% 21.7% 71.8% 28.2% San Clemente 62.4% 37.6% 65.6% 34.4% Santa Ana 49.3% 50.7% 46.0% 54.0% Tustin 49.6% 50.4% 50.6% 49.4% Orange County 61.4% 38.6% 58.7% 41.3% California 56.9% 43.1% 55.3% 44.7% Source: Census 2000 SF 1 Table DP -1, ACS 2009-2013 5 -Yr. Est. Table DP04 COMMUNITY AND REGIONAL PROFILES 23 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Household Size Household size is an important indicator identifying sources of population growth as well as overcrowding in individual housing units. A city's average household size will increase over time if trends move toward larger families. In communities where the population is aging, the average household size typically declines. Growth trends in the city can be attributed to cultural differences in relation to household size, privacy, and co -habitation of extended families. For instance, single - person households or seniors may often occupy smaller apartments or condominiums due to the lower cost and size of such homes. Younger families with children often prefer larger single-family homes. Understanding changes in household composition can thus provide insight into current and future housing needs. According to the 2013 ACS data presented in Table 3-9, the average household size of Orange County declined slightly from 3.02 in 2000 to 3.00 in 2013. However, at the city level, the household size changed significantly between 2000 and 2013 in several of the 16 cities. For example, cities such as Buena Park, Fullerton, Garden Grove, La Habra, Newport Beach, and Tustin experienced a decline of 0.15 to 0.22 in average household size. The Cities of Costa Mesa, Fountain Valley and Mission Viejo exhibited increases over the 2000 to 2013 period, with the City of Santa Ana experiencing the largest increase from 4.45 to 4.55 over this period. Source: Census 2000 SF1 Table H012, ACS 2009-2013 5Yr Est. Table 825010 COMMUNITY AND REGIONAL PROFILES 24 Table 3-9: Average Household Size by Tenure 20130 Renter Anaheim 3.39 3.46 3.33 3.34 3.24 3.45 Buena Park 3.51 3.39 3.66 3.32 3.28 3.36 Costa Mesa 2.68 2.72 2.65 2.69 2.66 2.71 Fountain Valley 2.97 3.07 2.73 3.00 3.07 2.79 Fullerton 3.02 2.97 3.08 2.83 2.87 2.77 Garden Grove 3.72 3.72 3.71 3.56 3.49 3.67 Huntington Beach 2.59 2.60 2.59 2.56 2.58 2.54 La Habra 3.25 3.07 3.47 3.08 3.04 3.13 Lake Forest 2.89 2.86 2.97 2.89 2.93 2.79 Mission Viejo 2.80 2.76 2.92 2.84 2.87 2.71 Newport Beach 2.24 2.38 2.06 2.09 2.30 1.83 Orange 3.07 2.99 3.20 3.02 2.91 3.20 Rancho Santa Margarita 2.94 3.06 2.64 2.90 3.06 2.35 San Clemente 2.63 2.66 2.58 2.56 2.59 2.51 Santa Ana 4.45 4.47 4.42 4.55 4.54 4.57 Tustin 3.04 2.96 3.13 2.82 2.70 2.93 Orange County 3.02 3.00 3.06 3.00 2.96 3.05 California 2.94 2.98 2.88 2.87 2.93 2.79 Source: Census 2000 SF1 Table H012, ACS 2009-2013 5Yr Est. Table 825010 COMMUNITY AND REGIONAL PROFILES 24 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 3-9 also shows the difference in household sizes by tenure. It shows that at the countywide level, renters had larger household sizes than owners for both 2000 and 2013. At the city level, household size patterns varied among cities. Renters had larger household sizes than owners in cities such as Anaheim, Garden Grove, Orange, and Tustin, while in cities such as Fountain Valley, Lake Forest, Mission Viejo, Newport Beach, and Rancho Santa Margarita, owner household sizes were higher than renters in 2013. Figure 3-4 illustrates the most recent average household sizes estimated by the California State Department of Finance (DOF), which provides annual estimates of population, household and housing for all cities in the state. The 2015 DOF data shows that the County's average household size is 3.06. It also shows that the City of Santa Ana has the largest household size among the all 16 cities at 4.48. In fact, according to the DOF estimates, Santa Ana is tied with the Cities of South EI Monte and Parlier as having the ninth highest household size among all California cities -- the city with the state's highest household is Greenfield (Monterey County) at 4.82. Figure 3-4: Household Size 5 4.5 4 3.5 Orange Co. 3 — — ————————————————----- — — -- 2.5 2 1.5 1 0.5 0 r to �e � \eA eye oma elo a\ °� , �� at �e e� ea ea �a�� cae� Pia ��e°a Ot tea\ J a`F \\e ta� � 0- 0°��� �a 00� C6a�C�o PyJQ Source: DOF 2015 Estimates COMMUNITY AND REGIONAL PROFILES 25 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS C. Income Profile Household income is the most important factor determining a household's ability to balance housing costs with other basic life necessities. Although economic factors that affect a household's housing choice are not a fair housing issue per se, the relationships among household income, household type, race/ethnicity and other factors often create misconceptions and biases that raise fair housing issues. County Income Limits Most state and federal housing programs are benchmarked to specific income limits. Consistent with federal regulations, income categories defined by HUD are: extremely low income (0-30% of Area Mean Income); low income (31-50% of AMI); moderate income (51-80% of AMI); and above moderate (greater than 80% of AMI). HUD does not publish income limits for above moderate income households as federal housing programs are not eligible to households earning greater than 80 percent of the AMI. Table 3-10 presents HUD and State income limits by income group for Orange County. The State of California also provides income limits that are updated annually, in accordance with procedures established by HUD at the federal level. The State income limits apply to designated programs and are used to determine applicant eligibility and to calculate affordable housing costs for applicable housing assistance programs. Table 3-10: 2015 HUD and State Income Limits for Orange County Income Group Percent AMI 2015 Income Limit HUD Extremely Low < 30% $28,900 Low 31%-50% $48,150 Moderate 51%-80% $77,050 Above Moderate >80% $77,050+ State Extremely Low < 30% $28,900 Very Low 31%-50% $48,150 Low 51%-80% $77,050 Moderate 81%-120% $104,650 Above Moderate > 120% -- Source: HUD and State HCD, Income Limits 2015 Based on $87,200 AMI for a four -person household COMMUNITY AND REGIONAL PROFILES 26 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Household Income As estimated in the 2013 ACS, the median household income in Orange County was $75,422 and the median family household income was $84,765. The difference between the two is that a family consists of two or more people (one of whom is the householder) related by birth, marriage, or adoption residing in the same housing unit. A household consists of all people who occupy a housing unit regardless of relationship. A household may consist of a person living alone or multiple unrelated individuals or families living together. Table 3-11 lists the income figures for each of the 16 cities and also compares these figures to Orange County and California. As shown in the table, the following cities had median household incomes significantly above the County median of $75,422: Newport Beach ($106,333), Rancho Santa Margarita ($104,113), Mission Viejo ($96,210), Lake Forest ($93,631), and San Clemente ($90,071) -- cities located primarily in the southern portion of Orange County. Cities with median household incomes significantly lower than the countywide median included: Santa Ana ($53,335), Anaheim ($59,165), Garden Grove ($59,648), and La Habra ($61,702) - - cities located more in the northern portion of the county. Table 3-11: Median Household Income Median.. Anaheim Household Income Households $59,165 $63,380 Buena Park $66,371 $70,703 Costa Mesa $65,830 $75,810 Fountain Valley $80,870 $90,317 Fullerton $67,384 $76,760 Garden Grove $59,648 $61,890 Huntington Beach $81,389 $97,443 La Habra $61,702 $68,218 Lake Forest $93,631 $108,636 Mission Viejo $96,210 $108,545 Newport Beach $106,333 $146,011 Orange $78,838 $86,226 Rancho Santa Margarita $104,113 $118,383 San Clemente $90,071 $106,382 Santa Ana $53,335 $51,045 Tustin $73,194 $80,897 Orange County $75,422 $84,765 California $61,094 $69,661 Source: ACS 2009-2013 5Yr Est. DP03 COMMUNITY AND REGIONAL PROFILES 27 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Household Income Distribution Additional analysis was completed on incomes by household distribution, as shown in Figure 3-5. Almost all cities had significant proportions (over 20%) of their households with incomes of $100,000 or more, with the exception of the City of Santa Ana. In fact, one-half of the households in the Cities of Newport Beach and Rancho Santa Margarita earn more than $100,000 annually. On the other end of the spectrum, cities where 40 to 50 percent of the households earning less than $50,00 per year included Santa Ana, Garden Grove, Anaheim, and La Habra. Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Tustin Orange County California United States Figure 3-5: Household Distribution by Income 2013 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% ■ Less than $25,000 0$25,000-$49,999 '- $50,000 - $74,999 ■ $75,000 - $99,999 $100,000 or more Source: ACS 2009-2013 5 Yr Est. Table DP03 COMMUNITY AND REGIONAL PROFILES 28 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Poverty Level Table 3-12 presents the percentage of family households below the poverty line in 2013. It shows that countywide, approximately nine percent of all families were below the poverty level. The City of Santa Ana's percentage of families below poverty (18.5%) was double the countywide figure in 2013. Other cities with family poverty levels higher than the countywide average poverty level included Garden Grove (13.6%), Anaheim (13.3%), Fullerton (11.1%), La Habra (11.0%), Costa Mesa (10.6%), and Tustin (9.0%). As indicated in the table below, single female headed households, and especially those with children, evidence much higher rates of poverty than family households as a whole. Table 3-12: Family Households Below Poverty Level, 2013 Families HHs with Single Female Children Single Female Headed HHs with City/Area All Family HI -Is < 18 Yrs Headed HH Children < 18 Yrs Anaheim 13.3% 19.1% 31.8% 41.5% Buena Park 9.0% 13.2% 18.1% 25.0% Costa Mesa 10.6% 16.9% 20.6% 29.2% Fountain Valley 5.5% 8.6% 14.6% 28.1% Fullerton 11.1% 16.9% 24.2% 34.0% Garden Grove 13.6% 19.2% 21.8% 31.4% Huntington Beach 5.8% 8.6% 14.0% 21.7% La Habra 11.0% 16.1% 20.0% 31.6% Lake Forest 4.2% 5.4% 8.8% 13.5% Mission Viejo 3.4% 4.5% 11.3% 14.5% Newport Beach 5.5% 6.2% 21.5% 20.8% Orange 8.2% 13.2% 19.9% 30.6% Rancho Santa Margarita 3.4% 3.9% 13.5% 18.8% San Clemente 5.4% 9.0% 17.8% 25.3% Santa Ana 18.5% 24.8% 31.8% 43.9% Tustin 9.0% 12.1% 20.5% 23.9% Orange County 8.8% 13.1% 21.0% 29.6% California 12.0% 17.8% 27.4% 36.8% Source: ACS 2009-2013 5Yr Est. Table DP03 COMMUNITY AND REGIONAL PROFILES 29 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Household Income by Tenure The U.S. Department of Housing and Urban Development (HUD) periodically receives "custom tabulations" of data from the U.S. Census Bureau that are largely not available through standard Census products, referred to as the Comprehensive Housing Affordability Strategy (CHAS) data. The most recently available CHAS estimates are derived from the 2008-2012 ACS. The primary purpose of the CHAS data is to investigate the extent of housing problems and housing needs, particularly for low income households. This is estimated by the number of households that have certain housing problems and have income low enough to qualify for HUD's programs (primarily 30, 50, and 80 percent of AMI). The CHAS data are used by local governments to plan how to spend HUD funds, and may also be used by HUD to distribute grant funds Table 3-13 details CHAS estimates of the distribution of households by income levels in 2012. Income levels of owners and renters were compared at the county and city levels. In summary, there was a major difference in the composition of the extremely low and low income households between the renter and owner categories. In Orange County 42 percent of the renters earned less than 50 percent of the area median income (AMI), while just 17 percent of homeowners earned less than this level of income. The following cities had over one half of their renters earning 50 percent or less of the AMFI: Santa Ana (56%), Garden Grove (55%), Anaheim (53%) and Buena Park (53%). In Orange County, 57 percent of owner households were in the income category that earn above 100 percent of the AMI. The eight cities that have their owner households above the County figure include: Newport Beach (74%), Orange (70%), San Clemente (64%), Lake Forest (64%), Mission Viejo (64%), Huntington Beach (62%), Orange (60%), and Tustin (60%). On the other hand, just 26 percent of renter households in Orange County are in the income category that earn above 100 percent of the AMI. The following eight cities have renters below the County average: Fountain Valley (25%), Orange (25%), Fullerton (21%), Anaheim (15%), Buena Park (15%), La Habra (14%), Garden Grove (14%), and Santa Ana (11%). COMMUNITY AND REGIONAL PROFILES 30 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS COMMUNITY AND REGIONAL PROFILES 31 Table 3-13: Income Levels by Tenure 2012 Low 0-30% AM 1 Low 31-50% AMI Moderate :0 AboveExtremely ModerateCity/County 00 .. 00 Anaheim 98,435 18,890 19.2% 16,935 17.2% 21,065 21.4% 10,925 11.1% 30,620 31.1% Owner 47,620 3,905 8.2% 5,260 11.0% 9,285 19.5% 6,260 13.1% 22,910 48.1% Renter 50,810 14,985 29.5% 11,675 23.0% 11,780 23.2% 4,665 9.2% 7,710 15.2% Buena Park 22,730 3,545 15.6% 3,725 16.4% 5,175 22.8% 2,625 11.5% 7,655 33.7% Owner 13,070 815 6.2% 1,335 10.2% 2,980 22.8% 1,705 13.0% 6,235 47.7% Renter 9,660 2,730 28.3% 2,390 24.7% 2,195 22.7% 920 9.5% 1,420 14.7% Costa Mesa 40,525 6,070 15.0% 5,590 13.8% 8,205 20.2% 5,020 12.4% 15,630 38.6% Owner 16,525 1,680 10.2% 1,575 9.5% 2,500 15.1% 1,630 9.9% 9,135 55.3% Renter 24,000 4,390 18.3% 4,015 16.7% 5,705 23.8% 3,390 14.1% 6,495 27.1% Fountain Valley 18,575 2,010 10.8% 1,815 9.8% 3,645 19.6% 2,225 12.0% 8,875 47.8% Owner 13,320 915 6.9% 1,125 8.4% 2,255 16.9% 1,475 11.1% 7,550 56.7% Renter 5,250 1,095 20.9% 690 13.1% 1,390 26.5% 750 14.3% 1,325 25.2% Fullerton 44,575 7,645 17.2% 6,215 13.9% 8,135 18.3% 4,695 10.5% 17,890 40.1% Owner 24,080 1,920 8.0% 2,305 9.6% 3,405 14.1% 2,830 11.8% 13,625 56.6% Renter 20,490 5,725 27.9% 3,910 19.1% 4,730 23.1% 1,865 9.1% 4,265 20.8% Garden Grove 45,930 9,470 20.6% 7,525 16.4% 10,265 22.3% 5,355 11.7% 13,315 29.0% Owner 25,830 2,580 10.0% 3,300 12.8% 5,875 22.7% 3,515 13.6% 10,560 40.9% Renter 20,100 6,890 34.3% 4,225 21.0% 4,390 21.8% 1,840 9.2% 2,755 13.7% Huntington Beach 74,045 8,275 11.2% 7,945 10.7% 12,375 16.7% 7,855 10.6% 37,600 50.8% Owner 44,530 3,265 7.3% 3,775 8.5% 5,950 13.4% 4,030 9.1% 27,515 61.8% Renter 29,515 5,010 17.0% 4,170 14.1% 6,425 21.8% 3,825 13.0% 10,085 34.2% La Habra 18,370 3,335 18.2% 2,890 15.7% 4,205 22.9% 2,115 11.5% 5,825 31.7% Owner 10,100 1,120 11.1% 1,070 10.6% 1,950 19.3% 1,285 12.7% 4,675 46.3% Renter 8,270 2,215 26.8% 1,820 22.0% 2,255 27.3% 830 10.0% 1,150 13.9% Lake Forest 27,050 2,015 7.4% 2,580 9.5% 4,390 16.2% 3,150 11.6% 14,915 55.1% Owner 19,195 950 4.9% 1,475 7.7% 2,600 13.5% 1,970 10.3% 12,200 63.6% Renter 7,860 1,065 13.5% 1,105 14.1% 1,790 22.8% 1,180 15.0% 2,715 34.5% COMMUNITY AND REGIONAL PROFILES 31 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: CHAS Data 2008-2012 COMMUNITY AND REGIONAL PROFILES 32 Table 3-13: Income Levels by Tenure 2012 Low Low ModerateExtremely ..Moderate City/County Total HHs 0-30% AM 1 31-50% AMI :0 00 .. 00 Mission Viejo 33,235 2,520 7.6% 3,440 10.4% 5,065 15.2% 3,205 9.6% 19,005 57.2% Owner 25,790 1,350 5.2% 2,070 8.0% 3,470 13.5% 2,500 9.7% 16,400 63.6% Renter 7,440 1,170 15.7% 1,370 18.4% 1,595 21.4% 705 9.5% 2,605 35.0% Newport Beach 38,345 4,175 10.9% 3,060 8.0% 4,090 10.7% 2,615 6.8% 24,405 63.6% Owner 21,115 1,605 7.6% 1,165 5.5% 1,710 8.1% 1,115 5.3% 15,520 73.5% Renter 17,230 2,570 14.9% 1,895 11.0% 2,380 13.8% 1,500 8.7% 8,885 51.6% Orange 43,115 5,730 13.3% 4,835 11.2% 8,070 18.7% 4,600 10.7% 19,880 46.1% Owner 26,260 1,750 6.7% 2,070 7.9% 4,120 15.7% 2,670 10.2% 15,655 59.6% Renter 16,855 3,980 23.6% 2,765 16.4% 3,950 23.4% 1,930 11.5% 4,225 25.1% Rancho Santa Margarita 16,370 1,125 6.9% 1,330 8.1% 2,200 13.4% 1,930 11.8% 9,790 59.8% Owner 11,775 455 3.9% 720 6.1% 1,210 10.3% 1,155 9.8% 8,240 70.0% Renter 4,595 670 14.6% 610 13.3% 990 21.5% 775 16.9% 1,550 33.7% San Clemente 24,070 2,560 10.6% 2,605 10.8% 3,830 15.9% 2,315 9.6% 12,760 53.0% Owner 15,690 1,160 7.4% 1,140 7.3% 1,875 12.0% 1,430 9.1% 10,085 64.3% Renter 8,380 1,400 16.7% 1,465 17.5% 1,955 23.3% 885 10.6% 2,675 31.9% Santa Ana 72,635 15,770 21.7% 15,250 21.0% 18,725 25.8% 8,315 11.4% 14,575 20.1% Owner 34,265 4,105 12.0% 5,605 16.4% 9,025 26.3% 5,340 15.6% 10,190 29.7% Renter 38,370 11,665 30.4% 9,645 25.1% 9,700 25.3% 2,975 7.8% 4,385 11.4% Tustin 24,715 3,455 14.0% 3,340 13.5% 4,840 19.6% 2,420 9.8% 10,665 43.2% Owner 12,620 830 6.6% 1,120 8.9% 1,970 15.6% 1,185 9.4% 7,515 59.5% Renter 12,095 2,625 21.7% 2,220 18.4% 2,870 23.7% 1,235 10.2% 3,150 26.0% Orange County 990,265 141,360 14.3% 127,185 12.8% 178,110 18.0% 102,330 10.3% 441,275 44.6% Owner 587,210 45,885 7.8% 54,810 9.3% 90,840 15.5% 60,240 10.3% 335,435 57.1% Renter 403,055 95,475 23.7% 72,375 18.0% 87,270 21.7% 42,090 10.4% 105,840 26.3% Source: CHAS Data 2008-2012 COMMUNITY AND REGIONAL PROFILES 32 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS D. Special Needs Households Certain households, because of their unique characteristics and needs, have more barriers to finding decent and affordable housing. These households are considered "special needs groups" and include families with female heads of household, large households, seniors, persons with disabilities, persons with HIV/AIDS, and homeless persons or families in need of emergency shelter. Due to their physical or socioeconomic conditions, their greater need for support services or special accommodations, or other factors, special needs households may have some difficulties in finding affordable housing. In certain situations they may be more susceptible to discriminatory housing practices. The following discussion highlights particular characteristics that could impede fair housing access for special needs groups. Female -Headed Households with Children Single -parent families, particularly female -headed families with children, often require special consideration and assistance because of their greater need for affordable housing and accessible day care, healthcare and other supportive services. Because of their relatively lower income and higher living expenses, female -headed families have comparatively limited opportunities for finding affordable and decent housing. Fair housing service providers have indicated that female -headed families may also be discriminated against in the rental housing market because some landlords are concerned about the ability of these households to make regular rent payments. Consequently, landlords may require more stringent credit checks or higher security deposits for women, which would be a violation of fair housing laws. As presented in Table 3-14 single female head of households with children represents 5.9 percent of the total countywide households in 2013. Single female -headed family households with children were also three times more prevalent than single male family households with children. The cities with the highest percentage of single female head family households include the Cities of Santa Ana (10.0%), Anaheim (8.5%), and Tustin (8.4%). COMMUNITY AND REGIONAL PROFILES 33 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS City/Area Table 3-14: Household Characteristics HouseholdsHouseholds 2013 % With % With Person(s) Persons Ave. HH Age 65+ Under 18 Size % Single % Single Female Male HH % of HH with with Total HH Children Children Ave. Family HH Size Anaheim 22.8% 44.7% 3.39 76.0% 8.5% 2.6% 3.86 Buena Park 27.3% 42.2% 3.51 81.9% 8.0% 4.1% 3.78 Costa Mesa 17.5% 30.5% 2.68 59.5% 6.3% 2.0% 3.34 Fountain Valley 37.1% 31.6% 2.97 75.8% 4.2% 1.7% 3.40 Fullerton 24.7% 35.4% 3.02 70.5% 5.9% 2.2% 3.50 Garden Grove 28.1% 45.5% 3.72 79.5% 7.7% 2.6% 4.09 Huntington Beach 27.2% 28.1% 2.59 65.6% 4.7% 1.8% 3.13 La Habra 23.4% 41.7% 3.25 76.0% 6.1% 3.9% 3.74 Lake Forest 19.9% 38.3% 2.89 75.1% 4.6% 1.8% 3.36 Mission Viejo 28.8% 34.5% 2.80 74.8% 3.2% 1.5% 3.23 Newport Beach 30.7% 20.9% 2.24 54.8% 3.2% 1.0% 2.90 Orange 24.2% 36.8% 3.07 72.2% 6.4% 2.7% 3.53 Rancho Santa Margarita 13.3% 44.8% 2.94 77.8% 7.4% 2.3% 3.38 San Clemente 26.0% 34.5% 2.63 69.9% 5.1% 2.0% 3.15 Santa Ana 21.0% 55.5% 4.45 81.7% 10.0% 4.6% 4.64 Tustin 17.7% 42.8% 3.04 72.3% 8.4% 2.8% 3.55 Orange County 25.7% 37.1% 3.02 71.6% 5.9% 2.2% 3.53 California 24.9% 36.8% 2.94 68.6% 7.2% 2.7% 3.53 Source: ACS 2009-2013 5Yr Est. Table DP02 Large Households Large households are defined as having five or more members. These households are usually families with more than one child or families with extended family members such as in-laws or grandparents. These can also include multiple families living in one housing unit in order to save on housing costs. Large households are a special needs group because the availability of adequately sized, affordable housing units is often limited. To save for necessities such as food, clothing and medical care, lower- and moderate -income large households may reside in smaller units, resulting in overcrowding. Furthermore, families with children, especially those who are renters, may face discrimination or differential treatment in the housing market. For example, some landlords may charge large households a higher rent or security deposit, limit the number of children in a complex, COMMUNITY AND REGIONAL PROFILES 34 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS confine them to a specific location, limit the time children can play outdoors, or choose not to rent to families with children altogether, which would violate fair housing laws. Table 3-15 displays the percentage of households by the number of persons by owner and renter in 2013. In general, on the city, county, and state levels, households with five or more members are more prevalent among renter households than among owner households. The only exceptions were the Cities of Fountain Valley, Newport Beach, and Rancho Santa Margarita. Santa Ana had the largest percent of large households (5 or more persons in household) among both renters (38.6%) and owners (37.9%), followed by Garden Grove (25.7% of renter households and 24.9% of owner households). Among renter households, other cities with the high percentages of large households were La Habra (25.7%), Buena Park (23.2%), and Anaheim (22.0%). For owner households, Anaheim (20.5%) and Buena Park (19.9%) also had high occurrences of households with five or more members. For both types of tenure, the city with the lowest percent of large households was Newport Beach - 2.6 percent of total renter households and 6.8 percent of total owner households. Table 3-15: Persons Per Owner and Renter Owner HouseholdsHousehold Households, 2013 Anaheim 14.9% 28.4% 36.1% 20.5% 21.2% 24.2% 32.6% 22.0% Buena Park 14.5% 27.5% 38.1% 19.9% 11.7% 24.7% 40.4% 23.2% Costa Mesa 24.2% 34.5% 32.0% 9.3% 29.6% 33.9% 24.7% 11.9% Fountain Valley 15.2% 34.3% 36.4% 14.1% 29.5% 28.9% 30.7% 10.9% Fullerton 17.7% 33.4% 36.2% 12.7% 24.0% 27.2% 32.3% 16.5% Garden Grove 14.9% 25.4% 34.9% 24.9% 15.4% 19.5% 39.4% 25.7% Huntington Beach 21.8% 40.1% 30.3% 7.8% 30.5% 32.2% 28.4% 8.9% La Habra 18.2% 31.6% 36.3% 13.9% 20.7% 19.7% 34.6% 24.9% Lake Forest 18.8% 32.1% 39.4% 9.7% 24.9% 26.2% 32.2% 16.7% Mission Viejo 18.2% 37.8% 35.4% 8.7% 25.0% 24.1% 37.3% 13.6% Newport Beach 27.5% 41.9% 23.8% 6.8% 41.6% 34.1% 21.7% 2.6% Orange 17.3% 34.5% 35.3% 12.9% 24.1% 25.3% 30.1% 20.4% Rancho Santa Margarita 13.5% 28.3% 46.1% 12.2% 30.8% 24.6% 34.3% 10.3% San Clemente 19.0% 39.1% 33.2% 8.7% 32.4% 30.1% 26.5% 11.0% Santa Ana 12.0% 19.1% 31.0% 37.9% 14.1% 16.2% 31.1% 38.6% Tustin 22.0% 29.2% 35.2% 13.6% 22.2% 25.5% 34.3% 18.0% Orange County 19.0% 33.1% 34.3% 13.6% 25.3% 26.4% 31.3% 16.9% California 20.0% 33.4% 32.6% 14.0% 29.5% 25.6% 30.1% 14.8% Source: A CS 2009-2013 5 Y Est. Table 825009 COMMUNITY AND REGIONAL PROFILES 35 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Seniors As shown previously in Tables 3-2 and 3-3 in the Age Composition section of this chapter, the elderly (persons over the age of 65) comprised 12.0 percent of total Orange County residents in 2013, and 5.5 percent in the over 75 years, which is considered "frail elderly." Eleven percent of the population was between 55 and 64 years of age, comprising the "future elderly" generation that will age into senior status in the upcoming years. Cities which exceed or equal the countywide percent of elderly residents include Newport Beach (19.3%), Fountain Valley (18.2%), Mission Viejo (15.1%), Huntington Beach (14.8%), San Clemente (13.9%), and Fullerton (12.0%). In terms of households, previous Table 3-15 shows that approximately one-quarter (25.7%) of total Orange County households have one or more elderly members. The cities with high percentages of total households featuring one or more persons over the age of 65 were Fountain Valley (37.1%), Newport Beach (30.7%), Mission Viejo (28.8%), and Garden Grove (28.1%). Persons with Disabilities Fair housing choice for persons with disabilities can be compromised based on the nature of their disability. Fair housing service providers have indicated at persons with physical disabilities may face discrimination in the housing market because of the need for wheelchairs, home modifications to improve accessibility or other forms of assistance. Landlords/owners sometimes fear that a unit might sustain wheelchair damage or might refuse to exempt disabled tenants with service/guide animals from a no -pet policy. A major barrier to housing for people with mental disabilities is opposition based on the stigma of mental disability. Landlords sometimes refuse to rent to tenants with a history of mental illness. Neighbors may object when a house becomes a group home for persons with mental disabilities. Table 3-16 presents information on persons with disabilities in Orange County and the 16 cities. As shown in the table, Orange County residents with a disability account of 5.5 percent of the 18-64 age group and 31.6 percent of the senior population. Of the 16 cities participating in this Al, Santa Ana has the highest percentage of residents with a disability, with 7.1 percent of the 18-64 age group and 38.4 percent of seniors. The type of disability most prevalent among countywide residents, especially among seniors, include ambulatory difficulties (19.8%) and those with independent living difficulties (15.7%). Other cities with relatively high percentage of residents with a disability include Garden Grove (6.4% of the 18-64 age group and 36.9% of seniors) and La Habra (7.1% of the 18-64 age group and 34.7% of seniors). Ambulatory difficulties and independent living difficulties appear to be the key types of disabilities among senior residents. Again, the City of Garden Grove has the highest percentages in both categories for seniors with 24.2 percent with ambulatory difficulties and 19.9 percent with independent living difficulties. As Table 3-17 shows, other cities with a relatively high proportion of seniors with these two difficulties include Costa Mesa, Anaheim, Santa Ana, La Habra and Tustin. COMMUNITY AND REGIONAL PROFILES 36 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 3-16: Disability Characteristics of Seniors and Working -Age Adults 2013 % Pop. Type of Disability Independent City/Area with a Disability Hearing.•Living 18-64 6.0% 1.0% 0.9% 2.4% 2.9% 1.1% 2.4% Anaheim 65+ 35.5% 12.7% 6.4% 10.4% 23.5% 11.7% 19.2% 18-64 6.8% 1.0% 1.2% 2.8% 3.5% 1.4% 2.2% Buena Park 65+ 34.5% 14.9% 7.7% 11.9% 21.5% 9.3% 16.0% 18-64 5.6% 1.0% 1.3% 2.5% 2.6% 1.2% 2.0% Costa Mesa 65+ 34.6% 13.8% 6.4% 11.8% 24.2% 10.6% 17.3% 18-64 5.8% 1.3% 1.3% 2.4% 2.7% 1.3% 2.1% Fountain Valley 65+ 30.2% 12.0% 5.4% 9.1% 18.9% 7.9% 14.6% 18-64 5.8% 1.0% 1.3% 2.3% 2.7% 1.0% 2.2% Fullerton 65+ 32.6% 14.0% 6.5% 9.2% 18.8% 8.8% 15.1% 18-64 6.4% 1.2% 1.0% 3.0% 2.9% 1.2% 2.7% Garden Grove 65+ 36.9% 13.7% 6.1% 13.4% 24.2% 12.4% 19.9% 18-64 5.3% 1.2% 0.7% 2.2% 2.5% 1.1% 1.7% Huntington Beach 65+ 28.9% 13.3% 4.5% 8.3% 17.2% 7.1% 12.1% 18-64 7.1% 1.2% 1.2% 2.6% 3.9% 1.1% 2.4% La Habra 65+ 34.7% 12.6% 6.0% 8.8% 22.8% 8.0% 16.5% 18-64 4.5% 1.3% 0.8% 1.6% 2.0% 1.2% 1.5% Lake Forest 65+ 28.1% 11.0% 4.2% 8.2% 17.7% 7.9% 14.8% 18-64 4.8% 1.1% 0.5% 2.0% 2.1% 1.1% 1.7% Mission Viejo 65+ 30.0% 13.1% 6.8% 11.2% 21.9% 11.4% 15.9% 18-64 3.2% 0.7% 0.3% 1.3% 1.2% 0.5% 1.0% Newport Beach 65+ 23.8% 10.2% 3.2% 6.1% 13.2% 5.5% 10.8% 18-64 5.1% 1.2% 0.9% 2.0% 2.0% 0.9% 2.1% Orange 65+ 32.0% 12.4% 6.1% 7.7% 20.6% 9.5% 15.5% 18-64 3.6% 0.8% 0.9% 1.3% 1.1% 0.6% 0.9% Rancho Santa Margarita 65+ 20.7% 9.4% 6.2% 6.7% 12.3% 4.4% 11.0% 18-64 6.0% 1.7% 0.7% 2.1% 2.4% 1.0% 1.7% San Clemente 65+ 25.0% 13.1% 4.6% 6.0% 14.9% 6.9% 11.1% 18-64 7.1% 1.0% 3.2% 2.0% 2.6% 1.1% 1.9% Santa Ana 65+ 38.4% 13.5% 11.2% 11.4% 22.7% 9.1% 18.1% 18-64 4.5% 1.0% 1.1% 1.5% 1.8% 0.8% 1.4% Tustin 65+ 32.3% 9.9% 5.5% 9.3% 21.1% 11.5% 18.7% 18-64 5.5% 1.0% 1.1% 2.1% 2.4% 1.0% 1.9% Orange County 65+ 31.6% 12.9% 5.9% 9.5% 19.8% 9.1% 15.7% 18-64 8.0% 1.5% 1.5% 3.4% 3.9% 1.6% 2.9% California 65+ 36.8% 14.7% 6.9% 10.5% 24.0% 10.4% 18.2% Source: ACS 2009-2013 Syr Est. Table S1810 Note: Single person may have multiple difficulties. COMMUNITY AND REGIONAL PROFILES 37 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Persons with disabilities might require special housing with ramps, elevators, modified bathrooms, kitchens and doorways. Therefore, the Fair Housing Act, as amended in 1988, requires that cities and counties provide reasonable accommodation to rules, policies, practices and procedures where such accommodation may be necessary to afford individuals with disabilities equal housing opportunities. Although fair housing laws intend that all people have equal access to housing, the law also recognizes that people with disabilities may need extra tools to achieve equality. Reasonable accommodation is one of the tools intended to further housing opportunities for people with disabilities. For developers and providers of housing for people with disabilities, who are often confronted with siting or use restrictions, reasonable accommodation provides a means of requesting from the local government flexibility in the application of land -use, zoning and building code regulations or, in some instances, even a waiver of certain restrictions or requirements because it is necessary to achieve equal access to housing. Cities and counties are required to consider requests for accommodations related to housing for people with disabilities and to provide the accommodation when it is determined to be "reasonable" based on fair housing laws and the case law interpreting the statutes. Persons with HIV/AIDS According to the California Public Health Department, Center for Infectious Diseases, there were a total of 45,670 persons living with HIV and 71,883 persons living with AIDS within the State as of December 31, 2012. New drugs, better treatment, and preventive education have reduced the number of AIDS fatalities. However, new cases of HIV infection continue to occur. Between the years 2001 and 2013, there were a total of 4,174 new cases of HIV reported in Orange County, averaging 321 cases per year for the 13 year time period. Persons with HIV/AIDS face an array of barriers to obtaining and maintaining affordable, stable housing. For persons living with HIV/AIDS, access to safe, affordable housing could be as important to their general health and wellbeing as access to quality healthcare. For many, the persistent shortage of stable housing can be the primary barrier to consistent medical care and treatment. In addition, persons with HIV/AIDS may be targets of hate crimes. Despite federal and state anti- discrimination laws, many people face illegal eviction from their homes when their illness is exposed. The Fair Housing Amendments Act of 1988, which is primarily enforced by HUD, prohibits housing discrimination against persons with disabilities, including persons with HIV/AIDS. COMMUNITY AND REGIONAL PROFILES 38 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Homeless Persons Over the last several decades, the increasing homeless population has become issues of local, regional, and national significance. Lack of affordable housing can exacerbate homelessness, and hinders a community's ability to effectively address this challenge. A homeless family or individual as defined by federal regulations is a person or family that lacks a fixed and regular nighttime residence. The homeless population can be divided into two major groups, the sheltered and the unsheltered homeless. Sheltered homeless are those individuals or families whose primary residence is an emergency shelter, transitional housing, a domestic violence shelter, a shelter for runaway children, or people living in a motel/hotel under a voucher arrangement. Unsheltered homeless are individual or families with a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, airport, or camping ground. Once every two years, Orange County conducts a count of the number of homeless in the county in a given 24-hour period, which is known as the Homeless Point -in -Time (PIT) count survey. The PIT is a one night snapshot of homelessness. The 2015 PIT count was conducted in the evening of January 23, 2015 for the sheltered count and the morning of January 24, 2015 for the unsheltered count. In the 2015 PIT count survey, 4,452 homeless persons were counted, as shown in Table 3-17. The 2015 count was represents approximately 0.14 percent of the total countywide population. It was also slightly higher than the previous 2013 PIT count of 4,251 homeless persons. This increase of 201 homeless person between the 2013 and 2015 PIT count was a slight shift from previous counts between 2011 and 2013, when the homeless counts declined by 2,688 persons. The 2015 count survey also shows that 2,251 homeless persons (51%) live in shelters and the remaining 2,201 are unsheltered (49%). Of those living in shelters, approximately 40 percent were living in emergency shelters and 60 percent in transitional housing. These shelter facilities are defined as: ■ Emergency Shelter — A facility that provides overnight shelter and fulfills a client's basic needs (i.e. food, clothing, medical care) either on-site or through off-site services. The permitted length of stay can vary from one day at a time to three months. ■ Transitional Housing — A residence that provides housing for up to two years. Residents of transitional housing usually include supportive services designed to assist the homeless in achieving greater economic independence and a permanent, stable living situation. Services may include mental and physical health care interventions, substance abuse treatment, job training and employment services, individual and group counseling and life skills training. In addition, some substance abuse programs offer limited transitional housing services in addition to treatment. Overall, homeless persons living in shelters declined by approximately 13 percent from the 2013 count, and homeless persons unsheltered increased by 31 percent from the 2013 count. The 2015 PIT count survey also indicates there were 3,354 homeless households, and of the total homeless households, 61 percent lived in unsheltered conditions. Other key findings from the 2015 count include: COMMUNITY AND REGIONAL PROFILES 39 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ 31 percent of all homeless persons are persons in households with children ■ Almost all (99%+) of homeless families were housed in emergency shelters or transitional housing programs ■ Five percent of homeless people are youths and young adults ■ 13 percent of homeless adults have a serious mental illness, and nearly two-thirds are unsheltered ■ 12 percent of homeless adults are veterans ■ The number of chronically homeless declined by 30 percent and the homeless with chronic substance abuse declined by 54 percent from the 2013 count Table 3-17: Homeless Point In Time Count 2013 and 2015 % Change W. .- HOMELESS PERSONS Sheltered 2,573 60.5% 2,251 50.6% -12.5% Emergency Shelter 1,145 44.5% 925 41.1% -19.2% Transitional Housing 1,428 55.5% 1,326 58.9% -7.1% Unsheltered 1,678 39.5% 2,201 49.4% 31.2% Total 4,251 100.0% 4,452 100.0% 4.7% HOMELESS HOUSEHOLDS Sheltered 1,545 48.4% 1,315 39.2% -14.9% Unsheltered 1,644 51.6% 2,039 60.8% 24.0% Total 3,189 100.0% 3,354 100.0% 5.2% HOMELESS SUBPOPULATIONS Chronically Homeless* 829 580 -30.0% Veterans 446 447 0.2% Severely Mentally III 480 475 -1.0% Chronic Substance Abuse 986 458 -53.5% Persons with HIV/AIDS 89 81 -9.0% ANNUALIZED ESTIMATE Homeless Persons per Year 1 12,707 1 15,291 20.3% Sources: Orange County Homeless 2015 PIT Report; Orange County Homeless County & Survey Report, July 2013 *Includes Chronically Homeless Individuals and Persons in Chronically Homeless Families COMMUNITY AND REGIONAL PROFILES 40 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS E. Housing Profile Housing Growth Table 3-18 details the number and growth rate of the housing stock of the 16 cities, Orange County, and California between 2000 and 2015. In general, there was consistent positive growth on the 16 cities, county and state levels during both the 2000-2010 and 2010-2015 time periods. The sole exception is the City of Garden Grove, which decreased in number of housing units by one-tenth of one percent between 2010 and 2015. During the last five years, Tustin experienced the greatest rate of housing growth at 3.0 percent, larger than both the county rate of 2.0 percent and the state rate of 1.7 percent. Overall, the City of Lake Forest had the largest percentage increase in housing; Lake Forest's growth rate was 32.2 percent during the 2000s and 1.4 percent from 2010 to 2015, totaling 34.0 percent housing growth during the 15 -year period. The only other cities to experience double- digit growth for the same time period were San Clemente (26.5%) and Newport Beach (18.6%). In comparison, total housing units within Orange County increased by 10.3 percent and within California by 13.9 percent between 2000 and 2015. The City of Garden Grove had the lowest overall housing growth rate, with a 2.2 percent increase between 2000 and 2015, followed by La Habra (3.2%), Buena Park (3.8%), and Santa Ana (3.9%). Sources: 2010 Census; Dept of Finance E-5 estimates, January 2015 COMMUNITY AND REGIONAL PROFILES 41 Table 3-18: Housing Growth 2000-2015 City/Areaoil % Change 000111illi2.1% �= Anaheim 99,719 104,237 106,407 4.5% Buena Park 23,826 24,623 24,726 3.3% 0.4% Costa Mesa 40,406 42,120 42,592 4.2% 1.1% Fountain Valley 18,473 19,164 19,303 3.7% 0.7% Fullerton 44,771 47,869 48,474 6.9% 1.3% Garden Grove 46,703 47,755 47,727 2.3% -0.1% Huntington Beach 75,662 78,003 79,896 3.1% 2.4% La Habra 19,441 19,924 20,060 2.5% 0.7% Lake Forest 20,486 27,088 27,454 32.2% 1.4% Mission Viejo 32,985 34,228 34,619 3.8% 1.1% Newport Beach 37,288 44,193 44,211 18.5% 0.0% Orange 41,920 45,111 45,267 7.6% 0.3% Rancho Santa Margarita 16,515 17,260 17,309 4.5% 0.3% San Clemente 20,653 25,966 26,116 25.7% 0.6% Santa Ana 74,588 76,896 77,477 3.1% 0.8% Tustin 25,501 26,476 27,262 3.8% 3.0% Orange County 969,484 1,048,907 1,069,450 8.2% 2.0% California 12,214,550 13,680,081 13,914,715 12.0% 1.7% Sources: 2010 Census; Dept of Finance E-5 estimates, January 2015 COMMUNITY AND REGIONAL PROFILES 41 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Housing Type The majority of Orange County's housing stock is comprised of single-family dwelling units. According to the California Department of Finance 2015 estimates, which are presented in Table 3- 19, 62.7 percent of the countywide housing stock is single-family units (detached and attached). Over one-third (34.2%) the housing stock is multi -family units (two dwelling units or more) and 3.1 percent are mobile homes. Of the 16 cities, Mission Viejo (83.7%), Fountain Valley (75.7%) and Rancho Santa Margarita (74.7%) have the highest percentage of single-family units in their housing stock. The city with the highest proportion of multi -family units is Tustin, which has slightly more multi -family units (48.9%) than single-family units (47.8%). Other cities with a high percentage of multi -family units include Costa Mesa (48.3%) and Anaheim (44.9%). Table Anaheim 3-19: 42.2% Housing Stock by 8.5% Type 2015 MultipleDU 10.7% 34.2% Mobile 4.4% Buena Park 58.2% 7.3% 7.0% 26.0% 1.4% Costa Mesa 39.4% 10.1% 13.4% 34.9% 2.2% Fountain Valley 65.6% 10.1% 3.6% 18.7% 2.0% Fullerton 50.3% 10.1% 8.4% 29.5% 1.8% Garden Grove 57.2% 8.3% 8.8% 22.3% 3.4% Huntington Beach 48.7% 11.6% 12.1% 23.7% 3.9% La Habra 53.1% 7.5% 7.7% 27.2% 4.4% Lake Forest 54.3% 15.1% 5.5% 20.5% 4.6% Mission Viejo 71.4% 12.3% 2.6% 13.5% 0.1% Newport Beach 45.6% 15.9% 11.6% 24.3% 2.7% Orange 57.5% 10.7% 10.8% 18.2% 2.7% Rancho Santa Margarita 54.0% 20.7% 3.6% 21.6% 0.1% San Clemente 56.9% 10.0% 15.7% 15.1% 2.3% Santa Ana 45.9% 7.3% 9.7% 31.8% 5.2% Tustin 34.7% 13.1% 14.8% 34.1% 3.3% Orange County 1 50.7% 12.0% 8.7% 25.5% 3.1% Source: CA Dept of Finance E-5 estimates, January 2015 COMMUNITY AND REGIONAL PROFILES 42 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Age of Housing Stock Over one-third of the existing housing stock in the county was constructed after 1980. This leaves approximately two-thirds of the homes over 35 years old. The median age of an Orange County home is 40 years. In general, homes built more than 30 years ago are likely to require structural renovation and increased maintenance, resulting in greater costs for the owner. Older homes can also create health and safety problems for occupants. Older, deteriorated structures often do not meet current building code standards and lack safety features such as fire suppression, home security devices and seismic safety retrofits. In fact, stringent seismic safety codes were not developed until after the 1971 Sylmar earthquake. After that event, many building codes were revised to ensure structures could withstand seismic activity of similar magnitude. Additionally, in 1978 the federal government prohibited the use of lead-based paint on residential property; therefore, homes built prior to 1979 have a potential risk of containing lead-based paint. Lead poisoning can cause learning disabilities, behavioral problems and even brain damage in children.' As presented in Table 3-20 , the age of the housing stock varies across the 16 cities. Among the 16 cities, Buena Park's housing stock is the oldest, with the median year of home construction in 1962. This is followed by the Cities of Garden Grove (1964), La Habra (1967) and Santa Ana (1967). The city with newest homes is Rancho Santa Margarita, with the median year of home construction in 1992. Other cities with newer residential construction include Lake Forest and San Clemente (both with 1981 as the median year of home construction). In San Clemente, 21.2 percent of its housing was constructed within the last 15 years. Housing Cost and Affordability Many housing problems are directly related to the cost of housing in a community. If housing costs are relatively high in comparison to household income, a correspondingly high prevalence of excessive housing cost burden and overcrowding occurs. This section evaluates the affordability of the housing stock in Orange County and the 16 cities accessible to low and moderate income households. Housing Prices. The value of homes varies substantially among the 16 cities, because prices depend on the age, size and location of homes. As shown in Table 3-21, the average sales price of all homes in Orange County (single-family and condominiums) was $615,000 in September 2015. In comparison to the previous year (2014), the average sales price increased by approximately five percent. Among the 16 cities, the highest sales price in September 2015 was in the City of Newport Beach, with prices averaging almost $1.5 million. The second and third highest home sale prices among the 16 cities were in the Cities of San Clemente and Huntington Beach at $860,000 and $719,000, respectively. Home sale prices in the $400,000 range include the Cities of Santa Ana ($445,000), Rancho Santa Margarita ($455,000), Buena Park ($462,500), La Habra ($470,000), Garden Grove ($475,000), and Anaheim ($485,000). An interesting fact is that the median age of Santa Ana's housing stock is 48 2Executive Order 12898—Environmental Justice COMMUNITY AND REGIONAL PROFILES 43 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS years old, while Rancho Santa Margarita has the youngest housing stock among the 16 cities at only 23 years. In general, home sale prices are lower in communities of older homes, such as the Cities of Buena Park, La Habra, and Garden Grove, where the median age of homes are about 50 years old. Table 3-20: Housing Stock by Year Built, 2013 Median Year iii . City/Area Built Before 1940 M later Anaheim 1972 2.6% 24.7% 43.2% 22.5% 7.0% Buena Park 1962 2.4% 43.9% 36.3% 12.4% 5.1% Costa Mesa 1969 1.6% 24.9% 50.2% 17.3% 6.1% Fountain Valley 1972 0.5% 2.4% 78.5% 13.1% 5.5% Fullerton 1969 5.5% 26.1% 44.2% 15.6% 8.7% Garden Grove 1964 1.8% 38.7% 40.7% 14.1% 4.6% Huntington Beach 1972 1.6% 6.6% 67.5% 19.4% 4.9% La Habra 1967 2.2% 30.6% 48.4% 15.0% 3.9% Lake Forest 1981 0.2% 1.7% 44.2% 51.6% 2.3% Mission Viejo 1979 0.4% 0.8% 51.9% 43.1% 3.8% Newport Beach 1974 3.8% 18.4% 41.3% 24.4% 12.1% Orange 1972 5.3% 15.6% 47.6% 23.1% 8.5% Rancho Santa Margarita 1992 0.2% 0.5% 3.3% 90.7% 5.3% San Clemente 1981 2.0% 11.8% 34.8% 30.2% 21.2% Santa Ana 1967 7.3% 27.0% 46.6% 15.4% 3.6% Tustin 1979 1.8% 4.9% 46.4% 36.4% 10.5% Orange County 1975 2.6% 15.7% 44.8% 27.2% 9.3% California 1974 9.5% 20.4% 32.0% 26.0% 11.8% Source: ACS 2009-2013 5Yr Est. Tables 825034 and 825035 Rental Rates. Table 3-21 also shows the average monthly rents of all rental units. According to information from RealFact.com, rental units in Orange County are renting, on average, at $1,848 per month. Average monthly rental rates by cities was available from another source, Realtor.com. The rental rate data shows that monthly rents range from $1,800 in the City of Garden Grove to as high as $4,800 in the City of Newport Beach. A recent article in the Orange County Register states that an improving job market and ongoing barriers to home -buying are driving up apartment rents in Orange County at the fastest pace in eight years. According to the article, the countywide average monthly rental rate of $1,848 is an all-time high, and 6.9 percent more than a year ago. As a result COMMUNITY AND REGIONAL PROFILES 44 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS of a low inventory of rental units and high demand, vacancy rates are very low -- 5.3 percent according to 2015 DOF estimates -- thus, owners can raise rents. According to the Orange County Register, New York had the nation's highest apartment rent at $3,374 a month and San Francisco was second, averaging $2,392 a month. Los Angeles County's average rent is $1,552 a month, with the Inland Empire's average rent at $1,159. Table 3-21: Cost of Housing, 2015 Sold'Average Average Sales Price of Monthly Rental City/Area Homes Anaheim 250 $485,000 $1,900 Buena Park 53 $462,500 $2,200 Costa Mesa 93 $700,000 $2,300 Fountain Valley 53 $687,500 $1,900 Fullerton 124 $507,000 $2,300 Garden Grove 111 $475,000 $1,800 Huntington Beach 231 $719,000 $2,500 La Habra 64 $470,000 $1,900 Lake Forest 98 $650,000 $2,600 Mission Viejo 125 $605,000 $2,800 Newport Beach 102 $1,475,000 $4,800 Orange 130 $566,000 $2,300 Rancho Santa Margarita 64 $455,000 $2,200 San Clemente 73 $860,000 $3,200 Santa Ana 167 $445,000 $2,000 Tustin 74 $572,500 $2,500 Orange County 3,193 $615,000 $1,8003 Source: 1 RealtyTrack and CorelLogic, September 2015. Includes average of single family and condominium units z Realtor.com, December 2015 3. RealFacts, Spring 2015 Affordability. Based on federal and state guidelines that households should not spend more than 30 percent of their gross income on housing, Table 3-22 estimates the maximum housing costs affordable to Extremely Low Income, Very Low Income, Low Income, and Moderate Income households in Orange County. The affordability threshold is based upon the four -person household. COMMUNITY AND REGIONAL PROFILES 45 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Using updated income guidelines, current housing affordability in terms of home ownership can be estimated for the various income groups. According to the State Income Limits for 2015, the Area Median Income (AMI) for a family of four in Orange County is $87,200. The income limit for an Extremely Low Income household (0-30% AMI) is $28,900, a Very Low Income household (31-50% AMI) is $48,150, a Low Income household (51-80% AMI) is $77,050, and Moderate Income (81-120% AMI) is $104,650. Assuming that the potential homebuyer for each income group has sufficient down payment, credit, and maintains housing expenses no greater than 30 percent of their income, the maximum affordable home prices can be calculated. Table 3-22 presents maximum affordability purchase prices and rents. Previous Table 3-21 is compared with information in Table 3-22, and it appears that: ■ Extremely Low, Very Low, and Low Income households cannot afford housing (rental or ownership) of adequate size in any of the 16 cities -- in particular, Extremely Low and Very Low Income households. ■ On average, even Moderate Income households would find it difficult to purchase a home that costs more than $475,200. Based on the average sales price of homes presented in previous Table 3-22, Moderate Income households would have been able to purchase a home in 2015 in the cities of Buena Park, Garden Grove, La Habra, Rancho Santa Margarita, and Santa Ana. Table 3-22: Maximum Affordable Housing Prices and Rents by Income Groups 2015 Max. Home Max. Home Income Category Income Limit Purchase Price Rental Rate Area Median Income (4 -Persons): $87,200 Extremely Low Income (0-30% AMI) $28,900 $116,600 $504 Very Low Income (31%- 50% AMI) $48,150 $195,900 $890 Lower Income (51-%- 80% AMI) $77,050 $315,500 $1,494 Moderate Income (101-120% AMI) $104,650 $475,200 $2,316 Calculation of affordable rent is based on 30% of gross household income. Calculation of affordable home purchase is based on down payment of 10%, annual interest rate of 4.00% 30 -year fixed mortgage, utilities of $150 (ELI), $200 (VLI), $250 (LI), $300 (MI), and tax/insurance of 20% of housing expense. Future Housing Needs Article 10.6 of the Government Code Section 65580-65590 requires all California localities to adopt a Housing Element as part of their General Plan. State Housing Element Law requires that cities and counties develop local housing programs to meet its "fair share" of existing and future housing needs for all income groups. The Southern California Association of Governments (SCAG), through the fifth - cycle of the Regional Housing Needs Assessment (RHNA), allocated the regional fair share of housing COMMUNITY AND REGIONAL PROFILES 46 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS needs to all cities within the five county region (Imperial, Los Angeles, Orange, San Bernardino, and Ventura Counties) for the 2014-2021 period. Each city is required to implement housing programs through it Housing Element to accommodate the level of housing growth identified in the RHNA by household income categories. Table 3-23 presents the distribution of the future housing needs for each of the 16 cities by four household income categories. As presented in the table, the City of Anaheim has the largest number of housing needs (5,702 units) during the 2014-2021 period, with the second largest need in the City of Lake Forest (2,727 units). On the other hand, the cities with the fewest number of future housing needs during the 2014-2021 period are the Cities of Costa Mesa and Rancho Santa Margarita, each with two units, followed by La Habra (4 units) and Newport Beach (5 units). With the exception of the Cities of Fullerton and San Clemente, each of the 16 cities have adopted Housing Elements which were certified by the State Department of Housing and Community Development (HCD). More details on the Housing Elements are discussed in Chapter 5: Public Policies and Practices. Table 3-23: Future Housing Needs by Income Level, 2014-2021 ModerateIncome Categories Total 0 Housing % % Above Cities/County Units Very Low Moderate Anaheim 5,702 22.0% 15.9% 18.2% 43.9% Buena Park 339 22.4% 15.6% 18.3% 43.7% Costa Mesa 2 50.0% 50.0% 0.0% 0.0% Fountain Valley 358 23.2% 16.5% 18.2% 42.2% Fullerton 1,841 22.3% 16.2% 18.3% 43.1% Garden Grove 747 22.0% 16.1% 18.1% 43.9% Huntington Beach 1,353 23.1% 16.3% 18.3% 42.3% La Habra 4 25.0% 25.0% 25.0% 25.0% Lake Forest 2,727 23.7% 16.5% 18.2% 41.5% Mission Viejo 177 23.7% 16.4% 18.6% 41.2% Newport Beach 5 20.0% 20.0% 20.0% 40.0% Orange 363 22.9% 16.3% 18.2% 42.7% Rancho Santa Margarita 2 50.0% 50.0% 0.0% 0.0% San Clemente 581 23.1% 16.4% 18.6% 42.0% Santa Ana 204 22.1% 15.7% 18.1% 44.1% Tustin 1,227 23.1% 15.9% 18.3% 42.8% Source: SCAG RHNA Final Allocation Plan 2014-2021 COMMUNITY AND REGIONAL PROFILES 47 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS F. Housing Issues Profile Overpayment According to HUD standards, a household is considered "cost -burdened" or overpaying for housing if housing costs (rent plus utilities) make up more than 30 percent of the household's income. Households are "severely cost burdened" or severely overpaying if they spend more than 50 percent of their income on housing costs. A major consequence of overpayment is that less income is available to satisfy other critical household needs, such as transportation, medical and education. According to Table 3-24, overpayment (greater than 30% of income) for housing occurred in 44.5 percent of total households in 2012, and severe overpayment (greater than 50% of income) occurred in 21.2 percent of total households. Additionally, the incidence of overpayment was higher for renters than owners, with 52.0 percent of renter households and 39.3 percent of owner households spending more than 30 percent of their income on housing costs. Source: CHAS Data 2012 COMMUNITY AND REGIONAL PROFILES 48 Table 3-24: Overpayment by Tenure 2012 Overpayment Severe Overpayment City/County 0��� Anaheim 41.5% 59.1% 50.6% 19.0% 31.3% 25.2% Buena Park 40.4% 54.8% 46.6% 14.8% 27.4% 20.1% Costa Mesa 40.7% 50.6% 46.5% 20.6% 24.1% 22.7% Fountain Valley 34.7% 53.2% 39.9% 16.9% 28.6% 20.2% Fullerton 36.9% 53.1% 44.4% 15.8% 29.3% 22.0% Garden Grove 38.5% 55.8% 46.1% 17.5% 29.9% 22.9% Huntington Beach 37.3% 47.0% 41.2% 15.4% 24.3% 18.9% La Habra 40.2% 57.5% 48.0% 14.1% 19.0% 15.5% Lake Forest 37.1% 45.0% 39.4% 14.0% 19.0% 15.5% Mission Viejo 36.0% 55.4% 40.4% 15.2% 28.0% 18.0% Newport Beach 39.6% 42.2% 40.7% 22.3% 23.4% 22.8% Orange 39.6% 51.8% 44.4% 16.7% 26.0 20.3% Rancho Santa Margarita 42.4% 51.1% 45.0% 15.0% 22.3% 17.1% San Clemente 44.6% 50.7% 46.7% 21.9% 28.7% 24.3% Santa Ana 42.8% 55.3% 49.4% 20.5% 28.4% 24.7% Tustin 43.6% 55.3% 49.3% 17.5% 26.6% 21.9% Orange County 39.3% 52.0% 44.5% 17.5% 26.6% 21.2% Source: CHAS Data 2012 COMMUNITY AND REGIONAL PROFILES 48 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS The rate of overpayment varied across jurisdictions, with over one-half (50.6%) of the total households in Anaheim overpaying, compared to 39.4 percent of Lake Forest households overpaying. Anaheim also had one-quarter (25.2%) of its households paying over 50 percent of their income on housing -- the highest percentage of severe overpayment among the 16 cities. In all cases, renter households were uniformly more likely to be cost burdened than owner households throughout the 16 cities. The incidence of overpayment among renter households was highest in the Cities of Anaheim and La Habra, where 59.1 percent and 57.5 percent of households were cost burdened, respectively. Among owner households, the highest percentage of overpaying occurred in the Cities of San Clemente (44.6%) and Tustin (43.6%). Overcrowding A lack of affordable housing can result in overcrowded households. As defined by HUD, overcrowding occurs when there is more than one person per room (excluding kitchens, bathrooms and hallways). Occupancy by more than 1.5 persons per room is considered severe overcrowding. Table 3-25 shows the overcrowding rate among renters and owners in the 16 cities and Orange County in 2013. As shown in the table, 9.3 percent of all households countywide were overcrowded. Overcrowding was substantially higher among renters than owners, with 16.8 percent of renters and 4.0 percent of owner households living in overcrowded conditions. The prevalence of overcrowding varied among the 16 cities. In the City of Santa Ana, almost one- third (32.5%) of the households lived in overcrowded conditions, significantly higher than the 9.3 percent overcrowding countywide. This was followed by La Habra with 19.1 percent of households living in overcrowded condition. The lowest percentage of overcrowding occurred in Newport Beach, where only 1.2 percent of household lived in overcrowding conditions. It should be noted that Newport Beach also has the lowest household size among the 16 cities at 2.24 persons per household. In all cases, rental overcrowding was significantly higher than owner occupied housing. Overcrowding was particularly high among renter households in Santa Ana and La Habra, where 42.6 percent and 33.1 percent of households were overcrowded, respectively. This indicates the need for larger rental units and/or rental subsidies to allow large households to afford adequately sized units. Conditions of overcrowding are largely a combination of the lack of large rental units and the inability of most large renter households to afford larger units and lack of available adequately -sized rental units, as larger housing units tend to be more common in the homeownership market. COMMUNITY AND REGIONAL PROFILES 49 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: ACS 2009-2013 5Yr Est. Table 825014 G. Public and Assisted Housing The availability and location of public and assisted housing is a fair housing concern if such housing is concentrated in one area of a city and, therefore, a household's access to housing may be limited to that area. In addition, public/assisted housing, including Section 8 rental assistance, must be accessible to qualified households regardless of race/ethnicity, disability or other special needs or protected class. Section 8 Rental Assistance Housing Program The Section 8 Housing Choice Voucher Program provides rental subsidies to low-income families that spend more than 30 percent of their gross income on housing costs. The program pays the difference between 30 percent of the recipients' monthly income and the federally approved COMMUNITY AND REGIONAL PROFILES 50 Table 3-25: Overcrowding by Tenure Percentage of Total Households • 2013 Overcrowded (1.51+ PPR) ��� 0Total Anaheim 8.1% 26.2% 17.6% 1.7% 10.5% 6.3% Buena Park 4.1% 21.3% 11.7% 0.4% 6.7% 3.2% Costa Mesa 1.8% 12.0% 7.9% 0.3% 4.1% 2.6% Fountain Valley 1.8% 6.5% 3.1% 0.2% 0.8% 0.4% Fullerton 3.2% 17.5% 9.7% 1.0% 7.0% 3.8% Garden Grove 10.5% 23.4% 16.2% 2.5% 8.4% 5.1% Huntington Beach 0.5% 6.1% 2.8% 0.1% 2.0% 0.9% La Habra 7.8% 33.1% 19.1% 2.6% 21.1% 10.9% Lake Forest 1.0% 12.5% 4.5% 0.3% 3.7% 1.3% Mission Viejo 1.1% 9.3% 2.8% 0.4% 1.2% 0.5% Newport Beach 0.5% 2.0% 1.2% 0.1% 1.0% 0.5% Orange 3.2% 21.0% 10.4% 0.6% 8.0% 3.6% Rancho Santa Margarita 0.9% 9.3% 3.3% 0.2% 2.8% 0.9% San Clemente 0.9% 8.3% 3.4% 0.1% 4.5% 1.6% Santa Ana 20.7% 42.6% 32.5% 7.1% 22.3% 15.3% Tustin 4.1% 16.1% 10.0% 1.3% 4.4% 2.8% Orange County 4.0% 16.8% 9.3% 1.1% 6.9% 3.5% Source: ACS 2009-2013 5Yr Est. Table 825014 G. Public and Assisted Housing The availability and location of public and assisted housing is a fair housing concern if such housing is concentrated in one area of a city and, therefore, a household's access to housing may be limited to that area. In addition, public/assisted housing, including Section 8 rental assistance, must be accessible to qualified households regardless of race/ethnicity, disability or other special needs or protected class. Section 8 Rental Assistance Housing Program The Section 8 Housing Choice Voucher Program provides rental subsidies to low-income families that spend more than 30 percent of their gross income on housing costs. The program pays the difference between 30 percent of the recipients' monthly income and the federally approved COMMUNITY AND REGIONAL PROFILES 50 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS payment standard. Recipients of Section 8 vouchers are able to find their own housing, including single-family homes, townhouses and apartments. Under this program, owners are given favorable tax treatment provided that they preserve the units at rents that are affordable to low-income households. Within the 16 cities participating in the regional Al, there are four housing authorities that administer the Housing Choice Voucher Program: Orange County Housing Authority (OCHA), Anaheim Housing Authority (AHA), Garden Grove Housing Authority (GGHA), and the Santa Ana Housing Authority (SAHA). Orange County Housing Authority. Within the 16 cities, the Orange County Housing Authority, as of October 2015, assists 6,263 households through the Section 8 Housing Choice Voucher Program. The total includes 774 households who have moved to Orange County through portability (housing vouchers issued by another housing authority, but administered by OCHA), and 852 households that are assisted by OCHA but live in the Cities of Garden Grove or Anaheim, which have their own housing authorities. As of October 2015, approximately 46,000 households are on the OCHA waiting list for the program. As presented in Table 3-26, of the 16 cities, the OCHA administers the largest number of Section 8 vouchers to the City of Huntington Beach, with 926 households (15%). This is followed by the City of Costa Mesa with 607 households (10%). The racial/ethnic characteristics of recipients include 40 percent non -Hispanic Whites, 27 percent non -Hispanic Asians, 22 percent Hispanic and 10 percent non -Hispanic Black/African American. As previously shown in this chapter, the non -Hispanic White population represents 44 percent of the countywide total in 2013. The Hispanic population represented 34 percent, non -Hispanic Asian 19 percent and non -Hispanic Black less than two percent. When comparing the elderly and disabled recipients of Section 8 vouchers, 43 percent of the households include at least one elderly person, and 40 percent are disabled head of households. Anaheim Housing Authority. According to the Anaheim Housing Authority, as of February 2016, there are 6,162 Section 8 Housing Voucher and Project -Based Voucher recipients. Of the total recipients, 35 percent are Hispanic, 28 percent are non -Hispanic Asian/Pacific Islander, 28 percent are non -Hispanic White, eight percent are non -Hispanic Black/African American, and less than one percent are Native American. Also, 42 percent of the total recipients are elderly and 37 percent are disabled. In addition, there are 31,033 households on the waiting list to participate in Section 8 and Project -Based Voucher programs and 12,893 households in the Affordable Housing program. Of those on the waiting list to participate in the Section 8 and Project -Based programs, 33 percent are Hispanic, 26 percent are non -Hispanic Black/African American, 21 percent are non -Hispanic Asian/Pacific Islander, 19 percent non -Hispanic White, and one percent non -Hispanic Native American. The waiting list for the Affordable Housing programs includes 48 percent Hispanic, 21 percent non -Hispanic White, 19 percent non -Hispanic Asian/Pacific Islander, nine percent non - Hispanic Black/African American, , and one percent Native American. COMMUNITY AND REGIONAL PROFILES 51 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 3-26: Orange County Housing Authority Section 8 Program Recipients by City Anaheim 385 123 99 98 60 5 136 173 Buena Park 464 115 156 51 140 2 149 163 Costa Mesa 607 366 107 113 13 5 235 220 Fountain Valley 480 111 34 334 4 4 335 187 Fullerton 590 242 194 71 76 7 207 238 Garden Grove 575 43 38 471 11 8 279 160 Huntington Beach 926 426 151 301 41 7 452 364 La Habra 187 49 113 9 15 1 66 80 Lake Forest 239 141 46 17 34 1 82 119 Mission Viejo 264 187 28 17 30 2 117 150 Newport Beach 144 99 20 7 15 2 69 52 Orange 598 220 189 137 46 6 264 254 Rancho Santa Margarita 145 84 27 8 24 2 66 70 San Clemente 136 102 24 4 5 1 84 69 Santa Ana 6 1 2 0 2 1 0 3 Tustin 517 190 184 58 82 3 177 191 Total 6,263 2,499 1,412 1,696 598 57 2,718 2,493 Percent of Total 39.9% 22.5% 27.1% 9.5% 0.9% 43.4% 39.8% Source: Housing Authority of Orange County as of October 2015 Garden Grove Housing Authority. According to information provided by the Garden Grove Housing Authority (GGHA) in November 2015, there are approximately 2,300 Section 8 Program participants in Garden Grove. The largest racial/ethnic group participating in the program are non -Hispanic Asian residents, which represents 80 percent of the total recipients. Hispanic families account of 11 percent, non -Hispanic White 16 percent and non -Hispanic Black/African American one percent. Approximately 56 percent of the total Section 8 participants are elderly and 33 percent are disabled. There were approximately 16,000 households on the current waiting list for the GGHA Section 8 Program, and of those, Asians account for over one-half (56%), while Hispanic residents account for 19 percent. Also, over one-half (56%) of residents on the waiting list are the elderly and one-third (33%) are persons with disabilities. COMMUNITY AND REGIONAL PROFILES 52 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Santa Ana Housing Authority. According to information provided by the Santa Ana Housing Authority (SAHA) in December 2015, there are 1,761 recipients participating in the Section 8 Voucher Program. Of the Section 8 recipients, over one-half (53%) are non -Hispanic Asian residents, followed by approximately one-third (34%) Hispanic residents. Non -Hispanic Whites account for nine percent and non -Hispanic Black/African Americans account for three percent. Additionally, elderly recipients represent one-half (50.5%) of the total and persons with disabilities account for 41 percent. According to SAHA, there are 5,128 residents on the current Section 8 Voucher waiting list. Hispanic and non -Hispanic Asian residents together account for three-quarters of the total residents on the waiting list, with Hispanics at 46 percent and non -Hispanic Asians at 31 percent. Waiting list residents that are elderly or disabled represent 18 percent and 16 percent, respectively. H. Residential Care Facilities Individuals with special needs, including the elderly or persons with physical or mental disabilities, need access to suitable housing in their community. This segment of the population often needs affordable housing that is located near public transportation, social and health services, and shopping. Persons with disabilities may require units equipped with wheelchair accessibility or other special features that accommodate physical or sensory limitations. Depending on the severity of the disability and support program regulations and reimbursement levels, people may live independently with some assistance in their own homes, in assisted living, or other special care facilities. Table 3-27 shows the number of licensed community care facilities in the each of the 16 cities. In total, there are 2,105 licensed community care facilities, with 1,011 facilities serving adults, elderly and persons with disabilities (including children) that are located in the 16 cities. The licensed care facilities for the special needs residents are defined as follows by the California Department of Social Services, Community Care Licensing Division: ■ Adult Residential Facilities (ARF) provide 24-hour non-medical care for adults ages 18 years through 59 years old who are unable to provide for their own daily needs. ARFs include board and care homes for adults with developmental disabilities and mental illnesses. ■ Residential Care Facilities for the Elderly (RCFE) provide care, supervision, and assistance with daily living activities, such as bathing and grooming. In California, "elderly" is considered age 60 and above. ■ Adult Day Care facilities provide care to persons 18 years of age or older in need of personal services, supervision, or assistance essential for sustaining the activities of daily living or for the protection of these individuals on less than a 24-hour basis. ■ Children's Residential Group Homes provide 24-hour non-medical care and supervision to children. Services include social, psychological, and behavioral programs for troubled youth. ■ Small Family Homes (SFH) provide 24-hour care in the licensee's family residence for six or fewer children who require special supervision as a result of a mental or developmental disability or physical handicap. COMMUNITY AND REGIONAL PROFILES 53 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS In addition to the residential care facilities described above, there are a wide variety of programs to assist special needs populations and homeless individuals and families, who are homeless or at risk of homelessness. Many programs also target specific groups such as youth, veterans, or persons with HIV/AIDS. Table 3-27: Licensed Community Care Facilities Asst. Living Resid. Care Children's Adult Resid. Adult Residential Small Family City/Area Facilities im Day Care Group Homes Homes Anaheim 96 97 8 2 0 Buena Park 29 26 1 3 0 Costa Mesa 9 42 1 9 2 Fountain Valley 2 42 1 2 1 Fullerton 11 38 2 6 0 Garden Grove 33 41 1 3 0 Huntington Beach 1 54 1 1 4 La Habra 1 16 0 0 0 Lake Forest 7 40 0 0 0 Mission Viejo 9 147 2 0 1 Newport Beach 0 13 0 0 0 Orange 23 47 3 11 1 Rancho Santa Margarita 0 0 0 0 0 San Clemente 1 20 0 0 1 Santa Ana 34 27 1 7 0 Tustin 2 22 1 5 0 Total 258 672 22 49 10 Source: California Department of Social Services, Community Care Licensing Division https://secure. dss. ca. gov/CareFacilitySearch/home/selecttype/ COMMUNITY AND REGIONAL PROFILES 54 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS I. Accessibility to Public Transportation Public transit is often the only travel option for lower income households. Public transit should link lower income households to major employment centers. A lack of relationship between public transit, job centers, and affordable housing may impede Fair Housing Choice because persons who depend on public transit will be limited in the choice of where they can live. Elderly persons and persons with disabilities are more likely than other groups to be transit dependent. Many rely on public transit to visit doctors, go shopping, or attend activities offered at the community centers. Housing for the elderly and persons with disabilities should be located near transit routes, or alternative transit should be made available for persons with special needs. This section discusses the accessibility of public transit to lower income residents and housing for persons with special needs. Public Transit - OCTA The Orange County Transportation Authority (OCTA) was formed in 1991 and provides transportation services to commuters moving throughout 34 cities and unincorporated areas of Orange County. The use of bus transportation and regional intermodal connections reduces freeway traffic congestion, improves safety and efficiency on local roads, and provides transportation options to people with special needs. The OCTA administrative offices are located in the City of Orange and it maintains bus operations bases in the cities of Garden Grove and Santa Ana. First Transit, which contracts with OCTA to provide public transit services to about operates about one-third of OCTA's Fixed Routes out of the Anaheim and Irvine bases. MV Transportation operates OCTA's paratransit base for the authority's ACCESS service also in Irvine. In addition to bus services, OCTA provides light rail service (Metrolink). OCTA also operates the State Route 91 Freeway Express lanes. Bus Service. OCTA operates approximately 77 bus routes in Orange County. Most of the bus riders are from lower income households. Tables 3-28 and 3-29 present the 2015 OCTA bus fares and a descriptions of various passes offered to riders. The OCTA is proposing a service plan for 2016 that includes the elimination of several bus routes. The proposed changes will affect some of the 16 cities, which are mostly located along the coast and also in the southern section of Orange County. Some of the key, proposed bus routes or segments that are planned to be discontinued include: ■ Anaheim: Eliminate a portion of bus line route 30 near the Metrolink station. Eliminate portion of bus line 167. ■ Buena Park: Eliminate a portion of bus line route 21 from Graham and McFadden to Pacific Coast Highway. ■ Costa Mesa: Eliminate bus lines 51 and 145 from Santa Ana to Costa Mesa. Eliminate bus lines 172 and 173 from Huntington Beach to Costa Mesa. COMMUNITY AND REGIONAL PROFILES 55 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ Fullerton: Eliminate portion of express bus line 721 from Fullerton to Los Angeles. ■ Garden Grove: Eliminate portions of bus line 56 from Garden Grove to Orange. ■ Huntington Beach: Eliminate a portion of bus line 35 from Graham and McFadden to Pacific Coast Highway. Eliminate bus line 76 from Huntington Beach to Newport Beach. Eliminate bus lines 172 and 173 from Huntington Beach to Costa Mesa. Eliminate bus line 178 from Huntington Beach to Irvine. Eliminate portion of express bus line 701 from Harbor Gateway Transit Center to Union Station. ■ La Habra: Eliminate bus line 20 from Imperial and Idaho to Lemon and Main. Table 3-28: OCTA Bus Fare Structure 2015 Local Routes: Regular Fare — Local Route $ 2.00 Customers 6 years and older Senior Citizen — Local Route $ 0.75 Customers 60 and older ACCESS - Local Fare $ 0.25 Customers with certified disability Children 5 yrs and younger ride free when riding with paying Children Free passenger. Limit: Three kids per customer Express Routes: Regular Fare $ 6.00 Express Routes: 701, 721 and 794 Additional fare, combined with any valid OCTA bus pass $ 4.00 Express Routes: 701, 721 and 794 Seniors (60 & Older), persons with disabilities and Medicare cardholders $ 5.00 Express Routes: 701, 721 and 794 Additional fare, combined with any valid OCTA bus pass $ 4.25 Express Routes: 701, 721 and 794 Regular Fare $ 4.00 Express Routes: 757 and 758 Additional fare, combined with any valid OCTA bus pass $ 2.00 Express Routes: 757 and 758 Seniors (60 & Older), persons with disabilities and Medicare cardholders $ 3.50 Express Routes: 757 and 758 Additional fare, combined with any valid OCTA bus pass $ 2.75 Express Routes: 757 and 758 Source: OCTA Web Site, December 2015 COMMUNITY AND REGIONAL PROFILES 56 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 3-29: OCTA Cost of Bus Passes 2015 Local Route Passes: Day Pass $ 5.00 Only sold on board by coach operators Day Pass -Seniors $ 1.50 Seniors (60 and older), persons w/disabilities and Medicare Pre -Paid Day Pass $ 4.50 Pre -Paid Day Pass -Seniors $ 1.35 Seniors (60 and older), persons w/disabilities and Medicare 7 -Day Pass $ 25.00 7 -Day Pass -Seniors $ 8.25 Seniors (60 and older), persons w/disabilities and Medicare 30 -Day Pass $ 69.00 30 -Day Pass -Youth $ 69.00 Ages 6-18 only 30 -Day Pass -Senior $ 22.25 Seniors (60 and older), persons w/disabilities and Medicare 5 Rides Pass $ 9.00 Valid for 5 rides, anytime. Valid for all ages. Express Route Passes: Express 30 -Day $187.50 Unlimited use on all local routs plus 701, 721 and 794 Express Day Pass $ 12.00 Only sold on board by coach operators, valid until 11:59 p.m. Express Senior Day Pass $ 10.00 Seniors (60 and older), persons w/disabilities and Medicare OC Express 30 -Day $125.00 Unlimited use on all local routes plus 757 and 758 OC Express Day Pass $ 8.00 Only sold on board by coach operators, valid until 11:59 p.m. OC Express Senior Day Pass $ 7.00 Seniors (60 and older), persons w/disabilities and Medicare Other Passes: Unlimited rides for 30 consecutive days between June 1 and Summer Youth Pass $ 20.00 Sep 30 30 -Day College Pass $ 46.00 Students "C -Pass" * 75 -Day Quarter College Pass $ 116.00 Students "C -Pass" * 120 -Day Semester College Pass $ 185.00 Students "C -Pass" * CSUF — University Pass $ 92.00 "U -Pass" cost for the four-month semester UC Irvine — University Pass $ 169.00 "U -Pass" cost for the academic year from July 1 to June 30 Chapman provides a $25 per month subsidy for regular monthly passes to 28 persons. If there are more than 28 persons that want the subsidy, Chapman conducts a simple lottery to select Chapman — University Pass $ 25.00 28 people that will receive the subsidy for that month. * C -Pass is available to qualified students at these participating colleges: Career College of California (30 -Day available), Cypress College, Fullerton College (30 -Day available), Goldenwest College, Irvine Valley College, NOCCCD School of Continuation Education, Orange Coast College, Saddleback College (30 -Day available), Santa Ana College (30 -Day available), Santiago Canyon College, The Art Institute of California Source: OCTA Web Site, December 2015 COMMUNITY AND REGIONAL PROFILES 57 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ Mission Viejo: Eliminate portion of bus line 85 from Crown Valley and Alicia to Golden Lantern and Dana Point. Eliminate bus line 191 from Mission Viejo to San Clemente. ■ Newport Beach: Eliminate bus line 76 from Huntington Beach to Newport Beach. Eliminate portion of bus line 71 from Yorba Linda to Newport Beach. ■ Orange: Eliminate portions of bus line 56 from Garden Grove to Orange. ■ Rancho Santa Margarita: Eliminate bus line 87 from Rancho Santa Margarita to Laguna Niguel. ■ San Clemente: Eliminate bus line 191 from Mission Viejo to San Clemente. Eliminate bus line 193. ■ Santa Ana: Eliminate bus lines 51 and 145 from Santa Ana to Costa Mesa. Eliminate express bus line 757. Metrolink Service. Metrolink is a system of eight (8) lines that serve the counties of Ventura, Los Angeles, Orange, Riverside and San Bernardino. It is a network of stations that connect to major destinations and employment centers. In Orange County, OCTA's Metrolink rail service has three lines and 13 stations from Buena Park to San Clemente, of which 10 are located within one of the 16 participating cities. OCTA operates the following: ■ OC -Line: The OC Line has stations in the following Orange County cities: Buena Park, Fullerton, Anaheim, Orange, Santa Ana, Tustin, Irvine, Laguna Niguel/Mission Viejo, San Juan Capistrano and San Clemente. This line ends in Oceanside. ■ 91 -Line: The 91 line has stations in the following Orange County cities: Buena Park and Fullerton. This line ends in Riverside. ■ Inland Empire/Orange County (IEOC) Line: The Inland Empire/Orange County (IEOC) Line has three stations in the following Orange County cities: Anaheim, Orange, Santa Ana, Tustin, Irvine, Laguna Niguel/Mission Viejo, San Juan Capistrano and San Clemente. This line ends in Oceanside.. Metrolink fares are based on trip length and it offers many different types of tickets. Seniors and persons with disabilities receive 50 percent off one-way and round-trip tickets and 25 percent off monthly and 7 -day passes. Children ages five and under ride free with each fare -paying adult (limited to three children per adult). Fares, discounts and other related Metrolink items are listed below: ■ Non-refundable and non -replaceable: Metrolink tickets are sold at ticket -vending machines on station platforms. ■ One -Way Ticket: Valid for a single one-way trip between the origin and destination stations. One-way tickets are valid for three hours from time of purchase. ■ Round -Trip Ticket: Valid for a round-trip on the same day between the origin and destination stations. Travel must begin within three hours from time of purchase and end that same day. COMMUNITY AND REGIONAL PROFILES 58 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ Advance Purchase Ticket: One-way or round-trip tickets can be purchased up to one year in advance. Unlike a same-day travel ticket, an advance purchase ticket will not include a printed expiration time. ■ 7 -Day Pass: Good for unlimited trips for seven consecutive days between a set origin and destination, the 7 -Day Pass is priced at seven one-way trips. Discounts apply for senior/disabled/Medicare (25% off) and students (10% off). It may not be purchased in advance. ■ $10 Weekend Day Pass: Available for purchase only on Saturday and Sunday, this pass is good for unlimited travel throughout the Metrolink system either Saturday or Sunday. The Weekend Day Pass is accepted for free transfers to connecting transit services, except Amtrak. ■ Monthly Pass: Valid for unlimited travel between the origin and destination station during the calendar month printed on the pass. . ■ Metrolink and Amtrak Transfers: Only OCTA buses that directly connect with Metrolink trains at or near rail stations will honor Metrolink tickets and passes. The following discounts apply to Metrolink fares and passes: ■ Youth (Ages 6 to 18): 25 percent off Monthly Pass, 7 -Day Pass, One -Way and Round -Trip tickets ■ Child (Ages 5 and under): Three children ride free with an adult using a valid ticket - each additional child pays youth fare. ■ Students: 25 percent off Monthly Pass, 7 -Day Pass, One -Way and Round -Trip tickets ■ Short Distance Fares — Starting January 1, 2016: Metrolink is lowering short distance fares system -wide to $3 for adults/youth/students and only $1.50 for senior/disabled/Medicare riders for one-way tickets. The short distance fare is offered to encourage local travel on Metrolink and is good for one station to the next station on any line Metrolink serves. ■ Senior (Ages 65 and over): 25 percent off Monthly Pass and 7 -Day Pass and 50 percent off One -Way and Round -Trip tickets ■ Persons with Disabilities: 25 percent off Monthly Pass and 7 -Day Pass and 50 percent off One -Way and Round -Trip tickets. A Personal Care Attendant (PCA) is allowed to accompany a person with a disability without purchasing a ticket. The PCA must board and detrain with the person with a disability. ■ Active Military: 10 percent off One -Way and Round -Trip tickets. Public transit also provides a link between residents and employment centers. Appendix B includes maps illustrating the location of major employment centers within each city to public transit routes. According to the 2013 ACS data, approximately three percent of the Orange County workers age 16 and older use public transit as a means of transportation. COMMUNITY AND REGIONAL PROFILES 59 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 4. Mortgage Lending Practices An essential aspect of fair housing choice is equal access to credit for the purchase or improvement of a home. In the past, fair lending practices were not always employed by financial institutions. Credit market distortions and other activities such as redlining — a practice whereby a lender provides unequal access to credit or unequal credit terms to a person because of their race, creed, color or national origin or other characteristic(s) of the residents of the area where the applicant resides or will reside - prevented some groups from equal access to credit. The passage of the Community Reinvestment Act (CRA) in 1977 and the Home Mortgage Disclosure Act (NMDA) in 1979 was designed to improve access to credit for all members of the community. This section reviews the lending practices of financial institutions, and the access that minorities and all income groups have to home loans. A. Lending Laws and Regulations Community Reinvestment Act The Community Reinvestment Act (CRA) is intended to encourage regulated financial institutions to help meet the credit needs of entire communities, including low and moderate -income neighborhoods. Depending on the type of institution and total assets, a lender may be examined by different supervising agencies for its CRA performance. A search in the Federal Reserve Board (FRB), Federal Financial Institutions Examination Council (FFIEC), Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and Office of Thrift Supervision (OTS) databases was performed. Home Mortgage Disclosure Act In tandem with the CRA, the Home Mortgage Disclosure Act (NMDA) requires lending institutions to make annual public disclosures of their home mortgage lending activity. Under HMDA, lenders are required to disclose information on the disposition of home loan applications and on the race or national origin, gender, and annual income of loan applicants. Detailed HMDA data for conventional and government -backed home purchase and home improvement loans in Orange County were examined. HMDA data provides some insight into the lending patterns that exist in a community. However, the HMDA data is used only to indicate the potential for unfair lending practices; the data cannot be used to reach definite conclusions on discriminatory practices. MORTGAGE LENDING PRACTICES 60 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Conventional, Government -Backed Financing Conventional financing involves market -rate loans provided by private lending institutions such as banks, mortgage companies, savings and loans, and thrift institutions. To assist lower and moderate income households that may have difficulty in obtaining home mortgage financing in the private market due to income and equity issues, several government agencies offer loan products that have below market rate interests and are insured ("backed") by the agencies. Sources of government - backed financing include loans insured by the Federal Housing Administration (FHA), the Department of Veterans Affairs (VA), and the Rural Housing Services/Farm Service Agency (RHA/FSA). Often government -backed loans are offered to the consumers through private lending institutions. Local programs such as first time homebuyer and rehabilitation programs are not subject to HMDA reporting requirements. Financial Stability Act The Financial Stability Act of 2009 established the Making Home Affordable Program, which assists eligible homeowners who can no longer afford their home with mortgage loan modifications and other options, including short sale or deed -in -lieu of foreclosure. The program is targeted toward homeowners facing foreclosure, who are unemployed, or who owe more on their mortgage than their home is worth. The Making Home Affordable Program includes several options for homeowners in need of assistance: ■ Home Affordable Modification Program: This program reduces a homeowner's monthly mortgage payment to 31 percent of their verified gross (pre-tax) income to make their payments more affordable. ■ Second Lien Modification Program: Program offers homeowners a way to lower payments on their second mortgage. ■ HARP 1.0: The Home Affordable Refinance Program, also known as HARP, is a federal program of the United States, set up by the Federal Housing Finance Agency in March 2009 to help underwater and near -underwater homeowners refinance their mortgages. Program assists homeowners whose mortgages are current and held by the Federal National Mortgage Association (Fannie Mae) or the Federal Home Loan Mortgage Corporation (Freddie Mac) refinance into a more affordable mortgage. Over 900,000 people have benefited from this program. In an effort to enable more struggling homeowners to take advantage of the Home Affordable Refinance Program, the deadline to submit an application to the program has been extended to December 31, 2016. ■ HARP 2.0: Many people who purchased their home with a down payment of less than 20% of the purchase price were required to have private mortgage insurance (PMI) a common practice with Freddie Mac or Fannie Mae loans. Having PMI attached to a loan made that loan easier to sell on the Wall Street secondary market as a "whole loan." PMI hedged the risk brought by the high loan -to -value ratio by offering insurance against foreclosure for whoever owned the "whole loan". Although HARP 2.0 allows homeowners with PMI to apply through the Making Home Affordable Refinance Program, many homeowners have faced MORTGAGE LENDING PRACTICES 61 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS difficulty refinancing with their original lender. HARP requires the new loan to provide the same level of mortgage insurance coverage as the original loan. This can be difficult and time-consuming, especially in the case of lender -paid private mortgage insurance (LPMI). As a result, many lenders are reluctant to refinance a PMI mortgage. HARP 2.0 enables homeowners to go to any lender to refinance, so the mortgage holder is not stymied if the original bank is unwilling to pursue a HARP refinance. HARP 2.0 refinancing is allowed on all occupancy types: primary residence (owner -occupied), second home, or investment (rental) property. However, HARP 2.0 refinancing of investment properties by Fannie Mae and Freddie Mac has higher mortgage rates than for owner -occupied properties. According to HARP.gov, there are still 430,000 homes that could qualify for HARP 2.0. FHFA, the organization that oversees HARP, examined homes with loans originated before June 2009 and have little or no equity and meet other requirements. Despite current rates in the low four percent range, nearly half a million people are still holding onto their mortgages at five percent, six percent, or even higher. ■ HARP 3.0: In 2012, President Barack Obama outlined a plan to give "every responsible homeowner the chance to save about $3,000 a year on their mortgage". The plan - sometimes referred to as "HARP 3 - has not yet passed. HARP 3 is expected to expand HARP's eligibility requirements to homeowners with non -Fannie Mae and non -Freddie Mac mortgages, including homeowners with jumbo mortgages and Alt -A mortgages, those whose original mortgages were stated income, stated asset, or both. ■ Unemployment Program: Program provides eligible homeowners a forbearance period during which their monthly mortgage payments are reduced or suspended while they seek re-employment. The minimum forbearance period is three months, although a mortgage servicer may extend the term depending on applicable investor and regulatory guidelines. ■ Principal Reduction Program: Offers homeowners who are underwater the opportunity to earn principal reductions over a three-year period by successfully making payments in accordance with their modified loan terms. ■ Home Affordable Foreclosure Alternatives Program (HAFA): For homeowners who can no longer afford their homes, but do not want to go into foreclosure, HAFA offers homeowners, their mortgage servicers, and investors' incentives for completing a short sale or deed -in -lieu of foreclosure. HAFA enables homeowners to transition to more affordable housing while being released from their mortgage debt. The program also includes a "cash for keys" component whereby a homeowner receives financial assistance to help with relocation costs in return for vacating their property in good condition. Helping Families Save Their Homes Act The Helping Families Save Their Homes Act was passed by Congress and signed by the President in May 2009 and expands the Making Home Affordable Program. This Act includes provisions to make mortgage assistance and foreclosure prevention services more accessible to homeowners and increases protections for renters living in foreclosed homes. It also establishes the right of a MORTGAGE LENDING PRACTICES 62 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS homeowner to know who owns their mortgage and provides over two billion dollars in funds to address homelessness. The Act targets underwater borrowers by easing restrictions on refinance and requiring principal write-downs to help these homeowners increase the equity in their homes. The new law also provides federally guaranteed Rural Housing loans and FHA loans as part of the Making Homes Affordable Program. In addition to expanding the Making Homes Affordable Program, the Act extends the temporary increase in deposit insurance, increases the borrowing authority of the FDIC and National Credit Union Administration (NCUA), and creates a Stabilization Fund to address problems in the corporate credit union sector. Under this bill, tenants also have the right to stay in their homes after foreclosure for 90 days or through the term of their lease. Prior to this bill, tenants were only guaranteed 60 days of notice before eviction and any current lease was considered terminated in the event of a foreclosure. This Act extends the 60 -day notification period to 90 days and requires banks to honor any existing lease on a property in foreclosure. On May 20, 2009, President Obama signed the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act into law reauthorizing HUD's Homeless Assistance programs. It was included as part of the Helping Families Save Their Homes Act of 2009. The HEARTH Act allows for the prevention of homelessness, rapid re -housing, consolidation of housing programs, and new homeless categories. In the eighteen months after the bill's signing, HUD must make regulations implementing this new McKinney program. Fraud Enforcement and Recovery Act The Fraud Enforcement and Recovery Act of 2009, or FERA, was enacted May 20, 2009. This federal law enhanced criminal enforcement of federal fraud laws, especially regarding financial institutions, mortgage fraud, and securities fraud or commodities fraud. FERA amends the definition of a financial institution to include private mortgage brokers and non-bank lenders that are not directly regulated or insured by the federal government, making them liable under federal bank fraud criminal statutes. The new law also makes it illegal to make a materially false statement or to willfully overvalue a property in order to manipulate the mortgage lending business. In addition, FERA includes provisions to protect funds expended under TARP and the Recovery Act and amends the Federal securities statutes to cover fraud schemes involving commodity futures and options. Additional funds were also made available under FERA to a number of enforcement agencies in order to investigate and prosecute fraud. MORTGAGE LENDING PRACTICES 63 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS B. Overall Lending Patterns Data and Methodology The availability of financing affects a person's ability to purchase or improve a home. Under HMDA, lending institutions are required to disclose information on the disposition of loan applications by the income, gender, and race of the applicants. This applies to all loan applications for home purchases, improvements, and refinancing, whether financed at market rate or with government assistance. HMDA data are submitted by lending institutions to the FFIEC. Certain data is available to the public via the FFIEC site either in raw data format or as pre-set printed reports. The analyses of HMDA data presented in this Al were conducted using data from Compliance Tech. Compliance Tech's Lending Patterns on-line database tool that analyzes lending records to produce reports on various aspects of mortgage lending was used in this report. HMDA data included in this report includes market share, approval rates, denial rates, low/moderate income lending, and high-cost lending, among other key lending aspects in the Orange County 16 City study area. General Overview A summary of all home purchase loan activities in each of the 16 cities and Orange County, including loans that went through the complete loan process, and loans approved and denied from 2008 to 2013 are found in Appendix C-1. Included is information on loan outcomes by race/ethnicity. In addition, Appendix C-2 lists denial rates of purchase loans by race by Census Tract in all 16 cities of the study area. In 2013, the cities that had the most loan applications — over 2,000 for the year — included Huntington Beach, Mission Viejo, Orange and Santa Ana. Anaheim had over 3,000 completed purchase home loans. The cities with fewer home loan completions — under 1,000 — included Buena Park, Fountain Valley and La Habra. Home purchase loan denial rates varied somewhat by city and from the Orange County average. In 2013 the average home purchase loan denial rate was 15 percent in Orange County. Out of the 16 cities in the study area, the following had denial rates in 2013 less than the Orange County average: Rancho Santa Margarita (11%), Mission Viejo (12%), San Clemente (12%), Fullerton (13%), Huntington Beach (13%), Lake Forest (14%) and Orange (14%). Denial rates in La Habra and Newport Beach were at 15 percent, the County average. On the other hand, the cities with denial rates higher than the Orange County average included: Anaheim (16%), Costa Mesa (16%), Tustin (16%), Buena Park (18%), Fountain Valley (18%), Garden Grove (20%) and Santa Ana (20%). Home loan denial rates have been declining since the peak of the financial crisis in 2008 when the Orange County denial rate was at 22 percent. Steadily, the denial rate has decreased and stabilized at 15 percent during the last three years. The same pattern occurred in most of the 16 cities. MORTGAGE LENDING PRACTICES 64 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Home Purchase Loans Home purchase loans were reviewed in the Orange County 16 City study area in 2013, as listed in Table 4-1. The approved loans included all loans that were originated and applications approved but not accepted. These loans went through the complete underwriting process. Overall, 85 percent of purchase loans were approved in Orange County. Table 41: Status of Home Purchase Loans 2013 ... ApplicationsLoans Approved Loans Denied Total Anaheim 3,655 3,064 84% 591 Buena Park 796 653 82% 143 Costa Mesa 1,471 1,242 84% 2297 Fountain Valley 640 528 83% 112 18% Ful I erton 1,741 1,521 87% 220 13% Garden Grove 1,944 1,548 80% 396 20% Huntington Beach 2,359 2,041 87% 318 13% La Habra 948 807 85% 141 15% Lake Forest 2,091 1,796 86% 295 14% Mission Viejo 2,387 2,091 88% 296 12% Newport Beach 2,011 1,716 85% 295 15% Orange 2,355 2,025 86% 330 14% Rancho Santa Margarita 1,641 1,456 89% 185 11% San Clemente 1,301 1,142 88% 159 12% Santa Ana 2,162 1,721 80% 441 20% Tustin 1,281 1,076 84% 205 16% OC County 33,742 28,842 85% 4,900 15% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 Note: Approved loans include loans originated and applications approved but not accepted. Denial Rate based on applications that went through complete underwriting process, and exlude applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 65 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Refinancing Loans Refinance home loans were also reviewed. (Please see Table 4-2.) Owners will usually refinance existing home loans for a number of reasons, including better interest rates, consolidating debts, changing from variable rate to fixed rate loans, or taking equity out of their homes for various reasons. The majority of loan applications submitted by Orange County households in 2013 were for home refinancing - over 100,000 applications. Approximately 80 percent of refinance applications were approved and 20 percent were denied in 2013. The study area's 16 cities approval and denial rates were fairly comparable to the countywide figures. Table 4-2: Status of Home Refinance Loans 2013 Anaheim 10,647 8,388 79% 2,259 21% Buena Park 2,802 2,185 78% 617 22% Costa Mesa 4,332 3,434 79% 898 21% Founta i n Va I I ey 2,451 1,952 80% 499 20% Fullerton 5,602 4,478 80% 1,124 20% Garden Grove 6,115 4,721 77% 1,394 23% Huntington Beach 8,117 6,626 82% 1,491 18% La Habra 2,538 2,038 80% 500 20% Lake Forest 4,111 3,343 81% 768 19% Mission Viejo 7,324 6,022 82% 1,302 18% Newport Beach 6,159 4,928 80% 1,231 20% Orange 7,938 6,494 82% 1,444 18% Rancho Santa Margarita 4,620 3,840 83% 780 17% San Clemente 4,021 3,243 81% 778 19% Santa Ana 6,704 5,055 75% 1,649 25% Tustin 4,351 3,513 81% 838 19% OC County 100,947 81,026 80% 19,921 20% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 Note: Approved loans include loans originated and applications approved but not accepted. Denial Rate based on applications that went through complete underwriting process, and exlude applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 66 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Home Improvement Loans Home improvement loans were also reviewed, and are shown in Table 4-3 below. These types of loans are used to make necessary repairs and maintenance or to expand the size of a home. Usually, home improvement loan applications have a higher rate of denial when compared to home purchase or refinance loans because adding debt may exceed an applicant's maximum level of debt per lender guidelines. Lowering equity is assessed as riskier by lenders and, for this reason, denial rates are higher in these types of loans. In 2013, 4,156 applications for home improvement loans were submitted by Orange County households. The overall approval rate for home improvement loans in 2013 was 74 percent while 26 percent of these applications were denied. Table 4-3: Status of Home Improvement Loans 2013 W -WIMP. 15-Malvem Loans Approved Loans Denied Applications mTotal �k,11111= Anaheim 447 307 69% 140 31% Buena Park 132 97 73% 35 27% Costa Mesa 169 120 71% 49 29% Fountain Valley 118 90 76% 28 24% Fullerton 239 171 72% 68 28% Garden Grove 314 218 69% 96 31% Huntington Beach 340 266 78% 74 22% La Habra 126 83 66% 43 34% Lake Forest 141 102 72% 39 28% Mission Viejo 298 231 78% 67 22% Newport Beach 213 171 80% 42 20% Orange 343 259 76% 84 24% Rancho Santa Margarita 199 143 72% 56 28% San Clemente 155 124 80% 31 20% Santa Ana 328 209 64% 119 36% Tusti n 172 129 75% 43 25% OC County 4,156 3,060 74% 1,096 26% Source: www.lendingpatterns.com, October 2015 Tabulations: GRCAssociates, Inc., October2015 Note: Approved loans include loans originated and applications approved but not accepted. Denial Rate based on applications that went through complete underwriting process, and exlude applications withdrawn orfiles closed for incompleteness. MORTGAGE LENDING PRACTICES 67 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS C. Lending Patterns by Race/Ethnicity and Income Level The federal Fair Housing Act prohibits discrimination in mortgage lending based on race, color, national origin, religion, sex, familial status or handicap -disability. Thus, it is important to assess not just overall approval and denial rates for a city, but also whether or not these rates vary by other factors, such as race/ethnicity. Loan Applications by Race Completed home purchase loan applications were also analyzed by race in the Orange County 16 city study area and compared to the countwide loan approval/denial rates for the 2008-2013 period. (Please see Tables 4-4 and 4-5). These are the loans that went through the complete underwriting cycle, which ultimately either led to a loan or denial of loan. In summary, completed application loans by race countywide included: ■ White (49 percent) ■ Asian (28 percent) ■ Hispanic (10 percent) ■ Black (0.6 percent) Since 2008, the White population has had a constant share of home loan applications in the County at figures ranging from 47 to 49 percent. Black application figures have decreased by about half, from 1.2 percent of all loans in 2008 to 0.6 in 2013. The Asian share of the completed home loan applications has increased countywide from 23 percent to 28 percent in 2013. In several cities, the Asian share of home purchase loan applications has increased to over 30 percent, including Anaheim, Buena Park, Fountain Valley, Fullerton, Garden Grove, La Habra, Lake Forest and Santa Ana. In contrast, Hispanics evidenced a significant decrease in mortgage loan applications over the past five years in Orange County. In 2008, Hispanics accounted for 16 percent of all home purchase loan applications, and this figure has steadily declined to 10 percent in 2013. All of the 16 cities in the study area have seen a drop in the number of completed Hispanic home purchase loan applications, including the cities with the largest Hispanic populations (Anaheim, Santa Ana and La Habra). MORTGAGE LENDING PRACTICES 68 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 69 Table 4-4: Status of Home Purchase Loans by Applicant Race - 2013 EE.. E Anaheim 3,655 1,336 36.55% 31 0.85% 722 19.75% 1,157 31.66% 4 0.11% 21 0.57% 11 0.30% 317 8.67%ME756 1.53%Buena Park 796 172 21.61% 6 0.75% 143 17.96% 38147.86% 1 0.13% 8 1.01% 3 0.38% 64 8.04% 2.26%Costa Mesa 1,471 897 60.98% 6 0.41% 90 6.12% 232 15.77% 0.00% 4 0.27% 6 0.41% 211 14.34% 1.70% Fountain Valley 640 195 30.47% 4 0.63% 24 3.75% 364 56.88% - 0.00% 4 0.63% 1 0.16% 48 7.50% - 0.00% Fullerton 1,741 553 31.76% 14 0.80% 254 14.59% 700 40.21% 3 0.17% 12 0.69% 6 0.34% 181 10.40% 18 1.03% Garden Grove 1,944 417 21.45% 4 0.21% 257 13.22% 1,110 57.10% - 0.00% 6 0.31% 7 0.36% 118 6.07% 25 1.29% Huntington Beach 2,359 1,478 62.65% 10 0.42% 126 5.34% 446 18.91% 3 0.13% 9 0.38% 7 0.30% 260 11.02% 20 0.85% La Habra 948 316 33.33% 10 1.05% 218 23.00% 315 33.23% - 0.00% 7 0.74% 1 0.11% 73 7.70% 8 0.84% Lake Forest 2,091 906 43.33% 9 0.43% 121 5.79% 814 38.93% 3 0.14% 24 1.15% 6 0.29% 205 9.80% 3 0.14% Mission Viejo 2,387 1,625 68.08% 15 0.63% 133 5.57% 289 12.11% 4 0.17% 19 0.80% 6 0.25% 294 12.32% 2 0.08% Newport Beach 2,011 1,257 62.51% 4 0.20% 36 1.79% 333 16.56% 4 0.20% 3 0.15% 6 0.30% 321 15.96% 47 2.34% Orange 2,355 1,236 52.48% 14 0.59% 238 10.11% 589 25.01% 5 0.21% 16 0.68% 9 0.38% 234 9.94% 14 0.59% Rancho Santa Margarita 1,641 1,113 67.82% 18 1.10% 111 6.76% 175 10.66% 2 0.12% 3 0.18% 8 0.49% 205 12.49% 6 0.37% San Clemente 1,301 990 76.10% 4 0.31% 50 3.84% 61 4.69% 1 0.08% 7 0.54% 5 0.38% 175 13.45% 8 0.61% Santa Ana 2,162 587 27.15% 7 0.32% 678 31.36% 670 30.99% 2 0.09% 6 0.28% 8 0.37% 176 8.14% 28 1.30% Tustin 1,281 654 51.05% 5 0.39% 129 10.07% 329 25.68% 2 0.16% 7 0.55% 4 0.31% 143 11.16% 8 0.62% Orange County Total 1 33,742 1 16,526 48.98% 201 0.60% 1 3,258 9.66% 1 9,517 28.21%1 41 0.12% 1 170 0.50% 1 123 0.36% 3,607 10.69%1 299 0.89% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 69 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 45: Home Purchase Loans - Completed Loan Applications Percent of Total, 2008 to 2013 Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Tusti n Orange County Total Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Tusti n Orange County Total 35% 26% 57% 28% 38% 21% 63% 34% 58% 67% 65% 50% 68% 70% 26% 44% 49% 26% 24% 9% 5% 20% 16% 6% 34% 13% 9% 3% 15% 7% 3% 40% 17% 16% 2009 12010 34% 34% 27% 23% 62% 60% 26% 26% 33% 35% 19% 19% 64% 62% 34% 35% 58% 49% 65% 64% 67% 66% 46% 47% 68% 69% 72% 72% 23% 23% 39% 40% 47% 47% 35% 34% 37% 1.8% 1.0% 0.7% 28% 23% 22% 3.1% 1.9% 1.6% 60% 58% 61% 0.6% 0.6% 0.5% 26% 30% 30% 0.7% 0.4% 0.4% 36% 35% 32% 1.6% 1.0% 0.8% 20% 18% 21% 1.1% 0.4% 0.4% 58% 61% 63% 0.6% 0.5% 0.6% 35% 36% 33% 1.1% 1.3% 0.9% 52% 47% 43% 1.2% 0.7% 0.7% 63% 66% 68% 1.1% 1.1% 1.0% 65% 64% 63% 0.3% 0.3% 0.3% 51% 50% 52% 1.3% 0.6% 0.9% 67% 68% 68% 0.9% 1.5% 1.2% 75% 76% 76% 0.2% 0.3% 0.5% 22% 23% 27% 0.9% 0.4% 0.9% 42% 46% 51% 0.8% 0.5% 1.0% 48% 48% 49% 1.2% 0.8% 0.8% m mm 23% 21% 23% 21% 17% 20% 6% 5% 6% 7% 5% 6% 20% 19% 20% 12% 13% 12% 6% 5% 5% 31% 27% 31% 10% 9% 11% 9% 7% 8% 2% 2% 3% 14% 11% 12% 6% 6% 7% 5% 5% 4% 38% 37% 39% 15% 13% 12% 14% 12% 13% 22% 20% 24% 30% 32% 18% 18% 34% 40% 47% 6% 6% 17% 18% 20% 7% 4% 56% 57% 58% 15% 15% 27% 34% 35% 10% 13% 54% 60% 58% 5% 5% 17% 19% 20% 25% 23% 20% 23% 26% 7% 6% 12% 17% 29% 8% 6% 8% 11% 12% 2% 2% 10% 11% 14% 12% 10% 19% 25% 27% 7% 7% 8% 11% 9% 4% 4% 4% 4% 5% 36% 31% 23% 28% 29% 14% 10% 25% 32% 32% 11% 10% 23% 25% 27% 2011 12012 1.0% 1.1% 1.7% 2.2% 0.7% 0.4% 0.3% 0.2% 0.9% 0.9% 0.7% 0.9% 0.7% 0.4% 1.8% 1.3% 1.1% 1.3% 0.9% 0.8% 0.5% 0.1% 0.9% 1.0% 1.3% 1.1% 0.1% 0.4% 1.1% 0.6% 1.2% 0.5% 0.9% 0.8% MM 28% 30% 39% 45% 16% 19% 56% 54% 31% 39% 58% 61% 20% 20% 21% 28% 23% 32% 12% 12% 10% 14% 22% 23% 11% 10% 4% 4% 28% 30% 32% 28% 25% 27% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Table includes all applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 70 0.8% 0.8% 0.4% 0.6% 0.8% 0.2% 0.4% 1.1% 0.4% 0.6% 0.2% 0.6% 1.1% 0.3% 0.3% 0.4% 0.6% 32% 48% 16% 57% 40% 57% 19% 33% 39% 12% 17% 25% 11% 5% 31% 26% 28% 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Loan Applicant Representation Ideally, the applicant pool for mortgage lending should be reflective of the demographics of a community. When one racial/ethnic group is overrepresented or underrepresented in the total applicant pool, it could be an indicator of unequal access to housing opportunities. Such a finding may be a sign that access to mortgage lending is not equal for all individuals. The percentage of loans completed in each city were compared to the percentage of the city's racial composition and presented in Tables 4-6, 4-7 and 4-8. All racial/ethnic categories have seen a decline in loan denial rates since the peak of the financial crisis in 2008. The following provides a summary of completed purchase loan applications by race compared to the composition of the 16 cities in the study area and County, is summarized below: ■ White. Throughout Orange County, including most of the 16 cities in the study area, the White racial group has a similar percentage of loan applications completed compared to the racial composition of these cities. Whites made up 43 percent of the County in 2013, and 49 percent of the home purchase loan applications were completed by this racial group. Three cities had a difference of over 10 percent between the loan applications completed and percentage of this racial category. In Newport Beach, for example, Whites made up 82 percent of the population, yet in 2013, only 63 percent of the loans in Newport Beach were to Whites. Lake Forest and Fountain Valley also had fewer loans completed by Whites compared to the racial composition of these cities. ■ Hispanic. Hispanics were severely underrepresented in the home loan market in Orange County — making up 34 percent of the County's population, compared to just 10 percent of the home purchase loan applications. The low percentage of loan applications by Hispanics relative to population figures was significant even in cities with large Hispanic populations. For example, Anaheim, which has a Hispanic population of 53 percent only had 20 percent of purchase loan applications being completed by Hispanics. La Habra, which is 60 percent Hispanic, only had 23 percent of the loan applications completed by Hispanics. And, Santa Ana — with 79 percent Hispanic population, the most in Orange County — had just 31 percent of loan applications completed by Hispanics. The relatively low loan figures could be due to various factors, such as, income, employment history, income -to debt ratio, and knowledge of the homebuyer process. ■ Asian. In Orange County, 28 percent of the loan applications were completed by Asians, while this group comprised 18 percent of the population in 2013. The cities that have had recent significant increases — of over 20 percent in loan applications completed, compared to percentage of population — include the following: Buena Park, Fountain Valley, La Habra, Lake Forest and Santa Ana. ■ Black. Blacks make up 1.5 percent of Orange County, and only 0.6 percent of the loan applications were completed by Blacks. Only two cities had purchase loan applications by Blacks over 1 percent: La Habra (1.1%) and Rancho Santa Margarita (1.1%). Out of the 16 cities in the study area, the one with the largest percentage of Blacks in 2013 was Buena Park with 4.3 percent of the population. However, only 0.8 percent of loan applications were completed by Blacks in this city. MORTGAGE LENDING PRACTICES 71 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 4-6: Home Purchase Loans - Comparison, Completed Loan Applications and Percent of City, 2013 Cities 0.8% 2.4% -1.6% 0.35 Anaheim 36.6% 27.4% 9.2% 1.33 Buena Park 21.6% 26.3% -4.7% 0.82 0.8% 4.3% -3.5% 0.18 Costa Mesa 61.0% 51.6% 9.4% 1.18 0.4% 1.2% -0.8% 0.34 Fountain Valley 30.5% 46.6% -16.1% 0.65 0.6% 1.2% -0.6% 0.52 Fullerton 31.8% 36.1% -4.3% 0.88 0.8% 2.5% -1.7% 0.32 Garden Grove 21.5% 21.3% 0.2% 1.01 0.2% 1.0% -0.8% 0.21 Huntington Beach 62.7% 66.1% -3.4% 0.95 0.4% 0.7% -0.3% 0.61 La Habra 33.3% 28.7% 4.6% 1.16 1.1% 1.6% -0.5% 0.66 Lake Forest 43.3% 56.9% -13.6% 0.76 0.4% 1.6% -1.2% 0.27 Mission Viejo 68.1% 70.9% -2.8% 0.96 0.6% 1.5% -0.9% 0.42 Newport Beach 62.5% 81.6% -19.1% 0.77 0.2% 0.6% -0.4% 0.33 Orange 52.5% 45.9% 6.6% 1.14 0.6% 1.0% -0.4% 0.59 Rancho Santa Margarita 67.8% 66.8% 1.0% 1.02 1.1% 1.1% 0.0% 1.00 San Clemente 76.1% 75.4% 0.7% 1.01 0.3% 0.7% -0.4% 0.44 Santa Ana 27.2% 9.6% 17.6% 2.83 0.3% 1.1% -0.8% 0.29 Tustin 51.1% 32.3% 18.8% 1.58 0.4% 2.3% -1.9% 0.17 Orange County Total 49.0% 43.5% 5.5% 1.13 0.6% 1.5% -0.9% 0.40 1.11111 Mill! Anaheim 19.8% 52.6% -32.8% 0.38 31.7% 15.2% 16.5% 2.08 Buena Park 18.0% 38.5% -20.5% 0.47 47.9% 27.9% 20.0% 1.72 Costa Mesa 6.1% 35.2% -29.1% 0.17 15.8% 9.0% 6.8% 1.75 Fountain Valley 3.8% 15.8% -12.1% 0.24 56.9% 33.7% 23.2% 1.69 Fullerton 14.6% 34.5% -19.9% 0.42 40.2% 23.8% 16.4% 1.69 Garden Grove 13.2% 36.8% -23.6% 0.36 57.1% 37.9% 19.2% 1.51 Huntington Beach 5.3% 18.7% -13.4% 0.29 18.9% 11.0% 7.9% 1.72 La Habra 23.0% 60.3% -37.3% 0.38 33.2% 7.4% 25.8% 4.49 Lake Forest 5.8% 23.5% -17.7% 0.25 38.9% 14.1% 24.8% 2.76 Mission Viejo 5.6% 15.8% -10.2% 0.35 12.1% 7.9% 4.2% 1.53 Newport Beach 1.8% 8.4% -6.6% 0.21 16.6% 6.9% 9.7% 2.40 Orange 10.1% 38.4% -28.3% 0.26 25.0% 12.6% 12.4% 1.98 Rancho Santa Margarita 6.8% 18.8% -12.0% 0.36 10.7% 10.6% 0.1% 1.01 San Clemente 3.8% 17.5% -13.7% 0.22 4.7% 3.4% 1.3% 1.38 Santa Ana 31.4% 78.5% -47.1% 0.40 31.0% 9.9% 21.1% 3.13 Tustin 10.1% 39.4% -29.3% 0.26 25.7% 22.7% 3.0% 1.13 Orange County Total 9.7% 33.8% -24.1% 0.29 28.2% 18.2% 10.0% 1.55 * Non -Hispanic Sources: www.lendingpatterns.com, October 2015, US Census, ACS 2009-2013 Table DP05 Tabulations: GRC Associates, Inc., October 2015 1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2 -Table includes all applications that went through the complete underwriting process, and excludes applications withdrawn or tiles closed tor incompleteness. MORTGAGE LENDING PRACTICES 72 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 47: Denied by Race - Home Purchase Loans - 2013 Denied Denied I Tot. I Denied I Denied I Tot. Denied I Denied Tot. Denied Denied Tot. Denied C pps. Apps. % Comp. A % Comp. Apps. % Comp. Apps. % Comp. Apps. Anaheim 3,655 591 16.17% 1,336 172 12.87% 31 7 22.58% 722 155 21.47% 1,157 190 16.42% Buena Park 796 143 17.96% 172 23 13.37% 6 1 16.67% 143 28 19.58% 381 78 20.47% Costa Mesa 1,471 229 15.57% 897 127 14.16% 6 - 0.00% 90 18 20.00% 232 40 17.24% Fountain Valley 640 112 17.50% 195 26 13.33% 4 - 0.00% 24 - 0.00% 364 78 21.43% Fullerton 1,741 220 12.64% 553 56 10.13% 14 1 7.14% 254 35 13.78% 700 98 14.00% Garden Grove 1,944 396 20.37% 417 55 13.19% 4 2 50.00% 257 50 19.46% 1,110 260 23.42% Huntington Beach 2,359 318 13.48% 1,478 168 11.37% 10 - 0.00% 126 17 13.49% 446 86 19.28% La Habra 948 141 14.87% 316 41 12.97% 10 1 10.00% 218 45 20.64% 315 37 11.75% Lake Forest 2,091 295 14.11% 906 119 13.13% 9 - 0.00% 121 17 14.05% 814 116 14.25% Mission Viejo 2,387 296 12.40% 1,625 183 11.26% 15 2 13.33% 133 16 12.03% 289 46 15.92% Newport Beach 2,011 295 14.67% 1,257 184 14.64% 4 1 25.00% 36 4 11.11% 333 49 14.71% Orange 2,355 330 14.01% 1,236 149 12.06% 14 8 57.14% 238 36 15.13% 589 89 15.11% Rancho Santa Margarita 1,641 185 11.27% 1,113 115 10.33% 18 4 22.22% 111 12 10.81% 175 24 13.71% San Clemente 1,301 159 12.22% 990 109 11.01% 4 - 0.00% 50 8 16.00% 61 11 18.03% Santa Ana 2,162 441 20.40% 587 92 15.67% 7 2 28.57% 678 155 22.86% 670 148 22.09% Tustin 1,281 205 16.00% 654 97 14.83% 5 - 0.00% 129 26 20.16% 329 44 13.37% Orange County Total 33,742 4,900 14.52% 16,526 2,036 12.32% 201 36 17.91% 3,258 607 18.63% 9,517 1,536 16.14% Anaheim 4 1 25.00% 21 1 4.76% 11 4 36.36%M7311 58 18.30% 56 3 5.36% Buena Park 1 - 0.00% 8 1 12.50% 3 1 33.33% it 17.19% 18 - 0.00% Costa Mesa - - - 4 1 25.00% 6 1 16.67% 42 19.91% 25 - 0.00% Fountain Valley - - - 4 - 0.00% 1 1 100.0% 7 14.58% - - - Fullerton 3 1 33.33% 12 2 16.67% 6 1 16.67% 181 25 13.81% 18 1 5.56% Garden Grove - - - 6 1 16.67% 7 1 14.29% 118 26 22.03% 25 1 4.00% Huntington Beach 3 - 0.00% 9 3 33.33% 7 - 0.00% 260 43 16.54% 20 1 5.00% La Habra - - - 7 2 28.57% 1 - 0.00% 73 13 17.81% 8 2 25.00% Lake Forest 3 - 0.00% 24 14 58.33% 6 2 33.33% 205 27 13.17% 3 - 0.00% Mission Viejo 4 - 0.00% 19 6 31.58% 6 2 33.33% 294 41 13.95% 2 - 0.00% Newport Beach 4 - 0.00% 3 1 33.33% 6 - 0.00% 321 52 16.20% 47 4 8.51% Orange 5 2 40.00% 16 - 0.00% 9 4 44.44% 234 41 17.52% 14 1 7.14% Rancho Santa Margarita 2 2 100.0% 3 - 0.00% 8 2 25.00% 205 26 12.68% 6 - 0.00% San Clemente 1 1 100.0% 7 - 0.00% 5 - 0.00% 175 30 17.14% 8 - 0.00% Santa Ana 2 2 100.0% 6 2 33.33% 8 2 25.00% 176 36 20.45% 28 2 7.14% Tustin 2 - 0.00% 7 1 14.29% 4 1 25.00% 143 35 24.48% 8 1 12.50% Orange County Total 41 7 17.07% 170 30 17.65% 123 22 17.89% 3,607 609 16.88% 299 17 5.69% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 73 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 48: Home Purchase Loans - Denial Rate Percentages, 2008 to 2013 Anaheim 22% 19% 18% 16% 17% 16% 17% 14% 14% 13% 13% 13% 34% 17% 10% 17% 12% 23% Buena Park 20% 17% 16% 13% 13% 18% 16% 13% 17% 11% 5% 13% 17% 19% 0% 17% 19% 17% Costa Mesa 24% 18% 16% 16% 17% 16% 24% 16% 16% 16% 15% 14% 14% 29% 0% 29% 0% 0% Fountain Valley 21% 23% 14% 16% 16% 18% 18% 15% 11% 13% 12% 13% 0% 50% 0% 0% 0% 0% Fullerton 19% 18% 15% 13% 13% 13% 17% 17% 13% 11% 12% 10% 8% 27% 27% 27% 0% 7% Garden Grove 22% 21% 19% 19% 20% 20% 19% 13% 13% 14% 14% 13% 18% 29% 0% 10% 14% 50% Huntington Beach 21% 16% 14% 16% 13% 13% 19% 15% 13% 14% 11% 11% 27% 13% 10% 0% 25% 0% La Habra 17% 16% 15% 16% 16% 15% 15% 14% 13% 16% 17% 13% 13% 0% 29% 17% 0% 10% Lake Forest 18% 16% 15% 12% 14% 14% 16% 15% 14% 10% 12% 13% 33% 0% 22% 18% 21% 0% Mission Viejo 19% 15% 15% 15% 12% 12% 18% 14% 14% 13% 11% 11% 21% 14% 20% 6% 25% 13% Newport Beach 24% 22% 19% 17% 16% 15% 23% 20% 19% 17% 16% 15% 0% 100% 0% 33% 0% 25% Orange 20% 15% 15% 13% 14% 14% 19% 13% 14% 11% 13% 12% 24% 8% 12% 25% 25% 57% Rancho Santa Margarita 19% 14% 14% 12% 11% 11% 17% 12% 13% 11% 10% 10% 10% 12% 14% 7% 29% 22% San Clemente 22% 17% 18% 13% 12% 12% 20% 16% 16% 13% 11% 11% 50% 0% 0% 0% 0% 0% Santa Ana 28% 24% 25% 20% 21% 20% 23% 19% 19% 15% 15% 16% 32% 18% 5% 25% 45% 29% Tustin 22% 15% 16% 13% 15% 16% 20% 13% 17% 11% 13% 15% 17% 0% 21% 13% 17% 0% Orange County Total 22% 18% 16% 15% 15% 15% 19% 15% 14% 14% 12% 12% 25% 15% 16% 15% 14% 18% Anaheim 30% 23% 25% 19% 19% 21% 18% 18% 16% 17% 20% 16% Buena Park 25% 20% 22% 12% 16% 20% 17% 15% 13% 14% 16% 20% Costa Mesa 24% 19% 28% 21% 19% 20% 20% 19% 13% 16% 21% 17% Fountain Valley 31% 45% 18% 17% 20% 0% 21% 23% 14% 18% 16% 21% Fullerton 23% 23% 18% 16% 17% 14% 16% 16% 13% 12% 12% 14% Garden Grove 35% 24% 31% 21% 25% 19% 18% 22% 16% 20% 21% 23% Huntington Beach 30% 19% 21% 15% 19% 13% 19% 17% 12% 17% 18% 19% La Habra 22% 19% 16% 14% 17% 21% 12% 15% 13% 15% 15% 12% Lake Forest 31% 20% 23% 19% 20% 14% 13% 13% 11% 10% 14% 14% Mission Viejo 31% 20% 18% 23% 21% 12% 14% 14% 14% 17% 17% 16% Newport Beach 31% 22% 19% 20% 9% 11% 26% 28% 19% 19% 20% 15% Orange 29% 19% 28% 18% 15% 15% 14% 13% 14% 11% 15% 15% Rancho Santa Margarita 43% 21% 21% 17% 15% 11% 15% 18% 13% 13% 14% 14% San Clemente 34% 24% 17% 2% 15% 16% 27% 18% 34% 15% 22% 18% Santa Ana 33% 27% 32% 23% 22% 23% 21% 21% 20% 19% 24% 22% Tustin 32% 20% 24% 20% 21% 20% 17% 13% 11% 11% 14% 13% Orange County Total 30% 23% 25% 19% 19% 19% 18% 17% 14% 15% 17% 16% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn orfiles closed for incompleteness. MORTGAGE LENDING PRACTICES 74 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Additional analysis was completed on loans denied by race/ethnicity. Loan denials at the Census Tract level by minority percentage were also analyzed. Table 4-9 and Figure 4-1 show the number and percent of purchase loans denied by minority category at the Census Tract level by city and County. Appendix C-2 shows the details, listing all Census Tracts and figures. In general, Overall, the lower the percentage of minority residents within a Census Tract, lower the denial rate. Table 49: Home Purchase Loans -Denied by Race/Ethnicity- Per Census Tract - 2013 Anaheim 3,655 591 16.17% 0 - - 0 - - 0 - - 534 62 11.61% 481 55 11.43% Buena Park 796 143 17.96% 0 - - 0 - - 0 - - 0 - - 0 - - Costa Mesa 1,471 229 15.57% 0 - - 91 13 14.29% 434 57 13.13% 200 29 14.50% 254 49 19.29% Fountain Valley 640 112 17.50% 0 - - 0 - 22 0 - - 180 28 15.56% 53 5 9.43% Fullerton 1,741 220 12.64% 0 - - 0 - - 0 - - 217 28 12.90% 388 35 9.02% Garden Grove 1,944 396 20.37% 0 - - 0 - - 93 6 6.45% 122 13 10.66% 39 7 17.95% Huntington Beach 2,359 318 13.48% 0 - - 121 22 18.18% 1,319 169 12.81% 638 73 11.44% 24 3 12.50% La Habra 948 141 14.87% 0 - - 0 - - 0 - - 0 - - 252 43 17.06%. Lake Forest 2,091 295 14.11% 0 - - 0 - - 260 32 12.31% 193 19 9.84% 1,221 179 14.66% Mission Viejo 2,387 296 12.40% 0 - - 247 37 14.98% 1,156 127 10.99% 598 63 10.54% 215 43 20.00% Newport Beach 2,011 295 14.67% 63 3 4.76% 885 133 15.03% 484 53 10.95% 106 22 20.75% 446 81 18.16% Orange 2,355 330 14.01% 0 - - 0 - - 213 33 15.49% 435 56 12.87% 780 96 12.31% Rancho Santa Margarita 1,641 185 11.27% 0 - 286 38 13.29% 404 34 8.42% 784 96 12.24% 167 17 10.18% San Clemente 1,301 159 12.22% 0 - - 530 74 13.96% 695 71 10.22% 49 9 18.37% 0 - - Santa Ana 2,162 441 20.40% 0 - - 0 - - 0 - - 0 - - 77 9 11.69% Tustin 1,281 205 16.00% 0 - - 0 - 14.49% 201 29 14.43% 191 34 17.80% 335 43 12.84%. Orange County Total 33,742 4,900 14.52% 63 3 4.76% 3,201 450 14.06% 5,953 687 11.54% 6,426 832 12.95% 6,074 829 13.65% Anaheim 251 51 20.32% 619 91 14.70% 735 116 15.78% 869 173 19.91% 166 43 25.90% - - #DIV/01 Buena Park 55 17 30.91% 417 64 15.35% 252 42 16.67% 72 20 27.78% 0 - - 0 - - Costa Mesa 209 33 15.79% 69 12 17.39% 157 29 18.47% 57 7 12.28% 0 - - 0 - Fountain Valley 104 22 21.15% 120 16 13.33% 89 19 21.35% 94 22 23,40% 0 - - 0 - - Fullerton 66 12 18.18% 434 60 13.82% 362 39 10.77% 274 46 16.79% 0 - - 0 - - Garden Grove 10 1 10.00% 198 39 19.70% 449 94 20.94% 887 201 22.66% 146 35 23.97% 0 - - Huntington Beach 147 22 14.97% 32 11 34.38% 78 18 23.08% - - - 0 - - 0 - - La Habra 236 29 12.29% 169 22 13.02% 166 22 13.25% 125 25 20.00% 0 - - 0 - Lake Forest 99 16 16.16% 318 49 15.41% - - - - - - 0 - - 0 - Mission Viejo 171 26 15.20% 0 - - - - - - - - 0 - - 0 - Newport Beach 0 - - 27 3 11.11% - - - - - - 0 - - 0 - - Orange 284 35 12.32% 517 92 17.79% 103 14 13.59% 23 4 17.39% 0 - 0 - - RanchoSantaMargarita 0 - - 0 - - - - - - - - 0 - - 0 - - San Clemente 27 5 18.52% 0 - - - - - - - 0 - 0 - - Santa Ana 218 34 15.60% 194 39 20.1% 302 55 18.21% 439 85 19.36% 932 219 23.50% 0 - Tustin 204 27 13.24% - - - 281 55 19.57% 41 6 14.63% 28 11 39.29% 0 - - Orange County Total 2,642 395 14.95% 3,272 474 14.49% 2,315 404 17.45% 2,635 543 20.61% 1,155 281 24.33% 6 2 33.33% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 75 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS MORTGAGE LENDING PRACTICES 76 hale Loan Denials s2013 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Income Level - Applicants In addition to analyzing loans by race, loans by income were also reviewed. Table 4-10 lists each of the Orange County 16 Cities' home purchase loans in 2013 by the following income categories: Low (<50% of AMI), Moderate (50-79% of AMI), Middle (80-119% of AMI) and Upper (>120% of AMI). The income levels used in the HMDA analysis is different than the definitions used by HUD to determine low and moderate areas. Given the relatively expensive housing market in Orange County, it is reasonable to note that over half of the purchase loans (61 percent) were made to applicants in the Upper income category. Table 410: Status of Home Purchase Loans by Applicant Income 2013 Anaheim 3,655 199 5.44%7136 19.04% 1,068 29.22% 1,539 42.11% 153 4.19% Buena Park 796 37 4.65% 17.09% 266 33.42% 318 39.95% 39 4.90% Costa Mesa 1,471 24 1.63% 113 7.68% 279 18.97% 999 67.91% 56 3.81% Fountain Valley 640 12 1.88% 90 14.06% 159 24.84% 353 55.16% 26 4.06% Fullerton 1,741 59 3.39% 230 13.21% 516 29.64% 875 50.26% 61 3.50% Garden Grove 1,944 153 7.87% 482 24.79% 572 29.42% 653 33.59% 84 4.32% Huntington Beach 2,359 34 1.44% 220 9.33% 437 18.52% 1,612 68.33% 56 2.37% La Habra 948 54 5.70% 171 18.04% 265 27.95% 417 43.99% 41 4.32% Lake Forest 2,091 34 1.63% 206 9.85% 408 19.51% 1,383 66.14% 60 2.87% Mission Viejo 2,387 42 1.76% 196 8.21% 490 20.53% 1,614 67.62% 45 1.89% Newport Beach 2,011 10 0.50% 42 2.09% 140 6.96% 1,684 83.74% 135 6.71% Orange 2,355 37 1.57% 212 9.00% 505 21.44% 1,518 64.46% 83 3.52% Rancho Santa Margarita 1,641 31 1.89% 154 9.38% 334 20.35% 1,085 66.12% 37 2.25% San Clemente 1,301 14 1.08% 59 4.53% 150 11.53% 1,052 80.86% 26 2.00% Santa Ana 2,162 172 7.96% 576 26.64% 648 29.97% 683 31.59% 83 3.84% Tustin 1,281 46 3.59% 149 11.63% 264 20.61% 792 61.83% 30 2.34% Orange County Total 33,742 978 2.90% 3,789 11.23% 7,128 21.13% 20,661 61.23% 1,186 3.51% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. Income Categories: Low (<50% AMI), Moderate (50-79% AMI), Middle (80-119% AMI) & Upper (>120% AMI) AMI =Area Median Income MORTGAGE LENDING PRACTICES 77 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Loan denial rates by income category of applicants were also reviewed. (Please see Table 4-11.) Lower income applicants had significantly higher denial rates, most likely due to lending institutions' strict underwriting standards, which have toughened since the financial/housing bubble problems of the mid 2000's. As noted earlier, on average, the purchase loan denial rate in Orange County was 15 percent in 2013. In Orange County, the overall denial rates by income level in 2013 were: ■ Low Income: 37 percent ■ Moderate Income: 20 percent ■ Middle Income: 15 percent ■ Upper Income: 12 percent MORTGAGE LENDING PRACTICES 78 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS iNEWMEWMEMM ��� M Table 411: Denied Home Purchase Loans by Applicant Income 2013 ��� ��� ��� M MEW= �Efflmsfflmffl ��� M M" M Anaheim 3,655 591 16.17% 199 74 37.19% 696 141 20.26% 1,068 162 15.17% 1,539 190 12.35% 153 24 15.69% Buena Park 796 143 17.96% 37 15 40.54% 136 24 17.65% 266 37 13.91% 318 63 19.81% 39 4 10.26% Costa Mesa 1,471 229 15.57% 24 10 41.67% 113 23 20.35% 279 56 20.07% 999 135 13.51% 56 5 8.93% Fountain Valley 640 112 17.50% 12 5 41.67% 90 20 22.22% 159 36 22.64% 353 47 13.31% 26 4 15.38% Fullerton 1,741 220 12.64% 59 23 38.98% 230 38 16.52% 516 58 11.24% 875 93 10.63% 61 8 13.11% Garden Grove 1,944 396 20.37% 153 62 40.52% 482 103 21.37% 572 111 19.41% 653 101 15.47% 84 19 22.62% Huntington Beach 2,359 318 13.48% 34 19 55.88% 220 37 16.82% 437 70 16.02% 1,612 186 11.54% 56 6 10.71% La Habra 948 141 14.87% 54 14 25.93% 171 36 21.05% 265 40 15.09% 417 45 10.79% 41 6 14.63% Lake Forest 2,091 295 14.11% 34 10 29.41% 206 47 22.82% 408 65 15.93% 1,383 152 10.99% 60 21 35.00% Mission Viejo 2,387 296 12.40% 42 12 28.57% 196 26 13.27% 490 61 12.45% 1,614 186 11.52% 45 11 24.44% Newport Beach 2,011 295 14.67% 10 3 30.00% 42 10 23.81% 140 38 27.14% 1,684 221 13.12% 135 23 17.04% Orange 2,355 330 14.01% 37 8 21.62% 212 40 18.87% 505 72 14.26% 1,518 194 12.78% 83 16 19.28% Rancho Santa Margarita 1,641 185 11.27% 31 9 29.03% 154 17 11.04% 334 35 10.48% 1,085 118 10.88% 37 6 16.22% San Clemente 1,301 159 12.22% 14 3 21.43% 59 16 27.12% 150 16 10.67% 1,052 121 11.50% 26 3 11.54% Santa Ana 2,162 441 20.40% 172 70 40.70% 576 138 23.96% 648 117 18.06% 683 100 14.64% 83 16 19.28% Tustin 1,281 205 16.00% 46 20 43.48% 149 41 27.52% 264 39 14.77% 792 99 12.50% 30 6 20.00% Orange County Total 33,742 4,900 14.52% 978 361 36.91% 3,789 764 20.16% 7,128 1,092 15.32% 20,661 2,473 11.97% 1,186 210 17.71% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications. 2 - Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn orfiles closed for incompleteness. Income Categories: Low (<50% AMI), Moderate (50-79% AMI), Middle (80-119% AMI) & Upper (>120% AMI) AMI =Area Median Income MORTGAGE LENDING PRACTICES 79 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS D. lending Patterns by Census Tract Characteristics Ing-Ome Level by Census Tract Loan denial rates based on residents income was reviewed by Census Tract in the Orange County 16 City study area. The purpose of this analysis was to identify differences in loan activities by geographic area. Table 4-12 lists loans by city per income level of Census Tract. The vast majority of census tracts in Orange County are considered middle or upper income. Over half of the 16 cities in the study area did not have any loans completed in low-income Census Tracts, most likely due to the fact that low-income Census Tracts were almost non-existent in these cities. The denial rates by income level per Census Tract in 2013 were: ■ Low Income: 22 percent ■ Moderate Income: 19 percent ■ Middle Income: 15 percent ■ Upper Income: 13 percent MORTGAGE LENDING PRACTICES 80 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 81 Table 412: Home Purchase Loans - Denied by Income - Per Census Tract - 2013 Anaheim 3,655 591 16.17% 331 62 18.73% 1,415 258 18.23% 1,031 176 17.07% 873 95 10.88% 5 0.00% Buena Park 796 143 17.96% 29 13 44.83% 228 34 14.91% 539 96 17.81% 0 - - - - Costa Mesa 1,471 229 15.57% 18 1 5.56% 466 86 18.45% 795 117 14.72% 192 25 13.02% Fountain Valley 640 112 17.50% 0 - - 217 28 12.90% 253 50 19.76% 170 34 20.00% Fullerton 1,741 220 12.64% 43 12 27.91% 395 43 10.89% 1,027 141 13.73% 276 24 8.70% Garden Grove 1,944 396 20.37% 63 17 26.98% 1,041 220 21.13% 743 145 19.52% 97 14 14.43% Huntington Beach 2,359 318 13.48% 0 - - 268 35 13.06% 810 119 14.69% 1,281 164 12.80% La Habra 948 141 14.87% 0 271 50 18.45% 551 82 14.88% 126 9 7.14% Lake Forest 2,091 295 14.11% 0 74 23 31.08% 574 90 15.68% 1,255 165 13.15% 188 17 9.04% Mission Viejo 2,387 296 12.40% 0 72 10 13.89% 667 100 14.99% 1,648 186 11.29% - - - Newport Beach 2,011 295 14.67% 0 236 48 20.34% 155 22 14.19% 1,620 225 13.89% Orange 2,355 330 14.01% 0 300 54 18.00% 626 84 13.42% 1,429 192 13.44% Rancho Santa Margarita 1,641 185 11.27% 0 - - - 385 44 11.43% 1,256 141 11.23% San Clemente 1,301 159 12.22% 0 85 9 10.59% 414 58 14.01% 802 92 11.47% Santa Ana 2,162 441 20.40% 178 40 22.47% 1,257 273 21.72% 671 122 18.18% 56 6 10.71% Tustin 1,281 205 16.00% 18 8 44.44% 215 48 22.33% 411 62 15.09% 637 87 13.66% Orange County Total 33,742 4,900 14.52% 696 151 21.70% 6,047 1,134 18.75% 10,574 1,567 14.82% 16,226 2,029 12.50% 199 19 9.55% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications. 2- Denial rate based on applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. MORTGAGE LENDING PRACTICES 81 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS E. Lending Performance by Lender General Overview Table 4-13 shows the top 10 lenders by city and Orange County in 2013. Wells Fargo is the top lender in all of the cities in the 16 cities and the County. The next two larger banks are Bank of America and JP Morgan Chase Bank. Table 4-13 also shows denial rates by mortgage lending institution by city and County. Most cities have the same lenders, with few exceptions at the lower end of the top 10 lenders. Notable is the fact that Wells Fargo has a denial rate of 19 percent countywide. Though, by city, the denial rate ranges from a low of 14 percent in Lake Forest and Newport Beach, to a high of 30 percent in Santa Ana. A few lenders had very low denial rates in some cities, such as Flagstar Bank, Quicken Loans and Chicago Mortgage Solutions, LLC. MORTGAGE LENDING PRACTICES 82 Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Total Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana County Total 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 4-13: Top 10 Lenders - All Home Loan Applications, 2013 14,749 2,990 20.27% Wells 1,497 346 23.11% BofA 1,002 221 22.06% JPM 863 225 26.07% Flag. 625 63 10.08% Cash 3,730 795 21.31% Wells 382 98 25.65% JPM 275 62 22.55% BofA 228 48 21.05% Flag. 149 14 9.40% Citi 5,978 1,176 19.67% Wells 642 134 20.87% BofA 337 80 23.74% Flag. 327 44 13.46% IPM 326 79 24.23% Citi 3,209 639 19.91% Wells 316 66 20.89% BofA 216 48 22.22% Flag. 193 21 10.88% School. 146 14 9.59% JPM 7,582 1,412 18.62% Wells 807 170 21.07% BofA 522 94 18.01% JPM 442 103 23.30% Flag. 351 40 11.40% Scho 8,373 1,886 22.52% Wells 709 201 28.35% BofA 592 117 19.76% JPM 464 112 24.14% Flag. 447 67 14.99% PMA 10,816 1,883 17.41% Wells 1,370 264 19.27% BofA 710 123 17.32% JPM 657 164 24.96% Flag. 596 53 8.89% Cash 3,612 684 18.94% Wells 428 93 21.73% BofA. 234 51 21.79% JPM 232 53 22.84% Flag. 143 12 8.39% Cash 6,343 1,102 17.37% Wells 875 121 13.83% BofA 362 59 16.30% Flag. 314 37 11.78% JPM 256 60 23.44% Nati( 10,009 1,665 16.64% Wells 1,129 205 18.16% BofA 664 120 18.07% Flag. 524 52 9.92% JPM 465 128 27.53% Cash 8,383 1,568 18.70% Wells 1,383 197 14.24% BofA 782 160 20.46% JPM 527 135 25.62% Union 489 116 23.72% Citi 10,636 1,858 17.47% Wells 1,211 235 19.41% BofA 712 130 18.26% JPM 589 136 23.09% Flag. 542 49 9.04% Cash 6,460 1,021 15.80% Wells 720 128 17.78% BofA 356 62 17.42% Flag. 347 38 10.95% JPM 275 63 22.91% Quic 5,477 968 17.67% Wells 844 131 15.52% BofA 347 53 15.27% Flag. 246 30 12.20% JPM 229 68 29.69% Cash 9,194 2,209 24.03% Wells 955 290 30.37% BofA 811 179 22.07% JPM 551 172 31.22% School. 427 97 22.72% Flag. 5,804 1,086 18.71% Wells 637 122 19.15% BofA 404 88 21.78% JPM 298 91 30.54% Flag. 293 33 11.26% Cash 138,845 25,917 18.67% Wells 16,700 3,186 19.08% BofA 9,553 1,795 18.79% JPM 7,465 1,895 25.39% Flag. 6,806 772 11.34% Cash lick. ag. pick. Ish lick. ti 526 100 19.01% Citi 442 105 23.76% Quick. 394 57 14.47% Nation. 331 121 36.56% Chicago 273 125 35 28.00% Cash 117 39 33.33% Nation. 94 37 39.36% Green. 94 41 43.62% Stearns 83 182 50 27.47% School 165 20 12.12% Chicago 151 * * Quick. 148 23 15.54% Univ. 133 116 35 30.17% Citi 108 29 26.9% JMAC 102 * * Quick. 89 13 14.61% PMAC 87 42 48.28% 254 80 31.50% Citi 248 64 25.81% Quick. 183 19 10.38% Nation. 177 69 38.98% Chicago 157 318 28 8.81% School 309 51 16.50% Citi 303 76 25.08% Cash 261 82 31.42% Quick. 211 41 19.43% 356 76 21.35% School 351 41 11.68% Quick. 312 52 16.67% Chicago 242 * * Stearns 233 110 21 19.09% Quick. 89 9 10.11% School 85 11 12.94% Nation. 85 36 42.35% Broker 67 9 13.43% 209 67 32.06% Quick. 190 27 14.21% Citi 169 31 18.34% School 160 37 23.13% Stearns 151 342 46 13.45% Citi 299 79 26.42% School 282 45 15.96% Chicago 281 22 7.83% Nation 238 93 39.08% 292 42 14.38% Quick. 229 37 16.16% US 205 64 31.22% Cash 176 57 32.39% Chicago 153 361 74 20.50% School 335 42 12.54% Citi 325 78 24.00% Chicago 255 * * Stearns 229 212 48 22.64% Chicago 189 * * Stearns 159 * * Citi 157 39 24.84% School. 149 19 12.75% 172 24 13.95% Citi 164 38 23.17% Chicago 152 14 9.21% US 148 43 29.05% Union 122 26 21.31% 312 79 25.32% Nation. 214 86 40.19% Quick. 214 44 20.56% Cash 214 72 33.64% PMAC 175 73 41.71% 194 23 11.86% Citi 189 36 19.05% Quick. 185 27 14.59% Chicago 138 * * Stearns 113 4,206 1,032 24.54% Quick. 4,061 653 16.08% School 4,041 671 16.60% Chicago 3,112 * * Nation 2,847 1,051 36.92% Loans by these financial institutions were out of the top 15 fi na nci a I institutions denying loans. FinanciaI Institutions: Wells =Wells Fargo Bank Citi =Citibank Univ. =Universal American Mortgageof CA BofA =Bank of America Quick. =Quicken Loans, Inc. JMAC =JMAC Lending, Inc. JPM =JPMorgan Chase Bank Nation = Nationstar Mortgage, LLC PMAC = PMAC Lending, Inc. Flag. =Flagstar Bk FSB Chicago = Chicago Mortgage Solutions LLC Broker = Broker Solutions, Inc. Cash =Cashcall, Inc. Green = Greenlight Financial Services Union =Union Bank School. =Schoolfi rst FCU Stearns = Stea rns Lendi ng, l nc. Us =US Bank Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 Denial rate based on applications that went through the complete underwriting process, and exclude applications withrawan or files closed for incompleteness. MORTGAGE LENDING PRACTICES 83 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Disposition by Loan Applicants Income Additional research was completed on mortgage lending institutions by income and minority applicants. Table 4-14 lists the top 10 lenders by city and County with the market share of each financial institution and percent of loans going to applicants with low and moderate incomes and percent minority. Some key findings include: ■ Wells Fargo has a 12 percent share of the home loan market. In some cities like Newport Beach, Wells Fargo has a large share of the market at almost 17 percent. While in another city, Wells Fargo has around eight percent of the market (Garden Grove). ■ Minority applicants typically have a third of the market share of loans. However, in some cities, minority applicants make up a much bigger share of the market for some lenders. PMAC Lending, Inc., which is favored by Asian applicants, makes 99 percent of their loans to minorities in Fountain Valley, 95 percent to minorities in Garden Grove and 94 percent to minorities in Santa Ana. MORTGAGE LENDING PRACTICES 84 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Loans bythese financial institutions were out ofthe top 15 financial institutions denying loans. Financial Institutions: Table 4-14: Top 30 Lenders - Market Share and Income and Minority Categories - All Home Loan Applications, 2013 Chicago = Chicago Mortgage Solutions LLC Broker = Broker Solutions, Inc. Cash=Cashcall, Inc. Green = Greenlight Financial Services Union =Union Bank School.=Schoolfirst FCU Stearns = Stearns Lending, Inc. US =US Bank Minority Category includes Asian, Black and Hispanic. Low =%of AMI and Mod =%of AMI Source: www.lendi ngpatterns.com, October 2015 Anaheim Wells 10.15% 27% 44% BofA 6.79% 41% 50% JPM 5.85% 39% 42% Flag. 4.24% 26% 48% Cash 3.72% Buena Park Wells 30.24% 28% 57% JPM 7.37% 41% 48% BofA 6.11% 44% 51% Flag. 3.99% 25% 59% Citi 3.59% 40% 46% Costa Mesa Wells 30.74% 12% 18% BofA 5.64% 19% 27% Flag. 5.47% 11% 27% JPM 5.45% 25% 18% Citi 3.31% 27% 20% Fountain Valley Wells 9.85% 21% 55% BofA 6.73% 40% 52% Flag. 6.01% 17% 52% School. 4.55% 24% 23% JPM 4.39% 28% 47% Fullerton Wells 10.64% 23% 48% BofA 6.88% 34% 48% JPM 5.83% 37% 42% Flag. 4.63% 15% 50% School. 3.75% 26% 34% Garden Grove Wells 8.47% 35% 59% BofA 7.07% 48% 62% JPM 5.54% 41% 51% Flag. 5.34% 35% 64% PMAC 3.97% 51% 95% Huntington Beach Wells 12.67% 12% 19% BofA 6.56% 21% 23% JPM 6.07% 24% 19% Flag. 5.51% 16% 25% Cash 3.76% 16% 16% La Habra Wells 11.85% 22% 50% BofA 6.48% 31% 52% JPM 6.42% 33% 41% Flag. 3.96% 16% 48% Cash 3.46% 23% 23% Lake Forest Wells 13.79% 12% 38% BofA 5.71% 25% 30% Flag. 4.95% 13% 40% JPM 4.04% 23% 25% Nation 3.72% 12% 39% Mission Viejo Wells 11.28% 12% 18% BofA 6.63% 22% 18% Flag. 5.24% 11% 22% JPM 4.65% 21% 15% Cash 3.43% 14% 15% Newport Beach Wells 16.50% 3% 14% BofA 933% 7% 12% JPM 6.29% 8% 10% Union 5.83% 2% 3% Citi 3.57% 13% 14% Orange Wells 11.39% 13% 27% BofA 6.69% 21% 29% JPM 5.54% 20% 30% Flag. 5.10% 10% 39% Cash 3.97% 14% 23% Rancho Santa Margarita Wells 11.15% 12% 16% BofA 5.51% 17% 16% Flag. 5.37% 11% 21% JPM 4.26% 18% 15% Quick. 3.64% 12% 14% San Clemente Wells 15.41% 9% 6% BofA 6.34% 15% 9% Flag. 4.49% 7% 11% JPM 4.18% 16% 9% Cash 3.34% 14% 14% Santa Ana Wells 10.39% 37% 63% BofA 8.82% 51% 70% JPM 5.99% 48% 57% School. 4.64% 41% 60% Flag. 3.74% 34% 62% Tustin Wells 10.98% 15% 30% BofA 6.96% 21% 36% JPM 5.13% 22% 28% Flag. 5.05% 12% 42% Cash 3.69% 18% 16% Orange County Total Wells 12.03% 15% 30% BofA 6.88% 26% 33% JPM 5.38% 26% 31% Flag. 4.90% 16% 39% Cash 3.30% 18% 20% MM Anaheim School. 3.57% 31% 43% Citi 3.00% 40% 44% Quick. 2.67% 23% 30% Nation. 2.24% 29% 37% Chicago 1.85% 24% 42% Buena Park School. 3.35% 39% 40% Cash 3.14% 30% 36% Nation. 2.52% 37% 49% Green. 2.52% 33% 39% Stearns 2.23% 39% 49% Costa Mesa Cash 3.04% 15% 15% School 2.76% 27% 12% Chicago 2.53% 11% 21% Quick. 2.48% 16% 13% Univ. 2.22% 15% 44% Fountain Valley Cash 3.61% 21% 40% Citi 3.37% 36% 34% JMAC 3.18% 21% 85% Quick. 2.77% 18% 30% PMAC 2.71% 38% 99% Fullerton Cash 3.35% 27% 30% Citi 3.27% 40% 44% Quick. 2.41% 15% 30% Nation. 2.33% 27% 34% Chicago 2.07% 17% 36% Garden Grove JMAC 3.80% 39% 92% School 3.69% 40% 42% Citi 3.62% 50% 56% Cash 3.12% 30% 29% Quick. 2.52% 27% 37% Huntington Beach Citi 3.29% 32% 15% School 3.25% 19% 11% Quick. 2.88% 11% 17% Chicago 2.24% 14% 17% Stearns 2.15% 21% 21% La Habra Citi 3.05% 39% 49% Quick. 2.46% 19% 31% School 2.35% 22% 31% Nation. 2.35% 24% 33% Broker 1.85% 25% 37% Lake Forest Cash 3.29% 15% 16% Quick. 3.00% 17% 21% Citi 2.66% 31% 28% School 2.52% 21% 24% Stearns 2.38% 17% 31% Mission Viejo Quick. 3.42% 15% 16% Citi 2.99% 24% 17% School 2.82% 21% 17% Chicago 2.81% 12% 14% Nation 2.38% 15% 21% Newport Beach Flag. 3.48% 9% 27% Quick. 2.73% 5% 10% US 2.45% 5% 8% Cash 2.10% 11% 15% Chicago 1.83% 8% 19% Orange Quick. 3.39% 11% 21% School 3.15% 16% 22% Citi 3.06% 25% 31% Chicago 2.40% 11% 31% Stearns 2.15% 13% 23% Rancho Santa Margarita Cash 3.28% 10% 14% Chicago 2.93% 12% 16% Stearns 2.46% 16% 13% Citi 2.43% 15% 17% School. 2.31% 15% 15% San Clemente Quick. 3.14% 10% 9% Citi 2.99% 16% 7% Chicago 2.78% 13% 9% US 2.70% 8% 6% Union 2.23% 4% 2% Santa Ana Citi 3.39% 51% 57% Nation. 2.33% 50% 51% Quick. 2.33% 38% 41% Cash 2.33% 30% 37% PMAC 1.90% 49% 94% Tustin School. 3.34% 24% 25% Citi 3.26% 25% 30% Quick. 3.19% 10% 20% Chicago 2.38% 17% 28% Stearns 1.95% 20% 25% Orange County Total Citi 3.03% 31% 31% lQuick. 2.92% 15% 21% 1 School 2.91% 25% 26% 1 Chicago 2.24% 15% 29% iNation 2.05% 22% 30% Loans bythese financial institutions were out ofthe top 15 financial institutions denying loans. Financial Institutions: Wells =Wells Fargo Bank Citi =Citibank Univ. =Universal American Mortgage of CA BofA =Bank of America Quick. = Quicken Loans, Inc. JMAC = JMAC Lending, Inc. JPM=JPMorgan Chase Bank Nation = Nationstar Mortgage, LLC PMAC = PMAC Lending, Inc. Flag.=Flagstar Bk FSB Chicago = Chicago Mortgage Solutions LLC Broker = Broker Solutions, Inc. Cash=Cashcall, Inc. Green = Greenlight Financial Services Union =Union Bank School.=Schoolfirst FCU Stearns = Stearns Lending, Inc. US =US Bank Minority Category includes Asian, Black and Hispanic. Low =%of AMI and Mod =%of AMI Source: www.lendi ngpatterns.com, October 2015 Tabulations: GRCAssociates, Inc., October2015 Denial rate based on applications that went through the complete underwriting process, and exclude applications withrawan or files closed for incompleteness. MORTGAGE LENDING PRACTICES 85 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS F. Sub -Prime Lending Market The subprime lending market in 2011 and 2013 was analyzed. In most cases, the best or prime loans are offered to applicants with good credit history, employment and income. Applicants who do not possess acceptable credit may be offered subprime loans. However, HMDA data does not identify specifically whether a loan is prime or subprime. The best that HMDA provides is whether a loan has a "Rate Spread". Table 4-15 lists the Rate Spread loans for 2011 and 2013. An HMDA Rate Spread occurs when a loan's interest rate exceeds a FFIEC defined "threshold". HMDA provides the following definition about Rate Spread: "For a home purchase loan, a refinancing, or a dwelling - secured home improvement loan that you originated, report the spread (difference) between the annual percentage rate (APR) and the applicable average prime offer rate if the spread is equal to or greater than 1.5 percentage points for first -lien loans or 3.5 percentage points for subordinate -lien loans." Table 4-15: Home Purchase Loans - Rate Spread, 2011 to 2013 Anaheim 2.58% 5.28 5.52% 3.41 2.94% (1.87) Buena Park 0.95% 3.60 4.18% 2.07 3.23% (1.53) Costa Mesa 1.31% 5.18 2.64% 3.26 1.33% (1.92) Fountain Valley 0.91% 5.49 1.48% 2.46 0.57% (3.03) Fullerton 2.04% 3.64 2.83% 3.90 0.79% 0.26 Garden Grove 1.64% 6.08 3.83% 3.22 2.19% (2.86) Huntington Beach 2.32% 5.25 3.11% 3.47 0.79% (1.78) La Habra 4.74% 6.66 6.33% 4.24 1.59% (2.42) Lake Forest 2.73% 3.29 3.02% 2.49 0.29% (0.80) Mission Viejo 1.41% 3.03 2.87% 2.04 1.46% (0.99) Newport Beach 1.65% 3.57 1.36% 2.83 -0.29% (0.74) Orange 1.47% 3.77 2.81% 2.94 1.34% (0.83) Rancho Santa Margarita 0.81% 1.80 3.11% 1.97 2.30% 0.17 San Clemente 1.26% 3.34 1.53% 1.95 0.27% (1.39) Santa Ana 2.85% 4.19 5.98% 2.88 3.13% (1.31) Tustin 1.53% 4.79 2.11% 2.52 0.58% (2.27) Orange County Total 1.79% 4.27 3.08% 2.77 1.29% (1.50) Source: www.lendingpatterns.com, November 2015 Tabulations: GRC Associates, Inc., November 2015 1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2 - Includes applications thatwent through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. 3- A HMDA Rate Spread occurs when a loan's interest rate exceeds a FFIEC defined "threshold". HMDA definition of "Rate Spread": For a home purchase loan, a refinancing, or a dwelling - secured home improvement loan thatyou originated, report the spread (difference) between the annual percentage rate (APR) and the applicable average prime offer rate if the spread is equal to or greater than 1.5 percentage points for first -lien loans or 3.5 percentage points for subordinate -lien loans. MORTGAGE LENDING PRACTICES 86 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS In 2011, less than two percent of loans had Rate Spreads (or had rates high enough that may be considered subprime). The average increase above a prime interest rate was 4.27. By 2013 the number of loans with high rates had increased to about three percent; however, the spread had decreased to 2.77. Thus, it appears lenders are getting more aggressive by providing loans to high- risk applicants and, at the same time, lowering the rates on these types of loans. This type of lending has the effect of both extending fair housing choice to a broader group of people, who would not qualify for regular mortgage lending programs. However, if there are too many of these types of loans, there may be an increase in foreclosures - a situation that occurred during the recent recession. The Rate Spread loans of top lenders for 2011 and 2013 were tabulated. Listed in Table 4-16 are the market share figures of the top lenders with the percentage of loans they make having a Rate Spread. For the most part, the top lenders have had very few of these type of loans. However, there is one lender that appears to make a significant amount of Rate Spread loans - 21s' Mortgage which has 16 percent of their loans being Rate Spread loans and with an average spread of 8.53 in 2013. Source: www.1endingpatterns.com, November 2015 Tabulations: GRC Associates, Inc., November 2015 1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2 - Includes applications that wentthrough the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. 3- A HMDA Rate Spread occurs when a loan's interest rate exceeds a FFIEC defined "threshold". HMDAdefinition of"Rate Spread": For a home purchase loan, a refinancing, or a dwelling -secured home improvement loan that you originated, reportthe spread (difference) between the annual percentage rate (APR) and the applicable average prime offer rate if the spread is equal to or greater than 1.5 percentage points for first -lien loans or 3.5 percentage points for subordinate -lien loans. MORTGAGE LENDING PRACTICES 87 Table 4-16: Home Purchase Loans - Rate Spread - Top Orange County Lenders, 2011 & 2013 NoW M, mm -M.'11111111 1 Wells Fargo 15.9% 0.40% 1.97 1 Wells Fargo 13.5% 0.20% 1.59 2 Bank of America 11.0% 0.10% 1.52 2 Flagstar 5.1% 0.60% 1.75 3 Flagstar Bank 4.6% 0.50% 1.68 3 Bank of America 4.0% 0.10% 1.57 4 JP Morgan 2.3% 0.20% 1.96 4 JP Morgan 3.7% 0.30% 1.55 5 Metlife Bank 2.2% 0.00% - 5 Stearns 2.3% 1.40% 1.70 6 PMC Corp 2.0% 0.00% - 6 21st Mortgage 1.9% 15.70% 8.53 7 Pacific Union 1.9% 2.50% 1.77 7 imortgage.com 1.9% 3.00% 1.95 8 Paramount Financial 1.8% 0.20% 1.51 8 Primelending 1.8% 1.50% 1.86 9 Primelending 1.6% 0.50% 1.56 9 Union Bank 1.7% 0.00% - 10 Stearns Lending 1.5% 0.00% - 10 Broker Solutions, Inc. 1.7% 5.30% 1.71 11 21st Mortgage 1.5% 27.20% 7.79 11 PMAC Lending 1.6% 0.50% 1.91 12 Pinnacle Capital 1.4% 0.30% 4.03 12 East W. Bank 1.6% 0.20% 1.51 13 Kiencta FCU 1.3% 0.00% - 13 Sierra Pacific 1.5% 0.20% 1.62 14 imorrgage.com 1.3% 0.80% 1.81 14 Paramount Residential 1.4% 5.80% 1.71 15 JMAC Lending 1.3% 0.00% - 15 Pacific Union 1.4% 5.20% 1.78 Orange County Total 100.0% 1.79% 4.27 Orange County Total 100.0% 3.08% 2.77 Source: www.1endingpatterns.com, November 2015 Tabulations: GRC Associates, Inc., November 2015 1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2 - Includes applications that wentthrough the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. 3- A HMDA Rate Spread occurs when a loan's interest rate exceeds a FFIEC defined "threshold". HMDAdefinition of"Rate Spread": For a home purchase loan, a refinancing, or a dwelling -secured home improvement loan that you originated, reportthe spread (difference) between the annual percentage rate (APR) and the applicable average prime offer rate if the spread is equal to or greater than 1.5 percentage points for first -lien loans or 3.5 percentage points for subordinate -lien loans. MORTGAGE LENDING PRACTICES 87 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS G. Predatory Lending The potential of predatory lending occurrences in the Orange County 16 City study area was also reviewed. Predatory lending occurs when applicants are targeted with abusive practices, such as higher fees, hidden costs and other related practices. The HMDA database identifies HOEPA or "high cost" loans. As defined by HMDA "HOEPA" loans include: "HOEPA Status. Report whether each loan you originated or purchased is covered by the Home Ownership and Equity Protection Act of 1994 (HOEPA), as implemented in Regulation Z (12 C.F.R. § 1026.32). Coverage under HOEPA, which requires special disclosures and regulates the terms of covered loans, is determined by comparing a loan's APR and its points and fees to triggers specified in the regulation. See 12 C.F.R. § 1026.32(a) and (b)." Table 4-17 lists the HOEPA loans in the study area and Orange County. Based on the HMDA database, there are very few in any of these types of loans. Table 4-17: All Types of Loans - High Cost Loans (HOEPA), 2011 to 2013 Change 2011 to 2013 • •Inc./Dec. Anaheim 1 1 Buena Park - - Costa Mesa Fountain Valley - - Fullerton 1 1 Garden Grove - - - Huntington Beach 1 (1) La Habra - - Lake Forest Mission Viejo Newport Beach Orange 1 (1) Rancho Santa Margarita - - San Clemente - Santa Ana - Tusti n - - Orange County Total 2 2 Source: www.lendingpatterns.com, November 2015 Tabulations: GRC Associates, Inc., November 2015 1 -Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2 -Includes applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. 3- HMDAdefinition of HOEPA Loans: HO EPA Status: Report whether each loan you originated or purchased is covered by the Home Ownership and Equity Protection Act of 1994 (HO EPA), as implemented in Regulation Z (12 C.F.R. § 1026.32). For further guidance, see Appendix A (I.G.3). Coverage under HOEPA, which requires special disclosures and regulates the terms of covered loans, is determined by comparing a loan's APR and its points and fees to triggers specified in the regulation. See 12 C.F.R. § 1026.32(a) and (b). MORTGAGE LENDING PRACTICES 88 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS H. Foreclosures Foreclosure data has been gathered for each of the 16 cities in the study area and countywide. The foreclosure process begins when owner(s) stop making mortgage payments and it can be stopped when the owner(s) makes all payments and becomes current with the lender. If owner(s) and lender do not agree on how to resolve the situation of missed mortgage payments, then the lender has the right to use the foreclosure process in court to take over the home and get its loan funds back. Table 4-18 shows the number of homes that are in various states of foreclosure in the 16 cities of the study area. As can be noted, there are few homes in foreclosure — less than one percent. Table 4-18: Foreclosures, September 2015 Foreclosure Distr• % of Total nomm Stock Housing Anaheim 230 246 90 566 0.5% Buena Park 69 14 69 152 0.6% Costa Mesa 49 49 28 127 0.3% Fountain Valley 8 25 21 55 0.3% Fullerton 135 39 48 222 0.5% Garden Grove 105 70 47 222 0.5% Huntington Beach 206 147 44 396 0.5% La Habra 55 71 39 165 0.8% Lake Forest 100 62 50 212 0.8% Mission Viejo 100 67 67 234 0.7% Newport Beach 68 54 14 135 0.3% Orange 125 105 20 249 0.6% Rancho Santa Margarita 81 107 - 188 1.1% San Clemente 47 20 40 107 0.4% Santa Ana 243 196 93 532 0.7% Tusti n 33 72 26 131 0.5% Orange County Total 2,922 2,654 1,299 6,875 0.6% Sources: RealtyTrack and Department of Finance, November 2015 Tabulations: GRC Associates, Inc., November 2015 MORTGAGE LENDING PRACTICES 89 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Foreclosure and market sales prices in the 16 cities and countywide for the years 2014 and 2015 were gathered and are listed in Table 4-19. The housing market has been increasing at very good rates, while the foreclosure market has stabilized. Home prices have increased about five percent in Orange County within the past year. The following cities have had increases of more than double the five percent Orange County figure at 10 percent or more: Fountain Valley (15 percent), La Habra (11 percent), Lake Forest (11 percent), San Clemente (14 percent) and Santa Ana (10 percent). Table 4-19: Foreclosure and Market Sales Prices, September 2014 & 2015 Anaheim Buena Park Costa Mesa Fountain Valley Ful I erton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Justin Orange County Total $ 443,000 $ 446,500 429,000 439,500 578,250 585,500 504,000 555,000 476,000 479,500 429,000 432,500 559,500 587,750 475,000 475,000 227,014 320,000 583,000 588,000 1,392,500 1,712,500 545,000 545,000 574,980 580,000 755,050 810,000 368,000 373,500 282,000 425,500 $ 520,000 $ 520,000 $ 468,500 $ 485,000 463,500 462,500 667,500 700,000 600,000 687,500 473,500 507,000 451,000 475,000 655,000 719,000 425,000 470,000 587,000 650,000 587,000 605,000 1,550,000 1,475,000 541,000 566,000 478,250 455,000 752,500 860,000 405,000 445,000 531,250 572,500 $ 584,000 $ 615,000 250 53 93 53 124 111 231 64 98 125 102 130 64 73 167 74 3,193 3.5% -0.2% 4.9% 14.6% 7.1% 5.3% 9.8% 10.6% 10.7% 3.1% -4.8% 4.6% -4.9% 14.3% 9.9% 7.8% 5.3% * All recorded home sales include sales of all single family residences and condominiums Sources: RealtyTrack and Core Logic, November 2015 Tabulations: GRC Associates, Inc., November 2015 MORTGAGE LENDING PRACTICES 90 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 5. Public Policies and Practices Public policies may affect the pattern of housing development, availability of housing choices, as well as access to housing. This section of the Al reviews the various public policies that may impact fair housing choice in Orange County, including: ■ General Plan Policies Affecting Housing Development ■ Zoning Ordinance ■ Building Codes and Occupancy Standards ■ Affordable Housing Development ■ Other Land Use Policies, Programs and Controls ■ Zoning Regulations and Practices for Persons with Disabilities ■ Local Housing Authorities ■ Community Representation and Participation A. General Plan Policies Affecting Housing Development General Plan Housing Element The Housing Element is one of seven state -mandated Elements of the General Plan. California housing element law, originally enacted in 1969, requires that local governments adequately plan to meet the existing and projected housing needs of all economic segments of their community. The most recent housing element for jurisdictions in the Southern California Association of Governments (SCAG) region, of which Orange County is a part, covers the 2014-2021 planning period. Among the 16 cities participating in this Al, 14 have an adopted 2014-2021 Housing Element that has been found in compliance with state housing element statutes by the State Department of Housing and Community Development (HCD). Important criteria for State HCD approval of any housing element include a determination that the local jurisdiction's policies do not unduly constrain the maintenance, improvement, and development of a variety of housing choices for all income levels. The following summarizes the status of the housing element in the two participating jurisdictions whose elements have not been found in compliance by HCD. ■ The City of Fullerton adopted it 2014-2021 Housing Element on May 5, 2015. HCDs review letter indicated that while the Element met most statutory requirements, the Element could not be found in full compliance until the City completed Policy Action 1.1 to establish minimum densities and identify site capacity for 41 lower income units. Compliance was also PUBLIC POLICIES AND PRACTICES 91 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS contingent upon Policy Action 4.4 to amend the Zoning Code to eliminate constraints to the provision of emergency shelters. In early 2016, the City was informed by HCD that they had met the statutory requirements and the Element was found in compliance. ■ The City of San Clemente adopted a Housing Element for the prior, 2008-2014 Housing Element cycle on July 5, 2011 which was found in compliance by HCD. The City is in the process of updating its Housing Element for the 2014-2021 planning period consistent with the City's new General Plan, and submitted a draft for HCD review in February 2016. Element adoption is targeted for spring of 2016. California "no net loss" zoning law requires a local government to make a finding that a density reduction, rezoning, or downzoning is consistent with its Housing Element prior to requiring or permitting a reduction of density of a parcel below the density used in determining Housing Element compliance. The legislation also allows courts to award attorneys' fees and costs if the court determines that the density reduction or downzoning was made illegally. General Plan Land Use Element The General Plan Land Use Element serves as the foundation for all land use controls within a jurisdiction, and identifies the location, distribution and density/intensity of permitted land uses. As it applies to residential land uses, the Land Use Element establishes a range of residential, and oftentimes mixed use, land use categories; defines densities for each category (typically expressed in dwelling units per acre [du/ac]); and describes the housing types which typify each land use category. Numerous factors, both market and governmental, affect the supply and cost of housing in a community. The governmental factor that most directly influences these market conditions is the allowable density range of residentially designated land. In general, higher densities allow developers to take advantage of economies of scale, reduce the per-unit cost of land and improvements, and reduce developments costs associated with new housing construction. Reasonable density standards ensure the opportunity for higher -density residential uses to be developed within a community, increasing the feasibility of producing affordable housing, and facilitating the provision of a greater range of housing types to address community needs. Table 5-1 presents a summary of allowable densities by land use type for the 16 participating Orange County jurisdiction. While most jurisdictions have Land Use Elements that allow a range of single- family and higher density multi -family residential uses, several cities do not accommodate multi- family uses at a density greater than 25 units per acre without a density bonus or other incentive for affordable housing. Cities that limit densities within residential neighborhoods include: Buena Park, Costa Mesa, Orange, Rancho Santa Margarita, Santa Ana and Tustin. Most of these cities have instead chosen to direct higher density housing into areas designated for residential/commercial mixed use. For example, the City of Santa Ana eliminated the high density residential land use designation that supported its R-3 and R-4 zoning districts in an effort to facilitate long term neighborhood stabilization; the City's Land Use Element now directs higher density housing and mixed use development in proximity to transit services within District Centers and Urban Neighborhood areas. Just two jurisdictions - Fountain Valley and Ranch Santa Margarita - do not include provisions for commercial/residential mixed use in their Land Use Element or Zoning Codes. PUBLIC POLICIES AND PRACTICES 92 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: General Plan Land Use Elements for Orange County jurisdictions. Note: Table represents a summary of typical land use categories by density category, and does not represent a specific jurisdiction's General Plan Land Use designations. Instead, these categories are meant to provide an overview of the type of residential land uses and densities permitted in that jurisdiction. PUBLIC POLICIES AND PRACTICES 93 Table 5-1: Typical Residential Land Use Designations General Land Use Density Range Typical (u n its/ Category Estate/ Very acre) Residential Type <2 Large lot, single-family, often in Low Density hillside or semi -rural setting X X X X Residential Low Density 0-7 Detached single-family dwellings, Residential typically constructed in X X X X X X X X X X X X X X X X subdivisions Low 7-15 Includes small lot single-family, Medium duplexes, townhomes, mobile X X X X X X X X X X X X X X X X home parks, and lower intensity Density apartments and condominiums. Medium 15-25 Multi -family apartments and Density condominiums, typically 2-3 X X X X X X X X X X X X X X X X stories High Density >25 Large multi -story apartment and X X X X X X X X X X X condominium complexes Mixed Use 30+ Apartments, condominiums, live - work units, flats and artist -style X X X X X X X X X X X X X X lofts integrated with commercial uses Source: General Plan Land Use Elements for Orange County jurisdictions. Note: Table represents a summary of typical land use categories by density category, and does not represent a specific jurisdiction's General Plan Land Use designations. Instead, these categories are meant to provide an overview of the type of residential land uses and densities permitted in that jurisdiction. PUBLIC POLICIES AND PRACTICES 93 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS B. Zoning Ordinance The Zoning Ordinance implements the General Plan Land Use and Housing Elements by establishing zoning districts and development standards that correspond with General Plan land use designations. To supplement review of the Zoning Ordinance, staff from each of the 16 participating jurisdictions completed HUD's recommended Zoning Survey, which reviews Zoning and Planning Codes to identify land use and zoning regulations, practices and procedures that may result in the creation or perpetuation of an impediment to fair housing choice. The survey has a particular focus on practices that can act as barriers to the provision of housing for individuals with disabilities, and also touches on areas that may affect fair housing choice for families with children, or otherwise serve as impediments to full fair housing choice. The completed HUD checklist Review of Public Policies and Practices for each participating jurisdiction is included in the Appendix to the Al. In summary, jurisdictions did not identify any public sector impediments to fair housing choice. Several jurisdictions did however identify actions to further fair housing, such as adding a definition of "disability" to the Municipal Code consistent with the Fair Housing Act. These specific actions are included in the Fair Housing Action Plan matrices provided in Chapter VIII of the Al. Aspects of the zoning ordinance that may affect a person's access to housing or limit the range of housing choices available are further discussed below. Variety of Housing Types To ensure fair housing choice in a community, a community's Zoning Ordinance should provide opportunities for a variety of housing types to promote diversity to meet the needs of its residents. This includes zoning provisions for single and multi -family housing, secondary dwelling units, mobile and manufactured homes, licensed residential care facilities, supportive and transitional housing, emergency shelters, and single room occupancy units (SROs). Table 5-2 provides a summary of each jurisdiction's Zoning Ordinance as it relates to providing for these various housing types, and indicates if a given use is permitted or conditionally permitted in at least one zone district in the City. Secondary Dwelling Units. Second units are attached or detached dwelling units that provide complete independent living facilities for one or more persons including permanent provisions for living, sleeping, cooking and sanitation. Second units may provide an alternative source of affordable housing for lower income households, particularly for seniors, persons with disabilities, and students, and typically rent for less than apartments of comparable size. These units can also assist older homeowners to remain in their homes, providing housing for caregivers and extended family members, and generating income for units used as rentals. PUBLIC POLICIES AND PRACTICES 94 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 5-2: Zoning for a Variety of Housing Types Anaheim P P P C P P C P P P C Buena Park P P P P P P C P P P -Z Costa Mesa P P P C P P C P P P C Fountain Valley P C P C P P C - 3 - 3 P C Fullerton P P P P P P C P P P C Garden Grove P P P P P P C P P P C4 Huntington Beach P P/C, P C P P C P P P C La Habra P P P P P P C P P P C Lake Forest P P P C P P C P P P C Mission Viejo PD/P6 PD/P6 P PD PD P C P P P C Newport Beach P P MUP7 P P P/C' C P P P C Orange P P P C P P C P/C, P/C, P -8 Rancho Santa Margarita P P P C P P C P P P P San Clemente P P/C, P C P P C P P P P Santa Ana P P P P P P C P P P --10 Tustin P P P C P P C P P P C11 P = Permitted Use PD =Planned Development Permit MUP =Minor Use Permit C= Conditional Use Permit 1For transitional and supportive housing, "permitted" means the jurisdiction treats these as residential uses under zoning, and only subject to the same provisions as other residential uses of the same type in the some zone. 2The Buena Park Zoning Code does not currently contain provisions for SROs. The City's 2013-2021 Housing Element includes an action to amend the Code within one year of adoption of the Housing Element to specifically address the provision of SRO units. 3The Fountain Valley Zoning Code does not currently specify provisions for transitional or supportive housing, but the City is in the process of amending the Code to treat as a residential use, as required under SB 2. 4The Garden Grove Zoning Code does not specify provisions for SROs. The City's 2014-2021 Housing Element indicates SROs are conditionally permitted as a boarding or lodging facility in R-2 and R-3 zones consistent with established development standards. 5The Huntington Beach Zoning Code currently requires a CUP for multi family projects with more than 4 units (5-9 units - Zoning Administrator, 10+ units - Planning Commission). The City's 2013-2021 Housing Element includes an action to evaluate permit streamlining to include increasing the threshold for units in a project to be permitted by right, and increasing the threshold for projects requiring review by the Planning Commission. 6The Mission Viejo Zoning Code requires a planned development permit for single- and multi family projects, except for projects in the RPD30a zone (Residential Planned Development By Right) which include 15-20% lower income units, as specified in the Housing Element. 7The Newport Beach Zoning Code limits occupancy of accessory dwelling units to persons age 55 and above. Licensed residential care facilities with 6 or fewer residents are a permitted use in residential zones, whereas as unlicensed facilities are subject to a CUP. SROs are classified under the Visitor Accommodation zoning classification. 8The City of Orange Zoning Code permits transitional and supportive housing with six or fewer occupants by -right in residential zones, whereas these housing types with more than seven residents are subject to a CUP. The City's Zoning Code does not currently contain provisions for SRO units. 9The San Clemente Zoning Code requires a CUP for multi family projects with more than 4 units. 10 The Santa Ana Zoning Code does not currently contain provisions for SRO units. 11 The Tustin Zoning Code does not currently contain provisions for SRO units, but are conditionally permitted as boarding houses. PUBLIC POLICIES AND PRACTICES 95 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS California law requires local jurisdictions to adopt ordinances that establish the conditions under which second units are permitted (Government Code Section 65852.2). No local jurisdiction can adopt an ordinance precluding second units in residential zones unless the ordinance contains findings acknowledging that prohibiting second units may limit housing opportunities in the region and result in adverse impacts on public health, safety, and welfare. An amendment to the State's second unit law in 2003 requires local governments to use a ministerial review process for second units, defined as a review and approval process that does not require public notice, public hearing or discretionary approval. Jurisdictions are permitted to impose standards on second units addressing issues such as building size, parking, height, setbacks and lot coverage. As summarized in Table 5-2, 15 of the 16 participating Orange County jurisdictions have amended their Zoning Ordinances to permit second units by right in single-family residential zones. The City of Newport Beach, however, does not provide for second units within single-family zones in its Zoning Ordinance, but does allow for "granny units" (accessory, age -restricted units) in single-family zones. More specifically, the City's Code specifies that accessory units are intended for the sole occupancy of one or two adult persons who are fifty-five (55) years of age or older, do not exceed six hundred forty (640) square feet, and are subject to Zoning Administrator approval of a Minor Use Permit. The City's age -restrictions on accessory dwelling units, combined with the requirement for discretionary approval, may serve to impede housing choice for lower income individuals in Newport Beach. Mobile Homes/Manufactured Housing. The manufacturing of homes in a factory is typically less costly than the construction of individual homes on-site thereby lowering overall housing costs. State law requires local governments to permit manufactured or mobile homes meeting federal safety and construction standards on a permanent foundation in single-family residential zones (Section 65852.3 of the California Government Code). State law also declares a mobile home park to be a permitted land use on any land planned and zoned for residential use, and prohibits requiring the average density in a new mobile home park to be less than that permitted by the Municipal Code. A city or county may, however, require use permits for mobile home parks. As presented in Table 5-2, all 16 Orange County cities comply with these State requirements. While the City of Mission Viejo requires a planned development permit for manufactured housing, this is consistent with the City's requirement for all market rate single- and multi -family developments. Residential Care Facilities. The Lanterman Developmental Disabilities Services Act ("Lanterman Act" - Sections 5115 and 5116 of the California Welfare and Institutions Code) is that part of California law that sets out the rights and responsibilities of persons with developmental disabilities. The Lanterman Act impacts local zoning ordinances by requiring the use of property for the care of six or fewer disabled persons to be classified as a residential use under zoning. More specifically, a State - authorized, certified or licensed family care home, foster home, or a group home serving six or fewer disabled persons or dependent and neglected children on a 24 -hour -a -day basis is considered a residential use that is to be permitted in all residential zones. No local agency can impose stricter zoning or building and safety standards on these homes. Due to the unique characteristics of larger (more than six persons) community care facilities, most jurisdictions require a Use Permit to ensure neighborhood compatibility in the siting of these facilities. PUBLIC POLICIES AND PRACTICES 96 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS According to the California Department of Social Services, Community Care Licensing Division, there are 672 State licensed assisted living residential care facilities for the elderly, 258 adult residential facilities, 22 adult day care facilities, 49 children's residential group homes, and 10 residential small family homes in the 16 Orange County cities participating in this Al. As depicted in previous Table 3- 28, which presents the numbers of residential care facilities by the 16 cities, the following cities have the highest numbers of residential care facilities by type: ■ Assisted living residential care for the elderly located in Mission Viejo with 147 facilities, followed by Anaheim with 97 facilities; ■ Adult residential facilities in Anaheim with 96 and eight adult day care facilities; ■ Children's residential group homes in Orange with 11 homes, followed by Costa Mesa with 9 homes; and, ■ Residential small family home for children with special needs in the City of Huntington Beach four homes. All but one of the 16 participating jurisdictions have at least a dozen or more licensed community care facilities, with Rancho Santa Margarita currently having no such facilities. As presented in Table 5-2, all 16 cities have provided by -right zoning for licensed residential care facilities with six or fewer residents, treating these facilities as a single-family residential use. All cities also specify one or more zone districts where residential care facilities with seven or more residents may be permitted, subject to a conditional use permit; operators of care facilities may also pursue a reasonable accommodation to locate in additional zone districts. While the City of Newport Beach requires a use permit for unlicensed facilities regardless of size, requirements for by -right residential zoning under the Lanterman Act are only applicable to State licensed facilities. Single Room Occupancy (SRO). Single Room Occupancy (SRO) residences are small, one room units occupied by a single individual, and may either have shared or private kitchen and bathroom facilities. SROs are rented on a monthly basis typically without rental deposit, and can provide an entry point into the housing market for extremely low income individuals, formerly homeless and disabled persons. California Housing Element law requires jurisdictions to address the provision of housing for extremely low income (30% AMI) households, including SROs. The majority of the 16 Orange County cities either contain specific provisions for SRO units in their Zoning Ordinances, or have clarified in their Housing Elements how SROs are provided for under other zoning classifications. For example, the Housing Elements for Garden Grove and Tustin clarify that SROs are conditionally permitted through zoning as boarding houses. However, as indicated in the footnotes to Table 5-2, the cities of Buena Park, Orange and Santa Ana do not explicitly provide for SROs in their Zoning Codes, or clarify in their Housing Elements how such uses would be provided for, though the City of Buena Park has indicated SROs could be accommodated through a development agreement. Lack of clarity on provisions for SROs can serve to limit housing choice to extremely low income households, including persons with disabilities and veterans. PUBLIC POLICIES AND PRACTICES 97 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Emergency Shelters. An emergency shelter is a facility that provides temporary shelter and feeding of indigents or disaster victims, operated by a public or non-profit agency. State law requires jurisdictions to identify adequate sites for housing which will be made available through appropriate zoning and development standards to facilitate and encourage the development of a variety of housing types for all income levels, including emergency shelters and transitional housing (Section 65583(c)(1) of the Government Code). Recent changes in State law (SB 2) require that local jurisdictions make provisions in the Zoning Ordinance to permit emergency shelters by right in at least one zoning district where adequate capacity is available to accommodate at least one year- round shelter. Local jurisdictions may, however, establish standards to regulate the development of emergency shelters. All 16 participating Orange County cities have complied with the requirement to permit emergency shelters by right within at least one zoning district. On November 17, 2015, the County Board of Supervisors approved the purchase of a warehouse in the City of Anaheim to build the county's first year-round, permanent emergency shelter for the homeless. The multi -service center is expected to house up to 200 people and act as a triage center where health, job and housing social workers would help homeless clients find permanent housing. Transitional and Supportive Housing. State law (AB 2634 and SB 2) requires local jurisdictions to address the provisions for transitional and supportive housing. Under Housing Element law, transitional housing means buildings configured as rental housing developments, but operated under program requirements that require the termination of assistance and re -circulating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance (California Government Code Section 65582(h)). Supportive housing means housing with no limit on length of stay, that is occupied by the target population, and that is linked to an onsite or offsite service that assists the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. Target population means persons with low incomes who have one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health condition, or individuals eligible for services provided pursuant to the Lanterman Developmental Disabilities Services Act (Division 4.5 (commencing with Section 4500) of the Welfare and Institutions Code) and may include, among other populations, adults, emancipated minors, families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, and homeless people (California Government Code Sections 65582(f) and (g)). In summary, State law establishes transitional and supportive housing as a residential use and prohibits local governments from treating it differently from other similar types of residential uses (e.g., requiring a use permit when other residential uses of similar type in the same zone do not require a use permit). The majority of the 16 participating jurisdictions have amended their Zoning Codes to define and regulate transitional and supportive housing as a residential use as specified under State law. The City of Orange Zoning Code, however, only addresses transitional and PUBLIC POLICIES AND PRACTICES 98 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS supportive housing structured in the form of group housing (which is permitted by right in all residential zones with 6 or fewer persons, conditionally permitted in R-3 and R-4 zones with seven or more persons); the Code does not specifically address transitional or supportive housing structured as an apartment building (which is permitted by right in multi -family zones). The City of Fountain Valley Zoning Code contains a definition of supportive housing, but does not currently specify how such uses are to be regulated; the City is in the process of amending the Code to treat transitional and supportive housing as a residential use, consistent with State requirements. Definition of Family A community's Zoning Ordinance can potentially restrict access to housing for relations failing to qualify as a "family" by the definition specified in the Zoning Ordinance. Even if the code provides a broad definition, deciding what constitutes a "family" should be avoided by cities to prevent confusion or give the impression of restrictiveness. Particularly, when Zoning Ordinance uses terms such as "single-family" homes, defining family in too detailed conditions may be viewed by some as restricting access to housing for certain segments of the population. According to California Housing Element Law, one of the ways communities can promote fair housing is to remove definitions of family that are restrictive. Although a recent federal court case upheld the definition of a family in the zoning code, California court cases have ruled that an ordinance that defines a "family" as (a) an individual, (b) two or more persons related by blood, marriage or adoption, or (c) a group of not more than a certain number of unrelated persons as a single housekeeping unit, is invalid. California court rulings stated that defining a family does not serve any legitimate or useful objective or purpose recognized under the zoning and land planning powers of the city, and therefore violates rights of privacy under the California Constitution. A zoning ordinance also cannot regulate residency by discrimination between biologically related and unrelated persons. None of the participating cities' Zoning Codes define the word "family" in a way that appears to have restrictive or discriminating effect, and place no limitations on how members of the family are related or the maximum number of member in the households. Several jurisdictions have removed the definition of family from their Zoning Codes entirely. C. Building Codes and Occupancy Standards Building codes were created to ensure the safety of buildings and residential structures. Many codes put in place were in response to the loss of life or property due to poor construction techniques or natural disasters (e.g., earthquakes or fires) from the past. It is unlikely that cities will relax housing codes; however, most of the 16 participating Orange County cities have housing rehabilitation programs that can assist lower income households ensure their homes are compliant with housing and building codes. In addition, each City implements a code enforcement program which works to correct code violations and respond to complaints from residents. Code enforcement is a critical component of retaining quality neighborhoods and residential structures. PUBLIC POLICIES AND PRACTICES 99 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Each of the participating cities have adopted the State Uniform Building and Housing Codes. These codes are considered to be the minimum necessary to protect the public health, safety, and welfare. No local amendment has either been initiated or approved that directly affects housing standards or processes. Each of the cities' building codes requires that new residential construction comply with the American with Disabilities Act (ADA) per federal law. ADA regulations include requirements for a minimum percentage of units in new developments to be fully accessible to the physical disabled. Section 504 of the Rehabilitation Act of 1973 adds an additional layer of accessibility requirements for projects receiving federal funds, such as HOME or CDBG. In federally assisted new construction or substantially rehabilitated housing with five or more units, five percent of the units, or at least one unit, must be accessible for persons with mobility disabilities. An additional two percent of the dwelling units, or at least one unit, must be accessible for persons with hearing or visual disabilities. These units must be constructed in accordance with the Uniform Federal Accessibility Standards (UFAS), or a standard that is equivalent or stricter. UFAS generally defines an accessible housing unit as a unit located on an accessible route that can be approached, entered and used by individuals with disabilities. Occupancy Standards Local occupancy standards more stringent than those established by the State have been deemed unconstitutional by the courts; none of the 16 participating cities contain residential occupancy standards more stringent than the State. California jurisdictions are mandated to follow the minimum occupancy standards established under the State Uniform Housing Code (UHC). The UHC requires that every dwelling, except studio apartments, have at least one room with a minimum of 120 square feet of floor area. Two persons are permitted to use a room for sleeping purposes if it has a total area of not less than 70 square feet. When more than two persons occupy a room, the required floor area must be increased by 50 square feet per occupant. There is nothing in the Housing Code that prevents occupants from sleeping in the living or dining rooms, provided these rooms have an operable window or door meeting California building code requirements for emergency egress. The UHC is based on health and safety considerations, and is not intended to discriminate based on familial status. Occupancy in housing receiving public funds, such as Section 8 rental assistance, is typically further regulated based on the number of bedrooms. Under the "two -plus -one" rule, maximum occupancy is based on two persons per bedroom plus one additional person. PUBLIC POLICIES AND PRACTICES 100 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS D. Affordable Housing Development Siting of Affordable Housing Market rents are generally well above the level of affordability to lower income households in Orange County. Table 5-3 below summarizes the number of rent -restricted units in each of the 16 Orange County cities, and calculates the proportion of rent -restricted housing to each community's total stock of rental housing. As shown, while the number of affordable rental units varies significantly by jurisdiction, the proportion relative to each city's total rental housing is relatively consistent at between five and six percent. Just two cities fall below this percentage - Newport Beach (3.4%) and La Habra (4.0%). Thus, affordable rental opportunities are generally well dispersed within the 16 cities relative to each city's size. Cities Anaheim Table 5-3: Affordable Rent Restricted Units 3,333 Rental Units Total Rental Units 50,800 % Rental Housing Rent Restricted 6.6% Buena Park 608 9,700 6.3% Costa Mesa 1,436 24,000 6.0% Fountain Valley 306 5,300 5.8% Fullerton 1,164 20,500 5.7% Garden Grove 1,321 20,100 6.6% Huntington Beach 1,726 29,500 5.9% La Habra 328 8,300 4.0% Lake Forest 453 7,900 5.7% Mission Viejo 369 7,400 5.0% Newport Beach 579 17,200 3.4% Orange 1,404 16,900 8.3% Rancho Santa Margarita 242 4,600 5.3% San Clemente 497 8,400 5.9% Santa Ana 2,508 38,400 6.5% Tustin 813 12,100 6.7% Source: Rent restricted units derived from each City's Housing Element and Consolidated Plan, as updated by City staff. Number of rental units derived from 2008-2012 American Community Survey, rounded to the nearest 100. PUBLIC POLICIES AND PRACTICES 101 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Development Fees/Assessments Local jurisdictions collect various fees on new residential development to recover the cost of permit processing, the costs of providing public services to the development, and to mitigate certain development impacts. Such fees typically include plan check and building permit fees, water meter fees, sewer connection fees, recreation taxes and school facilities fees. Multi -family development may also be subject to charges for various administrative or discretionary reviews, environmental review, and impact mitigation. When projects require multiple planning permit applications, such as a variance and conditional use permit, most cities place a cap on the combined fees. Planning fees for the 16 participating Orange County cities are summarized in Table 5-4, and vary by the needs of each jurisdiction. Each city conducts periodic assessments of fees to ensure they reflect the actual cost of providing services. Table 5-4: Development Fees Cities General Plan Conditional Amendment Permit Anaheim $181/hr; $12,000 $181/hr; $10,000 $181/hr; $10,000 deposit deposit deposit Buena Park $1,400 $1,600 $525 Costa Mesa $4,560 Minor: $1,050 $1,685 Major: $1,550 Fountain Valley $9,265 $3,455 $2,960 Fullerton $3,110 $3,110 $3,110 Garden Grove $1,950 $2,100 Existing SF: $500 Other: $1,675 Huntington Beach Minor: $24,890 ZA: $4,550 $4,230 Major: $46,580 PC: $9,990 La Habra $4,000 $3,200 $3,200 Lake Forest $10,000 deposit $6,500 deposit $6,000 deposit Mission Viejo $5,000 deposit $2,500 $4,500 $183/hr; ZA: $2,420 $183/hr; Newport Beach $7,500 deposit PC: $5,000 deposit; $5,000 deposit $183/hr Orange' FBHR +$3,000 deposit FBHR +$1,000 deposit FBHR +$1,000 deposit Rancho Santa Margarita $6,700 deposit Minor: $3,650 deposit $8,000 deposit Major: $7,300 deposit San Clemente2 Deposit + 28% GP )eposit + 28% GP Update Deposit + 28% GP Update Fee Fee Update Fee Santa Ana $8,250 $4,900 $4,750 Tustin$2,985 (text and map) Minor: $665 Minor: $380 Major: $3,000 deposit Major: $3,000 deposit Source: Housing Elements for Orange County jurisdictions, as updated by City staff. 1 FBHR: Fully Burdened Hourly Rate 'Deposit determined by City Planner, with actual hourly costs consisting of time, materials, and overhead. PUBLIC POLICIES AND PRACTICES 102 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS E. Other Land Use Policies, Programs and Controls Land use policies, programs, and controls can impede or facilitate housing development and can have implications for fair housing choice in a community. Density bonus and inclusionary housing policies can facilitate the provision of new affordable housing, whereas growth management programs and Article 34 of the California Constitution can impede new affordable housing development. The following section discusses land use policies, programs, and controls that may affect housing development and fair housing choice within the 16 participating Orange County cities. Programs/Incentives to Develop Affordable Housing Density Bonus and Other Incentives for Affordable Housing. California Government Code Section 65915 requires jurisdictions to grant a density bonus in exchange for the provision of affordable housing. In summary, applicants of residential projects of five or more units may apply for a density bonus and additional concession/incentive(s) if the project provides for construction of one of the following: ■ 10 percent of units in a housing project for lower income households; or ■ 5 percent of units in a housing project for very low income households; or ■ A senior citizen housing development, or mobile home park that limits residency based on age requirements for housing for older persons; or ■ 10 percent of units in a common interest development for moderate income households, provided that all units in the development are offered to the public for purchase. The amount of density bonus to which the applicant is entitled ranges from 20-35 percent above the specified General Plan density, based on the percentage and affordability of units provided. In addition, eligible projects may receive one to three additional development concessions/incentives, based on the applicant demonstrating that it is not financially feasible to build the project without the concessions. The number of concessions a project may be eligible for is based upon a combination of the level of affordability and the percentage of affordable units, as presented in Table 5-5: Table 5-5: Density Bonus Concessions Level of Affordability % Affordable Development Units Incentives Very Low Income At least 5% 1 At least 10% 2 At least 15% 3 Low Income At least 10% 1 At least 20% 2 At least 30% 3 Moderate Income At least 10% 1 (for -sale condo or planned At least 20% 2 development) At least 30% 3 PUBLIC POLICIES AND PRACTICES 103 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS State density bonus law also specifies alternative parking standards which may be utilized at the request of the developer; use of these standards does not count towards a project's development incentives/concessions. These reduced parking standards are inclusive of guest parking and handicapped parking, may be tandem and/or uncovered, and are applicable to the entire development project. ■ Zero to one bedroom: one on-site parking space ■ Two to three bedrooms: two on-site parking spaces ■ Four or more bedrooms: two and one-half on-site parking spaces AB 2222 (effective January 2015), has made important changes to State density bonus law in an effort to help address potential displacement of existing tenants. Specifically, AB 2222 now prohibits an applicant from receiving a density bonus (and related incentives and waivers) unless the proposed housing development or condominium project would, at a minimum, maintain the number and proportion of affordable housing units within the proposed development, including affordable dwelling units that have been vacated or demolished in the five-year period preceding the application. AB 2222 also increases the required affordability from 30 years or longer to 55 years or longer for all affordable rental units that qualified an applicant for a density bonus, and requires replacement rental units to be subject to a recorded affordability restriction for at least 55 years. If the units that qualified an applicant for a density bonus are affordable ownership units, they must be subject to an equity sharing model rather than a resale restriction. AB 744, signed into law in October 2015, further amends density bonus law to provide additional by - right reductions in parking for density bonus projects. Specifically, for density bonus projects which include the maximum percentage of low income or very low income units (20% and 11%, respectively) and located within one-half mile of a major transit stop with "unobstructed access"", upon the request of the developer, the jurisdiction shall not impose a vehicular parking ratio, inclusive of handicapped and guest parking, that exceeds 0.5 spaces per bedroom. Senior rental housing (as defined in Sections 51.2 and 51.3 of the Civil Code) and housing for special needs populations (as defined in Section 51312 of the Health and Safety Code) also qualify for by -right parking reductions when either paratransit service is provided, or unobstructed access to a fixed bus route service that operates at least eight times per day is available within one-half mile. All 16 cities have adopted local density bonuses which implement state density bonus law. With the recent addition of anti -displacement provisions under AB 2222 and modified parking standards for transit -accessible projects under AB 744, all jurisdictions should update their ordinances to reflect these new State requirements. 1 A development is defined as having unobstructed access to a major transit stop if a resident is able to access the major transit stop without encountering natural or constructed impediments. PUBLIC POLICIES AND PRACTICES 104 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Inclusionary Housing Programs. Inclusionary zoning is a tool that can be used by cities to integrate affordable units within market rate developments. One-third of cities and counties in California have adopted some form of inclusionary zoning, including ten in Orange County, requiring a stated percentage (typically 10 to 20%) of affordable units to be provided within newly constructed housing projects. The majority of these regulations allow for payment of a housing in -lieu fee as an alternative to providing the required affordable units on-site. The goal of inclusionary housing programs is to increase the supply of affordable housing proportionate to market -rate development, and to disperse affordable units throughout the community. Among the 16 participating Orange County cities, the following currently have in place inclusionary zoning requirements to help address local affordable housing needs and contribute towards Housing Element production requirements: ■ Huntington Beach. The City's Zoning Ordinance requires projects with three or more units to provide at least 10 percent of the total units for low to moderate income households. Affordable units are permitted to be provided at an off-site location (unless otherwise outlined as part of a specific plan project), and may be new construction, substantial rehabilitation, or preservation of assisted rental housing at -risk of conversion or mobile homes. Projects up to 30 units in size are permitted to pay an in -lieu fee. ■ Lake Forest. The City has adopted Affordable Housing Implementation Plans (AHIPs) for four "New Neighborhoods" created from the rezoning of vacant business/industrial land. Each of the New Neighborhoods' land owners/developers has entered into a development agreement with the City which encompasses the AHIP, and reflects the City's policy to incorporate a minimum of 15 percent affordable units in new developments. ■ San Clemente. Inclusionary Housing Program, adopted in 1980, requires developers of six or more units to set aside four percent of the total number of units for very low income households. This affordable requirement can be provided either on-site, off-site, or through the payment of an in -lieu fee or provision of land. In addition, the City established an Affordable Housing Overlay Zone along the EI Camino Real commercial corridor in 2006, allowing for senior housing or mixed income housing with a minimum of 51 percent affordable to very low income households. ■ Santa Ana. The City's Housing Opportunity Ordinance requires eligible housing development projects of 5 or more units to include at least 15 percent of the units as affordable to lower income households (rental) and at least 15 percent as affordable to moderate income households (ownership). The inclusionary requirement is triggered by: a request to increase the permitted density above that permitted in the zone, conversion of commercial or industrial land to residential uses, conversion of rental units to condominiums, and various other conditions. Financial Assistance for Affordable Housing. The 16 participating Orange County cities have access to a number of financial resources which can provide critical gap financing in support of affordable housing development. As entitlement jurisdictions, the federal government provides annual allocations of Community Development Block Grant (CDBG), and for most jurisdictions, HOME funds. The State of California administers the Proposition 1C Housing Bond funds for a variety of PUBLIC POLICIES AND PRACTICES 105 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS competitive housing programs. The State also administers federal tax credits and housing bonds allocated competitively throughout the state. The primary local source of funds for affordable housing has traditionally been each Redevelopment Agency's Low- and Moderate -Income Housing Fund. With the passage of Assembly Bill (AB)1X 26, redevelopment agencies across California have been eliminated as of February 1, 2012, removing the primary local tool for creating affordable housing. However, with the passage of AB 1484 in June 2012, the Supplemental Educational Revenue Augmentation Funds (SERAF) borrowed by the State from Redevelopment Agencies Low and Moderate Income Housing Funds are to be repaid, and will be deposited into each Successor Agency's Housing Asset Fund (pursuant to Health and Safety Code Section 34191.4(b)(2)(B) and (C)). Growth Management Growth management programs facilitate well-planned development and ensure that the necessary services and facilities for residents are provided. However, a growth management program may act as a constraint if it prevents a jurisdiction from addressing its housing needs, which could indirectly impede fair housing choice. Among the 16 participating Orange County cities, only the City of Newport Beach currently has any form of growth control in place. The Newport Beach City Charter (Section 423) requires voter approval of any project that increases density, intensity, or peak hour trip, above that provided for in the General Plan. Significance is quantified as 100 or more dwelling units, over 100 peak hour trips, or 40,000 or more square feet of nonresidential floor area. It is important to note, however, that Charter Section 423 does not have any impact on the allowed density established for the sites identified to meet the City's Regional Housing Needs Allocation (RHNA) in its 2014-2021 Housing Element, including affordable units. A Growth Management Initiative was approved by the voters in San Clemente in 1986 which limited residential construction to 500 units per year and established a competitive allocation process. The Growth Management Ordinance expired on December 31, 2006 and was not extended. Article 34 Article 34 of the State Constitution requires a majority vote of the electorate to approve the development, construction, or acquisition by a public body of any "low rent housing project" within that jurisdiction. In other words, for any projects to be built and/or operated by a public agency where at least 50 percent of the occupants are low income and rents are restricted to affordable levels, the jurisdiction must seek voter approval known as "Article 34 authority" to authorize that number of units. In the past, Article 34 may have prevented certain projects from being built. In practice, most public agencies have learned how to structure projects to avoid triggering Article 34, such as limiting public assistance to 49 percent of the units in the project. Furthermore, the State legislature has enacted Sections 37001, 37001.3, and 37001.5 of the Health and Safety Code to clarify ambiguities relating to the scope of the applicability of Article 34 which now exist. PUBLIC POLICIES AND PRACTICES 106 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS F. Zoning Regulations for Persons with Disabilities Review of each city's zoning standards, policies and practices has not identified anything discriminatory against persons with disabilities, or that impedes the availability of housing for these individuals. Examples of the ways in which the cities facilitate housing for persons with disabilities include: ■ Each City defines "family" or "single housekeeping unit" in such a way that does not have the effect of discriminating against unrelated individuals, or individuals with disabilities who reside together in a congregate or group living arrangement. ■ Zoning Codes do not distinguish housing for persons with disabilities who are residing in a single housekeeping unit from any other residential use in which individuals are residing as a single housekeeping unit. ■ Through reasonable accommodations, and in certain instances use permits, Zoning Codes permit disabled individuals not living as a single housekeeping unit to reside in residential zones where all other groups not living as a single housekeeping unit are prohibited. ■ Each City's Building Code requires new residential construction to comply with the American with Disabilities Act (ADA) per federal law. ADA regulations include requirements for a minimum percentage of units in new developments to be fully accessible to the physical disabled. Reasonable Accommodation Both the federal Fair Housing Act and the California Fair Employment and Housing Act impose an affirmative duty on local governments to make reasonable accommodations in their zoning and other land use regulations when such accommodations may be necessary to afford disabled persons an equal opportunity to use a dwelling. Jurisdictions must grant variances and zoning changes if necessary to make new construction or rehabilitation of housing for persons with disabilities feasible, but are not required to fundamentally alter their Zoning Ordinance. For example, it may be a reasonable accommodation to allow covered ramps in the setbacks of properties that have already been developed to accommodate residents with mobility impairments. If specific reasonable accommodation policies and procedures are not adopted by a jurisdiction, if a public hearing or discretionary action is required, or if a fee is charged to process a reasonable accommodation request, this may present an impediment to equal access to housing for residents with disabilities. The majority of the 16 participating Orange County cities have adopted formal procedures in their Municipal Code to process Reasonable Accommodation requests; the City of San Clemente currently considers such requests as they are made, and includes a program action in its Housing Element to adopt a formal reasonable accommodation ordinance by 2016. Three cities charge a fee (Anaheim, Tustin and La Habra), and one city requires a public hearing (Newport Beach). The Al includes recommended actions for each of these jurisdictions to modify these current practices to better facilitate housing opportunities to persons with disabilities PUBLIC POLICIES AND PRACTICES 107 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS G. Local Housing Authorities Orange County's four housing authorities provide rental assistance through the Housing Choice Voucher Program (HCVP) to an estimated 16,486 households'. Thus, the authorities' fair housing policies affect the well-being of a significant number of renter households, most of whom are very low- and low-income families. The assisted tenant's are informed about fair housing rights and the services provided by the Fair Housing Council of Orange County (FHCOC), and the Fair Housing Foundation (FHF). The housing authorities' policies contribute to attaining HUD's mandate to affirmatively further fair housing. If this mandate were not effectively carried out it would adversely impact thousands of very low and low income renter households. All four housing authorities are performing well, however. For example, HUD evaluates the performance of housing authorities through the Section 8 Management Assessment Program (SEMAP). This program measures the performances of public housing agencies (PHAs) that administer the HCVP in 14 key areas, including "Expand housing choice outside areas of poverty or minority concentration." All four housing authorities have received a "high performance rating" with SEMAP scores of 90 percent or greater. The Orange County Housing Authority has consistently received bonus points in SEMAP for de -concentration. The paragraphs below summarize key fair housing policies of the housing authorities. Anaheim Housing Authority (AHA) The AHA 5 -Year Plan for the Housing Choice Voucher Program contains a goal to expand housing opportunities by completing a survey of Section 8 landlords to establish an inventory of units that are accessible to the disabled. Another important goal is to ensure equal opportunity and affirmatively further fair housing by ensuring accessible housing to persons with all varieties of disabilities regardless of unit size required. The Administrative Plan contains policies promoting fair housing and equal opportunity. Policies are established for nondiscrimination, for persons with disabilities, and improving access to services for persons with limited English speaking proficiency. As noted in the Administrative Plan, Federal regulations prohibit discrimination against certain protected classes. State and local requirements, as well as PHA policies, prohibit discrimination against additional classes of people. The PHA shall not discriminate because of race, color, sex, religion, familial status, age, disability or national origin (called "protected classes"). Anaheim PHA Policy: The PHA will not discriminate on the basis of marital status or sexual orientation. 2 This estimated figure includes approximately 6,263 household receiving HCVP assistance from the Orange County Housing Authority, 2,300 households from the Garden Grove Housing Authority, 1,761 households from the Santa Ana Housing Authority and 6,162 households receiving Section 8 or Project -Base Voucher Program assistance from the Anaheim Housing Authority PUBLIC POLICIES AND PRACTICES 108 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS The PHA will not use any of these factors to: ■ Deny to any family the opportunity to apply for housing, nor deny to any qualified applicant the opportunity to participate in the housing choice voucher program ■ Provide housing that is different from that provided to others ■ Subject anyone to segregation or disparate treatment ■ Restrict anyone's access to any benefit enjoyed by others in connection with the housing program ■ Treat a person differently in determining eligibility or other requirements for admission ■ Steer an applicant or participant toward or away from a particular area based any of these factors ■ Deny anyone access to the same level of services ■ Deny anyone the opportunity to participate in a planning or advisory group that is an integral part of the housing program ■ Discriminate in the provision of residential real estate transactions ■ Discriminate against someone because they are related to or associated with a member of a protected class ■ Publish or cause to be published an advertisement or notice indicating the availability of housing that prefers or excludes persons who are members of a protected class Garden Grove Housing Authority (GGHA) It is the policy of the Housing Authority to comply fully with all Federal, State, and local nondiscrimination laws and with the rules and regulations governing protected classes of the Fair Housing Act and Equal Opportunity in Housing and Employment. The GGHA shall not deny any family or individual the equal opportunity to apply for or receive assistance under the HCVP on the basis of race, color, sex, religion, creed, national or ethnic origin, age, familial or marital status, handicap or disability, or sexual orientation. To further its commitment to full compliance with applicable Civil Rights laws, the GGHA will provide Federal/State/local information to voucher holders regarding unlawful discrimination and any recourse available to families who believe they are victims of a discriminatory act. Such information will be made available during the family briefing session and all applicable Fair Housing Information and Discrimination Complaint forms will be made a part of the voucher holder's briefing packet. They also will be available upon request at the front desk. All Housing Authority staff will be informed of the importance of affirmatively furthering fair housing and providing equal opportunity to all families; including providing reasonable accommodations to persons with disabilities as a part of the overall commitment to quality customer service. PUBLIC POLICIES AND PRACTICES 109 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Fair Housing posters are posted in the Housing Authority office lobby and the equal opportunity logo will be used on specific outreach materials. When available, staff will attend local Fair Housing update training sessions sponsored by HUD and other local organizations to keep current with new developments. Santa Ana Housing Authority (SAHA) The SAHA's Annual Plan states that it will take affirmative measures to ensure equal opportunity and affirmatively further fair housing. These measures include: ■ Undertake affirmative measures to ensure access to assisted housing regardless of race, color, religion, national origin, sex, familial status, and disability. ■ Undertake affirmative measures to provide a suitable living environment for families living in assisted housing, regardless of race, color, religion, national origin, sex, familial status, and disability. ■ Undertake affirmative measures to ensure accessible housing to persons with all varieties of disabilities regardless of unit size required. Among the action steps taken to implement these measures are the following: ■ Provide referrals to the Fair Housing Council of Orange County when the Housing Authority receives complaints of possible housing discrimination. ■ Invite the Fair Housing Council of Orange County to make presentations to Authority staff regarding equal opportunities for fair housing (at least one presentation per year). ■ Include fair housing information in all tenant briefing packets. ■ Provide fair housing information and materials at all landlord training sessions. Other activities to affirmatively further fair housing include: ■ Counsel Section 8 tenants as to location of units outside areas of poverty or minority concentration and assist them to locate those units. ■ Market the Section 8 program to owners outside of areas of poverty/minority concentrations. ■ Awareness training will be provided to staff by representatives of the Fair Housing Council of Orange County. Orange County Housing Authority (OCHA) OCHA furthers the HUD strategic goal of ensuring equal opportunity for all Americans by undertaking affirmative measures to provide access to a suitable living environment in assisted housing regardless of race, color, religion, national origin, sex, familial status, or disability, in any bedroom size unit. Examples of specific affirmative measures are given below: PUBLIC POLICIES AND PRACTICES 110 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS OCHA undertakes affirmative measures, initially at program briefings and again during annual re - certifications, to keep participant and applicant families advised of their civil rights regarding access to assisted housing regardless of race, color, religion, national origin, sex, familial status, and disability. In addition, OCHA networks with over 180 community organizations and 31 participating cities to ensure awareness of and enforcement of fair housing laws. OCHA's Annual Plan is also consistent with Orange County's Consolidated Plan in furthering these objectives. OCHA includes a Fair Housing brochure in all Briefing Packets, advising applicants and participants on how to file a fair housing complaint. The brochure includes the toll-free number for the Housing Discrimination Hotline: 1-800-669-9777, and the Federal Information Relay Service number: 800-877- 8339. In addition, Fair Housing posters are printed in three Languages; English, Spanish and Vietnamese and are placed in OCHA's lobby for distribution. OCHA affirmatively furthers fair housing by certifying to HUD that it will: ■ Examine OCHA's programs and proposed programs ■ Identify any impediments to fair housing choice within those programs ■ Address those impediments in a reasonable fashion in view of the resources available ■ Work with local jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that requires OCHA's involvement ■ Maintain records reflecting these analyses and actions Additionally, OCHA implements the following policies for persons with disabilities: ■ In accordance with rent reasonableness requirements, approve higher rents to owners that provide accessible units with structural modifications for persons with disabilities. ■ Provide technical assistance, through referrals to the Fair Housing Council of Orange County, to owners interested in making reasonable accommodations or units accessible to persons with disabilities. OCHA's Administrative Plan further explains its role in implementing laws and HUD regulations requiring OCHA to affirmatively further civil rights and fair housing in all federally -assisted housing programs. The letter and spirit of these laws are implemented through consistent policy and processes. The responsibility to further nondiscrimination pertains to all areas of OCHA's Housing Choice Voucher (HCV) operations. The Administrative Plan Fair Housing and Equal Opportunity rules and policies include: ■ Nondiscrimination: Laws and regulations governing the responsibilities of OCHA regarding nondiscrimination. ■ Policies Related to Persons with Disabilities: Rules and policies of the HCVP related to reasonable accommodation for persons with disabilities. These rules and policies are based on the Fair Housing Act (42.U.S.C.) and Section 504 of the Rehabilitation Act of 1973, and incorporate guidance from the Joint Statement of The Department of Housing and Urban Development and the Department of Justice (DOJ), issued May 17, 2004. PUBLIC POLICIES AND PRACTICES 111 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ Prohibition of Discrimination Against Limited English Proficiency Persons: Obligations of OCHA to ensure meaningful access to the HCVP and its activities by persons with limited English proficiency (LEP). This part incorporates HUD and DOJ's Notice of Guidance, published December 19, 2003 in the Federal Register. H. Community Representation and Participation It is important to provide residents various opportunities to express their concerns about fair housing issues through community involvement and representation. Information from the public provides first hand information on impediments to fair housing choice. As part of the community outreach for this Al, residents, community organizations, housing advocates, fair housing and social service providers, and City staff had numerous opportunities to voice concerns and receive information on fair housing. This was through community fair housing workshops, fair housing surveys, monthly Al Working Group meetings, and interviews with various organization and agencies. In addition, each city offers a variety of ways to receive public input regarding housing issues. Residents can express their concerns through the following: ■ City Level: City residents are given opportunities to provide their housing concerns at city councils and commissions, and in some cities, housing advisory boards have been established. Table 5-6 presents, some of the key public input opportunities by city. ■ County: Orange County, through its Housing and Community Development Division encourages citizen involvement throughout the housing development process, from planning to implementation. Orange County's community participation process promotes involvement from residents of all income levels, persons with disabilities, homeless, minority groups, non-English speaking residents, and from different geographic areas within the County. The County hosts public meetings on a regular basis and provides timely notification and information regarding the purpose of these housing meetings in order to allow for full public participation. ■ Fair Housing Foundation: Eleven of 16 participating cities contract with the Fair Housing Foundation (FHF) to address housing discrimination and other issues. According to the Foundation (in addition to providing services to address discrimination) the FHF conducts a comprehensive, extensive education and outreach program. The purpose of the program is to educate tenants, landlords, owners, Realtors and property management companies on fair housing laws. FHF conducts training sessions with tenants, provide staff booths at public events, and conduct community presentations. ■ Fair Housing Council of Orange County: The Fair Housing Council of Orange County (FHCOC) provides fair housing services to five of the 16 participating cities. FHCOC provides comprehensive community education, individual counseling, mediation, advocacy and other services to try to eliminate housing discrimination. Even though there are a variety of ways for the community to identify impediments to fair housing choice, there may be a need for improvement. Results of the Al housing surveys, shown in the PUBLIC POLICIES AND PRACTICES 112 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Chapter 2 Community Participation, indicate that many residents did not know where to go or who to contact regarding housing discrimination. Over one half (57%) of the respondents indicated that they encountered discrimination, mostly by landlord/property managers (88%). However, one-third of these respondents did not know what to do or where to go when discrimination occurs. Therefore, more information to the public and more opportunities for community involvement will further improve opportunities for fair housing choice. Table 5-6: Community Outreach by Cities Cities Key Outreach Task Anaheim Anaheim has 4 Neighborhood Councils that assist in soliciting citizen input. Buena Park City has a Citizen's Advisory Committee to obtain input Costa Mesa Public meetings are regularly scheduled for the public At least three public meetings are held each year at different times by the Housing Fountain Valley Division of the City. Housing and Community Development Advisory Board encourages public participation Fullerton Minimum of two public hearings are held per year to respond to proposal and questions. Garden Grove Public workshops on housing include inviting service providers to help residents, including those with special needs Huntington Beach HB established the Citizen Participation Advisory Board to represent diverse views on various issues La Habra Established the Citizen Participation Committee to outline strategies and ensure citizen participation Lake Forest City contracts with the Fair Housing Council to work with the community on housing discrimination issues Mission Viejo Surveys, public meetings, hearings, and two commissions that address housing issues Newport Beach City has nearly 40 active boards, commissions and committees, including the Affordable Housing Task Force Orange City contracts with the FHF to assist in providing fair housing services. Rancho Santa Margarita City participation is welcome at regularly scheduled meetings, hearings and/or workshops San Clemente The Las Palmas Leadership Group has had results in obtaining input from underserved residents Santa Ana Regular public meetings are scheduled and encouraged at existing boards/commissions and ad hoc committees Tustin City's Citizen Participation Committee holds regularly scheduled public meetings and makes recommendations to City Council PUBLIC POLICIES AND PRACTICES 113 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 6. Fair Housing Profile Chapter 6 provides an overview of the institutional structure of the housing industry with regard to fair housing practices. In addition, this section discusses the fair housing services available to residents, as well as the nature and extent of fair housing complaints received by the City. Typically, fair housing services encompass the investigation and resolution of housing discrimination complaints, discrimination, auditing/testing, education and outreach, including the dissemination of fair housing information. Tenant/landlord counseling services are usually offered by fair housing service providers but are not considered fair housing. A. Fair Housing Practices in the Homeownership Market In 1996, HUD and the National Association of Realtors (NAR) entered into a Fair Housing Partnership. Article VII of the HUD/NAR Fair Housing Partnership Resolution provides that HUD and the NAR develop a Model of Affirmative Fair Housing Marketing Plan for use by members of the NAR to satisfy HUD's Affirmative Fair Housing Marketing regulations. Even so, discrimination still occurs in the housing market. Homeownership Process One of the main challenges in owning a home versus renting a home is the process. Buying a house takes considerably more time and effort than finding a home to rent. The major legal and financial implications surrounding the process also intimidate potential buyers. People can be overwhelmed by the unique terminologies, the number of steps required, and the financial considerations involved. The process is costly and fair housing issues could surface at any time during this process. Real Estate Associations and Practices National Association of Realtors The NAR has developed a Fair Housing Program to provide resources and guidance to Realtors in ensuring equal professional services for all people. The term Realtor identifies a licensed professional in real estate who is a member of the NAR, however, not all licensed real estate brokers and salespersons are members of the NAR. Article 10 of the NAR Code of Ethics provides that "Realtors shall not deny equal professional services to any person for reasons of race, color, religion, sex, handicap, familial status, or national origin. Realtors shall not be a party to any plan or agreement to discriminate against any person or persons on the basis of race, color, religion, sex, handicap, familial status, or national origin." A Realtor pledges to conduct business in keeping with the spirit and letter of the Code of Ethics. Article 10 imposes obligations on realtors and is a firm statement of support for equal opportunity in housing. A realtor who suspects discrimination is instructed to call the local Board of Realtors. Local Boards of FAIR HOUSING PROFILE 114 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Realtors will accept complaints alleging violations of the Code of Ethics filed by a home seeker who alleges discriminatory treatment in the availability, purchase or rental of housing. Local Boards of Realtors have a responsibility to enforce the Code of Ethics through professional standards, procedures, and corrective action in cases where a violation of the Code of Ethics is proven to have occurred. In addition, Standard of Practice Article 10-1 states that "REALTORS® shall not volunteer information regarding the racial, religious, or ethnic composition of any neighborhood and shall not engage in any activity which may result in panic selling. REALTORS® shall not print, display, or circulate any statement or advertisement with respect to the selling or renting of a property that indicates any preference, limitations, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin." Realtor Fair Housing Declaration. In accordance with the Code of Ethics, each Realtor signs the following pledge, developed in 1996 as a result of the HUD -NAR agreement. The Realtor agrees to: ■ Provide equal professional service without regard to race, color, religion, sex, handicap, familial status, or national origin of any prospective client, customer, or of the residents of any community. ■ Keep informed about fair housing law and practices, improving clients' and customers' opportunities and his/her business. ■ Develop advertising indicating that everyone is welcome and no one is excluded, expanding his/her clients' and customers' opportunities to see, buy or lease property. ■ Inform clients and customers about their rights and responsibilities under the Fair Housing Laws by providing brochures and other information. ■ Document efforts to provide professional service, which will assist him/her in becoming a more responsive and successful Realtor. ■ Refuse to tolerate non-compliance. ■ Learn about those who are different and celebrate those differences. ■ Take a positive approach to fair housing practices and aspire to follow the spirit, as well as the letter, of the law. ■ Develop and implement fair housing practices for his/her firm to carry out the spirit of this declaration. NAR also provides training on working with a diverse population. NAR's training program At Home With Diversity offers information about conducting business in culturally competent ways. It includes updated statistics, fair housing laws, business plan development, and business etiquette. At Home With Diversity addresses the topics of diversity, fair housing and business planning development, and teaches REALTORS' how to: FAIR HOUSING PROFILE 115 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ Assess and understand attributes of diversity in local markets and their impact on the real estate industry ■ Build a business plan and selling strategy to successfully service all client profiles ■ Understand basic competencies to earn the confidence of potential buyers and sellers, regardless of race, ethnicity, religion, gender, handicaps, familial status, or national origin California Association of Realtors The California Association of Realtors (CAR) is a trade association of nearly 170,000 Realtors statewide. As members of this organization, Realtors subscribe to a strict code of ethics. Over the years, CAR's membership better reflects the changing demographics of a diverse state. Through its Leadership Summit meetings, it has grown to include the African American Economic Development Association of REALTORS® and Affiliates (AAEDARA), California Association of Real Estate Brokers (CAREB), National Association of Hispanic Real Estate Professionals (NAHREP), Asian Real Estate Association of America (AREAA), Chinese-American Real Estate Association (CAREA), Chinese Real Estate Association of America (CREAA), Chinese American Real Estate Professionals Association (CAREPA), Filipino American Real Estate Professionals Association (FAREPA), South Asian Real Estate Association of America (SAREAA), Korean Real Estate Brokers Association of Southern California (KREBA), Korean Association of REALTORS° and Lenders (KARL) and the Multicultural Alliance. CAR has three meetings per year, which include sessions on fair housing issues. CAR directs outreach efforts Southern California area to underserved communities, State -licensed brokers, and sales persons who are not CAR members. California Department of Real Estate (DRE) The California Department of Real Estate (DRE) is the licensing authority for real estate brokers and salespersons. As noted earlier, not all licensed brokers and salespersons are members of the national or California Association of Realtors. DRE has adopted education requirements that include courses in ethics and fair housing. To renew a real estate license, each licensee is required to complete 45 hours of continuing education, including three hours in each of four mandated areas: Agency, Ethics, Trust Fund and Fair Housing. The fair housing course contains information that will enable an agent to identify and avoid discriminatory practices when providing real estate services to clients. For the initial renewal on or after January 1, 1996, the law requires, as part of the 45 hours of continuing education, completion of four mandatory three-hour courses in Agency, Ethics, Trust Fund Handling and Fair Housing. These licensees will also be required to complete a minimum of 18 additional hours of courses related to consumer protection. The remaining hours required to fulfill the 45 hours of continuing education may be related to either customer service or consumer protection, at the option of the licensee. FAIR HOUSING PROFILE 116 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Orange County Associations of Realtors The Orange County Association of Realtors is generally the first line of contact for real estate agents who need continuing education courses, legal forms, career development and other daily work necessities. The frequency and availability of courses varies among these associations, and local association membership is generally determined by the location of the broker for which an agent works. Complaints involving agents or brokers may be filed with this association. The monitoring of services by these associations is difficult as statistics on the education/services that the agencies provide or statistical information pertaining to the members is rarely available. Offices of the Orange County Association of Realtors are located at: Laguna Hills 25552 La Paz Road Laguna Hills 92653 Tel: (949) 586-6800 Fax: (949) 586-0382 http://www.ocar.org/# Huntington Beach 8071 Slater Avenue, Ste. 240 Huntington Beach 92647 Tel: (714) 375-9313 Fax: (714) 375-9322 Pacific West Association of Realtors The Pacific West Association of Realtors serves realtors in communities from Long Beach to northern Orange County. They provide many continuing education opportunities to members, including courses on the topics of ethics and professional conduct, trust funds, fair housing, and real estate agency. The Association also has trained mediators on staff that provide extensive mediation services for unresolved issues relating to financial disputes and fair housing issues. Realtors with fair housing questions, or who are in need of additional information, are usually referred to the California Association of Realtors. The Pacific West Association of Realtors also provides resource information on ethics and standards of practice. FAIR HOUSING PROFILE 117 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS B. Fair Housing Practices in the Rental Market Similar to the homeownership market, a major challenge to ensuring fair housing in the rental market is the complexity of the process. There are several stages in the process of renting a home or apartment: 1) the advertising and outreach stage, 2) pre -application inquiries and responses, 3) the criteria for acceptance, 4) the lease and 5) administration of the lease. This section discusses these phases of the rental process. Although a potential homebuyer might face discriminatory practices primarily during the process of purchasing a home, a renter could confront housing discrimination not only during the process of renting but also throughout the tenancy. Rental Process Although the process of renting an apartment may be less expensive and burdensome up -front than the home -buying process, it may still be just as time-consuming. Potential renters might still face discrimination during the various stages of the rental process. Advertising. The main sources of information are the internet, the realtor through the MLS, classified advertisements in local newspapers, word of mouth, and signs. The same types of discriminatory language previously described under the Homeownership Process may be used by landlords or apartment managers to exclude "undesirable elements." Compliance with fair housing laws is difficult to monitor among the large number of small property owners. Outreach to this group is also difficult because many of these owners may not belong to the Apartment Owners or Apartment Managers associations, or do not actively participate in events/trainings offered by these associations. Advertising by small property owners may not always comply with the fair housing laws. For example, rental ads in local Spanish-language newspapers do not always appear in the English-language newspapers, as required by law. Viewing the Unit. Viewing the unit is the most obvious place where potential renters could encounter discrimination because landlords or managers might discriminate based on race or disability, or judge on appearance whether a potential renter is reliable or might violate any of the rules. For example, a participant at a fair housing workshop conducted for this Al, indicated that a manager frowning on the presence of young children accompanying a viewer. Discrimination against families with children and people with disabilities is even more prevalent than racial discrimination. Credit/Income Check. Landlords may ask potential renters to provide credit references, lists of previous addresses and landlords, and employment history/salary. The criteria for tenant selection, if any, are typically not known to those seeking to rent. Many landlords often use credit history as an excuse when trying to exclude certain groups. Recent legislation provides for applicants to receive a copy of the report used to evaluate applications. In addition, applicants may also request a copy of their credit report (for a fee) to verify that the information used to approve/deny their application is accurate. Lease. Most apartments are rented under either a lease agreement or a month-to-month rental agreement. A lease is favorable from a tenant's point of view for two reasons: the tenant is assured FAIR HOUSING PROFILE 118 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS the right to live there for a specific period of time and the tenant has an established rent during that period. Most other provisions of a lease protect the landlord. Information written in a lease or rental agreement includes the rental rate, required deposit, length of occupancy, apartment rules and termination requirements. In a tight housing market, when a landlord can "financially afford" to choose tenants, the tendency is to offer shorter lease terms. In this case, a landlord might simply ask the "not -so -desirable" tenant to leave with a 60 -day Notice to Vacate. Short-term leases also allow the landlord to raise rent more frequently. Typically, the lease or rental agreement is a standard form completed for all units within the same building. However, the enforcement of the rules contained in the lease or agreement might not be standard for all tenants. A landlord might act in a discriminatory way and choose strict enforcement of the rules for certain tenants based on arbitrary factors, such as race, presence of children or disability. Because of the recent escalation of housing prices throughout California, complaints regarding tenant harassment through strict enforcement of lease agreements as a means of evicting tenants have increased. Security Deposit. A security deposit is typically required to rent a housing unit. To deter "less -than - desirable" tenants, a landlord might ask for a security deposit higher than usual. Tenants could also face differential treatment when vacating the units. The landlord might choose to return a smaller portion of the security deposit to some tenants, claiming excessive wear and tear. A landlord might require that persons with disabilities with service animals pay an additional pet rent, a monthly surcharge for pets or a deposit, which is also a discriminatory act. During the Tenancy. During tenancy, the most common forms of discrimination a tenant could face are based on familial status, race, national origin, sex or disability. Usually these types of discrimination appear in differential enforcement of rules, overly strict rules for children, excessive occupancy standards, and refusal to make a reasonable accommodation for handicapped access, refusal to make necessary repairs, eviction, notices, illegal entry, rent increases or harassment. These actions may be used as a way to force undesirable tenants to move on their own without the landlord having to make an eviction. Rental Associations and Practices California Apartment Association. The California Apartment Association (CAA) is the country's largest statewide trade association for rental property owners and managers. The CAA was incorporated in 1941 to serve rental property owners and managers throughout California. The CAA represents rental housing owners and professionals who manage more than 1.5 million rental units. Under the umbrella agency, various apartment associations cover specific geographic areas. The CAA has developed the California Certified Residential Manager (CCRM) program to provide a comprehensive series of courses geared toward improving the approach, attitude and professional skills of onsite property managers and other interested individuals. The CCRM program consists of 31.5 hours of instruction that includes training on fair housing and ethics issues. FAIR HOUSING PROFILE 119 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS The CAA supports the intent of all local, state and federal fair housing laws for all residents without regard to color, race, religion, sex, marital status, mental or physical disability, age, familial status, sexual orientation or national origin. Members of the CAA agree to abide by the following provisions of the organization's Code for Equal Housing Opportunity: ■ We agree that in the rental, lease, sale, purchase, or exchange of real property, owners and their employees have the responsibility to offer housing accommodations to all persons on an equal basis, ■ We agree to set and implement fair and reasonable rental housing rules and guidelines and will provide equal and consistent services throughout our residents' tenancy; ■ We agree that we have no right or responsibility to volunteer information regarding the racial, creed, or ethnic composition of any neighborhood, and we do not engage in any behavior or action that would result in steering; and ■ We agree not to print, display, or circulate any statement or advertisement that indicates any preference, limitations, or discrimination in the rental or sale of housing. C. Fair Housing Services Fair housing services include the investigation and resolution of housing discrimination complaints, discrimination auditing/testing, and education and outreach, including the dissemination of fair housing information such as written material, workshops, and seminars. Landlord/tenant counseling services involves informing landlords and tenants of their rights and responsibilities under the California Civil Code and mediating conflicts between tenants and landlords. There are two private non-profit organizations that provide fair housing programs and services to Orange County residents. The Fair Housing Council of Orange County (FHCOC) and the Fair Housing Foundation (FHF) are the primary organizations providing fair housing services. Fair Housing Council of Orange County The Fair Housing Council of Orange County, which was established in 1965, provides fair housing service to the cities of Fountain Valley, La Habra, Lake Forest, Rancho Santa Margarita, and Santa Ana. Fair housing services include discrimination counseling, intake, investigation, and resolution, landlord/tenant fair housing counseling, mediations and training, certificate management training, community outreach, and fair housing education to cities. As part of the FHCOC's education and counseling service, its team provides one-on-one education, mediation, and counseling for individuals and families throughout Orange County and is a HUD Approved Housing Counseling Agency. Fair Housing Council of Orange County 1516 Brookhollow Drive, Suite A Santa Ana, CA 92705 714.569-0823 or 800.698.FAIR FAX: 714.835-0281 http://www.fairhousingoc.org/ FAIR HOUSING PROFILE 120 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Fair Housing Foundation The Fair Housing Foundation has provided programs and services for the elimination of housing discrimination, general housing assistance, and education and outreach activities to cities since 1964. Among the 16 cities participating in this Al, FHF provides fair housing services to the cities of Anaheim, Buena Park, Costa Mesa, Fullerton, Garden Grove, Huntington Beach, Mission Viejo, Newport Beach, Orange, San Clemente, and Tustin. The objective of FHF is to affirmatively further fair housing in the City through a program comprised of services formulated to address the issues specific to their service cities. Those components include but are not limited to: ■ General Housing counseling, mediations, unlawful detainer assistance, and referrals to tenants, landlords, managers, and rental property owners ■ Discrimination counseling, complaint intake, in-depth testing, and resolution ■ Audits of housing practices based on areas of concern uncovered through counseling and testing ■ Education and Outreach services target specific areas and concerns. Education and training to Housing Consumers, and Housing Providers ■ Workshops and presentations designed to educate the public on fair housing laws and issues ■ Tester and other volunteer training ■ Promoting media interest in eliminating housing violations The FHF has two office locations: Fair Housing Foundation 3605 Long Beach Boulevard, Suite 302 Long Beach, CA 90807 562-989-1206 800-446-3247 FAX 562-989-1836 http://www.fairhousingfoundation.com/ Fair Housing Foundation 600 W. Santa Ana Boulevard, Suite 214A Santa Ana, CA 92701 714-918-8001 800-446-3247 FAIR HOUSING PROFILE 121 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS D. Fair Housing Statistics and Trends A key service provide by both the Fair Housing Council of Orange County and the Fair Housing Foundation is the handling of fair housing complaints filed by residents in their service cities. The following discussion summarizes the results of fair housing services provided by both organizations to each city in the Regional Al. Table 6-1 displays the number and type of fair housing cases for fiscal years 2012/13, 2013/14 and 2014/15. As presented in Table 6-1, during the last three fiscal years, there were 254 discrimination cases in the 16 cities participating in the Regional Al. The City of Tustin, with a population of about 80,000, had the highest number of discrimination cases at 32, which represents 12.6 percent of the total discrimination cases in the 16 cities. This was closely followed by Garden Grove and Huntington Beach, both at 31 cases or 12.2 percent of the total cases. The City of Anaheim had 29 cases during the same three-year period and accounted for 11.4 percent of the total. Rancho Santa Margarita had no discrimination cases during the last three years. A comparison of the types of discrimination cases shows that over one-half (53.9%) of the total cases were related to a person's disability -- including both mental and physical disabilities. The next highest number of discrimination cases were related to familial status, which includes the presence of children under age of 18 and pregnant women, comprising 21.2 percent of the total 254 cases. National origin and race were also frequent bases for alleged discrimination, representing 11.6 percent and 7.5 percent of all cases, respectively. As the table shows, there were no discrimination cases based on age or religion. Of the 254 fair housing cases opened by the Fair Housing Foundation and Fair Housing Council of Orange County within the 16 cities during fiscal years 2012/13 to 2014/15, approximately 38 percent were found by investigation that discrimination did in fact occur. In slightly fewer cases (34.7%), the fair housing provider did not find sufficient evidence to indicate potential fair housing violations. Another one-quarter of the cases were inconclusive, with 2.8 percent pending an outcome. FAIR HOUSING PROFILE 122 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Source: Fair Housing Council of Orange County and Fair Housing Foundation FAIR HOUSING PROFILE 123 Table 6-1: Discrimination Cases by Protected Class: 2012/13 - 2014/15 I- Source Familial National of Disability Origin •Income Age Arbitrary M Emi Anaheim 0 0 12 6 0 0 4 4 0 3 0 29 11.4% Buena Park 0 0 10 2 0 0 0 3 0 1 0 16 6.3% Costa Mesa 2 0 12 4 1 0 4 2 0 0 0 25 9.8% Fountain Valley 0 0 2 1 0 0 0 0 0 0 0 3 1.2% Fullerton 0 0 14 3 0 2 3 2 0 0 0 24 9.4% Garden Grove 0 0 15 6 0 0 5 4 0 0 1 31 12.2% Huntington Beach 0 0 23 6 1 0 0 0 0 0 1 31 12.2% La Habra 0 0 3 4 0 0 1 1 0 0 0 9 3.5% Lake Forest 0 0 1 0 0 0 0 0 0 0 0 1 0.4% Mission Viejo 0 0 4 1 0 0 1 0 0 0 0 6 2.4% Newport Beach 0 0 4 1 0 0 1 1 0 0 0 7 2.8% Orange 0 0 6 3 0 0 3 0 0 0 0 12 4.7% Rancho Santa Margarita 0 0 0 0 0 0 0 0 0 0 0 0 0.0% San Clemente 0 0 3 2 0 0 3 0 0 0 0 8 3.1% Santa Ana 0 1 11 3 0 0 4 1 0 0 0 20 7.9% Tustin 0 1 17 11 0 1 1 1 0 0 0 32 12.6% Total 2 2 137 53 2 3 30 19 0 4 2 254 100.0% Source: Fair Housing Council of Orange County and Fair Housing Foundation FAIR HOUSING PROFILE 123 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS E. Tenant -Landlord Services In addition to services directly related to fair housing, the Fair Housing Foundation (FHF) and Fair Housing Council of Orange County (FHCOC) provide services related to general landlord/tenant issues. Both landlords and tenants contact the FHF and FHCOC regarding a multitude of issues, such as lease terms, repairs and unlawful detainers. Each organizations' Housing Counselors resolve general housing inquiries through a variety of methods: ■ Counsel and resolve: Well over 80 percent of all landlord or tenant calls are resolved without further referrals. Many client issues can be resolved through counseling by informing them of the law, civil codes, rights and responsibilities, and the remedies available to them ■ Unlawful Detainer Assistance: Clients receiving Unlawful Detainers can contact the fair housing provider in their city, make appointments and receive assistance with completing their paperwork. Although FHF and FHCOC staff will not represent the client in court, agency staff will attend the Unlawful Detainer hearing and speak as a witness when requested. ■ Mediations: The fair housing agencies also use mediations to resolve disputes. In mediation, agency staff acts as a neutral third party to facilitate dispute resolution between two disagreeing parties. In order to mediate, both parties must want the mediation and agree to enter into good faith resolution agreements. ■ Referrals: Many clients contact their fair housing agency for problems not related to fair housing or general housing issues or require services not provided by the agency such as on- site health department reviews. In these cases, the agency provides referrals to other resources for assistance. Table 6-2 provides a breakdown of the number of residents and landlords in the 16 participating cities provided with general housing counseling, mediation, unlawful detainer assistance and referral services over the past three years (2012/13 - 2014/15). Combined, the FHF and FHCOC handled over 24,000 complaints or requests for assistance, with the most prevalent issues as follows: ■ Lease Terms - 25% ■ Notices - 21% ■ Repairs and Maintenance - 13% ■ Security Deposits - 7% ■ Unlawful Detainer - 6% ■ Harassment and Retaliation - 5% ■ General Information - 5% FAIR HOUSING PROFILE 124 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 6-2: Tenant/Landlord Complaints and Inquiries 2012/13 - 2014/15 Lease Terms 6,013 2,546 24 63 109 57 295 391 117 135 35 Notices 5,174 1,494 141 253 67 243 111 430 104 96 54 Repairs, Maintenance 3,264 1,101 112 174 63 196 225 333 59 28 52 Security Deposit 1,600 414 53 70 39 94 106 179 31 25 27 Unlawful Detainer 1,345 441 25 32 20 45 54 94 33 23 12 Harassment/Retaliation 1,310 336 35 58 21 57 63 101 20 10 17 Other, General Information 1,171 215 57 64 13 102 103 87 14 14 21 Rentlncrease 673 164 24 44 7 51 48 47 8 10 7 Self -Help Eviction, Relocation 582 83 28 48 6 57 72 49 2 3 11 Nuisance 501 117 13 26 6 22 32 47 22 7 4 Entry by Landlord 459 147 9 6 12 18 5 48 8 10 4 Disability Accommodation 449 72 16 33 5 36 41 73 5 2 13 Reimbursement/Receipts 325 169 15 26 7 4 Lockout 251 99 1 2 7 5 2 16 6 10 1 Utilities 234 46 8 10 7 13 18 19 6 6 Discrimination 168 40 11 7 3 11 7 15 1 5 3 Late Fees 140 40 3 2 8 7 7 4 2 Housing Assistance Info 140 41 4 5 2 1 12 17 3 3 1 Pets 130 47 3 6 2 8 9 15 2 4 Parking 128 48 1 5 3 4 4 2 2 4 Abandonment 92 20 6 6 4 3 14 4 2 2 Guests and Subtenants 78 31 3 5 1 Personal Belongings 77 37 1 5 2 2 Total 24,304 7,748 524 914 1 401 1,030 1,2281 2,012 456 400 273 Source: Fair Housing Council of Orange County Quarterly Reports, Fair Housing Foundation Annual Reports. Compiled by Karen Warner Associates, Inc. Data missing for cities for the following quarters: Anaheim (QI 2013114), La Habra (Q1 - Q4 2014115) FAIR HOUSING PROFILE 125 74 270 109 92 325 40 85 215 21 60 101 38 4 79 8 25 76 14 62 79 14 25 63 13 27 39 3 8 38 9 13 33 21 34 29 2 22 5 8 3 2 19 5 5 14 17 1 10 1 4 15 2 3 9 1 7 2 3 9 1 5 1 8 2 527 1,473 358 27 1,702 59 90 1,498 136 49 755 96 41 266 56 14 449 12 18 413 46 33 217 76 23 110 29 32 88 34 13 128 9 4 113 8 11 43 34 77 91 3 65 7 6 23 17 2 47 6 6 16 8 19 2 46 1 13 4 32 20 373 6,231 639 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS F. Hate Crimes Hate crimes are committed because of a bias against race, religion, sexual orientation, ethnicity, disability, gender, and gender identity. In an attempt to determine the scope and nature of hate crimes, the Federal Bureau of Investigation's (FBI) Uniform Crime Reporting Program collects statistics on these incidents. Hate crimes provide insight into the context of discrimination occurring in a jurisdiction. As presented in Table 6-3, based on the most recent five years of FBI hate crime statistics (2010- 2014), all the 16 Al participating cities reported some level of hate crime. In total, 169 incidents of hate crime were reported in the 16 -city Al region. Of the types of hate crimes (bias motivation), 57 incidents were related to race, 38 to religion, 37 to sexual orientation, 33 to ethnicity, and 2 to disability and 2 to gender identity. The Orange county Human Relations Commission reports that race/ethnicity continues to be the most common motivation for hate crimes (37%), followed by religion (29%). During the five year period, nearly 60 percent of the total 169 hate crimes in the 16 participating cities occurred within the following four jurisdictions: Huntington Beach (36 incidents), Santa Ana (31 incidents), Newport Beach (18 incidents), and Garden Grove (15 incidents). Services for Hate Crime Victims Both the State and County have programs providing assistance to hate crime victims. The Office of Attorney General has established an Office of Victims' Services that provides advocacy, support, educational and referral services. The aims of this Office are to help victims and their families understand their rights, help them get the support they need, and to guide them through the criminal justice system. The Office of Attorney General also has a Hate Crime Prevention Program Manager. In 1991 the Orange County Human Relations Commission formed the Hate Crime Network to bring together representatives from law enforcement, community organizations, and the Orange County District Attorney, California Attorney General and the United States Attorney General's offices to facilitate the sharing of current hate crime issues. The Network is dedicated to creating a united voice against hate, developing resources for victims of hate, and building an appreciation of diversity in the community. Some of its objectives are: ■ To Increase immediate and effective assistance to victims of hate. ■ To address the under -reporting of hate crimes and hate incidents in our communities ■ To build and develop collaborations between community organizations and law enforcement ■ To educate communities about roots and trends of hate crimes and hate incidents Periodic meetings of the Network are held and open to the public, listed on the OC Human Relations Calendar of Events http://www.ochumanrelations.org/hatecrime/hate-crime-victim-assistance- partnership/#sthash.0il5GUKh.dpuf FAIR HOUSING PROFILE 126 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS The Orange County Human Relations Commission collects hate crime and incident data from law enforcement agencies, prosecutors, community organizations, and hate crime and incident victims. The data is then analyzed and compiled into an annual report, which is broadly disseminated to policy -makers, law enforcement agencies, community groups and educators throughout Orange County. The information presented in these reports allows all parties to better understand hate crime and incident trends; measure the outcome of their work; and, direct prevention campaigns in their communities or schools. The reports also serve to advise policy decisions and inform the development of services for victims of hate. Source: F81 Uniform Crime Report, 2010-2014 Hate Crime Statistics ' 2013 was the first year F81 began tracking hate crimes based on gender identity. FAIR HOUSING PROFILE 127 Table 6-3: FBI Hate Crime Statistics 2010-2014 ims Number of Incidents per Bias Motivation M Anaheim 3 1 2 1 7 Buena Park 2 - 3 3 8 Costa Mesa 2 2 2 2 8 Fountain Valley 2 1 2 - 1 6 Fullerton - - 1 - - 1 Garden Grove 6 2 3 4 - - 15 Huntington Beach 15 9 4 7 - 1 36 La Habra 5 1 1 - - - 7 Lake Forest 3 - 1 1 - 1 6 Mission Viejo 3 2 - 2 - - 7 Newport Beach - 12 3 3 - 18 Orange 3 3 1 2 - 9 Rancho Santa Margarita 1 1 - - - 2 San Clemente 1 1 1 1 - 4 Santa Ana 10 2 13 5 1 31 Tustin 1 1 - 2 - - 4 Total 57 38 37 33 2 2 169 Source: F81 Uniform Crime Report, 2010-2014 Hate Crime Statistics ' 2013 was the first year F81 began tracking hate crimes based on gender identity. FAIR HOUSING PROFILE 127 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 7. Progress Since 2010 This chapter summarizes private and public sector impediments identified in the prior Al and the region's progress in implementing actions to address these impediments. The continued existence of these impediments, along with the appropriateness of identified actions to be carried forward in the 2016-2020 Al are also evaluated. The following two Als are evaluated: ■ Orange County Regional Analysis of Impediments to Fair Housing Choice 2010-2015 ■ Cities of Costa Mesa, Mission Viejo, San Clemente, and Tustin Analysis of Impediments to Fair Housing Choice 2010-2015 A. Status of 2010-2015 Orange County Regional Al Actions The 2010-2015 Orange County Regional Analysis of Impediments to Fair Housing Choice (AI) identified the following private sector impediments: ■ Housing Discrimination ■ Discriminatory Advertising ■ Denial of Reasonable Accommodation ■ Hate Crimes ■ Unfair Lending These regional impediments have not been eliminated, and have thus been carried over into the 16 Orange County Cities Regional Analysis of Impediments for the 2015-2020 period. The following section summarizes the actions identified in the 2010-2015 Orange County Regional Al to address identified impediments, and the progress made by the Orange County Fair Housing Council in implementing these actions. Housing Discrimination Housing discrimination, especially in the rental housing market, is an impediment to fair housing choice. The Fair Housing Council of Orange County (FHCOC) opens an average of 50 cases on an annual basis for allegations of housing discrimination. Actions to be Taken 1. Continue to process housing discrimination complaints filed by city and county residents. PROGRESS SINCE 2010 128 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 2. Conduct testing of housing provider practices to determine whether there are differences in treatment based on a protected class. 3. Revise FHCOC website to provide direct access to a housing discrimination complaint form and provide an explanation of the process for investigating and resolving a complaint. 4. Revise FHCOC website to add more information on how residents can detect whether they have been victims of unlawful housing discrimination. 5. Publish a quarterly report on the FHCOC website summarizing the remedies pertaining to filed housing discrimination complaints. 6. Ensure that all jurisdictions provide a link to the FHCOC website. 7. Compile an Annual Report on housing discrimination complaints filed with the FHCOC, the DFEH and HUD, and transmit to participating jurisdictions. Progress ■ During the 2011/12 - 2014/15 period, the Fair Housing Council of Orange County (FHCOC) opened a total of 236 case files for allegations of housing discrimination in its client cities and the County. ■ During the same time period, the FHCOC addressed housing -related inquiries from 15,137 unduplicated clients. These inquiries were screened for possible issued of housing discrimination and clients were provided counseling on their fair housing rights, obligations and remedies. ■ During 2011/12 - 2014/15, FHCOC conducted 561 paired, on-site, systemic tests for discriminatory housing practices in both for -sale real estate brokerage transactions and rental housing transactions. ■ FHCOC's website currently has an on-line contact form that can be used housing discrimination complaint reporting. The tool generates an e-mail to FHCOC. It is often used for complaints for other, non-discrimination, housing -related issues. ■ FHCOC has received a grant under the HUD Fair Housing Initiatives Program (FHIP), Education and Outreach Initiative (EOI) that included $14,000 in funding for web site improvements. Work has begun and will include the improvements identified in the Al. These will include upgrades to help further differentiate between discrimination and non-discrimination complaints. Also, information regarding the process of investigating and resolving complaints will be added. Discriminatory Advertising Rental housing ads that state "no pets" or indicate rental discounts for seniors are impediments to fair housing choice because they make housing unavailable to disabled persons and the non -elderly. "No Section 8" ads may become an impediment to fair housing choice because they could make housing unavailable disproportionately to a protected class such as persons with disabilities. PROGRESS SINCE 2010 129 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Actions to be Taken 1. Encourage the Orange County Register to publish a Fair Housing Notice in the for rent classified ad section and to identify the FHCOC as an agency that can respond to fair housing questions. Encourage apartment rental websites to display more prominently their Fair Housing Notice. 2. Encourage the Los Angeles Times and Orange County Register to publish a "no pets" disclaimer that indicates rental housing owners must provide reasonable accommodations, including "service animals" and "companion animals" for disabled persons. 3. Support an amendment to the Communications Decency Act of 1996 to state no provider or user of an interactive computer service shall be treated as the publisher or speaker of any information provided by another information content provider, except for notices, statements, or advertisements with respect to the sale, rental, financing or insuring, or any other service of a dwelling that violate the Fair Housing Act. 4. Periodically review for rent and for sale ads published in the print media. 5. Prepare a summary of the accomplishments each year and transmit to the Urban County and participating cities. Progress ■ FHCOC periodically reviewed rental advertisements in the LA Times, the OC Register and other local weekly newspapers. This review did not find any overtly discriminatory advertisements, although ads were observed statements possibly presenting impediments, including stating 'no pets' without distinguishing that assistance animals would be allowed, or the use of phrases like 'active senior living' in advertising for senior housing that could discourage individuals with a disability. Additionally, many ads lacked any affirmative marketing language or symbols, such as the use of the phrase 'equal housing opportunity' or the display of HUD's 'equal housing' logo. ■ FHCOC also periodically reviewed advertising for Orange County rentals listed on Craigslist for discriminatory content. Any discriminatory ads were either flagged as prohibited, responded to in order to inform the poster of possible discriminatory content, brought to the attention of Craigslist, or referred to FHCOC investigators for possible enforcement action. Problematic postings indicated restrictions with regard to children under the age of 18 or improper preference for seniors or 'older adults' for housing opportunities that did not appear to qualify as housing for older persons. ■ Additional issues of potentially discriminatory content were found in postings in the roommates/shared listings. These typically dealt with religious, national origin, race or sexual orientation preferences or limitations. Given recent court decisions holding that such preferences might be permissible in shared housing situations, attempting to obtain correction or removal was a low priority of the FHCOC. PROGRESS SINCE 2010 130 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Denial of Reasonable Accommodation Denial of a reasonable modification or reasonable accommodation is an impediment to fair housing choice because they account for almost one-fifth of all alleged discriminatory acts. Actions to be Taken 1. Provide education and information on why this practice is unlawful to the owners and managers of apartment complexes and homeowner associations. 2. Provide information on the unlawful practice of denying reasonable modifications/ reasonable accommodations at fair housing seminars conducted by the Apartment Association of Orange County. Progress ■ FHCOC responded to inquiries regarding reasonable accommodations and modifications, and directly assisted numerous clients to request and receive a reasonable accommodation or permission for a reasonable modification. In instances where clients were denied or effectively denied their requested accommodation, FHCOC assisted in them in filing an administrative housing discrimination complaint with the Fair Housing and Equal Opportunity (FHEO) Office of the U.S. Department of Housing and Urban Development. ■ FHCOC provided training to rental property owners and managers through training seminars which addressed requirements for reasonable accommodations. ■ FHCOC conducted fair housing seminars in cooperation with the Apartment Association of Orange County. The curriculum included discussion of reasonable accommodations and modifications. Hate Crimes Hate crimes committed at a residence are an impediment to fair housing choice because they impact the lives of 20-30 households per year. Almost one-half of all hate crime events in Orange County had an anti -Black or anti -Latino bias motivation. Actions to be Taken 1. Coordinate with the Orange County Human Relations Commission, Center OC and the Orange County Victim Assistance Partnership. 2. Provide affected residents — when needed - with referrals to hate crime victim resources. Progress ■ On the rare occasion FHCOC is contacted by a victim of a hate crime occurring at their residence, the FHCOC refers them to the O.C. Human Relations Commission, while still possibly taking their fair housing complaint. PROGRESS SINCE 2010 131 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Unfair Lending Disparities in the loan denial rates experienced by Hispanic and Black/African applicants create an impediment to fair housing choice as they have loans denied at rates 1.5 to 2.0 times greater than White applicants. Actions to be Taken 1. Monitor the HMDA data annually using the 2008 HMDA analysis as a benchmark. 2. Complete a HMDA analysis of the top 10 lenders in Orange County to compare and contrast loan denial rates. 3. Conduct a follow-up analysis of loan denial rates at the neighborhood level to determine to what extent, if any, redlining may exist in Orange County. This follow-up will be completed when Census 2010 data are available on minority populations at the census tract level. The Census 2010 data will enable an analysis of loan activity and minority population characteristics for the same time period. 4. Conduct outreach to cultural, ethnic and minority organizations to potentially increase interest and readiness in home purchases. 5. Provide homebuyer education programs in neighborhoods with high denial rates, high minority population concentrations and limited English speaking proficiency to help increase loan approval rates. Progress ■ As part of its outreach efforts FHCOC informs individuals and organizations of its services, which include housing counseling for individuals seeking to become ready for a home purchase. FHCOC participates in numerous education and/or outreach activities, reaching a culturally and ethnically diverse audience, in which they inform participants of fair housing laws and of their counseling services. ACTIONS TAKEN BY FHCOC TO AMELIORATE PUBLIC SECTOR IMPEDIMENTS As part of the Fair Housing Action Plan developed in conjunction with the Regional Al, FHCOC will provide technical assistance to cities that have identified public sector impediments in the following areas: ■ Family definition inconsistent with fair housing laws ■ Lack of a definition of disability ■ Lack of a reasonable accommodation procedure ■ Lack of zoning regulations for special needs housing ■ Lack of a fair housing discussion in zoning and planning documents ■ Compliance with HUD AFFH requirements PROGRESS SINCE 2010 132 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS The most common public sector impediments are: ■ The zoning regulations do not define "disability". ■ The zoning regulations do not define "supportive" and "transitional housing" as required by Government Code Section 65583(a)(5). ■ Some cities have not adopted a reasonable accommodation procedure. ■ The zoning regulations do not discuss housing for "special needs" populations. ■ The zoning regulations do not discuss fair housing. a. Definition of Disability Question #3 asks: Does the code or any policy document define 'disability, if at all, at least as broadly as the federal Fair Housing Act? Almost all cities do not define "disability." Those cities with an adopted reasonable accommodation procedure define disability in the procedure. b. Supportive Housing Question #5 asks: Does the code limit housing opportunities for disabled individuals through restrictions on the provision of on-site supportive services? Government Code Section 65583(a)(5) requires local zoning to treat supportive and transitional housing as a residential use and subject only to those restrictions that apply to other residential uses of the same type in the same zone. For example, if transitional housing is a multifamily use proposed in a multifamily zone, zoning should treat transitional housing the same as other multifamily uses proposed in the zone. The purpose of Government Code Section 65583(a)(5) is to address the need for housing for the disabled. The population to be served by supportive and transitional housing is people with different kinds of disabilities. Actions by the entitlement cities and Urban County to provide zoning regulations will eliminate a potential impediment to the development of such housing. c. Reasonable Accommodation Procedure Question #7 asks: Does the jurisdiction have, either by ordinance or policy, a process by which persons with disabilities can request reasonable accommodations (modifications or exceptions) to the jurisdiction's codes, rules, policies, practices, or services, necessary to afford persons with disabilities an equal opportunity to use or enjoy a dwelling? Many cities have not yet adopted a reasonable accommodation procedure. Cities without an adopted procedure have stated in their housing elements that they intend to enact such a procedure pursuant to the requirements of state law. d. Special Needs Zoning Question #20 asks: Does the zoning code or other planning document address housing for "special needs" populations. PROGRESS SINCE 2010 133 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Most cities answered this question in the affirmative. However, the documents addressing special needs housing was typically a housing element and not the zoning code. Consequently, most cities do not have zoning regulations that describe development standards for special needs populations such as: homeless people, victims of domestic violence, people with disabilities, and people living with HIV/AIDS, all of whom have direct fair housing implications. Entitlement cities and the Urban County should consider enacting special needs housing zoning regulations. e. Fair Housing Discussion Question 24 asks: Does the zoning ordinance or other planning or policy document include a discussion affair housing? Most cities answered this question in the affirmative. However, the document discussing fair housing was typically a housing element and not the zoning code. Consequently, most cities do not have zoning regulations that discuss fair housing. Entitlement cities and the Urban County should consider enacting fair housing zoning regulations. ACTIONS TO BE TAKEN BY THE FHCOC AND CITY TO AMELIORATE OR ELIMINATE PUBLIC SECTOR IMPEDIMENTS. a. Actions to be Taken by the FHCOC The FHCOC will provide technical assistance to cities that have identified public sector impediments in the following areas: ■ Family definition inconsistent with fair housing laws ■ Lack of a definition of disability ■ Lack of a reasonable accommodation procedure ■ Lack of zoning regulations for special needs housing ■ Lack of a fair housing discussion in zoning and planning documents ■ Compliance with HUD AFFH requirements The technical assistance will consist of providing background information on the above impediments and model ordinances or regulations that adequately address the fair housing concerns posed by the impediments. PROGRESS SINCE 2010 134 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS B. Status of 2010-2015 Sub -Regional Al Actions (Cities of Costa Mesa, Mission Viejo, San Clemente, and Tustin) Identified Impediments The Sub -Regional Al identified the following impediments to fair housing choice in the four cities: ■ Areas of racial/ethnic concentrations in each City indicate that residential patterns are evident; however, they do not indicate the reasons behind the patterns. Given that many of the ethnically concentrated areas do not overlap the low- and moderate -income areas, the trends are likely related to other factors. Each of the Cities may need to target these areas with fair housing services, education/outreach, and/or additional testing to ensure that these patterns are related to individual preferences and not a discriminatory force within the market. ■ Residents who speak Spanish at home represented the majority of linguistically isolated households in each jurisdiction. These language barriers may prevent residents from accessing services, information, housing, and may also affect educational attainment and employment needed to earn higher incomes. ■ Analyzing tenure by race indicates that minorities are significantly underrepresented in the ownership market. ■ When looking at overcrowding by race and ethnicity, the 2000 Census shows that the percentage of overcrowded households is significantly higher for Hispanic households, though it is unclear if this is a cultural preference, result of socio-economic status, or intentional discrimination. ■ Housing designated for persons living with AIDS is scarce and many of these people encounter discrimination (based on interviews with service providers). In addition, complaints involving bias against persons with disabilities, denial of reasonable accommodations, and the availability of accessible housing is a growing concern. ■ The housing stock contains a significant amount of older units that may potentially contain lead-based paint. In addition, lower income households tend to live in the older housing stock since it is more affordable. While there were relatively few cases of elevated blood levels reported during the last five years, all of the cases involved children of Hispanic ethnicity. Given this group also reported earning lower incomes, outreach and education efforts may need to be expanded to include Hispanics and residents in the low- and moderate -income areas. ■ Given the demographics of each City, Asians appear underrepresented as there were no complaints received by the fair housing service providers from this group in any of the four Cities (with the exception of one complaint from San Clemente). Yet, it is difficult to PROGRESS SINCE 2010 135 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS determine the significance of this trend, because of the large number of complaints that declined to state their race/ethnicity in each City. ■ Discrimination based on Disability (physical and mental), Race, and Familial Status constituted the majority of complaints received by the fair housing service provides within each City. These categories also represented the majority of protected classes of cases filed with HUD, FHEO, and DFEH. Moreover, there was a consistent pattern of the top three allegations including eviction, denial of a reasonable accommodation and unequal terms. These topics may need to be emphasized in outreach efforts and/or targeted to landlords through literature. Bias against physical and mental disability, familial status, sex, race, and retaliation should also receive focus in education and outreach materials. ■ Bias against race and/or ethnicity appears to be the biggest motivator of hate crimes within each of the four Cities. ■ While each City has tried to provide for the accommodation of affordable housing, residents have sought to block affordable housing developments due to not in my backyard (NIMBY) sentiments; several of which involved Homeowner's Associations (HOAs). ■ While most of the impediments listed in previous AI's do not appear to still exist in each of the four Cities, fair lending and education and outreach services pertaining to fair housing laws (especially to immigrant populations) does continue to be a need in each jurisdiction. ■ The disparate impact of credit scoring and loan approval rates (since the use of credit scores are still widely used in lending) also appears to remain a concern since the last Al. ■ The pattern of Whites having higher approval rates than minority groups has not changed since the last Al and Hispanics represented a significant portion of loan applications received with substantially lower approval rates in each City. ■ Lack of advertising by lenders in particular neighborhoods is one area which may be of concern due to the lack of home purchase loan applications received by African Americans and Hispanics. ■ The current housing market has resulted in many new concerns that were not present during the last Al, which may provide opportunities for additional incidents of discrimination including: foreclosures, loan modifications, short sales, and real estate owned (REO) properties that have flooded the market. Proposed Actions to Address Identified Impediments The following actions were proposed in the Sub -Regional Al to address identified impediments to fair housing choice. A summary of the Fair Housing Foundation and the four partner cities progress made in implementing these actions is identified after each. Action 1: Each City should consider providing a Housing Page on its website that provides links to the fair housing service provider and other agencies that provide related services. Access to program information in Spanish should also be provided or links to agencies that provide information in Spanish, such as OCAR's link to agents who speak various languages, DRE's Spanish webpage, and PROGRESS SINCE 2010 136 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS HUD's Spanish webpage. [This will address impediments involving language barriers, access to information, racial disparity in the ownership and lending markets, NIMBYism, and disproportionate complaints.] Timeframe: By the end of FY 2010-11, and annually thereafter. Progress: The Cities of Tustin, San Clemente, Costa Mesa, and Mission Viejo have updated their websites to provide information regarding education opportunities and links to the Fair Housing Foundation (FHF). Information was also provided in Spanish in Costa Mesa. The FHF has reported that during this Consolidated Plan period, 17,754 hits to their website have been received, and as of current, they have 187 Facebook, and 65 Twitter followers. Action 2: Each City should explore ways to collaborate with local lenders (especially the top ten), real estate agents, and special networks for Hispanic, African American and Asian professionals within these groups to develop and expand marketing efforts for services provided by each group within each of the low- and moderate -income and racial/ethnic concentrated areas. Collaborative efforts should ensure that various racial/ethnic groups have access and knowledge of City programs, supportive services, and provide for networking opportunities with these groups such as a housing fair or similar event. Services providers for those with special needs, especially the disabled and those living with HIV/AIDS, should also be included. [This will address impediments involving language barrier, access to information, racial disparity in the ownership and lending markets, and problems faced by those with special needs.] Timeframe: By the end of FY 2010-11, and annually thereafter. Progress: FHF has provided fair housing trainings throughout the sub -region and currently provides trainings for landlords, managers, realtors, and other housing providers on a regular basis. The FHF regularly reaches out to real estate boards, property owner associations, and offers fair housing trainings for their members. The general types of trainings conducted for housing providers are: Landlord Workshops - A two-hour training geared toward property owners and managers that covers the Federal and State Fair Housing Laws, the rental process, selection criteria, rental agreements, rules and regulations, obligations and guidelines regarding late fees, security deposits, rent increases, and termination. The training also covers specific concerns regarding families with children, occupancy standards and reasonable accommodations and modifications. Certificate Management Trainings — A four-hour intensive training geared towards property owners, managers, management companies and real estate professionals that covers a detailed overview of the Fair Housing Laws, general guidelines, families with children, lead disclosure, occupancy limits, reasonable regulations of facilities, people with disabilities, sexual harassment, advertising guidelines, prohibited practice and hate crimes. A question and answer session follows the training. Disability Policy Workshop- A two-hour training geared towards housing providers, which covers the basics of what needs to be addressed in a property's disability policy. The training discusses property PROGRESS SINCE 2010 137 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS accessibility, reasonable accommodations and modifications, accessibility policies, and disability discrimination. Action 3: Each City should continue to collaborate with their fair housing service provider and include testing/audits within the contractual work scope of each agreement. In addition, each City should review their agreements annually to make sure that increased and comprehensive services are being provided each year, and that education and outreach efforts are expanded and affirmatively marketed in the low- and moderate income and racial/ethnic concentrated areas. [This will address impediments involving racial disparities, discrimination complaints, and unexplained trends in residential patterns.] Timeframe: By the end of FY 2010-11, and annually thereafter. Progress: ■ Through counseling and case management, the Fair Housing Foundation has identified that in addition to complaints on familial status, more prevalent in the sub -region are complaints regarding disability, specifically in the form of denying reasonable accommodations for perspective tenants with physical disabilities. While provisions for audit services were not always available to address this issue, the Fair Housing Foundation did open nearly 100 bonafide discrimination cases within the sub -region since 2010 which were investigated through on site testing, document review, and surveys. Most complainants were in place tenants, of lower income, and Latino. ■ When there was provision for audits and testing, or when the number of cases opened and investigated fell short of the annual performance goal, the FHF conducted discrimination and educational audits and workshops to address the most common concerns found in the housing industry. For Mission Viejo specifically, the FHF conducted 7 audits on physical disability and reasonable accommodations and concluded that one of the seven audits had evidence to support the discrimination allegation. ■ Educational audits were conducted by randomly selecting housing providers and asking them to complete questionnaires based on the three most alleged protective classes: Disability, Race, and Familial Status. Of the 15 housing providers who participated in the educational audit, most were knowledgeable in all areas of the questionnaire. ■ The Fair Housing Foundation held several Accommodation & Modification 101 workshops for housing providers. The workshop covered the following topics: 13 Overview of protected classifications 13 Definition of disability, life activities, and impairments Modifications and accommodations Examples of common accommodations and modifications Important data needed o verification forms Approval notices Denial of request for accommodations/modifications PROGRESS SINCE 2010 138 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Construction requirements and accessibility Hoarding Action 4: Several entities exist in Orange County that assist with fair housing and related issues, including, but not limited to: Orange County Human Relations, the Public Law Center, Legal Aid Society, and the Center Orange County. Each City should consider increasing collaborative efforts with these and similar groups to expand education and outreach efforts and increase the diversity of services provided. [This will address impediments involving racial disparities, discrimination complaints, and unexplained trends in residential patterns.] Timeframe: By the end of FY 2010-11, and annually thereafter. Progress: Due to a lack of funding, the four cities in the sub -region did not have an opportunity to collaborate with the Orange County Human Relations, the Public Law Center, Legal Aid Society, or the Center Orange County. However, the cities contracted with the Fair Housing Foundation to provide education and outreach to both housing providers and consumers in their cities. A component of these services is providing referrals, when necessary, to these organizations, as well as to the California Department of Fair Employment and Housing and HUD. Action 5: Each City should increase education and outreach efforts related to the home buying process to increase knowledge of how credit history, debt -to -income ratios, collateral, and cash needed to close affect a person's ability to successfully qualify for a loan. Information on down - payment assistance programs available should be included as well. Given that Hispanics are the group most affected in each of the cities and represent the second largest proportion of each City's population, information should be made available in Spanish. [This will address impediments involving language barriers, access to information, impediments involving racial disparities in the ownership and lending markets.] Timeframe: By the end of FY 2010-11, and annually thereafter. Progress: Due to the loss of significant revenue (e.g., redevelopment) and continued reductions in HUD funding, three of the four cities in the sub -region did not carry out any education or outreach efforts related to home buying or down payment assistance. In past years, education and outreach efforts had been conducted in conjunction with the City's redevelopment -funded homebuyer assistance program. The City of Tustin, however, did provide education to 46 households that received down payment assistance from nonfederal funds since 2010. Action 6: Each City should continue to affirmatively market their first-time homebuyer and housing rehabilitation programs if already doing so, and/or expand their efforts to include programs available through the County and private sector to residents in the low and moderate -income and racial/ethnic concentrated areas. In addition, outreach efforts should be expanded to include Hispanics, elderly, large, and disabled households, as they represented a significant proportion of households reporting problems. [This will address impediments involving racial disparities and housing problems.] PROGRESS SINCE 2010 139 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Timeframe: By the end of FY 2010-11, and annually thereafter. Progress: Each city's ability to fund and hence, affirmatively market, affordable housing programs, such as a first-time homebuyer or housing rehabilitation program has been limited due to the elimination of Redevelopment Agencies in California which provided leverage funding for these programs. Continual annual reductions in HOME entitlement funds, also make it challenging to effectively administer these programs. However, the sub -region had these accomplishments to report for Action 6: ■ Costa Mesa affirmatively marketed their HOME -funded owner -occupied rehabilitation program and assisted 108 households of diverse ethnicity, age, size, and physical ability since 2010. ■ Since 2010, Mission Viejo affirmatively marketed their owner -occupied rehabilitation program and was successful at funding 62 loans and grants to eligible households. ■ Since 1994, the City of San Clemente has marketed and operated a CDBG-funded single- family rehabilitation loan program. The program, offering up to $15,000 to owners for home improvements, is advertised in the City's quarterly magazine, which is mailed to over 31,000 residents and businesses in the city, and is publicly noticed in the city's local newspaper. ■ The City of Tustin assumed responsibility for marketing 262 affordable rental units at Tustin Legacy to low and moderate income households. Tustin also collaborates with the Orange County Housing Authority to provide 347 senior, disabled, and lower income households with housing assistance vouchers through the County's Section 8 program. Action 7: Each City should continue to collaborate or expand efforts with various property management companies, mobile home parks, and Homeowner Associations (HOA's) to ensure that each is knowledgeable of fair housing laws, services, education opportunities, and City -funded programs. Emphasis on discrimination toward the categories of Disability (mental, physical, and persons living with HIV/AIDS), Race, and Familial Status (single parents, children, and issues with lead-based paint) should be included as well as discriminatory acts of eviction, denial of a reasonable accommodation, and unequal terms. [This will address impediments involving racial disparities, discrimination complaints, housing problems faced by those with special needs, and NIMBYism. It will also get more groups involved in the fair housing process.] Timeframe: By the end of FY 2010-11, and annually thereafter. Progress: Each city in the sub -region contracts with the Fair Housing Foundation to offer a comprehensive fair housing program to their residents. FHF provides fair housing trainings throughout the City and currently provides trainings for landlords, managers, realtors, and other housing providers on a regular basis. There are several types of trainings offered including landlord workshops, Certificate Management Training Seminars and Realtor trainings. ■ Landlord Workshops - A two-hour training geared toward property owners and managers that covers the Federal and State Fair Housing Laws, the rental process, selection criteria, rental agreements, rules & regulations, obligations & guidelines regarding late fees, security PROGRESS SINCE 2010 140 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS deposits, rent increase, termination, etc. The training also covers specific concerns regarding families with children, occupancy standards and reasonable accommodations and modifications. ■ Certificate Management Trainings —A four-hour intensive training geared towards property owners, managers, management companies and real estate professionals that covers a detailed overview of the Fair Housing Laws, general guidelines, families with children, lead disclosure, occupancy limits, reasonable regulations of facilities, people with disabilities, sexual harassment, advertising guidelines, prohibited practice and hate crimes. This training also includes a "What would you do?" session with specific Fair Housing scenarios discussed in a group forum. ■ Realtor Trainings — A four-hour training geared towards Realtors that covers a summary of the Fair Housing Laws, general guidelines, policies and practices, equal treatment needs and examples and guidelines to showing properties. Additionally, the FHF has conducted and continues to offer a Fair Housing 101 and Reasonable Accommodations and Modifications workshops, and conducts educational surveys and audits in the areas of the most common protected classes: Disability, Familial Status, and Race. PROGRESS SINCE 2010 141 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 8. Fair Housing Plan The Orange County 16 City Analysis to Fair Housing Choice (AI) evaluates a wide range of private and public sector housing issues and potential barriers to fair housing. This chapter builds upon the previous analysis, summarizes conclusions and presents a list of recommendations to help address the impediments. The Fair Housing Action Plan (Table 8-1) is provided at the end of this Chapter: only those actions pertinent to a specific jurisdiction are included in each city's individual Fair Housing Action Plan. Periodically, during the Consolidated Plan Annual Action Plan and Consolidated Annual Performance Evaluation Report (CAPER) processes, individual jurisdictions may adjust their Fair Housing Action Plan depending on funding availability and progress and effectiveness in implementing the actions. A. Regional, Private Sector Impediments Carried Over from 2010 Regional and Subregional Al 1. Housing Discrimination Impediment A-1: Housing discrimination continues to exist throughout Orange County, as evidenced by the number of complaints and fair housing cases opened by the Fair Housing Foundation and Fair Housing Council of Orange County. An average of 85 cases were opened in the participating cities over the past three years, with the leading bias based on disability (physical and mental), followed by familial status, national origin and race. Recommendations for All Jurisdictions: ■ In partnership with each city's fair housing provider, conduct multi -faceted fair housing outreach to tenants, landlords, property owners, realtors, and property management companies. Methods of outreach should include workshops, informational booths at community events, presentations to civic leaders and community groups, staff trainings, and distribution of multi-lingual fair housing literature. ■ Conduct focused outreach and education to small property owners/landlords on fair housing, and race, reasonable accommodation and familial status issues in particular. Conduct property manager trainings on a regular basis, targeting managers of smaller properties, and promote fair housing certificate training offered through the fair housing providers. ■ Provide general counseling and referrals to address tenant -landlord issues through each city's fair housing contractor, and provide periodic tenant -landlord walk-in clinics at City Halls and other community locations. FAIR HOUSING PLAN 142 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS ■ Include testing/audits within the scope of work for each city's fair housing provider. Support enforcement activity and publicize outcomes of fair housing litigation as a means to deter discriminatory practices and to encourage reporting. 2. Racial and Ethnic Segregation Impediment A-2: Residential segregation refers to the degree in which groups live separately from one another. Within the County there are areas of racial/ethnic concentrations, such as in Santa Ana where over three-quarters of the population is Hispanic and ten percent Asian. Approximately ten percent of households in the County are considered to be limited English-speaking households. Recommendations for All Jurisdictions: ■ Coordinate with fair housing providers to focus fair housing services, education/outreach, and/or additional testing in identified areas of racial/ethnic concentrations. ■ Offer a variety of housing opportunities to enhance mobility among residents of all races and ethnicities. Facilitate the provision of affordable housing throughout the community through: 1) available financial assistance; 2) flexible development standards; 3) density bonuses; and 4) other zoning tools. ■ Promote equal access to information on the availability of affordable housing by providing information in multiple languages, and through methods that have proven successful in outreaching to the community, particularly those hard -to -reach groups. ■ Affirmatively market first-time homebuyer and/or housing rehabilitation programs to low and moderate income areas, and areas of racial/ethnic concentration. ■ Work collaboratively with local housing authorities to ensure affirmative fair marketing plans and de -concentration policies are implemented. 3. Denial of Reasonable Modifications/ Reasonable Accommodations Impediment A-3: Denial of reasonable modification or reasonable accommodation is a continuing impediment to fair housing choice, and represents over one-half of alleged discriminatory acts in the 16 participating jurisdictions. Recommendations for All Jurisdictions: ■ Through each city's fair housing contractor, continue to provide fair housing education and information to apartment managers and homeowner associations on why denial of reasonable modifications/accommodations is unlawful. ■ Provide information on the unlawful practice of denying reasonable modifications/ accommodations at fair housing seminars conducted by the Apartment Association of Orange County. FAIR HOUSING PLAN 143 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 4. Discriminatory Advertising Impediment A-4: Regionally, there were incidents of discriminatory advertising that have the potential to discourage a certain type of renter or buyer from pursuing a housing opportunity. Ads indicating a preference for a certain type of tenant or buyer, such as "no pets", "no children", or "Ideal for single adult" have the effect of housing discrimination. Recommendations for All Jurisdictions: ■ Through each city's fair housing contractor, periodically monitor local newspapers and online media outlets to identify potentially discriminatory housing advertisements. When identified, make contact with the individual or firm and provide fair housing education. ■ Take steps to encourage both the Los Angeles Times and Orange County Register to publish a Fair Housing Notice and a "no pets" disclaimer that indicates rental housing owners must provide reasonable accommodations, including "service animals" and "companion animals" for disabled persons. 5. Hate Crimes Impediment A-5: Hate crimes committed at a residence are an impediment to fair housing choice because they impact the lives of an average of 35 households per year in the 16 participating Orange County cities. Of the total 169 hate crime incidents reported between 2010 and 2014, 57 incidents were related to race, 38 to religion, 37 to sexual orientation, 33 to ethnicity, 2 to disability and 2 to gender identity. Nearly 60 percent of these incidents occurred within the following four jurisdictions: Huntington Beach (36 incidents), Santa Ana (31 incidents), Newport Beach (18 incidents), and Garden Grove (15 incidents). Recommendations for All Jurisdictions: ■ Continue to monitor FBI data to determine if any hate crimes are housing related and if there are actions that may be taken by the City or its fair housing service provider to address potential discrimination linked to the bias motivations of hate crimes. ■ Continue to coordinate with various City and County housing, building and safety, health and sanitation, law enforcement and legal aid offices to maintain a comprehensive referral list of support services for victims of hate crimes or other violent crimes — inclusive of housing resources. 6. Unfair Lending Impediment A-6: Disparities in the home purchase loan denial rates experienced by Hispanic and Black/African American applicants within the 16 Orange County cities creates an impediment to fair housing choice as they have loans denied at rates 1.5 to 1.6 times greater than White applicants. In addition, Hispanic residents, which comprise 34 percent of Orange County's population, account for just 10 percent of applications for home purchase loans. Examples of the disparity between Hispanic residents and Hispanic applicants for home purchase loans include: Anaheim has a 53 FAIR HOUSING PLAN 144 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS percent Hispanic population, with 20 percent of purchase loan applicants comprised of Hispanics; La Habra has a 60 percent Hispanic population, with 23 percent Hispanic mortgage loan applicants; and Santa Ana has a 79 percent Hispanic population, with just 30 percent of home purchase loan applications made by Hispanics. In addition, the proportion of Hispanics to the total pool of mortgage loan applicants in the 16 Orange County cities has decreased in each of the past five years, from 16 percent in 2008 to 10 percent in 2013. Recommendations for All Jurisdictions: ■ As resources permit, monitor HMDA data annually using the 2013 HMDA analysis as a benchmark. ■ As resources permit, monitor the top 10 lenders in Orange County to compare and contrast loan denial rates and percentage of loans completed to minority populations. ■ Both of the Orange County fair housing service contractors should assist in identifying potential issues regarding redlining, predatory lending and other illegal lending activities. In addition, each city should review their agreements annually to make sure that increased and comprehensive services are being provided, and that education and outreach efforts are expanded and affirmatively marketed in low and moderate income and racial concentrated areas. ■ Each city should explore ways to collaborate with local lenders and support lenders' efforts to work with community groups to help minority households purchase their homes. Collaborative efforts should ensure that minority groups have access and knowledge of City programs, supportive services, and provide for networking opportunities with these groups. ■ Coordinate with local lenders to expand outreach efforts to first time homebuyers in minority neighborhoods. ■ Affirmatively market first-time homebuyer and/or housing rehabilitation programs in neighborhoods with high denial rates, high minority population concentrations and limited English speaking proficiency to help increase loan approval rates. B. Public Sector Impediments 1. Housing Element Compliance Impediment 13-1: According to HCD, of the 16 participating jurisdictions, 15 Housing Elements were in compliance, and San Clemente had submitted a draft Housing Element for the current 2014-2021 period in early 2016. Recommendations for Specific Jurisdictions: ■ San Clemente should pursue State certification of its Housing Element. FAIR HOUSING PLAN 145 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 2. Housing for Persons with Disabilities Impediment 13-2: Disability is the greatest cited basis for discrimination, comprising over half of the fair housing cases opened by the Orange County Fair Housing Council and Fair Housing Foundation in the 16 cities over the past three years. With the exception of the City of San Clemente, all participating jurisdictions have adopted formal policies and procedures in the Municipal Code to reasonably accommodate the housing needs of disabled residents. However, three cities charge a fee (Anaheim, Tustin and La Habra), and one city requires a public hearing (Newport Beach). Imposing a fee or a requirement for a public hearing could serve as an impediment to persons with disabilities seeking reasonable accommodation. Recommendations for Specific Jurisdictions: ■ The City of San Clemente should adopt formal Reasonable Accommodations policy and procedure in 2016. ■ The cities of Anaheim, Tustin and La Habra should consider eliminating the processing fee for reasonable accommodation requests. ■ The City of Newport Beach should consider amending its Reasonable Accommodation procedures to eliminate the requirement for a public hearing, and to approve administratively. 3. Zoning Regulations Impediment 13-3: The analyses of the land use controls and zoning codes identified the following potential issues: ■ Second Units: The City of Newport Beach does not currently provide for second units in its Zoning Code for single-family zoned properties, but does allow for "granny units" (accessory, age -restricted units) subject to Zoning Administrator approval of a Minor Use Permit. The City's age restrictions, combined with the requirement for non -ministerial approval, may serve to impede housing choice. ■ Single -Room Occupancy Housing: The majority of the 16 participating cities either contain specific provisions for SROs in their Zoning Ordinances, or have clarified in their Housing Elements how SROs are provided for under other zoning classifications. The cities of Buena Park, Orange and Santa Ana, however, do not currently specify zoning for SROs, or otherwise clarify how such uses would be provided for, though Buena Park has indicated SROs could currently be accommodated through a development agreement. Buena Park and Orange both include programs in their 2014-2021 Housing Elements to amend the Zoning Code to specifically address the provision of SRO units. Lack of clarity on provision for SROs can serve to limit housing choice to extremely low income households, including persons with disabilities and veterans. ■ Transitional/Supportive Housing: In all participating jurisdictions, with the exception of the cities of Fountain Valley and Orange, transitional and supportive housing is permitted in the FAIR HOUSING PLAN 146 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS manner prescribed by State law, regulated as a residential use and subject to the same permitting and standards as similar residential uses of the same type in the same zone. The City of Orange Zoning Code currently only addresses transitional and supportive housing structured in the form of group housing, and the City of Fountain Valley Zoning Code contains a definition of supportive housing but doesn't specify how such uses are to be regulated. Recommendations for Specific Jurisdictions: ■ The City of Newport Beach should consider pursuing a Zoning Code amendment to eliminate the current age restriction on second units and establish a ministerial review process. ■ The cities of Buena Park, Orange and Santa Ana should amend their Zoning Codes to specify provisions for SRO units. ■ The cities of Fountain Valley and Orange should amend their Zoning Codes to regulate transitional and supportive housing as a residential use, subject to the same standards as other residential uses of the same type in the same zone. 4. Density Bonus Incentives Impediment B-4: All 16 jurisdictions have adopted local density bonus ordinances which implement state density bonus law, providing density and other development incentives and concessions for the provision of affordable housing. However, with the recent addition of anti -displacement provisions under AB 2222, and modified parking standards for transit -accessible projects under AB 744, jurisdictions should update their density bonus ordinances to reflect these new State requirements. Recommendations for All Jurisdictions: ■ All 16 jurisdictions should amend the Zoning Code to reflect current State density bonus law. FAIR HOUSING PLAN 147 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20 Impediment I Actions Time Frame A. Regional, Private Sector Impediments Carried Over from 2010 Regional and Subregional Al A-1. Housing Data indicates housing discrimination a) Conduct multi -faceted fair housing outreach to tenants, Discrimination continues to exist throughout Orange landlords, property owners, realtors, and property County, as evidenced by the number of management companies. Methods of outreach should complaints and fair housing cases opened include workshops, informational booths, by the Fair Housing Foundation and Fair presentations to civic leaders and community groups, Housing Council of Orange County. An staff trainings, and distribution of multi-lingual fair average of 85 cases were opened in the housing literature. participating cities over the past three b) Conduct focused outreach to small property owners/ years, with the leading bias based on landlords; conduct property manager trainings on a Ongoing disability (physical and mentals followed by regular basis; promote fair housing certificate training. 2015/16 -2019/20 familial status, national origin and race. c) Provide general counseling and referrals to address tenant -landlord issues, and provide periodic tenant - landlord walk-in clinics at City Halls and other community locations. d) Include testing/audits within the scope of work for each city's fair housing provider. Support enforcement activity and publicize outcomes of fair housing litigation. A-2. Racial and Ethnic Residential segregation refers to the degree a) Coordinate with fair housing providers to focus fair Segregation in which groups live separately from one housing services, education/outreach, and/or additional another. As presented within the testing in areas of racial/ethnic concentrations. Community Profile, there are areas of b Offer a varietyof housing opportunities to enhance ) g pp Ongoing racial/ethnic concentrations in the County. mobility among residents of all races and ethnicities. 2015/16 -2019/20 Approximately ten percent of households Facilitate affordable housing throughout the are considered to be limited English- community through: 1) available financial assistance; 2) speaking households. flexible development standards; 3) density bonuses; and 4) other zoning tools. FAIR HOUSING PLAN 148 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20 Impediment Actions Time Frame c) Promote equal access to information on the availability of affordable housing by providing information in multiple languages, and through methods that have proven successful in outreaching to the community, particularly those hard -to -reach groups. d) Affirmatively market first-time homebuyer and/or housing rehabilitation programs to low and moderate income areas, and areas of racial/ethnic concentration. e) Work collaboratively with local housing authorities to ensure affirmative fair marketing plans and de - concentration policies are implemented. A-3. Denial of Denial of reasonable modification or a) Through each city's fair housing contractor, continue to Reasonable reasonable accommodation is a continuing provide fair housing education and information to Modifications/ impediment to fair housing choice, and apartment managers and homeowner associations on Reasonable represents over one-half of alleged why denial of reasonable modifications/ Accommodations discriminatory acts in the 16 participating accommodations is unlawful. Ongoing jurisdictions. 2015/16 -2019/20 b) Provide information on the unlawful practice of denying reasonable modifications/accommodations at fair housing seminars conducted by the Apartment Association of Orange County. A-4. Discriminatory Regionally, there were incidents of a) Through each city's fair housing contractor, periodically Advertising discriminatory advertising that have the monitor local newspapers and online media outlets to potential to discourage a certain type of identify potentially discriminatory housing renter or buyer from pursuing a housing advertisements. When identified, make contact with Ongoing opportunity. Ads indicating a preference the individual or firm and provide fair housing 2015/16 - 2019/20 for a certain type of tenant or buyer, such education. as "no pets", "no children", or "Ideal for b) Take steps to encourage both the Los Angeles Times single adult" have the effect of housing and Orange County Register to publish a Fair Housing discrimination. Notice and a "no pets" disclaimer that indicates rental FAIR HOUSING PLAN 149 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20 Impediment Actions Time Frame housing owners must provide reasonable accommodations, including "service animals" and "companion animals" for disabled persons. A-5. Hate Crimes Hate crimes committed at a residence are a) Continue to monitor FBI data to determine if any hate an impediment to fair housing choice crimes are housing related and if there are actions that because they impact the lives of an average may be taken by the City or its fair housing service of 35 households per year in the 16 provider to address potential discrimination linked to participating Orange County cities. Of the the bias motivations of hate crimes. total 169 hate crime incidents reported b) Continue to coordinate with various City and County Ongoing 2015/16 -2019/20 between 2010 and 2014, 57 incidents were housing, building and safety, health and sanitation, law related to race, 38 to religion, 37 to sexual enforcement and legal aid offices to maintain a orientation, 33 ethnicity, 2 to disability comprehensive referral list of support services for and 2 to gender identity. i victims of hate crimes or other violent crimes —inclusive of housing resources. A-6. Unfair Lending Disparities in the home purchase loan a) As resources permit, monitor HMDA data annually using Annually denial rates experienced by Hispanic and the 2013 HMDA analysis as a benchmark. Black/African American applicants within b) As resources permit, monitor the top 10 lenders in 2017 the 16 Orange County cities creates an Orange County to compare and contrast loan denial impediment to fair housing choice as they rates and percentage of loans completed to minority have loans denied at rates 1.5 to 1.6 times populations. greater than White applicants. In addition, Hispanic residents, which comprise 34 c) Both of the Orange County fair housing service Ongoing percent of Orange County's population, contractors should assist in identifying potential issues 2015/16 -2019/20 account for just 10 percent of home regarding redlining, predatory lending and other illegal purchase loans, and the percentage of lending activities. Each city should review their completed mortgage loans by Hispanics has agreements annually to make sure that increased and decreased in each of the past five years. comprehensive services are being provided, and that education and outreach efforts are expanded and affirmatively marketed in low and moderate income and racial concentrated areas. FAIR HOUSING PLAN 150 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20 Impediment Actions Time Frame d) Each city should explore ways to collaborate with local 2017 lenders and support lenders' efforts to work with community groups to help minority households purchase their homes. Collaborative efforts should ensure that minority groups have access and knowledge of City programs, supportive services, and provide for networking opportunities with these groups. e) Coordinate with local lenders to expand outreach 2017 efforts to first time homebuyers in minority neighborhoods. f) Affirmatively market first-time homebuyer and/or 2016 housing rehabilitation programs in neighborhoods with high denial rates, high minority population concentrations and limited English speaking proficiency to help increase loan approval rates. B. Public Sector Impediments (Only actions pertinent to Newport Beach identified) B-2. Housing for Disability is the greatest cited basis for Jurisdiction -Specific Actions: Persons with Disabilities discrimination, comprising over half of the c) The City of Newport Beach should consider amending its fair housing cases in the 16 cities over the Reasonable Accommodation procedures to eliminate 2017 past three years. With the exception of San the requirement for a public hearing, and to approve Clemente, all participating jurisdictions administratively. have adopted formal policies and procedures to reasonably accommodate the housing needs of disabled residents. However, three cities charge a fee (Anaheim, Tustin and La Habra), and one city requires a public hearing (Newport Beach). Imposing a fee or a requirement for a public hearing could serve as an impediment to persons with disabilities. FAIR HOUSING PLAN 151 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20 Impediment I Actions Time Frame B-3. Zoning Regulations The analyses of the land use controls and zoning codes identified the following Jurisdiction -Specific Actions: potential issues: Second Units: Newport Beach does not a) Second Units: The City of Newport Beach should 2017 currently provide for second units in its consider pursuing a Zoning Code amendment to Zoning Code for single-family zoned eliminate the current age restriction on second units properties, but does allow for "granny and establish a ministerial review process. units" subject to Zoning Administrator approval of a Minor Use Permit. The City's age restrictions, combined with the requirement for non -ministerial approval, may serve to impede housing choice. B-4. Density Bonus All 16 jurisdictions have adopted local a) All 16 jurisdictions should amend their Zoning Codes to 2016 Incentives density bonus ordinances which implement reflect current State density bonus law. state density bonus law, providing density and other development incentives and concessions for the provision of affordable housing. However, with the recent addition of anti -displacement provisions under AB 2222, and modified parking standards for transit -accessible projects under AB 744, all 16 jurisdictions should update their density bonus ordinances to reflect these new State requirements. FAIR HOUSING PLAN 152 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Appendix A: Community Participation APPENDIX A-1: Fair Housing Workshops APPENDIX A-2: Fair Housing Surveys APPENDIX A-3: Public Review Notices APPENDIX A We invite you to participate in one of five Fair Housing Workshops hosted by a group of 16 Orange County cities.* These workshops are aimed at tenants, landlords, social service providers, housing professionals and anyone who has concerns about fair housing in their community. Your input will help develop the federally -required Analysis of Impediments to Fair Housing Choice — the planning document for providing equal housing opportunities. Anaheim Tuesday, September 22, 2015 6:00 PM -7:30 PM Assembly Hall, Downtown Anaheim Community Center 250 E. Center Street, Anaheim r— Tustin Wednesday, September 23, 2015 6:00 PM -7:30 PM Professional Training Center Tustin Library 345 E. Main Street, Tustin Fountain Valley Thursday, September 24, 2015 6:00 PM -7:30 PM City Hall Council Chambers 10200 Slater Avenue, Fountain Valley Santa Ana Wednesday, September 30, 2015 6:00 PM -7:30 PM Santa Ana Police Community Room 60 Civic Center Plaza, Santa Ana Fair Housing issues to be discussed include: ❖ Housing affordability/availability ❖ Tenant/landlord relations ❖ Accessibility to persons with disabilities ❖ Real estate and mortgage lending practices ❖ Public policies affecting fair housing choice For more information, please contact: John Oshimo at 626.331.6373 or joshimo@grcassoc.com Please take our brief Fair Housing Survey online: English https.11www.surveymonkey.com/r/OC- A1160tiesSurvey ENGLISH Spanish https://www.surveymonkey.com/r/OC- A116CitiesSurvey SPANISH Vietnamese https://www.surveVmonkeV.com/r/OC- A1160tiesSurvey VIETNAMESE Korean https://www.surveymonkey.com/r/OC- A116CitiesSurvev KOREAN Lake Forest Thursday, October 1, 2015 6:00 PM -7:30 PM City Hall, Community Room 25550 Commercentre Drive, Lake Forest Le invitamos a participar en uno de los cinco Talleres de Equidad de Viviendas organizada por un grupo de 16 ciudades del Condado de Orange.* Estos talleres estan dirigidos a inquilinos, propietarios, proveedores de servicios sociales, profesionales de viviendas y cualcluier persona clue tenga inquietudes sobre la equidad de viviendas en su comunidad. Su contribuci6n ayudara a desarrollar el informe requerido por el gobierno federal, Analisis de Impedimentos de Elecci6n de Vivienda Justa (Analysis of Impediments to Fair Housing Choice) — el documento de planificaci6n para proporcionar igualdad de oportunidades de viviendas. Anaheim Martes, 22 de septiembre 2015 6:00 PM -7:30 PM Assembly Hall, Downtown Anaheim Community Center 250 E. Center Street, Anaheim Tustin Miercoles, 23 de septiembre 2015 6:00 PM -7:30 PM Professional Training Center Tustin Library 345 E. Main Street, Tustin Fountain Valley Jueves, 24 de septiembre 2015 6:00 PM -7:30 PM City Hall Council Chambers 10200 Slater Avenue, Fountain Valley Santa Ana Miercoles, 30 de septiembre 2015 6:00 PM -7:30 PM Santa Ana Police Community Room 60 Civic Center Plaza, Santa Ana Cuestiones de equidad de vivienda que se consideraran incluyen: ❖ Disponibilidad / Asequibilidad de Viviendas ❖ Las relaciones de inquilino / propietario ❖ Accesibilidad a las personas con discapacidad ❖ Las practicas de prestamos de bienes raices e hipotecas ❖ Las politicas publicas que afectan a la elecci6n de vivienda justa Para obtener mas informaci6n, p6ngase en contacto: Robert G. Vasquez at 626.331.6373 o rvasquez@grcassoc.com Por favor tome nuestra breve encuesta de Vivienda Justa en linea : Ingles https://www.surveymonkey.com/r/OC A1160tiesSurvey ENGLISH Espanol https://www.surveymonkey.com/r/OC- A116CitiesSurvey SPANISH Vietnamita https://www.surveymonkey.com/r/OC- A1160tiesSurvey VIETNAMESE Coreano https://www.surveymonkey.com/r/OC- A116Citiessurvey KOREAN Lake Forest Jueves, 01 de octubre 2015 6:00 PM -7:30 PM City Hall, Community Room 25550 Commercentre Drive, Lake Forest I Kfnh md! quy vj tham dg m8t trong ndm buai H$l Th'ao v6 Ung Bung Gia Cr, dugc dang td ch0c b8i 16 thdnh pha thu6c QuAn Cam.* Cdc bu$i h6i thho ndy ddnh cho nha7ng ngudi thud nhd, chu nhd, cdn sit xd h6i, chuydn vidn va gia cLIvd bat ca3 ai c6 quan tdm don van da cling bang gia cLitrong c$ng d$ng c6a hp. l( kion d6ng g6p cua qug vi sd giaa p fch cho vioc phdn tfch cdc ydu cau cua Lidn bang va nh�7ng tib ng4ki trong Fair Housing Choice— Cdc tdi IiQu ka hooch cho vioc sung carp nht7ng cd hoi trg cap gia cal mot cdch cSng binh. Anaheim Thi, Ba, 22 thong 9 ndim 2015 6:00 PM -7:30 PM Assembly Hall, Downtown Anaheim Community Center 250 E, Center Street, Anaheim Tustin Thi, TV, 23 thdng 9 n6m 2015 6:00 PM -7:30 PM Professional Training Center Tustin Library 345 E. Main Street, Tustin Fountain Valley Thif N6m, 24 thong 9 nom 2015 6:00 PM -7:30 PM City Hall Council Chambers 10200 Slater Avenue, Fountain Valley Nhitng v5n dfi Ung BAng Gla Cu s6 duglc birn b6c bao g6m: # Nha $ gia phdi chdng/ co son 4� Quan h6 thud nhd / chu nhd • 1-6i vdo nhd ddnh cho ngudi khuyat tot • Cdc phucng thuc cho vay bat dung shn va nha dot • Chfnh sdch cling c8ng dnh huizing d6n skf IkIa chgn trong cling bang gia cu Dd bi6t th6m chi ti6t, An 116n I4c: Jahn Oshimo at 626.331.6373 or joshimo@gmassoc.com I Xin mdi than gia cu�c khio sdt ngan g9n va Cdng Bang Gia Cu Santa Ana trdn website: Thi, Tal, an th6ng 9 nAm 2015 6:00 PM -7:30 PM Santa Ana Police Community Room 60 Civic Center Plaza, Santa Ana Lake Forest Thi, N6m, 1 th6ng 10 ndm 2016 6:00 PM -7:30 PM City Hall, Community Room 25550 Commercentre Drive, Lake Forest English haps.!/www.surve ymonke y.cum/r/OC- A116Cit1esSurvey ENGLISH Spanish hsurveymonkey.com/��`/0C- A116GHesSurvey SPANISH Vietnamese https://www surve ymonkey cnm/r/OC- A1I60tlesSurvev VIETNAMESE Korean httns4llwww.surveymonkey.com/r/0C- A1160desSurve ry_KOREW * 16 thdnh ph6 d$ng tham gia baa g6m: Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, La Habra, Lake Forest, Mission Viejo, Orange, Newport Beach, Rancho Santa Margarita, San Clemente, Santa Ana, and Tustin Cts 71 Danck 'MCkT V��o Nl�ti�UG 2 �Q t� l�lc�ti�i �e vl - (e ` 33GC� z ' ov-\C-, �?,e n aa� 11��,ti. ;�� ��,�rQ�.t� Start/��, �l y -5�� - 2-SS b rQ a �, C'Gt v►'��(Gv�C 1- c� �ia� c�1� �; Cts dent/Organization Phone or email 112 22 i Name !. Fair Housing Workshop September• Tustin • _•rr • ._ Cy' • r Email ZZL N ! gr 2 C,-3� I Fair Housing Workshop September 24, 2015 Fountain Valley Name Resident / Organization Address Phone or Email Name Fair Housing Workshop September 30, 2015 Santa Ana Resident / Organization Address Phone or Email .MMIire, 1 '►.�� f 1 i .. /.. r /h. ue M1INA I�iF�IA rM WIN 'L1. _ � .,..ice •• ..z_.•i s • + � �• �I'M SEEM =1�1 IMIM gPrMt?Y�", 'JJ,l�QIZ ,4 rg Fair Housing Workshop September 30,2015 Santa Ana Name Resident• .. F . f D,41-, Lp i22 f LZF- 71 58 1 a3 3 7 �}F 14 J-� 71,f sa&a r 55 7 71Y Th �AYKA APs Mainz 41W1M� �gU r. ` i�o,Hq�L�-✓eh-7(q836 73qSI N11 Yap ihveLP-14,/o2 61 es. u,°� �' S r Chiu WT-f N4� �►�I �ic� l'xgG �vCc7K PS` YYl0* 14x1\ ova j , -RAStrA C 01)-71 1 S-Ik-zsuSU E rUfl i C r6)ciJ iIU($1i1 ?jI Pt'haS4 :i /C 4�� (UG7�, '7S '�e,./C p .tJ.vtarJ.�+,e•3�2s4hfriustG �/.5�5 cj 6 C S �e.�z.ohnSl;an ��G-� �-. --i-�e �fr,� S-{--2. LA e c.�1=fh� C Co-I r IZ e k-L A-O vacel i u ho.V-e S IZ "e 5 i �A�-iS Z N. F� f tiC ✓ �.S - &4 #3 I co pnt Fair Housing Workshop October 1. 2015 Lake Forest Name Resident / Organization Address Phone or Email ifs r 1 G Y-6UA iji5lCA CI &VI v i rx v C, Q36 1 f 4\4 Cif c 0 �y CJKV @ SAIA �G C'i 04I.ocq Fifth Fair Housing Workshop Lake Forest City Hall, Community Room 25550 Commercentre Drive, Lake Forest Regional Analysis of Impediments to Fair Housing Choice ■ Jurisdictions receiving federal funds must certify that they are affirmatively promoting fair housing. Certification means: Prepare an Analysis of Impediments to Fair Housing Choice (AI) every 5 years Take actions to eliminate identified impediments Maintain fair housing records reflecting the actions taken 16 Orange County Cities have elected to prepare Regional All Anaheim ■ lake Forest Buena Park Mission Viejo Costa Mesa ■ Newport Beach Fountain Valley Orange Fullerton Rancho Santa Margarita Garden Grove San Clemente Huntington Beach Santa Ana La Habra Tustin )rest ober 1, 2015 :30 PM unity Room Drive, Lake Forest 0 Fair housing describes a condition in which individuals of similar income levels in the same housing market have a similar range of choices available to them regardless of a protected class status Prohibits discrimination in housing choice because of one's: ✓ Race or color ✓ Religion ✓ Sex Marital or familial status National origin ✓ Disability Gender Gender identity and expression Sexual orientation Source of income ■ Any actions, omissions, or decisions that restricts the availability of housing choice on account of one's protected class status ■ Communities must work to remove impediments to fair housing choice ■ Regional and Community Profiles Demographic and socioeconomic Household and housing characteristics Employment ` Special needs Public assisted housing Access to public transportation Mortgage Lending Practices Lending patterns by race/ethnicity and income levels Lending performance by lenders ■ Public Policies and Practices (General Plans/Zoning/ Building Codes) Land use policies/development standards Reasonable accommodations Housing for special needs (disabled, seniors, homeless, etc) Residential development fees Fair Housing Practices Rental and homeownership market Fair housing services Trends in discrimination cases Status of Actions from the 2010-2015 Al Were the actions implemented and were they successful? Should the actions be continued in the 2015-2020 Al? r Findings and Recommendations Identify potential impediments to fair housing choice Recommendations /actions to address impediments 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Lake Forest Mission Viejo Rancho Santa San Clemente Orange County Margarita 2 Races NH -Black NH -Asian Hispanic NH -White Source: American Community Survey 2009-2013 ■ Dependent Population About one-quarter (24%) of total County population under the age of 18 years 12% over the age of 65 years Persons with Disability 8% of total County population include persons with a disability or 237,000 residents Of the population 65 years and over, almost one-third (32%) persons with disability Source: American Community Survey 2009-2013 Anaheim Anaheim Assembly Hall, Downtown Tuesday Anaheim Community Center Sept. 22 250 E. Center St., Anaheim Tustin Professional Training Center, 7Fe Tustin Library Tu st i n 345 E. Main St., Tustin Wednesday Sept. 23 Fountain Valley Regional City Hall Council Chambers 10200 Slater Ave., Fountain Valley Santa Ana Santa Ana Police Community Rm. ® 60 Civic Center Plaza, Santa Ana Santa Ana Fountain Valley Lake Forest Wednesday Thursday City Hall, Community Rm. Sept. 30 Sept. 24 25550 Commercentre Dr., Lake Forest ■ Key Questions of the Survey Have you encountered discrimination? Who discriminated against you? Where did the discrimination occur? What was the basis for the discrimination? Did you report the incident? Have you been denied "reasonable accommodation"? How well inform are you on your fair housing rights? What would you do if you encounter discrimination? Do you believe housing discrimination occurs in Orange County? Online Fair Housing Survey on City Websites English: https://www.surveymonkey.com/r/OC-AI16CitiesSurveV ENGLISH Spanish: https://www.surveymonkey.com/r/OC-AI16CitiesSurveV SPANISH Vietnamese: https://www.surveymonkey.com/r/OC-Al16CitiesSurveV VIETNAMESE Korean: https://www.surveymonkey.com/r/OC-AI16CitiesSurveV KOREAN Hardcopy Fair Housing Survey City Halls and libraries Mailed to housing and social service providers County Fair Housing Workshops M Outreach Effort Community Outreach Notices 01 M Workshops: 9/22 Anaheim 9/23 Tustin 9/24 Fountain Valley 9/30 Santa Ana 10/1 Lake Forest Needs Surveys Ci M M Working Results of Group Workshops Study and Needs Session on Survey Screen Draft Al M Draft Al Available at City Halls, » libraries and City Websites Public Hearings i i i ■ What are the Most Important Fair Housing Issues and Needs? ■ What Actions can the City, Fair Housing Service Providers, and Community Stakeholders Pursue to Address These Fair Housing Needs? ■ Provide programs and services for the elimination of discrimination, general housing (tenants and landlords) service and education to cities Fair Housing Foundation (800) 446-3247 Housing service to Anaheim, Buena Park, Costa Mesa, Fullerton, Garden Grove, Huntington Beach, Mission Viejo, Newport Beach, Orange, San Clemente, and Tustin Fair Housing Council of Orange County (714) 569-0823 Housing service to Fountain Valley, La Habra, Lake Forest, Rancho Santa Margarita, and Santa Ana If you have additional questions or comments after this workshop, please contact: John Oshirno or Robert Vasquez GRC Associates 626-331-6373 or bshimo frcassoc. com rvasquez pgrcassoc. com Appendix A-1 Compiled List of Workshop Outreach from 16 cities City of Anaheim All Workshop Outreach_FY 15/16 HUD Subrecipients Allyson Crosby acrosby@ifhomeless.org Alycia Capone alycia.capone@pathwaysofhope.us Ann Trovada atrovada@anaheimymca.org Ashley Spindler aspindler@lestonnacfreeclinic.org Audrey Mcintosh meg@grandmashouseofhope.org Barbara Jennings Barbara.Jennings@pathwaysofhope.us Bradford Jones dmassethjones@ywcanoc.org Bradford Jones dmassethjones@yweanoc.org Bryon Reliford breliford@anaheimymca.org Carol Anne Williams carol@intervalhouse.org Carol McKinny cmckinney@mariposacenter.org Cyndee Albertson Cyndee@ThomasHouseShelter.org Diana Meier dmeier@ocasf.org Diana Stalter dstalter@healinghomelessness.org Diane Messeth-Jones DianeMassethjones@ywcanoc.org Dr. Brad Fieldhouse bfieldhouse@citynet.org Dr. Cynthia Smith, MT -BC creativeidentityanaheim@yahoo.com Dr. Krista Driver, LMFT kdriver@mariposacenter.org Evette Nadolny enadolny@anaheimymca.org Gracelene Gracia ggracia@anaheimymca.org Janeth Velazquez jvelazquez@seniorserv.org John Kim jkim@ifhomeless.org John Machiaverna jmac@theboysandgirlsclub.org Julie Durte jduarte@acacia-services.ort Karen B. Williams kwilliams@211oc.org Kathleen Weidner kweidner@coaoc.org Laura Bates laura.bates@learninglight.org Mailory Vega mvega@acacia-services.org Maria Mazzenga-Avellaneda maria.mazzenga@pathwaysofthope.uc Marytza Rubio MRubio@ifhomeless.org Mayra Mejia Gille mmejia@211oc.org Megan Hartman MHartman@bigbrooc.org Michael Baker mike@theboysandgirlsclub.org Michael Shephard michael@grandmashouseofhope.org Michaela Lemelin Michaela.lemelin@learninglight.org Nahla Kayali nkayali@accesscal.org Odezza Larida odezza@grandmashouseofhope.org Paul Cho PCho@ifhomeless.org Penelope Agosta penelope@hope4arts.org Philip Yaeger pyaeger@acasf.org Ray Harper rharper@coaoc.org Roseann Peters rpeters@lestonnacfreeclinic.org Sharon Wie accounting@intervalhouse.org Sofia Burns sburns@211oc.org Suhail Mulla smulla@accesscal.org Susan Contreras scontreras@mariposacenter.org SuzAnne Mathai smathai@hopeu.org Tatiana Caicedo tcaicedo@seniorserv.org Willian O'Connell coletteschildren@aol.com City of Buena Park Al Workshop mailing list/Outreach Summary The City of Buena Park used the non-profit lists from their Finance Department's Business License Division. The City mailed out approximately 25 from the list and 6 were returned as no longer in business. Additionally, the City sent out the survey to six of their CDBG subrecipients. To the City's knowledge, two of the subrecipients replied. Additionally, the City posted the survey on their website. City of Costa Mesa Meeting/Survey Distribution Mercy House Transitional Living Center — Homeless/at risk Fair Housing Foundation — Landlord and Tenants City of Costa Mesa Senior Center — Seniors Elwyn California — Disabled Adults Project Independence — Disabled Adults Alzheimer's Family Services Center — Adults with dementia Community SeniorSery - Seniors Women Helping Women — Low/Mod and homeless persons Serving People In Need — Homeless/substance recovery Council on Aging, Orange County — Seniors living in managed care Orange Coast Interfaith Shelter — Homeless families Human Options — Victims of domestic violence Working Wardrobes — Low/mod and homeless persons Families Forward — Homeless and at risk families Colette's Children's Home—Transitional housing City of Costa Mesa website City of Fountain Valley Community Care Health Centers Council on Aging of Orange Co Community Senior Sery Women's Transitional Living Center Fair Housing Council of Orange Co Wico Dinro Better Vision for Children Assistance League of Garden Grove Mercy House Homeless Veterans Outreach Sweet Success Ext Program SSEP City of Fullerton Boys & Girls Clubs of Huntington Valley Interval House Crisis Shelters Alzheimer's Family Services Community Service Programs California Elwyn, Inc nART 2-1-1 Lutheran Program Supreme Court OC/Central Justice Ctr Mental Health Association of Orange Co Fair Housing Foundation Mailed notices to over 600 community groups and multi -family apartments (including the City's 17 affordable housing projects) and management companies. Placed a community meeting notice in the local paper (Fullerton News Tribune) in the September 10, 2015 edition. Noticed on the City's website homepage including a direct link to survey money. City of Garden Grove Agency contact list: Mercy House Assistance League of Garden Grove Fair Housing Foundation College of Optometry Interval House HPP Cares Child Abuse Prevention Center Thomas House Mental Health Assoc. of Orange County Dayle Macintosh Center Community SeniorSery Fletcher House, DBA Halfway Homes Legal Aid Society of Orange County Rebuilding Together O.C. H.0.P.E. Orange County Superior Court, Central Justice Center Hospital Assoc. of Southern California OC Partnership Family Support Network Women's Transitional Living Center Illumination Foundation Jamboree Housing Corporation (CHDO — Non Profit Developer) Veterans First Acacia Adult Day Services AIDS Services Foundation Jamboree Housing International Crusade of the Penny American Lung Association Lutheran Social Services of So. Cal. Breast Cancer Angels Illumination Foundation Public Law Center Community Health Care Centers Interval House Garden Grove United Methodist Church The Syriac Charitable Society of America American Family Housing Vietnamese Community of Orange County Boat People SOS Salvation Renovation St. Anselm Cross Cultural Community Center 211 Orange County Colette's Children's Home Workshop invitations to 80 property managers of apartment buildings in Garden Grove and invited City's 7 NI Commissioners. City of La Habra Delivered or placed the flyers in all of the following places: 1. City's website 2. Community Services Center which provides notification of City Events to: Community Groups, Block Clubs, Faith -Based and Social Organizations 3. City Hall — Public Counters 4. Public Library 5. Community Services Commission members 6. City Council members City of Lake Forest For the Al Workshop, city advertised it via our monthly electronic newsletter, on our website, and emails to our subrecipients and local non -profits. The surveys and meeting notice (in different languages) was sent to the following agencies. Also, the City posted notice and links to survey/meeting notice on the City's website and the City's Econ Dev website. Additionally, info was sent via e -newsletter to approximately 4,000 businesses in the City. Saddleback Valley Unified School District Childcare services Vocational Visons Disabled services Human Options Domestic violence services Families Forward Low/Mod & at -risk families services Age Well Senior Services Senior services Camino Health Center Health care services Boys & Girls Club of Laguna Beach Youth services South County Outreach Low/Mod & at -risk families services City of Mission Viejo Vocational Visions Disabled Services Age Well Senior Services Senior Services Camino Health Center Health Care Services Saddleback Valley USD Childcare Services Families Forward L/M Services South County Outreach L/M Services Council on Aging - OC Senior Services Birth Choice Health Clinic Health Care Services Fair Housing Foundation Fair Housing Services City of Newport Beach The City published the attached flyer approximately 10 days in advance of the first community meeting in the Daily Pilot, a newspaper of general circulation in the Costa Mesa and Newport Beach area. The flyer was also emailed to a community interest email list with over 700 email addresses for residents, businesses and other community stakeholders. City of Rancho Santa Margarita Information regarding Fair Housing Survey and Al workshops was emailed to current and past public service grant recipients — see list below: Vocational Visions South County Outreach Laura's House Families Forward Dayle McIntosh Age Well Santiago Seniors Club Saddleback Valley Unified School District City of San Clemente Advertised on the City's homepage and we passed out flyers/surveys at the Boys and Girls Club, all public schools, ten churches, library, City Hall, and social service providers including Family Assistance Ministries and OC Human Relations. City of Santa Ana The City posted workshop flyers and surveys on the City's website, released an email notification to approximately 14,339 subscribers of the City's Nixle notification system (https://local.nixle.com/alert/5499002/), and emailed information to local community centers and nonprofits. Flyer and Surveys distributed through: Santa Ana Housing Authority Santa Ana WORK Center Santa Ana Public Library Santa Ana Senior Center Santa Ana South West Senior Center Santa Ana Police Athletic and Activities League Santa Ana Youth Council Garfield Community Center Fair Housing Council of Orange County America on Track Boys and Girls Club of Santa Ana Community SeniorSery Council on Aging Delhi Center Human Options KidWORKS Public Law Center Orange County Children's Therapeutic Arts Center The Cambodian Family WISE Place City of Tustin Mailed flyers to over 80 agencies and 400 property managers/realtors. Appendix A-1 Public Comments For Fair Housing Workshops Analysis Of Impediments — Group Of 16 Orange County Cities Public Fair Housing Workshop # 1 Northern Orange County Subregion: Anaheim, Buena Park, Fullerton, La Habra September 22, 2015 - 6:00 to 7:30 pm City of Anaheim Assembly Hall - Community Center Public Comments • Who can educate property managers/leasing agents about fair housing issues? (The Orange County Fair Housing Council and the Fair Housing Foundation both provide these services. Each city contracts with one of these fair housing providers). • Spanish-speaking resident brought up her situation about landlord that may be discriminating against large families. (She took various copies of Spanish fair housing survey and said she would ask residents in her apartment complex to complete). • Concerns about housing affordability were brought up by resident. • Question about how property managers can be tracked. • Concern over current, very high rents. Landlords are asking for $1,450 for a two- bedroom unit that was recently rented at $1,200 for the same unit. • It is not possible for some residents on Social Security to qualify for apartments now because property owners are requiring them to earn 2, or 2.5 times the income as compared to their required rent • Workshop participant wanted to get a copy of the actions required in the Al for the previous Al five years ago. (2010-2015 Orange County Regional Al with actions is available on-line @ http://www.newportbeachca.gov/home/showdocument?id=10768 Public Fair Housing Workshop # 2 Central Orange County Subregion: Garden Grove, Orange, Santa Ana, Tustin September 23, 2015 - 6:00 to 7:30 pm City of Tustin Library — Professional Training Center Public Comments • Can property owners discriminate against anyone? For example, can owners limit people renting a room in their homes to single women only? • Various issues regarding housing affordability were raised. Resident stated that some housing complexes that are "affordable" have asking rents that are nearly the same as non -restricted, market rate housing. • There is a lack of housing opportunities for disabled people. • Rents are increasing quickly and there are no vacancies. A property manager from Tustin Villas said that she takes a monthly survey of rents of nearby apartment complexes and all are 100% occupied and rents are increasing. Currently asking $1,600 to $1,800 per month for a 2 -Bedroom, $1,395 to $1,420 for a 1 -Bedroom unit and a studio is going for $1,295 per month. Rents are being paid on time and the waiting list is "real". Comment was made that "strawberry pickers" or seasonal farm workers are crowding into some units, with two or three families per apartment unit. Overcrowding was discussed at length. Residents wanted to know how to address this big issue. Property manager mentioned that the key is to have good on-site management. A resident brought up question about what can be done for veterans regarding housing options. Some of the responses included that there were specific mortgages for veterans, housing complexes targeting veterans, programs by HUD (HUD-VASH) specifically for veterans, programs to assist homeless veterans and specific local projects for veterans were identified (Village of Hope). Services of the Fair Housing Council of OC were presented and referral information provided to workshop participants. Public Fair Housing Workshop # 3 Western Orange County Subregion: Costa Mesa, Fountain Valley, Huntington Beach, Newport Beach September 24, 2015 - 6:00 to 7:30 pm Fountain Valley City Hall, Council Chambers Public Comments • Comments were made that residents do not know who to call about discrimination issues. • Some residents do not know they are being discriminated against and it was commented that lack of education on housing discrimination may be an impediment. • Workshop attendees were informed that City websites have information on housing programs and resources that may be useful. Some cities, like Huntington Beach, also provide information on housing resources available through Orange County. • A comment was made about how some struggling people do not have good access to computers, may have issues with literacy, and face other barriers which limit their access to housing resources. Many are close to being homeless once they have dropped down various rungs on the housing/economic ladder. • There is not enough funding to help everyone. • Some cities have walk-in hours open to the public for fair housing assistance scheduled each month at their city halls. • Some cities, like Fountain Valley, have programs to help residents purchase a home. Education on the buying process is necessary for many. • Housing affordability issue was brought up. Cities would prefer to have affordable units mixed in with market rate units. • Retired police officer who is now volunteering with a non-profit property management group explained her organization's goals. In essence, they want to expand to other areas (North OC and others). She also stated that the biggest housing needs that her non-profit is noticing are housing for seniors and single parents. • Resident requested PowerPoint presentation available and it was agreed that it would be put on website in the near future. Public Fair Housing Workshop # 4 City of Santa Ana September 30, 2015 - 6:00 to 7:30 pm Santa Ana Police Community Room Public Comments • A resident said that there was discrimination against families with children. Asked who could be contacted regarding specific issues. (Referred to Fair Housing Council of Orange County. Three staff from the Fair Housing Council were present at the workshop). • Person discussed situation where families with disabled children have difficulties finding apartments that do not have stairs. • Some attendees were unclear which classes of people were protected against discrimination. • Seniors have a difficult time finding housing they can afford as rents are too high relative to their fixed incomes. • Single parent families have a hard time finding housing. • Disabled seniors (wheelchair bound) do not know where to obtain housing. • Affordable housing is a major issue in Santa Ana and Orange County as a whole. (Issue was raised numerous times) • Residents discussed that they do not know where to go with discrimination problems. • Resident asked about specific things that Fair Housing Council can do to help, and if they offered legal services. • Some said that residents need help with foreclosure situation. • Some residents feel overwhelmed by the documentation required by landlords to rent an apartment. • The need for educational workshops on fair housing was brought up by a resident. • There is the need to properly notify the public about the importance of housing workshops. (Consultant responded that the Fair Housing Council offers workshops/services and let the attendees know that there were representatives from Fair Housing present at this public workshop meeting.) • Resident asked about programs to assist them in their housing needs. (They were informed that cities have rehab programs and that they can find specific information on the cities' websites). • Some landlords now have waiting lists for rental units. A resident commented that she would like to see the specific waiting list information as she thinks the waiting list is used to exclude applicants. • A resident asked if Al report will cover the need for additional housing. (She was informed that other documents address this specific information- the cities' Housing Elements, Consolidated Plans, etc.) • A question was asked about the draft Al being available for public review. (The draft Al will be made available on city websites and in hard copy at City Halls). • Landlord requirements that were onerous to some tenants came up. • Non-profit property manager mentioned that some tenants break rules (pets, overcrowding and others) and then expect owners not to enforce rules. • Non-profit property manager said survey was one sided towards tenants and that landlords also have rights. • The services of both the Fair Housing Council of Orange County, and the Fair Housing Foundation are important in Santa Ana to provide residents and landlords more choice/help with housing issues. Public Fair Housing Workshop # 5 Southern Orange County Subregion: Lake Forest, Mission Viejo, Rancho Santa Margarita, San Clemente October 1, 2015 - 6:00 to 7:30 pm Lake Forest City Hall — Community Room Public Comments • Motel Issue: Many residents use motels as apartments. In Costa Mesa there are various motels that are being converted to luxury condominiums. Does the Al report address motels? (Other related reports, such as Housing Element address motel conversion issue). • Since apartment vacancies are so low, several attendees questioned if perhaps landlords were being too picky to the point of discrimination. • If tenants discover they are being discriminated against — can they go to the police? • There were 35 written surveys completed in San Clemente that were submitted at this public workshop. • There were questions about how the Al will be implemented, and if 16 individual reports would be completed or one regional report. • One of the goals of the Al Report is to show progress. A resident asked if a city has a poor record of addressing housing discrimination, is it possible to assess progress before the end of the five year period. (Resident was informed that policies/actions would be addressed prior to the five year period, since many of these policies are also in the Housing Element. There is a yearly Action Plan, also CAPER, Consolidated Plan and other reports required by HUD that would ensure that there would be close scrutiny on cities' housing activities. If a city does not make the needed corrections, they may lose HUD funding. All cities have the similar goal to provide fair housing to all). Appendix A-2 Fair Housing Survey for Orange County Residents A group of 16 Orange County cities' is conducting a study to evaluate fair housing conditions in their communities, and is interested in gathering information from residents on any experience they may have had with housing discrimination. Your input is greatly needed to provide a clear picture of the situation within these areas, which will in turn assist the group in developing a plan to improve equal and fair housing choice for all residents. Please take a few minutes to fill out this survey. Your answers will be kept confidential. You can also respond to the survey on-line at https://www.surveymonkey.com/r/OC-AI16CitiesSurvey ENGLISH. For additional information, please contact: Robert G. Vasquez, GRC Associates, Inc., (626) 331-6373, rvasquez@grcassoc.com. 1. Please identify the ZIP code of your residence. 2. Have you ever encountered any form of housing discrimination in one of the 16 Orange County cities? O YES City name O NO O NOT SURE (If YES or NOT SURE, proceed to questions 3-7. If NO, skip to question 8) 3. If yes, which of the following best describes the person responsible for discriminating against you? O A landlord/property manager O A real estate agent O A lending institution O A City staff person O Other: Examples of discrimination include: ➢ A rental advertisement that says, "Perfect for couples or singles without children" or "No Pets" without an exception for service animals. ➢ A real estate agent "steers" you to houses in neighborhoods different than the ones you have requested and think you can afford. Y A landlord refuses to let you install a ramp in your shower (at your own expense) to accommodate your disability. 4. Which of the following best describes the location where the act of discrimination occurred? O An apartment complex O A trailer or mobile home park O A single-family neighborhood O A subsidized housing project O A condominium development O When applying for City programs O When applying for a loan 5. Please explain how you believe you were discriminated against. 1 The following 16 cities are participating in the regional Analysis of Impediments to Fair Housing Choice: Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, La Habra, Lake Forest, Mission Viejo, Orange, Newport Beach, Rancho Santa Margarita, San Clemente, Santa Ana, and Tustin. 6. On what basis do you believe you were discriminated against? Check all that apply.- 0 pply. O Race O Disability O Color O Ancestry O National Origin O Sexual Orientation O Gender O Marital Status O Age O Source of Income (i.e. welfare) O Religion O Other: O Family Status (e.g. due to children) Z Did you report the incident? O YES - If Yes, who did you contact? O NO - If No, why not? O Don't know where to report O Afraid of retaliation O Too much trouble O Don't believe it makes any difference O Other: 8. Have you ever been denied "reasonable accommodation" (flexibility) in rules, policies, or practices that you required to accommodate a disability related to housing? O YES O NO If YES, what was your request? 9. How well informed do you feel yourself to be about housing discrimination laws? O Very well informed O A little informed O Somewhat informed O Not informed at all 10. What would you do if you encountered housing discrimination? O Tell the person you believe they are discriminating O Report it O Do nothing and seek other housing options O Wouldn't know what to do 11. Do you believe there is housing discrimination occurring in Orange County and, if so, what types of discrimination problems do you think are the worst? Your input is greatly appreciated! Please return the survey by October 15, 2015 to: Robert G. Vasquez, GRC Associates, Inc., 858 Oak Park Road, Suite 280, Covina, CA 91724 (626) 331-6373 (phone), (626) 331-6375 (fax), rvasquez@grcassoc.com Appendix A-2 Encuesta de Vivienda Justa para los Residentes del Condado de Orange Un grupo de 16 ciudades del Condado de Orange' esta Ilevando a cabo un estudio para evaluar las condiciones de equidad de vivienda en sus comunidades y estan interesados en recompilar informaci6n de los residentes acerca de cualquier experiencia discriminatoria que hayan tenido relacionada con viviendas. Su ayuda es necesaria para proporcionar una imagen clara de la situaci6n dentro de estas areas, que a su vez ayudara al grupo en el desarrollo de un plan para mejorar la elecci6n justa y equitativa de viviendas para todos los residentes. Por favor tome unos minutos para Ilenar esta encuesta. Sus respuestas seran confidenciales. Tambien puede responder a la encuesta en linea en el sitio web https://www.surveymonkey.com/r/OC-Al16CitiesSurveV SPANISH. Para obtener informaci6n adicional, por favor p6ngase en contacto con Robert G. Vasquez, GRC Associates, Inc., (626) 331-6373, rvasquez@grcassoc.com. 1. Por. favor identifique el c6digo postal de su hogar. 2 Z Aiguna vez ha tenido alguna forma de discriminaci6n de viviendas en una de las 16 ciudades del Condado de Orange? 0 Si Nombre de Ciudad 0 NO 0 NO ESTOY SEGURO(A) (Si "SI" o "NO ESTOY SEGURO(A)", continue con las preguntas 3-7. Si "NO", pase a la pregunta 8) 2 3. En caso afirmativo, cu61 de las siguientes opciones describe mejor la persona responsable de discriminar en contra de usted? 0 Un administrador o manejador de la propiedad 0 Un agente de buenas raices 0 Una instituci6n de credito 0 Personal de Ciudad 0 Otro: Ejemplos de discriminaci6n incluyen: ➢ Un anuncio de alquiler que dice, "Perfecto para parejas o solteros sin hijos " o " no mascotas", sin una excepci6n para los animales de servicio. ➢ Un agente de bienes raices que to "dirige" a casas en barrios diferentes que las que usted habia requerido y podria pagar. ➢ Un propietario le niega a usted de instalar una rampa en el baro (a su propio costo) para ayudarle con su discapacidad. 2 4. Cu61 de las siguientes opciones describe mejor el lugar donde ocurri6 el acto de discriminaci6n? 0 Un apartamento 0 Un Remolque o complejo de casas m6viles 0 Un barrio de casas 0 Un complejo de viviendas subsidiadas 0 Un proyecto de condominios 0 Al solicitar programas de la Ciudad 0 Al solicitar un prestamo 5. Por favor, explique c6mo usted cree que fue discriminado: 1 Las siguientes 16 ciudades estan participando en un estudio, el Analisis Regional de los Impedimentos para la Justa Selecci6n de Viviendas: Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, La Habra, Lake Forest, Mission Viejo, Orange, Newport Beach, Rancho Santa Margarita, San Clemente, Santa Ana, and Tustin. z 6. Sobre que base usted cree que fue discriminado? Marque todo to que corresponda: 0 Raza 0 Discapacidad 0 Color 0 Linaje 0 Origen Nacional 0 Orientacion Sexual 0 Genero 0 Estado Civil (Matrimonio) 0 Edad 0 Fuente de ingresos (ejemplo el 0 Religion bienestar) 0 Estado Familiar (e.g. debido a los ninos) 0 Otro: 2 7. Denuncio o reporto el incidente?? 0 SI — En caso afirmativo, ?A quien contacto? 0 NO — En caso negativo, Por que no? 0 No sabia a quien contactar 0 Miedo de represalia 0 Demasiados problemas 0 No crei que haria ninguna diferencia 0 Otro: 2 S. Alguna vez se le ha negado " ajustes razonables " (flexibilidad) en las reglas, politicas, o pr6cticas que se requieren para dar cabida a una discapacidad de usted relacionada con viviendas? 0 SI 0 NO 7 Si afirmativo, cual era su peticion? 9. Que tan bien informado to sientes a ti mismo ser acerca de las leyes de discriminacion de vivienda? 0 Muy bien informado 0 Informado un poco 0 Algo informado 0 No informado en ninguna manera 10. Que haria usted si usted encontrara discriminacion de viviendas? 0 Le diria a la persona que yo creo que ellos estan discriminando 0 Reportarlo 0 No haria nada y buscaria otras opciones de viviendas 0 No sabria que hacer 11. tree usted que est6 ocurriendo discriminacion de viviendas en el Condado de Orange y, si es asi, que dpos de problemas de discriminacion cree usted que son los peores? Sus respuestas son muy apreciadas! Por favor devuelva esta encuesta para el 15 de Octubre de 2015 para: Robert G. Vasquez, GRC Associates, Inc., 858 Oak Park Road, Suite 280, Covina, CA 91724 (626) 331-6373 (phone), (626) 331-6375 (fax), rvasquez@grcassoc.com Appendix A-2 2tlT1 3 EI X01; -or �9 -1 �)i sF� �-�c��E � � TL-� T � 00 � T `O ��� 2t"TI3 El LH 16 A°l-'--L-J\I€__2d011Ad'T,IC'MYlLHooi�T71sEo�oI7FSTI` 01 _2o�-11 Oil CH OH 0�apF�7CtC. �IO�1 �1 ��-TZ� I -M T r O=j 0 01 TI a'LHoo2°o�sFoF7ilU10"01-1_Hd�=)\l�2oFOH012ooH=- 0— oFoo` z O lid c 0 7C{ 0 7C QF 71 o Ll EH o f-- O 1 : a' o d F- � C o �I 7� 01 TSO OoO � OO � T� 0 E � ER T ML —2 � z0 L C 1�O FM t:=j , til z 0� iO 0ooO4�0 I� I �F 01 � 1.�I F _I EH t� �o 1 O O sl Sc _1 aR z_I t=J od F_- _FT t=J o ALF https://www.surveymonkey.com/r/OC-Al16CitiesSurveV KOREAN. 011AI AF_d =C:1_71__)\F011 J � OF z' T� M d LI CF. zF�11 `E LH T Robert G. Vasquez, GRC Associates, Inc., (626) 331-6373, rvasquez@grcassoc.com oFl\l 71 HF dFLI Q. 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TJl Xf-- L --f HoH mol pl z a/Lf -- -L f � oH�Eofd'L/JJf? 0 O O T Z � ZM o O -�' - o o O `i aj F-- � o 10. zkz� OF�°C� �lFzF0ll7il �CO ozL O zk�0il CHoH d2LEEl O 0[iLz1 U C� ���"�a]oFLT OILT O TaEE SH0k zz1 2zM'Cl 11. Qff1Xl3f` E1011 / T X1 z 0/ z'oyOf � 0u1Gf � oy�'�Of�u-'L/JJf? -:4 011�2 l21 �fz � �fof o'-FofCf oy-7 61� � o o T �' I L/JJf? [HoH CHEEoI o'Af=d'LICH. 2015 vA 10 iz 15 ' Oil 14 p 3'--A}-Kik V-4 - �' Al —0: Robert G. Vasquez, GRC Associates, Inc., 858 Oak Park Road, Suite 280, Covina, CA 91724 (626) 331-6373 (phone), (626) 331-6375 (fax), rvasquez@grcassoc.com Appendix A-2 Khao Sat Ve Cong Bang Gia Cu' Cho Cu' Dan Orange County Mub'i sau thanh pho trong Quan Cam' (Orange County) dang titin hanh mot cuoc khao sat de tim Neu ve van de tong bang gia cu' (fair housing) trong tong dong. Cac vien chk c6a cuoc khao sat se thu thap thong tin c6a cu• dan lien quan den viec ky thi trong van de nha 6. Chung toi rat can cac y kien d6ng g6p c6a quy vi de tim Neu them van de nay, W d6 ho tra cho cac thanh pho phac thao ke hoach cai titin quyen bjnh dang va tong bang ve nha & cho cu' da"n. Xin vui long danh ra vai phut de dien vao ban khao sat dLrai day. Cau tra Iii c6a quy vi se duac giu' kin. Quy vi cung c6 the dien vao ban khao sat tren mang tai dia chi: https://www.surveymonkey.com/r/OC-Al16CitiesSurvey VIETNAMESE. Won biet them chi tiet, Anlien lac: Robert G. Vasquez, GRC Associates, Inc., (626) 331-6373, rvasquez@grcassoc.com. 1. Cho biet ma so vung noxi cu' ngu c6a quj vi (ZIP Code). 2. Cd bao gi& quj vi bi ky thi ve nha 6,tai mot trong 16 thdnh pho 6, Orange County? O CO Ten thanh pho" O KHONG O KHONG CHAC (Neu cau tra lai la CO hoac KHONG CHAC, tra IM tiep tU cau 3 den cau 7. Neu cau tra IM la KHONG, tiep tuc tra lai cau so 8) 3. Ne -u da tirng bi kk th% quj vi nghT rang nhirng ngLrdi/cling ty/to chirc ndo dirai d6y da kk thi quj vi? O Chu nha /ngLro'i quan ly khu gia cLr (property manager) O Chuyen vien dia oc O Nai cho vay na O Nhan vien Thanh Pho O NgLrai/cong ty/to chtk khong de cap & tren: 4. Viet kk thi da dien ra tai dia diem nao dudi day? O Khu chung cLr O Khu nha dun (single-family neighborhood) O Khu nha condo O Khi quy vi nop dun xin vay mot khonn na 5. Giai thich tai sao quj vi tin rang minh da bi kk thi: Vi du ve phan biet d6i xir bao gom: ➢ Mau rao vat ghi: "Thich hap cho va thong hoac ngLr&i doc than khong co con nh6" hoac "Khong nhan thu nu6i" Mau rao vat khong de cap den trLr&ng hap ngoai le cho phep cac loai cho giup da cho ngLr&i tan tat (service animals). ➢ Chuyen vien dia oc ter chuyen hlrang kiem nha cua quy vi sang mot khu vu'c khac - khong phai khu vLrc ma quy vi yeu cau. Chuyen vien dia oc nghT rang b khu vuc khac quy vi moi c6 kha nang tai chinh de mua nha. ➢ Chu nha tU cho "i khong cho phep quy vi, ngLrai bi tan tat, lap dat "ramp" trong phbng tam (v&i chi phi do quy vi ter tra). ["Ramp" - tam not 2 vi tri vai 2 do cao khac nhau, giup ngLr&i tan tat di chuyen de clang -] O Khu mobile home/trailer O Trong mot chLrang trinh tra cap gia cu' O Khi quy vi nop dun cho mot chLrang trinh c6a Thanh Pho (1) Danh sach 16 thanh pho tham gia cuoc khao sat ve cong bang gia cir Analysis of Impediments to Fair Housing Choice: Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, La Habra, Lake Forest, Mission Viejo, Orange, Newport Beach, Rancho Santa Margarita, San Clemente, Santa Ana, and Tustin. 6. Quy vi nghi rang minh dd bi kk thi b6,i yeu to neto dLr6,i day? Danh ddu veto tdt ca nhCrng yeu to ma quy vi cho la bi kk thi: 0 Chungtoc 0 Mau da 0 Qu6c gia 0 Giai tinh 0 Tubi tac 0 Ton giao 0 Tinh trang gia dinh (vi du: do co con nh6) 0 Tan tat 0 To titin 0 Xu hLrang tinh duc (Sexual Orientation) 0 Tinh trang h6n nhan 0 Ngu6n Iqi Uuc (vi du: do lanh try cap xa h6i) 0 Bi ky thi b&i cac yeu to khac, ghi ra: 7. Quy vi co bao cao trirang hap bi kk thi khong? O CO — Neu CO, quy vi bio cao cho ai? 0 KHONG — Neu KHONG, tai sao khong bio cao? 0 Kh6ng biet bao cao cho ai? 0 Lo sq bi tra thu 0 Cam thay phien phLrc qua 0 Cho rang bao cao cung kh6ng lam du'ac gi 0 Ly do khac: 8. Co bao gia quy vi bi tir chdi khong dLrg c "Trg, Giup Hap Ly" ("Reasonable Accommodation") — Reasonable Accommodation let mot sir uye'n chuye'n vet thay doi ve chinh sach, luat le, quy dinh nham giup cho ngu'6,i bi tetn tat hu'ang dLrgc quyen loi tong bang ve gia cu: O CO 0 KHONG Neu CO, de nghi An try pup cua quy vi la gi? 9. Quy vi nghi rang minh dd du'oc thong bao ve cac luat lien quan den vdn de kk thi gia cu' 6, mirc neto? 0 Dayc th6ng bao day du 0 Du'gc thong bao khong day du 0 Duyc thong bao rat it 0 Kh6ng clauc thong bio 10. Quy vi se lam gi neu bi ky thi ve nhet 6,? 0 Cho ngLr&i d6 biet ho Bang ky thi minh 0 Bao cao 0 Kh6ng lam gi ca, di kiem nha khac 0 Kh6ng biet phai lam gi 11. Quy vi co nghi rang co tinh trang kk thi gia cLr tai Orange County. Neu co, theo quy vi, hinh thirc kk thi neto Id toi to nhdt? Cam an quy vi da danh thi gia cho cuoc khao sat nay! Vui long g&i lai ban khao sat truck ngay 15 thang MLr&i, 2015 cho chung t6i den dia chi sau: Robert G. Vasquez, GRC Associates, Inc., 858 Oak Park Road, Suite 280, Covina, CA 91724 LA HABRA BUENA PARK FULLERTON ANAHEIMAUI�l air ousinGARDEN GROVEurve esu is SAA FOUNTA VALLEY UNTICOSTA _ " U ES BEACHACH MESA �If NEVIPORTMISSION BEACH VIEJO RANCHO SANTA MARGARITA SAN MENTE Total English Spanish Vietnamese Korean 188 76 110 2 0 • Top 10 Zip Codes of Respondents' Residences Num. Zip Code # 1 92701 54 2 92672 23 3 92703 19 4 92706 13 5 92673 9 6 92705 9 7 92704 7 8 92707 7 9 92708 6 10 92801 4 Total 151 82% Total % Total English Spanish Vietnamese 36.3% 66 39 27 0 NO 7.1% 13 9 4 0 NOT SURE 56.6% 103 25 77 1 ES 100.0% 182 73 108 1 Tota 1 Total % Total English Spanish Vietnamese landlord/property 87.5% 98 30 67 1 manager real estate agent 5.4% 6 0 6 0 lending institution 1.8% 2 0 2 0 City staff person 1.8% 2 1 1 0 Other: 3.6% 4 1 3 0 �otal 100.0% 112 321 791 1 Options Total % Response English Spanish Vietnamese Count 80.2% 89 23 66 0 An apartment complex 10.8% 12 7 5 0 single-family neighborhood 0.9% 1 1 0 0 condominium development 1.8% 2 0 2 0 When applying for a loan 4.5% 5 1 3 1 trailer or mobile home park 0.0% 0 0 0 0 subsidized housing project 1.8% 2 1 1 0 When applying for City programs 100.0% 111 33 77 1 �otal Total English Spanish Vietnamese 105 Answered question 27 77 1 83 Skipped question 49 33 1 188 Total 76 110 2 Options Total % Response Count English Spanish Vietnamese Race 42.9% 48 13 34 1 Color 29.5% 33 5 28 0 National Origin 35.7% 40 4 35 1 Gender 13.4% 15 4 11 0 Age 4.5% 5 2 3 0 Religion 0.0% 0 0 0 0 Family Status (e.g. due to children 50.9% 57 12 45 0 Disability 12.5% 14 4 10 0 ncestr 0.9% 1 1 0 0 Sexual Orientation 0.9% 1 1 0 0 Marital Status 9.8% 11 2 9 0 Source of Income (i.e. welfare) 35.7% 40 9 31 0 Other leasespecify) 10.7% 12 9 3 0 Total 112 32 791 1 Source: 2007-2011 CHAS A Response Answer Total % Count English Spanish Vietnamese 9.2% 10 4 6 0 YES 90.8% 99 29 69 1 NO 100.0% 109 29 69 1 Total Source: 2007-2011 CHAS A Answer Total % Total English Spanish Vietnamese 14.0% 23 8 15 0 ES 86.0% 141 58 82 1 NO 100.0% 164 66 97 1 Tota Answer Total % Total English Spanish Vietnamese Very well informed 10.7% 18 16 2 0 Somewhat 15.4% 26 17 9 0 informed little informed 33.7% 57 16 41 0 Not informed at all 40.2% 68 15 52 1 Tota 1 100.0% 169 64 104 1 Answer Total % Total English Spanish Vietnamese Tell the person you believe they are 14.6% 24 11 13 0 discriminating 17.7% 29 8 21 0 Do nothing and seek other housing options 34.8% 57 28 29 0 Report it 32.9% 54 16 37 1 Wouldn't know what to do 100.0% 164 63 100 1 �otal Answer Total % Total English Spanish Vietnamese Answered 76.1 % 143 Question 46 97 0 Skipped Question 23.9% 45 30 13 2 Total 100.0% 188 76 110 2 Nam Thu Hai Mutii Lam eX a ! 25 Dents S9 tido 7643 o Copryty Thu ea 8-3-78A11,'�; 8outhe'rYt,o itotnia Edition. Thdng Bao Ung Cling 16 thanh ph6 trong Quan Cam dit thio ph5n tick vd W ngai doi vdi cac Ltia Chon Ong Bang Gia Cit M tbi s£u thanh ph6 Quin.Cam da tham gia trong du th'ao phat trien ac Phan tich trong qudn hat cua cac Lia Clip 'CBng Bing Gia Cu (AI)AG thanh ph6 tham gia bao gbm: Anaheim Huntington Beach Orange .Buena Park La Habra Rancho Santa Costa Mesa Lake Forest. Sanclemente Fountain Valley MissionVlejo Santa Ana. Fullerton Newport Beach Tustin - GardenGrove Muc(1ichcuah0inghiAllax£cdinhvit.d nhgiac5cWngaiti'mtingd$iv8i khi n£ng caa mpt ngubi'ddi vbi Sv l r4ch9n nai cit' ' cua hp ma kh8ng cb sy phan biet chung t$j:, va khuyen kh ch nh- g hanh d¢ng nhum ir£c dinh c£c trd' ngai nay. DV thao Al cung cnp: 1) Mot e£i nhint$ng quit ve hiit ph£p, nhimg quy dinh, chink sachva c£c thu tpc hanh chinh; 2) Mot d$nh gi£'nhting'phtfong c£ch malu4t phap inh hubng den not ch6n, sys£n c6 vii tach tiep con gia cu; 3) M§t dinh gi� vii c£c di�u kiln, 6 hat khu vvc cbng Ong vd,hiph"an, c6 anhbOng 1 ch nc6ng bean I On � 4t? 4 g gia cu Ban sao cua du tMo Al Bang cb An de cbng chung xem xet tai V$n Phbng cda City Clerk tai m8i.thanh ph6 eb tham gia v3 tren mang then to cua c£c tlianh ph6 do, C6 thbi gian30 ngay de c&ng chting xem xet iai ban dtf thio Al b6tdau tts ngay 9 thing 3 va chSm dut vao ngay 7 thing 4, 2016. Yin quy vi vui lbng nbp nhiing: bin gbp 9 vi6t tay v� bin dv thao Alden td chuc GRC Associates, nhungnha tuvSn clang trd gidP c£ctlianh ph6 chuazi bi the Al, tai dia chi San .day:.. GRCAssociates 8060 Florence Avenue, Suite 303 Downey, CA 90240 Neu quy vi co that m9c ve Du Thio Al, xin gpi Robert Vasquez ho4c John Oshimo thu$c GRC Associates tai s6di@n thoai 626-331-6373. 24 1 LaOphd6n MARTES 8 MARZO 2016 servialos www.laopinion-com/clasificados State Bar #18985 AF INMIGRACION ,&En quien confiaria su destino? ® En Notarios? ® En su preparador de Taxes? En una abogada con extensa trayectoria y la mayor experiencia en Inmigraci6n, Aplicaci6n de Nuevas Leyes, Peticiones de Familia y Trabajo, Visas y Defensa de Deportaciones. iNo se deje enganar! Llamenos para una consulta gratuita en nuestras oficinas. Miembro Activo De La Barra Estatal Con Licencia Para Ejercer Leyes En California. I �o Construcci6n __J CONTRATISTA GENERAL Disenos, planos permisos, solucion de problemas del 'housing', legaliza- cion de unidades, adiciones y cases nuevas, Restaurantes y Locales Comercia- les. Lic. #554524 562-412-5307 Plomeria CALEFACCION, A/C. 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Informes Ilamar at 213-605-2784 323-252-8931 310-651-4569 626-486-8046 562-200-3659 818-660-3115 eusquelo en Clasificados de La Opini6n (888)526.7464 Avisos Legales Grlias "ARTURO" COMPRO AUTOS Para Chatarra (junk). Pago los mejores precios. Servicio de grua. Toda area. Arturo Rizk (323) 221-0631 Lotes de Chatarra AGUILA ' COMPRO TODD' TIPO DE CARBO, ' camine o no camine. I pago $500 a $1,500 p/up, vans. 24hrs Llame Hoy ' 1( 323) 228-3733 �c sca auto aomesnco o importado? encuentralo Clasificados de La ODini6n Avisos Legales Transmisiones Transmisiones de la policia local, Kiran Ka- ESPECIAL DE TRANSMISIONES Usadas y Recons. en inventario, Grua TRANSMISIONES gratis. Se acepta Automaticas, V/MC. Info. Javier Garantizadas (310)604-4743 Presupuestos (310) 367-3797 Gratis 830 E. Florence L.A. 323/277-9181 la India es el criquet, aunque LUCID TRANSMI-L 323/244-7882 SION A cambio $100 futbol aumenta afio tras alio instaladas. $180 TRANSMISIONES Garan. diagnostico Garantizadas Buen computarizados. Precio. Grua Gratis Grua gratis 10 Millas 10 Millas. Diagn6sti- NUEVA cos computarizados LOCALIDAD DE gratis. 323/232-1045 LANCASTER 323/527-4747 323-233-1947 La mejor manera que OFERTA DE compradores sepan Transmisiones acerca de su pro- Automaticas duct0 0 Servicio. regulares $180, se Publicandose en los trabajan estandar, Clasificados Grua Gratis de 323-231-2786 La Opinion Avisos Legales Avisos Legales Aviso de Opinion Hiblica 16 Ciudades del Condado de Orange Analisis Regional de Impedimentos para la Elecci6n Justa de Viviendas Dieciseis ciudades del Condado de Orange han participado an el desarrollo del analisis regional de impedimentos para la elecci6n justa de viviendas (AI). Las 16 ciudades participantes incluyen: Anaheim Huntington Beach Orange Buena Park La Habra Rancho Santa Margarita Costa Mesa Lake Forest San Clemente Fountain Valley Mission Viejo Santa Ana Fullerton Newport Beach Tustin Garden Grove EI objetivo del Al es identificar y evaluar los posibles obstaculos o impedimentos de personas para elegir sus residencias libre de discriminaci6n, y recomendar acciones que aborden tales impedi- mentos. EI Al ofrece: 1) una vision general de las leyes, reglamentos, politicas administrativas y procedimientos; 2) una evaluaci6n de c6mo estas leyes afectan la ubicaci6n, la disponibilidad y accesibilidad de las viviendas; y 3) una evaluaci6n de las condiciones, tanto p6blicas tomo priva- das, que afectan a la elecci6n justa de viviendas. Copias del Borrador Al estan disponibles para consulta p6blica en la Oficina del Secretario de la Ciudad (Office of the City Clerk) de Cada Ciudad participante y en at sitio web de la Ciudad. EI periodo de revision p6blica de 30 dias para el Borrador Al comienza 9 de marzo y termina el 7 de abril de 2016. Por favor, envie sus comentarios por escrito sobre el Borrador At a GRC Associates, los consultores que asisten a las ciudades para preparar el At, a la siguiente direction: GRC Associates 8060 Florence Avenue, Suite 303 Downey, CA 90240 Si tiene alguna pregunta con respecto al Al, por favor Ilame a Roberto G. Vasquez o John Oshimo de GRC Associates at 626-331-6373. 41DEMP01 TEM'S It FUTBOL D iscusibn sobre C117 ymessi t tragedia en India Nigerian de 24 anos es asesinado por su amigo EFE BOMBAY, INDIA Un hombre mato a uno de sus amigos durante una discusi6n sobre quien es mejor futbolista, si el por- tugues Cristiano Ronaldo o el argentino Lionel Messi, en la fiesta de cumpleafios de la victima en la Ciudad india de Bombay, inform6 una fuente policial. Los dos j6venes, de na- cionalidad nigeriana, Ile- vaban desde el sabado ce- lebrando el 34 cumpleafios de uno de ellos en su apar- tamento en Nalasopara, a las afueras de la metr6polis (oeste), cuando en la mana- na del domingo la disputa sobre las estrellas del Real Madrid y del FC Barcelo- na desencaden6 la pelea. La pasi6n futbolera por Cristiano Ronaldo y Lionel Messi Ileg6 all extremo en India, donde mur16 un joven. /GETTY IMAGES Segun explic6 un inspector La policia lleg6 al lugar tras de la policia local, Kiran Ka- ser avisada por los vecinos, badi, el joven que celebraba que escucharon la disputa, y el cumpleafios, identificado arrest6 al joven nigeriano por Como Obinna y seguidor de el cargo de asesinato, conclu- Ronaldo, lanz6 un vaso con- y6 el agente. tra el fan de Messi, Nwabu, El deporte hegem6nico en de 24 anos, pero fa116 y el ob- la India es el criquet, aunque jeto impact6 contra la pared. el n6mero de seguidores del Entonces el fan del argen- futbol aumenta afio tras alio tino agarr6 uno de los cris- de manera exponencial y el tales del vaso roto y degol16 interes por las competiciones a su amigo, que muri6 des- europeas es masivo. • angrado en el apartamento. laopinion.com Vela se da una escapadita Todo sea por ver a Chris Brown. La Real Sociedad ya le prepara un expediente disciplinario a Carlos Vela por ausentarse del entrenamiento matutino de ayer. La noche del domingo, el mexicano realiz6 un viaje relampago a Madrid para asistir a un concierto de Brown, cantante de rap. EI mexicano debia presentarse ayer por la manana en el complejo deportivo de Zubieta, donde el equipo hizo trabajo regenerativo. De acuerdo a informes, el delantero mexicano justific6 su ausencia por una gastroenteritis. /REFORMA 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Appendix 6: Public Transit and Major Employment Centers APPENDIX 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Appendix B Public Transit and Major Employment Centers LPL q,e SGrtuIly [Inft eeavvy APPENDIX B: PUBLIC TRANSIT AND EMPLOYMENT CENTERS B-1 Top 10 Employment Centers North Tustin Top 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Appendix B Public Transit and Major Employment Centers APPENDIX B: PUBLIC TRANSIT AND EMPLOYMENT CENTERS B-2 Tol 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Appendix 6 Public Transit and Major Employment Centers APPENDIX B: PUBLIC TRANSIT AND EMPLOYMENT CENTERS B-3 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Appendix B Public Transit and Major Employment Centers 0 Top 10 Employment Centers Rancho Santa Margarita 74i,�d APPENDIX B: PUBLIC TRANSIT AND EMPLOYMENT CENTERS B-4 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Appendix C: Mortgage Lending Practices APPENDIX C-1: Home Purchase Loan Activities 2008- 2013 APPENDIX C-2: Percent Of Denied Purchase Loans - By Census Tract - Applicant Race/Ethnicity APPENDIX Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Tustin Orange County Total Anaheim Buena Park Costa Mesa Fountain Valley Fullerton Garden Grove Huntington Beach La Habra Lake Forest Mission Viejo Newport Beach Orange Rancho Santa Margarita San Clemente Santa Ana Tustin Orange County Total Appendix C-1 Home Purchase Loans - Completed Loan Applications Percent of Total 2008-2013 2008 1 2009 1 2010 1 2011 1 2012 1 2013 1 2008 1 2009 1 2010 1 2011 1 2012 1 2013 35% 34% 34% 35% 34% 37% 1.8% 1.0% 0.7% 1.0% 1.1% 0.8% 26% 27% 23% 28% 23% 22% 3.1% 1.9% 1.6% 1.7% 2.2% 0.8% 57% 62% 60% 60% 58% 61% 0.6% 0.6% 0.5% 0.7% 0.4% 0.4% 28% 26% 26% 26% 30% 30% 0.7% 0.4% 0.4% 0.3% 0.2% 0.6% 38% 33% 35% 36% 35% 32% 1.6% 1.0% 0.8% 0.9% 0.9% 0.8% 21% 19% 19% 20% 18% 21% 1.1% 0.4% 0.4% 0.7% 0.9% 0.2% 63% 64% 62% 58% 61% 63% 0.6% 0.5% 0.6% 0.7% 0.4% 0.4% 34% 34% 35% 35% 36% 33% 1.1% 1.3% 0.9% 1.8% 1.3% 1.1% 58% 58% 49% 52% 47% 43% 1.2% 0.7% 0.7% 1.1% 1.3% 0.4% 67% 65% 64% 63% 66% 68% 1.1% 1.1% 1.0% 0.9% 0.8% 0.6% 65% 67% 66% 65% 64% 63% 0.3% 0.3% 0.3% 0.5% 0.1% 0.2% 50% 46% 47% 51% 50% 52% 1.3% 0.6% 0.9% 0.9% 1.0% 0.6% 68% 68% 69% 67% 68% 68% 0.9% 1.5% 1.2% 1.3% 1.1% 1.1% 70% 72% 72% 75% 76% 76% 0.2% 0.3% 0.5% 0.1% 0.4% 0.3% 26% 23% 23% 22% 23% 27% 0.9% 0.4% 0.9% 1.1% 0.6% 0.3% 44% 39% 40% 42% 46% 51% 0.8% 0.5% 1.0% 1.2% 0.5% 0.4% 49% 47% 47% 48% 48% 49% 1.2% 0.8% 0.8% 0.9% 0.8% 0.6% 2008 12009 12010 12011 12012 12013 12008 12009 12010 12011 12012 12013 26% 23% 21% 23% 22% 20% 24% 30% 32% 28% 30% 32% 24% 21% 17% 20% 18% 18% 34% 40% 47% 39% 45% 48% 9% 6% 5% 6% 6% 6% 17% 18% 20% 16% 19% 16% 5% 7% 5% 6% 7% 4% 56% 57% 58% 56% 54% 57% 20% 20% 19% 20% 15% 15% 27% 34% 35% 31% 39% 40% 16% 12% 13% 12% 10% 13% 54% 60% 58% 58% 61% 57% 6% 6% 5% 5% 5% 5% 17% 19% 20% 20% 20% 19% 34% 31% 27% 31% 25% 23% 20% 23% 26% 21% 28% 33% 13% 10% 9% 11% 7% 6% 12% 17% 29% 23% 32% 39% 9% 9% 7% 8% 8% 6% 8% 11% 12% 12% 12% 12% 3% 2% 2% 3% 2% 2% 10% 11% 14% 10% 14% 17% 15% 14% 11% 12% 12% 10% 19% 25% 27% 22% 23% 25% 7% 6% 6% 7% 7% 7% 8% 11% 9% 11% 10% 11% 3% 5% 5% 4% 4% 4% 4% 4% 5% 4% 4% 5% 40% 38% 37% 39% 36% 31% 23% 28% 29% 28% 30% 31% 17% 15% 13% 12% 14% 10% 25% 32% 32% 32% 28% 26% 16% 14% 12% 13% 11% 10% 23% 25% 27% 25% 27% 28% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2 - Table includes all applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black Hispanic Applicant Race Asian I Haw. Nat. Am. Multi I Unk/NA I Total Min. % Anaheim 0116.02 Low 25% n/a 33% 33% n/a n/a n/a 0% 28% 33% Anaheim 0117.14 Low 0% n/a n/a 0% n/a n/a n/a n/a 0% 0% Anaheim 0117.20 Low n/a n/a 25% 0% n/a n/a n/a 33% 18% 14% Anaheim 0117.22 Middle 38% 0% 0% 33% n/a n/a n/a n/a 27% 11% Anaheim 0218.07 Upper 9% n/a 1 33% 29% 0% n/a n/a 1 25% 16% 29% Anaheim 0218.12 Middle 12% n/a 15% 14% n/a n/a n/a 29% 14% 15% Anaheim 0218.13 Unk/NA 0% n/a n/a n/a n/a n/a n/a n/a 0% 0% Anaheim 0218.21 Middle 25% 0% 25% 15% n/a n/a 100% 0% 21% 21% Anaheim 0218.26 Upper 6% n/a 0% 0% n/a n/a n/a 0% 3% 0% Anaheim 0219.03 Middle 9% n/a 14% 20% n/a n/a n/a 1 50% 14% 17% Anaheim 0219.05 Upper 0% n/a 22% 6% n/a n/a n/a 13% 7% 11% Anaheim 0219.12 Upper 6% n/a 17% 15% 0% n/a n/a 0% 8% 15% Anaheim 0219.15 Upper 7% n/a 0% 19% n/a n/a 100% 0% 10% 18% Anaheim 0219.16 Upper 12% n/a 1 43% 17% n/a n/a 0% 0% 15% 29% Anaheim 0219.19 Middle 10% n/a 0% 14% n/a n/a n/a 20% 12% 11% Anaheim 0219.20 Upper 15% n/a 20% 10% n/a n/a n/a 17% 14% 12% Anaheim 0219.21 Upper 12% n/a 0% 24% n/a n/a 0% 17% 16% 21% Anaheim 0219.22 Upper 12% 0% 0% 6% 0% n/a 0% 0% 8% 4% Anaheim 0219.23 Upper 15% 100% 14% 9% 0% n/a n/a 0% 13% 11% Anaheim 0219.24 Upper 0% n/a 0% 7% n/a n/a n/a 0% 2% 6% Anaheim 0758.13 Upper 6% 0% 0% 9% n/a n/a n/a 10% 7% 6% Anaheim 0761.01 Middle 22% n/a 13% 0% n/a n/a n/a 67% 20% 10% Anaheim 0761.02 IMod 0% 100% 0% 0% n/a n/a n/a 0% 5% 8% Anaheim 0762.02 Middle 13% 0% 14% 14% 0% n/a I n/a 40% 15% 13% Anaheim 0863.01 Mod 20% n/a 17% 7% 0% n/a n/a 0% 14% 13% Anaheim 0863.03 Mod 0% 100% 8% 6% n/a n/a n/a 0% 5% 10% Anaheim 0863.04 Middle 8% n/a 9% 13% 0% n/a n/a 0% 8% 9% Anaheim 0863.05 IMiddle 13% 0% 0% 13% 0% n/a n/a 25% 11% 7% Anaheim 0863.06 Middle 0% n/a 0% 0% n/a n/a n/a 50% 4% 0% Anaheim 0864.02 Mod 8% 50% 7% 0% n/a n/a n/a 25% 9% 8% Anaheim 0864.04 Mod 25% n/a 42% 0% n/a 0% n/a 33% 25% 24% Anaheim 0864.05 Mod 11% n/a 25% 0% n/a n/a n/a 0% 15% 17% Anaheim 0864.06 Mod 0% n/a 20% 25% n/a n/a I n/a 25% 16% 22% Anaheim 0864.07 Mod 8% n/a 17% 20% n/a n/a n/a 33% 16% 19% Anaheim 0865.01 Mod 19% n/a 38% 20% n/a n/a n/a 43% 29% 33% Anaheim 0865.02 Mod 0% n/a 31% 38% n/a n/a n/a 25% 29% 33% Anaheim 0866.01 Low n/a n/a 25% 8% n/a n/a n/a 22% 17% 15% Anaheim 0866.02 Mod 33% 0% 20% 17% n/a n/a I n/a 0% 21% 18% Anaheim 0867.01 Mod 7% n/a 12% 9% 0% n/a n/a 0% 9% 10% Anaheim 0867.02 Mod 0% n/a 30% 9% n/a n/a n/a 25% 16% 19% Anaheim 0868.01 Middle 44% 0% 33% 38% 0% n/a n/a 33% 36% 33% Anaheim 0868.02 Mod 1 0% 0% 0% 0% n/a n/a n/a 50% 4% 0% Page 1 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic Applicant Race Asian I Haw. Nat. Am. I Multi I Unk/NA I Total Min. % Anaheim 0868.03 Mod 11% 0% 10% 11% n/a n/a n/a 0% 9% 10% Anaheim 0869.01 Mod 0% 0% 0% 14% 0% n/a n/a 0% 8% 12% Anaheim 0869.02 Mod 11% n/a 20% 0% n/a n/a n/a 17% 10% 8% Anaheim 0869.03 Mod 0% n/a 0% 0% n/a n/a n/a n/a 0% 0% Anaheim 0870.01 Mod 40% n/a 1 13% 7% n/a n/a n/a 1 20% 16% 9% Anaheim 0870.02 Mod 11% n/a 36% 27% n/a 100% n/a 25% 28% 35% Anaheim 0871.01 Mod 0% n/a 0% 0% n/a n/a 100% 0% 7% 17% Anaheim 0871.02 Mod 11% n/a 18% 23% n/a n/a n/a 100% 23% 21% Anaheim 0871.03 Middle 0% 0% 36% 17% n/a n/a 0% 29% 18% 21% Anaheim 0871.05 Mod 14% n/a 0% 14% n/a n/a n/a 1 0% 11% 13% Anaheim 0871.06 Low 20% n/a 0% 27% n/a n/a 0% 10% 16% 18% Anaheim 0872.00 Mod 21% n/a 18% 9% n/a n/a n/a 29% 19% 14% Anaheim 0873.00 Low 12% n/a 45% 17% n/a n/a n/a 27% 20% 23% Anaheim 0874.01 Middle 14% 0%1 23% 5% n/a n/a 0% 29% 13% 11% Anaheim 0874.03 Mod 33% 100% 50% 67% n/a n/a n/a 33% 50% 60% Anaheim 0874.04 Low 0% 0% 0% 0% n/a n/a n/a #DIV/0! 0% 0% Anaheim 0874.05 Low 0% n/a 67% 29% n/a n/a n/a 0% 22% 40% Anaheim 0875.03 Mod 21% n/a 17% 50% n/a n/a n/a 33% 32% 40% Anaheim 0875.04 Low 0% n/a 50% 50% n/a n/a I n/a 14% 28% 50% Anaheim 0875.05 Low 9% 0% n/a 20% n/a n/a n/a 0% 13% 18% Anaheim 0876.01 IMod 14% n/a 0% 27% 0% n/a n/a 0% 15% 23% Anaheim 0876.02 Middle 13% n/a 27% 19% 0% n/a n/a 0% 17% 21% Anaheim 0877.01 Mod 33% n/a 33% 17% n/a n/a n/a 50% 29% 25% Anaheim 0877.03 Mod 0% 0% 40% 20% n/a n/a I n/a 17% 18% 24% Anaheim 0877.04 Middle 7% n/a 18% 17% 100% 0% n/a 50% 17% 19% Anaheim 0878.01 Mod 0% 0% 8% 23% n/a 0% n/a 0% 11% 17% Anaheim 0878.02 Mod 36% 0% 40% 36% 0% n/a n/a 0% 31% 34% Anaheim 0878.03 Low 50% n/a 0% 0% n/a n/a n/a 20% 13% 0% Anaheim 0878.05 Mod 50% 100% 33% 28% n/a n/a n/a 50% 36% 320o Anaheim 0878.06 Low 20% n/a 18% 20% n/a n/a n/a 0% 16% 19% Anaheim 0883.02 Middle 13% n/a 17% 26% n/a n/a n/a 50% 24% 25% Anaheim 0884.02 Mod 0% n/a 0% 10% n/a n/a n/a 0% 7% 9% Anaheim 0884.03 Mod 14% 0% 36% 19% n/a n/a n/a 20% 21% 23% Anaheim 1102.01 Mod 6% n/a 40% 10% 0% n/a 0% 0% 14% 18% Anaheim 1102.02 Mod 0% n/a 20% 23% n/a n/a n/a 11% 17% 22% Anaheim 1102.03 Middle 20% n/a 25% 48% n/a n/a n/a 0% 31% 39% Anaheim 1104.01 Middle 13% n/a 17% 0% n/a n/a n/a 0% 8% 9% Anaheim 1104.02 Middle 15% 100% 9% 14% 0% n/a n/a 0% 14% 15% Anaheim 9800.00 Unk/NA 0% n/a n/a 0% n/a n/a n/a n/a 0% 0% Anaheim Total 13% 23% 21% 16% 5% 25% 36% 16% 16% 18% Buena Park 0018.01 Mod 0% n/a 1 40% 13% n/a n/a n/a 0% 14% 23% Page 2 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic Applicant Race Asian I Haw. Nat. Am. I Multi I Unk/NA I Total Min. % Buena Park 0868.01 Middle 44% 0% 33% 38% 0% n/a n/a 33% 36% 33% Buena Park 0868.03 Mod 11% 0% 10% 11% n/a n/a n/a 0% 9% 10% Buena Park 1101.02 Middle 0% n/a 0% 19% n/a n/a n/a 14% 14% 16% Buena Park 1101.10 Mod 0% n/a 17% 27% 0% n/a n/a 0% 21% 24% Buena Park 1102.01 Mod 6% n/a 1 40% 10% 0% n/a 0% 0% 14% 18% Buena Park 1102.02 Mod 0% n/a 20% 23% n/a n/a n/a 11% 17% 22% Buena Park 1102.03 Middle 20% n/a 25% 48% n/a n/a n/a 0% 31% 39% Buena Park 1103.01 Middle 0% n/a 0% 10% 0% n/a n/a 25% 7% 6% Buena Park 1103.02 Middle 20% n/a 25% 25% 0% 0% n/a 38% 25% 23% Buena Park 1103.03 Middle 17% n/a 11% 13% n/a n/a n/a 1 67% 17% 12% Buena Park 1103.04 Middle 17% n/a 14% 18% 0% n/a n/a 0% 15% 17% Buena Park 1104.01 Middle 13% n/a 17% 0% n/a n/a n/a 0% 8% 9% Buena Park 1104.02 Middle 15% 100% 9% 14% 0% n/a n/a 0% 14% 15% Buena Park 1105.00 Mod 0% 0%1 17% 14% n/a n/a n/a 0% 10% 14% Buena Park 1106.03 Low 50% 0% 50% 50% 100% n/a n/a 0% 45% 50% Buena Park 1106.04 Middle 0% n/a 0% 19% n/a n/a 50% 20% 16% 19% Buena Park 1106.06 Mod 50% 0% 0% 29% n/a n/a n/a 50% 31% 22% Buena Park 1106.07 Middle 0% n/a 0% 15% n/a n/a n/a n/a 11% 14% Buena Park Total 13% 17% 20% 20% 13% 0%1 33% 13% 18% 20% Costa Mesa 0626.10 Mod 14% n/a 33% 24% 0% n/a n/a 31% 19% 24% Costa Mesa 0631.01 Mod 31% n/a n/a 25% n/a n/a n/a 20% 28% 25% Costa Mesa 0631.02 IMiddle 12% n/a 1 13% 0% n/a n/a n/a 19% 13% 8% Costa Mesa 0631.03 Upper 19% n/a 0% n/a n/a n/a 0% 0% 15% 0% Costa Mesa 0632.01 Middle 14% n/a 100% 0% n/a n/a n/a 13% 15% 50% Costa Mesa 0632.02 Middle 12% 0% 0% 0% n/a n/a n/a 0% 8% 0% Costa Mesa 0633.01 Middle 6% n/a n/a n/a n/a n/a 100% 0% 8% 100% Costa Mesa 0633.02 jUpper 14% n/a 1 50% 0% n/a n/a 1 0% 13% 14% 17% Costa Mesa 0636.01 Middle 13% n/a 0% 0% n/a n/a n/a 25% 14% 0% Costa Mesa 0636.03 Middle 17% n/a 0% 0% n/a n/a n/a 8% 14% 0% Costa Mesa 0636.04 Mod 11% n/a 0% n/a n/a n/a n/a 0% 7% 0% Costa Mesa 0636.05 Low 0% 0% 0% 0% n/a n/a n/a 20% 6% 0% Costa Mesa 0637.01 Mod 0% n/a I n/a 0% n/a n/a n/a 0% 0% 0% Costa Mesa 0637.02 Mod 18% 0% 20% 14% n/a n/a n/a 31% 20% 15% Costa Mesa 0638.02 Upper 11% n/a n/a 0% n/a n/a n/a 0% 8% 0% Costa Mesa 0638.03 Middle 11% n/a 0% 0% 0% n/a 0% 20% 10% 0% Costa Mesa 0638.05 Upper 8% n/a 0% 14% n/a n/a n/a 50% 12% 13% Costa Mesa 0638.06 Middle 16% n/a n/a 0% n/a n/a n/a 33% 19% 0% Costa Mesa 0638.07 Middle 20% n/a 0% 0% n/a n/a n/a 0% 15% 0% Costa Mesa 0638.08 Mod 20% n/a 38% 33% n/a n/a n/a 0% 24% 36% Costa Mesa 0639.02 Middle 6% n/a 67% 17% n/a I n/a n/a 33% 17% 33% Costa Mesa 0639.03 Mod 7% n/a 1 20% 100% n/a I n/a n/a 1 20% 17% 50% Page 3 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic Applicant Race Asian I Haw. Nat. Am. Multi I Unk/NA I Total Min. % Costa Mesa 0639.04 Mod 0% n/a 0% 13% 0% n/a n/a 40% 11% 10% Costa Mesa 0639.05 Middle 0% 0% 0% 0% n/a n/a n/a 50% 3% 0% Costa Mesa 0639.06 Mod 13% n/a 25% 0% n/a n/a 0% 20% 16% 21% Costa Mesa 0639.07 Middle 18% 0% 50% 38% n/a n/a n/a 11% 21% 36% Costa Mesa 0639.08 Middle 25% n/a 1 0% 0% n/a n/a n/a 1 17% 16% 0% Costa Mesa 0755.15 Middle 20% n/a 20% 16% 100% n/a n/a 18% 18% 18% Costa Mesa 0992.40 Upper 17% n/a 0% 0% n/a n/a 0% 14% 15% 0% Costa Mesa Total 14% 0% 20% 17% 25% n/a 17% 18% 16% 18% Fountain Valley 0992.02 Mod 0% n/a 0% 15% 0% n/a n/a 1 25% 13% 13% Fountain Valley 0992.03 Middle 29% n/a 0% 37% n/a n/a n/a #DIV/0! 33% 34% Fountain Valley 0992.04 Middle 40% n/a 0% 44% n/a n/a n/a 100% 44% 42% Fountain Valley 0992.23 Mod 13% n/a 0% 25% n/a n/a n/a 100% 23% 24% Fountain Valley 0992.24 Upper 0% n/a 0% 36% n/a n/a n/a 0% 24% 33% Fountain Valley 0992.25 Upper 0% n/a n/a 35% n/a n/a n/a 0% 27% 35% Fountain Valley 0992.26 Middle 0% n/a n/a 38% n/a n/a n/a 0% 24% 38% Fountain Valley 0992.27 IMod 16% 0% 0% 14% 0% n/a n/a 0% 13% 12% Fountain Valley 0992.29 Middle 33% 0% 0% 13% n/a n/a n/a 0% 18% 11% Fountain Valley 0992.30 Middle 14% n/a 0% 6% n/a n/a n/a 0% 9% 5% Fountain Valley 0992.31 Upper 6% n/a 0% 26% n/a n/a n/a 8% 15% 24% Fountain Valley 0992.32 Upper 15% n/a 0% 31% n/a n/a n/a 0% 21% 27% Fountain Valley 0992.33 Middle 0% n/a 0% 0% n/a n/a I n/a 50% 7% 0% Fountain Valley 0992.34 Middle 0% n/a n/a 6% n/a n/a n/a 25% 7% 6% Fountain Valley 0992.50 Middle 0% n/a n/a 20% n/a n/a n/a 50% 22% 20% Fountain Valley 0992.51 Mod 0% n/a 0% 12% 0% n/a 100% 0% 11% 13% Fountain Valley Total 13% 0% 0% 21% 0% n/a 100% 15% 18% 20% Fullerton 0014.04 Mod 0% n/a 38% 50% n/a n/a n/a 50% 30% 42% Fullerton 0015.03 Middle 10% 100% 0% 8% 0% n/a 0% 25% 11% 10% Fullerton 0015.05 Middle 17% n/a 0% 12% n/a 0% 0% 33% 15% 10% Fullerton 0016.01 Middle 9% n/a 11% 14% n/a n/a I n/a 0% 10% 13% Fullerton 0016.02 Upper 4% n/a 0% 17% n/a n/a n/a 14% 11% 15% Fullerton 0017.04 Middle 0% 0% 33% 18% n/a n/a n/a 10% 16% 19% Fullerton 0017.05 Middle 13% n/a 0% 0% n/a n/a n/a 29% 11% 0% Fullerton 0017.06 jUpper 21% n/a 0% 15% n/a 0% n/a 1 0% 13% 14% Fullerton 0017.07 Upper 6% n/a 0% 6% 0% n/a n/a 20% 6% 6% Fullerton 0017.08 Middle 7% n/a 0% 5% 67% n/a n/a 0% 9% 12% Fullerton 0018.01 Mod 0% n/a 40% 13% n/a n/a n/a 0% 14% 23% Fullerton 0018.02 Mod 0% n/a 11% 10% n/a n/a n/a 17% 8% 11% Fullerton 0019.01 IMiddle 0% 0% 50% 0% n/a n/a I n/a I n/a 25% 33% Fullerton 0019.02 Mod 0% n/a 0% 0% n/a n/a n/a 1 0%1 25% 0% Fullerton 0019.03 IMiddle 1 25% n/a 0% 45% n/a I n/a n/a 1 0% 0%1 31% Page 4 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic I Applicant Race Asian I Haw. Nat. Am. Multi I Unk/NA I Total Min. % Fullerton 0110.00 Middle 5% 0% 22% 10% 0% n/a n/a 0% 7% 13% Fullerton 0111.01 Middle 13% 0% 40% 0% n/a n/a n/a 0% 12% 13% Fullerton 0111.02 Middle 11% 0% 6% 29% 0% n/a n/a 0% 13% 16% Fullerton 0112.00 Middle 0% 0% 8% 17% n/a n/a n/a 0% 5% 10% Fullerton 0113.00 Middle 30% n/a 1 0% 29% 0% n/a n/a 1 40% 29% 26% Fullerton 0114.01 Upper 8% n/a n/a 0% n/a n/a n/a 0% 6% 0% Fullerton 0114.02 Upper 0% n/a 0% 20% n/a n/a 0% 0% 5% 11% Fullerton 0114.03 Mod 4% 0% 18% 10% 0% n/a n/a 13% 9% 13% Fullerton 0115.02 Mod 13% 0% 0% 29% n/a n/a n/a 25% 15% 13% Fullerton 0115.03 Upper 0% n/a I n/a 0% n/a n/a I n/a 50% 5% 0% Fullerton 0115.04 Mod 20% n/a 0% 0% 0% n/a n/a 60% 19% 0% Fullerton 0116.01 Mod 18% n/a 7% 13% n/a 100% 0% 14% 14% 12% Fullerton 0116.02 Low 25% n/a 33% 33% n/a n/a n/a 0% 28% 33% Fullerton 0117.07 Middle 8% n/a 13% 0% n/a n/a n/a 0% 5% 3% Fullerton 0117.08 Middle 13% n/a 1 0% 31% n/a n/a n/a 17% 18% 25% Fullerton 0117.11 Mod 20% n/a 0% 9% n/a n/a n/a 0% 10% 6% Fullerton 0117.12 Middle 13% n/a 0% 22% n/a n/a n/a 20% 14% 13% Fullerton 0867.01 IMod 7% n/a 12% 9% 0% n/a n/a 0% 9% 10% Fullerton 0868.01 Middle 44% 0% 33% 38% 0% n/a n/a 33% 36% 33% Fullerton 0868.02 Mod 0% 0% 0% 0% n/a n/a n/a 50% 4% 0% Fullerton 1104.01 Middle 13% n/a 17% 0% n/a n/a n/a 0% 8% 9% Fullerton 1106.04 Middle 0% n/a 0% 19% n/a n/a 50% 20% 16% 19% Fullerton 1106.05 Middle 0% n/a n/a 10% n/a n/a n/a 67% 12% 10% Fullerton Total 10% 7% 14% 14% 17% 33% 17% 13% 13% 14% Garden Grove 0761.03 Mod 0% n/a 20% 22% n/a n/a n/a 50% 17% 21% Garden Grove 0875.03 Mod 21% n/a 17% 50% n/a n/a n/a 33% 32% 40% Garden Grove 0876.02 Middle 13% n/a 27% 19% 0% n/a n/a 0% 17% 21% Garden Grove 0878.06 Low 20% n/a 18% 20% n/a n/a n/a 0% 16% 19% Garden Grove 0879.01 Middle 17% n/a 38% 15% 0% n/a n/a 33% 24% 23% Garden Grove 0879.02 Mod 0% n/a 29% 33% n/a n/a n/a 0% 28% 32% Garden Grove 0880.01 Middle 0% n/a 0% 31% n/a n/a n/a 25% 22% 27% Garden Grove 0880.02 Middle 20% n/a 50% 29% n/a n/a n/a 0% 27% 30% Garden Grove 0881.01 Middle 0% 0%1 25% 27% n/a n/a 0% 0% 16% 24% Garden Grove 0881.04 Mod 27% n/a 0% 25% n/a n/a n/a n/a 23% 20% Garden Grove 0881.05 Mod 33% n/a 0% 16% n/a n/a 100% 0% 18% 17% Garden Grove 0881.06 Mod 8% n/a 0% 31% n/a n/a n/a 14% 17% 22% Garden Grove 0881.07 Mod 0% n/a n/a 29% n/a n/a n/a 1 0% 24% 29% Garden Grove 0882.01 Mod 0% n/a 0% 19% n/a n/a 0% 0% 10% 17% Garden Grove 0882.02 Middle 13% n/a 0% 23% n/a n/a n/a 0% 14% 17% Garden Grove 0882.03 Mod 1 0% n/a 25% 19% n/a n/a n/a 0% 16% 19% Garden Grove 0883.01 Middle 1 40% n/a 50% 22% n/a n/a n/a 20% 28% 25% Page 5 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic Applicant Race Asian I Haw. Nat. Am. Multi I Unk/NA Total Min. Garden Grove 0883.02 Middle 13% n/a 17% 26% n/a n/a n/a 50% 24% 25% Garden Grove 0884.01 Middle 25% n/a 9% 35% n/a n/a n/a n/a 26% 26% Garden Grove 0884.02 Mod 0% n/a 0% 10% n/a n/a n/a 0% 7% 9% Garden Grove 0884.03 Mod 14% 0% 36% 19% n/a n/a n/a 20% 21% 23% Garden Grove 0885.01 Mod 33% n/a 1 20% 14% 0% n/a n/a 1 33% 19% 14% Garden Grove 0885.02 Mod 0% n/a 33% 30% 0% n/a 0% 100% 27% 29% Garden Grove 0886.01 Mod 11% n/a 13% 13% n/a n/a n/a 25% 13% 13% Garden Grove 0886.02 Middle 25% n/a 25% 32% n/a n/a n/a 0% 26% 30% Garden Grove 0887.01 Mod 33% n/a 33% 3% n/a n/a n/a 33% 12% 6% Garden Grove 0887.02 Mod 0% n/a 50% 31% n/a n/a I n/a n/a 31% 32% Garden Grove 0888.01 Mod 18% n/a 100% 21% n/a n/a n/a 100% 24% 24% Garden Grove 0888.02 Mod 33% n/a 60% 27% n/a n/a n/a 50% 34% 33% Garden Grove 0889.01 IMod 25% n/a 0% 27% n/a n/a 0% 67% 31% 26% Garden Grove 0889.02 Mod 100% n/a 0% 15% n/a n/a n/a 100% 22% 14% Garden Grove 0889.03 Mod n/a n/a 0% 37% n/a n/a 0% n/a 32% 32% Garden Grove 0889.04 Mod 50% n/a n/a 47% n/a n/a n/a n/a 47% 47% Garden Grove 0890.01 Mod n/a n/a 0% 4% n/a n/a n/a 0% 3% 4% Garden Grove 0890.03 IMod 0% n/a 1 0% 28% n/a n/a n/a 0% 23% 26% Garden Grove 0891.02 Mod 14% n/a 16% 19% n/a n/a n/a 0% 16% 18% Garden Grove 0891.04 Low 0% n/a 30% 11% n/a n/a n/a 0% 18% 21% Garden Grove 0891.06 Low n/a n/a 100% 75% n/a n/a n/a 100% 80% 78% Garden Grove 0891.07 Middle 0% n/a 18% 23% n/a n/a n/a 50% 23% 22% Garden Grove 0992.03 IMiddle 29% n/a 1 0% 37% n/a n/a I n/a n/a 33% 34% Garden Grove 0998.01 Mod 0% n/a 25% 18% n/a n/a n/a 50% 19% 19% Garden Grove 0999.02 Middle 0% n/a 0% 20% n/a n/a n/a 100% 14% 17% Garden Grove 0999.03 Mod 0% n/a 0% 14% n/a n/a n/a 0% 11% 13% Garden Grove 0999.05 Middle 14% n/a n/a 0% n/a n/a n/a n/a 10% 0% Garden Grove 0999.06 jUpper 6% n/a 1 0% 33% n/a n/a I n/a 0% 12% 24% Garden Grove 1100.01 Middle 9% n/a 0% 25% 100% n/a n/a 0% 13% 27% Garden Grove 1100.03 Middle 6% n/a 0% 0% n/a n/a n/a 0% 4% 0% Garden Grove 1100.04 Middle 13% 100% 0% 0% n/a n/a 0% 0% 8% 8% Garden Grove 1100.05 Middle 0% n/a 0% 20% 0% n/a n/a 0% 3% 10% Garden Grove 1100.10 Upper 19% n/a 1 33% 19% n/a n/a n/a 0% 18% 21% Garden Grove Total 1 13% 50% 19% 23% 17% n/a 14% 19% 20% 23% Huntington Beach 0992.12 IMod 10% n/a I n/a 25% n/a n/a I n/a 33% 17% 25% Huntington Beach 0992.14 Middle 15% n/a 0% 0% n/a n/a n/a 0% 11% 0% Huntington Beach 0992.15 Middle 14% 0% 13% 0% 0% n/a 0% 0% 9% 4% Huntington Beach 0992.16 Middle 6% n/a 0% 0% n/a n/a 0% 60% 12% 0% Huntington Beach 0992.17 Middle 23% n/a n/a 0% n/a n/a n/a 1 0%1 21% 0% Huntington Beach 0992.20 Middle 14% 0% 25% 6% 0% n/a I n/a 1 30% 14% 9% Huntington Beach 0992.35 Mod 0% n/a 1 0% 22% n/a n/a I n/a 1 14% 7% 18% Page 6 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract I Income White Black I Hispanic I Applicant Race Asian I Haw. Nat. Am. Multi Unk/NA Total Min. Huntington Beach 0992.37 Upper 0% n/a 0% 11% n/a n/a n/a 0% 3% 10% Huntington Beach 0992.38 Upper 6% n/a 0% 20% n/a n/a n/a 50% 11% 17% Huntington Beach 0992.39 Upper 8% n/a 0% 13% n/a n/a n/a 13% 9% 10% Huntington Beach 0992.40 Upper 17% n/a 0% 0% n/a n/a 0% 14% 15% 0% Huntington Beach 0992.41 Middle 14% n/a 1 0% 27% n/a n/a n/a n/a 22% 25% Huntington Beach 0992.42 Middle 0% n/a 50% 22% n/a n/a 0% 0% 11% 25% Huntington Beach 0992.43 Upper 9% 0% 0% 60% n/a n/a 0% 29% 13% 27% Huntington Beach 0992.44 Middle 13% n/a 0% 20% n/a 0% n/a 50% 13% 11% Huntington Beach 0992.45 Upper 13% n/a 0% 40% n/a n/a n/a 0% 17% 33% Huntington Beach 0992.46 Upper 10% 0% 0% 17% n/a n/a I n/a 17% 12% 14% Huntington Beach 0993.05 Mod 15% n/a 0% 0% n/a n/a n/a 20% 14% 0% Huntington Beach 0993.06 Middle 8% n/a 50% 31% n/a n/a n/a 18% 14% 33% Huntington Beach 0993.07 Upper 13% n/a 25% 67% n/a n/a n/a 14% 19% 43% Huntington Beach 0993.08 Upper 3% n/a 50% 16% n/a n/a n/a 6% 7% 22% Huntington Beach 0993.09 Upper 17% n/a 1 0% 29% n/a 0% n/a 17% 17% 17% Huntington Beach 0993.10 Upper 13% n/a 0% 38% n/a n/a n/a 0% 14% 33% Huntington Beach 0993.11 jUpper 14% n/a 40% 25% 100% n/a n/a 13% 19% 33% Huntington Beach 0994.02 IMod 10% n/a 0% 0% n/a n/a n/a 25% 10% 0% Huntington Beach 0994.04 jUpper 0% 0% 0% 0% n/a 0% n/a 0% 18% 0% Huntington Beach 0994.05 IMiddle 12% n/a 1 0% 0% n/a n/a n/a 0% 0% 0% Huntington Beach 0994.06 IMiddle 5% n/a 33% 0% n/a n/a n/a 0% 6% 9% Huntington Beach 0994.07 lUpper 24% n/a 0% 0% n/a n/a n/a 33% 19% 0% Huntington Beach 0994.08 jUpper 5% 0% 0% 0% n/a n/a n/a 20% 5% 0% Huntington Beach 0994.10 IMod 20% n/a n/a 0% n/a n/a n/a 100% 15% 0% Huntington Beach 0994.11 IMod 9% 0% 0% 17% n/a n/a n/a 20% 12% 14% Huntington Beach 0994.12 jUpper 16% n/a 33% 0% n/a n/a n/a 0% 13% 11% Huntington Beach 0994.13 jUpper 13% 0% 0% 13% 0% n/a 0% 29% 13% 8% Huntington Beach 0994.15 lUpper 4% n/a n/a 27% n/a n/a n/a 0% 11% 27% Huntington Beach 0994.16 IMod 19% n/a 1 0% 0% n/a n/a n/a 17% 16% 0% Huntington Beach 0994.17 lUpper 13% n/a 0% 36% 0% n/a n/a 26% 19% 27% Huntington Beach 0995.08 Middle 12% n/a 50% 50% n/a n/a n/a 0% 16% 50% Huntington Beach 0995.13 Upper 25% n/a 0% 38% n/a n/a n/a 0% 24% 25% Huntington Beach 0995.14 Upper 3% n/a 0% 18% n/a n/a n/a 7% 7% 16% Huntington Beach 0996.02 Middle 0% n/a 25% 0% n/a n/a n/a 50% 13% 8% Huntington Beach 0996.03 jUpper 6% n/a 38% 7% 0% n/a n/a 20% 12% 17% Huntington Beach 0996.04 lUpper 13% n/a 0% 0% n/a n/a n/a 0% 8% 0% Huntington Beach 0996.05 Middle 6% n/a n/a 15% 100% n/a n/a 0% 10% 21% Huntington Beach 0997.02 Middle 40% 0% 0% 25% 50% n/a n/a 1 33% 28% 24% Huntington Beach 0997.03 Middle 18% n/a 50% 47% n/a n/a n/a 1 0%1 34% 47% Huntington Beach Total 11% 0%1 13% 19% 33% 0% 0%1 16% 13% 18% La Habra 1 0011.01 IMiddle 1 13%1 0%1 10%1 9%1 n/a I n/a I n/a 1 25%1 11%1 9% Page 7 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic I Applicant Race Asian I Haw. Nat. Am. Multi I Unk/NA I Total Min. La Habra 0011.02 Mod 8% 0% 11% 0% n/a n/a n/a 20% 8% 5% La Habra 0011.03 Mod 0% 0% 17% 0% 0% n/a n/a 0% 8% 13% La Habra 0012.01 Mod 23% n/a 15% 14% n/a n/a n/a 0% 17% 15% La Habra 0012.02 Middle 14% 0% 20% 20% n/a n/a n/a 0% 17% 19% La Habra 0013.01 Middle 7% 50% 23% 14% n/a n/a n/a 1 0% 15% 21% La Habra 0013.03 Mod 25% n/a 32% 5% 0% n/a n/a 25% 22% 20% La Habra 0013.04 Mod 17% n/a 33% 17% n/a n/a n/a 0% 21% 24% La Habra 0014.01 Mod 29% 0% 15% 29% 0% n/a n/a 0% 21% 18% La Habra 0014.02 Middle 0% n/a 0% 40% n/a n/a n/a 17% 15% 25% La Habra 0014.03 Upper 10% n/a 10% 0% n/a n/a I n/a 0% 9% 9% La Habra 0014.04 Mod 0% n/a 38% 50% n/a n/a n/a 50% 30% 42% La Habra 0015.01 Middle 17% 0% 33% 22% n/a n/a 0% 38% 24% 26% La Habra 0016.01 Middle 9% n/a 11% 14% n/a n/a n/a 0% 10% 13% La Habra 0017.05 Middle 13% n/a 0% 0% n/a n/a n/a 29% 11% 0% La Habra 0017.07 Upper 6% n/a 0% 6% 0% n/a n/a 20% 6% 6% La Habra 0017.08 Middle 7% n/a 0% 5% 67% n/a n/a 0% 9% 12% La Habra Total 13% 10% 21% 12% 29% n/a 0% 19% 15% 15% Lake Forest 0320.14 Mod 11% n/a 22% 30% 85% n/a I n/a 40% 31% 44% Lake Forest 0320.27 Middle 11% n/a 31% 15% 75% 0% 100% 0% 16% 31% Lake Forest 0320.29 Upper 9% n/a 22% 18% 0% n/a n/a 20% 13% 18% Lake Forest 0320.47 IMiddle 11% n/a 11% 0% n/a n/a n/a 0% 8% 6% Lake Forest 0524.04 Unk/NA 9% n/a 0% 7% 0% n/a n/a 43% 9% 7% Lake Forest 0524.08 Upper 13% n/a 0% 0% 0% n/a n/a 33% 11% 0% Lake Forest 0524.10 Middle 13% n/a 0% 15% n/a n/a 0% 0% 12% 13% Lake Forest 0524.11 Middle 19% 0% 0% 13% n/a n/a n/a 17% 16% 8% Lake Forest 0524.15 Upper 14% 0%1 17% 20% 0% n/a n/a 8% 14% 18% Lake Forest 0524.16 Middle 14% 0% 29% 33% 0% n/a 0% 13% 17% 26% Lake Forest 0524.22 Upper 7% n/a 20% 10% n/a n/a n/a 0% 7% 13% Lake Forest 0524.23 Middle 21% n/a 17% 31% n/a n/a n/a 0% 23% 29% Lake Forest 0524.24 Middle 19% 0% 14% 0% n/a n/a n/a 50% 18% 5% Lake Forest 0524.25 Middle 14% n/a 0% 10% 0% n/a n/a 0% 10% 6% Lake Forest 0524.26 Upper 13% 0% 0% 15% n/a 0% 33% 11% 14% 15% Lake Forest 0524.27 Upper 19% 0% 0% 8% n/a n/a n/a 0% 12% 7% Lake Forest 0524.28 Upper 10% 0% 0% 13% n/a n/a n/a 20% 11% 11% Lake Forest Total 13% 0% 14% 14% 58% 0% 33% 13% 14% 15% Mission Viejo 0320.02 Middle 10% n/a 20% 0% n/a n/a n/a 11% 10% 9% Mission Viejo 0320.03 Upper 20% n/a 0% 0% 0% n/a 0% 25% 18% 0% Mission Viejo 0320.12 Upper 11% 0% 0% 0% n/a n/a n/a 0% 9% 0% Mission Viejo 0320.13 Middle 15% n/a 50% 0% n/a n/a n/a 0% 14% 25% Mission Viejo 0320.15 Upper 8% n/a 1 0%1 13% n/a n/a 0% 0% 6% 8% Page 8 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract I Income White Black I Hispanic I Applicant Race Asian I Haw. Nat. Am. Multi Unk/NA I Total Min. % Mission Viejo 0320.20 Upper 7% n/a 25% 14% 0% n/a n/a 9% 9% 17% Mission Viejo 0320.22 Mod 10% 0% 17% 14% n/a n/a n/a 33% 14% 13% Mission Viejo 0320.27 Middle 11% n/a 31% 15% 75% 0% 100% 0% 16% 31% Mission Viejo 0320.28 Middle 14% n/a 40% 20% 100% n/a n/a 11% 18% 29% Mission Viejo 0320.30 Upper 12% 0% 0% 17% n/a n/a n/a 29% 13% 8% Mission Viejo 0320.31 Upper 7% n/a 0% 25% 0% n/a n/a 0% 7% 13% Mission Viejo 0320.32 Upper 7% n/a n/a 0% n/a n/a n/a 20% 9% 0% Mission Viejo 0320.33 Middle 15% n/a 14% 29% n/a 0% n/a 22% 18% 20% Mission Viejo 0320.34 Upper 3% 0% 0% 8% n/a n/a n/a 20% 6% 6% Mission Viejo 0320.35 Upper 26% n/a 1 0% 40%1 100% 0% n/a 0% 24% 25% Mission Viejo 0320.36 Upper 9% n/a 0% 0% n/a n/a n/a 0% 7% 0% Mission Viejo 0320.37 Middle 7% 100% 0% 44% n/a n/a n/a 8% 11% 38% Mission Viejo 0320.38 JUpper 14% n/a 0% 20% n/a n/a n/a 19% 15% 15% Mission Viejo 0320.39 Upper 8% 0% 11% 14% 0% 0% n/a 25% 11% 12% Mission Viejo 0320.40 Upper 9% n/a 1 0% 50% 0% n/a n/a 0% 10% 25% Mission Viejo 0320.47 Middle 11% n/a 11% 0% n/a n/a n/a 0% 8% 6% Mission Viejo 0320.48 Upper 7% 0% 0% 13% 0% n/a n/a 10% 8% 9% Mission Viejo 0320.49 JUpper 10% 0% 0% 0% 0% n/a n/a 6% 7% 0% Mission Viejo 0320.58 Upper 10% 0% 0% 16% 50% n/a 0% 17% 12% 14% Mission Viejo 0320.61 Upper 19% n/a 1 0% 0% n/a n/a n/a 7% 16% 0% Mission Viejo 0423.15 Upper 10% 50% 0% 11% n/a n/a 100% 18% 13% 21% Mission Viejo 0423.28 Upper 10% n/a 0% 0% n/a n/a n/a 67% 20% 0% Mission Viejo 0423.33 Upper 16% 0% n/a 0% 0% n/a n/a 18% 14% 0% Mission Viejo 0524.23 Middle 21% n/a 17% 31% n/a n/a n/a 0% 23% 29% Mission Viejo 0524.28 Upper 10% 0% 0% 13% n/a n/a n/a 20% 11% 11% Mission Viejo Total 11% 13% 12% 16% 32% 0% 33% 14% 12% 15% Newport Beach 0626.04 Upper 17% n/a 25% 15% n/a n/a n/a 23% 17% 16% Newport Beach 0626.10 IMod 14% n/a 33% 24% 0% n/a n/a 31% 19% 24% Newport Beach 0626.14 Middle 17% 0% 0% 33% n/a n/a n/a 0% 17% 20% Newport Beach 0626.42 Upper 16% n/a n/a 0% 100% n/a n/a 10% 14% 14% Newport Beach 0626.43 Upper 9% 0% 0% 11% n/a 0% n/a 21% 12% 10% Newport Beach 0626.44 Upper 16% 0% 0% 0% n/a n/a n/a 12% 13% 0% Newport Beach 0626.45 JUpper 11% n/a 1 0% 12% n/a n/a I n/a 29% 14% 11% Newport Beach 0627.01 Upper 20% n/a n/a 50% n/a n/a n/a 11% 18% 50% Newport Beach 0627.02 Upper 16% n/a 0% 0% n/a n/a 0% 17% 15% 0% Newport Beach 0628.00 Upper 23% n/a n/a 29% 0% n/a 0% 14% 20% 20% Newport Beach 0629.00 Upper 5% n/a n/a n/a n/a n/a n/a 0% 4% #DIV/0! Newport Beach 0630.04 Upper 12% n/a 25% 0% n/a 0% n/a 8% 11% 11% Newport Beach 0630.05 Upper 0% n/a n/a 0% n/a n/a n/a 0% 18% 0% Newport Beach 0630.06 Upper 8% n/a n/a 0% n/a n/a n/a 0% 0% 0% Newport Beach 0630.07 Upper 5% n/a 0% 7% n/a n/a n/a 1 5% 5% 5% Page 9 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract I Income White Black Hispanic I Applicant Race Asian Haw. Nat. Am. Multi Unk/NA I Total Min. % Newport Beach 0630.08 Upper 20% n/a n/a 0% n/a n/a n/a 0% 17% 0% Newport Beach 0630.09 Upper 14% n/a n/a 17% n/a n/a n/a 18% 16% 17% Newport Beach 0630.10 Upper 19% n/a 0% 20% n/a n/a 0% 9% 16% 11% Newport Beach 0631.01 Mod 31% n/a n/a 25% n/a n/a n/a 20% 28% 25% Newport Beach 0631.03 Upper 19% n/a 0% n/a n/a n/a 0% 0% 15% 0% Newport Beach 0633.02 Upper 14% n/a 50% 0% n/a n/a 0% 13% 14% 17% Newport Beach 0634.00 Upper 10% n/a 0% 20% n/a 0% n/a 13% 10% 14% Newport Beach 0635.00 Upper 22% 100% n/a 0% n/a 0% n/a 22% 20% 9% Newport Beach 0636.01 Middle 13% n/a 0% 0% n/a n/a n/a 25% 14% 0% Newport Beach 0636.03 Middle 17% n/a 1 0% 0% n/a n/a I n/a 8% 14% 0% Newport Beach 0636.04 Mod 11% n/a 0% n/a n/a n/a n/a 0% 7% 0% Newport Beach Total 15% 25% 11% 15% 33% 0% 0% 15% 15% 14% City of Orange 0219.12 Upper 6% n/a 17% 15% 0% n/a n/a 0% 8% 15% City of Orange 0219.13 Middle 16% 100% 17% 20% n/a n/a n/a 0% 17% 22% City of Orange 0219.14 Upper 22% n/a 0% 10% n/a 0% n/a 0% 12% 6% City of Orange 0219.15 jUpper 7% n/a 0% 19% n/a n/a 100% 0% 10% 18% City of Orange 0219.17 Upper 13% n/a 0% 40% n/a n/a n/a 20% 16% 25% City of Orange 0219.18 Upper 7% n/a 36% 22% 0% n/a 0% 0% 12% 25% City of Orange 0219.20 Upper 15% n/a 1 20% 10% n/a n/a n/a 17% 14% 12% City of Orange 0219.23 Upper 15% 100% 14% 9% 0% n/a n/a 0% 13% 11% City of Orange 0219.24 jUpper 0% n/a 0% 7% n/a n/a n/a 0% 2% 6% City of Orange 0524.19 Upper 14% n/a 0% 17% n/a n/a n/a 29% 16% 13% City of Orange 0524.20 Upper 15% n/a 46% 12% 0% n/a 0% 29% 16% 14% City of Orange 0756.04 Upper 17% n/a 1 0% 12% n/a 0% 100% 31% 18% 14% City of Orange 0756.05 Upper 11% n/a 56% 14% 0% n/a n/a 43% 18% 29% City of Orange 0758.05 Middle 13% n/a 17% 0% n/a n/a n/a 0% 10% 11% City of Orange 0758.06 Middle 4% n/a 13% 38% n/a n/a n/a 33% 13% 25% City of Orange 0758.07 Middle 0% n/a 0% 22% n/a n/a 100% 0% 8% 23% City of Orange 0758.08 Upper 14% n/a 1 0% 10% n/a n/a n/a 0% 9% 7% City of Orange 0758.09 Upper 6% n/a n/a 0% n/a n/a n/a 14% 7% 0% City of Orange 0758.10 Upper 5% n/a 0% 18% n/a n/a n/a 0% 8% 15% City of Orange 0758.11 Mod 14% n/a 0% 50% 0% n/a n/a 50% 23% 25% City of Orange 0758.12 Mod 0% 75% 0% 0% 0% n/a 0% 0% 8% 20% City of Orange 0758.13 Upper 6% 0% 0% 9% n/a n/a n/a 10% 7% 6% City of Orange 0758.14 Upper 25% n/a 50% 13% n/a n/a 0% 0% 19% 18% City of Orange 0758.15 Middle 10% n/a 14% 11% n/a n/a n/a 25% 14% 13% City of Orange 0758.16 Middle 14% 50% 33% 20% n/a n/a n/a 0% 18% 25% City of Orange 0759.01 Mod 24% 0% 0% 50% n/a n/a 100% 0% 24% 40% City of Orange 0759.02 Mod 9% n/a 33% 50% n/a n/a n/a 0% 14% 38% City of Orange 0760.00 Mod 1 25% 100% 0%1 26% 0% 100% n/a 259/o 25% 24% City of Orange 0761.01 Middle 1 22% n/a 13% 0% n/a n/a n/a 1 67% 20% 10% Page 10 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic Applicant Race Asian I Haw. Nat. Am. I Multi I Unk/NA I Total Min. % City of Orange 0761.02 Mod 0% 100% 0% 0% n/a n/a n/a 0% 5% 8% City of Orange 0761.03 Mod 0% n/a 20% 22% n/a n/a n/a 50% 17% 21% City of Orange 0762.01 Middle 8% 0% 0% 22% 0% 0% n/a 23% 13% 15% City of Orange 0762.02 Middle 13% 0% 14% 14% 0% n/a n/a 40% 15% 13% City of Orange 0762.04 Mod 17% n/a 1 13% 0% 0% n/a n/a 1 25% 15% 11% City of Orange 0762.05 Middle 8% n/a 0% 0% n/a n/a n/a 17% 8% 0% City of Orange 0762.06 Middle 14% n/a 0% 40% 0% n/a n/a 33% 17% 29% City of Orange 0762.08 Middle 9% n/a 13% 13% n/a n/a 0% 0% 9% 12% City of Orange Total 12% 57% 15% 15% 0% 40% 44% 17% 14% 16% Rancho SM 0320.34 Upper 3% 0% 0% 8% n/a n/a n/a 20% 6% 6% Rancho SM 0320.37 Middle 7% 100% 0% 44% n/a n/a n/a 8% 11% 38% Rancho SM 0320.38 Upper 14% n/a 0% 20% n/a n/a n/a 19% 15% 15% Rancho SM 0320.41 Upper 11% n/a 0% 0% n/a n/a n/a 0% 6% 0% Rancho SM 0320.42 Upper 16% n/a 0% 0% n/a n/a n/a 20% 15% 0% Rancho SM 0320.43 Upper 9% 0% 0% 22% n/a n/a n/a 0% 9% 18% Rancho SM 0320.44 jUpper 12% 0% 9% 32% n/a 100% 0% 14% 15% 24% Rancho SM 0320.45 Upper 8% n/a 0% 0% n/a n/a 0% 0% 6% 0% Rancho SM 0320.48 Upper 7% 0% 0% 13% 0% n/a n/a 10% 8% 9% Rancho SM 0320.49 Upper 10% 0% 0% 0% 0% n/a n/a 6% 7% 0% Rancho SM 0320.50 Upper 12% 50% 0% 0% n/a n/a 0% 23% 12% 6% Rancho SM 0320.51 IMiddle 7% 67% 8% 11% n/a 100% n/a 0% 10% 20% Rancho SM 0320.53 Upper 12% 0% 23% 0% n/a n/a 67% 12% 13% 14% Rancho SM 0320.54 Middle 13% 0%1 25% 0% n/a n/a 0% 33% 14% 10% Rancho SM 0320.55 Middle 9% n/a 33% 20% n/a n/a n/a 11% 11% 25% Rancho SM 0320.56 Upper 13% n/a 9% 20% n/a n/a n/a 10% 13% 15% Rancho 5M Total 10% 22% 11% 14% 0% 100% 25% 12% 11% 14% San Clemente 0320.23 Upper 7% 0% 10% 17% 0% n/a 0% 12% 8% 12% San Clemente 0421.03 Upper 14% n/a 33% n/a 0% n/a 0% 8% 13% 17% San Clemente 0421.06 Middle 6% n/a 33% n/a n/a n/a n/a 0% 10% 33% San Clemente 0421.07 Mod 20% n/a 0% n/a n/a n/a n/a 17% 19% 0% San Clemente 0421.08 IMiddle 18% n/a 1 0% 0% n/a 100% n/a 17% 18% 20% San Clemente 0421.09 Middle 6% n/a 0% 0% 0% n/a n/a 8% 6% 0% San Clemente 0421.11 Upper 11% n/a 0% 33% n/a n/a n/a 20% 13% 25% San Clemente 0421.12 Upper 8% 0% 0% 29% n/a n/a n/a 12% 9% 20% San Clemente 0421.13 Middle 5% n/a 20% 0% n/a n/a n/a 50% 12% 17% San Clemente 0421.14 IMod 5% n/a 1 33% 25% n/a n/a n/a 0% 7%1 29% San Clemente 0422.01 Middle 25% n/a 33% 0% n/a n/a n/a 27% 24% 14% San Clemente 0422.03 Upper 16% 0% 18% 9% 0% n/a 0% 24% 16% 12% San Clemente 0422.05 Middle 9% n/a 0% 33% n/a n/a 0% 17% 12% 23% San Clemente 0422.06 Middle 10% n/a 0% 0% n/a I /a I n/a 30% 13% 0% Page 11 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic I Applicant Race Asian I Haw. Nat. Am. I Multi I Unk/NA I Total Min. % San Clemente Total 11% 0% 16% 18% 0% 100% 0% 16% 12% 16% Santa Ana 0740.03 Middle 40% n/a 67% 10% n/a n/a n/a 0% 36% 37% Santa Ana 0740.04 Middle 25% n/a 33% 17% n/a n/a n/a 0% 22% 24% Santa Ana 0740.05 Mod 14% n/a 1 0% 7% n/a n/a n/a 1 20% 9% 5% Santa Ana 0740.06 Mod 13% 0% 8% 14% n/a n/a n/a 67% 15% 10% Santa Ana 0741.02 Mod 33% n/a 20% 20% n/a n/a n/a 100% 24% 20% Santa Ana 0741.03 Middle 0% n/a 16% 0% n/a n/a n/a 0% 10% 12% Santa Ana 0741.06 Mod 7% n/a 13% 40% n/a n/a n/a 0% 17% 26% Santa Ana 0741.07 Middle 17% 0% 38% 14% n/a n/a 1 50% 33% 22% 24% Santa Ana 0741.08 Mod 50% n/a 31% 15% n/a n/a n/a 0% 23% 23% Santa Ana 0741.09 Mod 0% n/a 20% 22% n/a n/a n/a 50% 22% 21% Santa Ana 0741.10 Middle 50% n/a 0% 31% n/a n/a 0% 50% 23% 16% Santa Ana 0741.11 Mod 0% n/a 17% 0% n/a n/a n/a n/a 5% 7% Santa Ana 0742.00 Mod 13% n/a 27% 33% n/a n/a n/a 33% 26% 28% Santa Ana 0743.00 Mod 20% n/a 28% 33% n/a n/a n/a 0% 25% 29% Santa Ana 0744.03 Low n/a n/a 17% n/a n/a n/a n/a 0% 14% 17% Santa Ana 0744.05 Low 0% n/a 0% 0% n/a n/a n/a 0%1 19% 0% Santa Ana 0744.06 Mod 0% n/a 33% 0% n/a n/a n/a 100% 0% 29% Santa Ana 0744.07 Low 45% n/a 75% 0% n/a n/a n/a 0% 44% 50% Santa Ana 0745.01 Low 100% n/a 0% 60% n/a n/a n/a 0% 36% 33% Santa Ana 0745.02 Mod 0% n/a 40% 38% n/a n/a n/a 0% 35% 39% Santa Ana 0746.01 Mod 31% n/a 11% 22% n/a n/a n/a 17% 20% 15% Santa Ana 0746.02 Mod 0% n/a 4% 20% n/a n/a n/a 14% 8% 7% Santa Ana 0747.01 Mod 0% n/a 32% 21% 0% n/a n/a 0% 25% 27% Santa Ana 0747.02 Mod 0% n/a 42% 0% n/a n/a n/a 0% 32% 38% Santa Ana 0748.01 Mod 0% n/a 20% 20% n/a n/a n/a 0% 15% 20% Santa Ana 0748.02 Mod 0% n/a 21% 25% n/a n/a n/a n/a 20% 22% Santa Ana 0748.03 Mod 33% n/a 27% 24% n/a n/a 100% 75% 31% 27% Santa Ana 0748.05 Low n/a n/a 0% 0% n/a n/a n/a n/a 17% 0% Santa Ana 0748.06 Low 0% n/a 0% 20% n/a n/a n/a 0% 0% 11% Santa Ana 0749.01 Mod 33% n/a 19% 33% n/a n/a n/a 50% 26% 23% Santa Ana 0749.02 Mod 0% n/a 40% 25% n/a n/a 0% 0% 29% 33% Santa Ana 0750.02 Mod 1 13% 100% 50% 33% n/a n/a n/a 1 25% 30% 45% Santa Ana 0750.03 Low 40% n/a 75% 50% n/a n/a n/a 0% 43% 67% Santa Ana 0750.04 Low 25% n/a 33% n/a n/a n/a n/a 0% 25% 33% Santa Ana 0751.00 Low 0% n/a 40% 0% n/a n/a n/a 20% 18% 32% Santa Ana 0752.01 Mod 0% n/a 50% 41% n/a n/a n/a 25% 40% 45% Santa Ana 0752.02 Mod 0% n/a 29% 20% n/a n/a n/a 0% 23% 27% Santa Ana 0753.01 Middle 18% n/a 40% 0% n/a n/a n/a 0% 17% 18% Santa Ana 0753.02 Mod 13% n/a 22% 0% n/a n/a n/a 0% 16% 19% Santa Ana 1 0753.03 jUpper 3% n/a 17% 67% n/a I n/a 0% 13% 11% 25% Page 12 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract Income White Black I Hispanic I Applicant Race Asian I Haw. Nat. Am. Multi I Unk/NA I Total Min. % Santa Ana 0754.01 Middle 5% 0% 8% 33% n/a n/a n/a 0% 9% 15% Santa Ana 0754.03 Mod 17% n/a 16% 38% 0% n/a n/a 50% 20% 21% Santa Ana 0754.04 Mod 25% n/a 0% 0% n/a n/a n/a 25% 15% 0% Santa Ana 0754.05 Middle 9% n/a 14% 40% n/a n/a n/a 0% 16% 21% Santa Ana 0755.04 Middle 9% n/a 1 17% 0% n/a n/a n/a 1 17% 10% 8% Santa Ana 0755.05 Mod 38% 0% 33% 0% n/a n/a n/a 30% 33% 22% Santa Ana 0755.15 Middle 20% n/a 20% 16% 100% n/a n/a 18% 18% 18% Santa Ana 0757.01 Middle 11% 0% 0% 0% n/a n/a n/a 14% 9% 0% Santa Ana 0758.06 Middle 4% n/a 13% 38% n/a n/a n/a 33% 13% 25% Santa Ana 0759.02 Mod 9% n/a 33% 50% n/a n/a I n/a 0% 14% 38% Santa Ana 0760.00 Mod 25% 100% 0% 26% 0% 100% n/a 25% 25% 24% Santa Ana 0889.03 Mod n/a n/a 0% 37% n/a n/a 0% n/a 32% 32% Santa Ana 0890.01 Mod n/a n/a 0% 4% n/a n/a n/a 0% 3% 4% Santa Ana 0890.04 Mod 33% n/a 14% 23% n/a n/a n/a 0% 21% 21% Santa Ana 0891.02 Mod 14% n/a 16% 19% n/a n/a n/a 0% 16% 18% Santa Ana 0891.04 Low 0% n/a 30% 11% n/a n/a n/a 0% 18% 21% Santa Ana 0891.05 Mod n/a n/a 33% 44% n/a n/a n/a 0% 35% 39% Santa Ana 0891.07 Middle 0% n/a 18% 23% n/a n/a n/a 50% 23% 22% Santa Ana 0992.02 Mod 0% n/a 0% 15% 0% n/a n/a 25% 13% 13% Santa Ana 0992.03 Middle 29% n/a 0% 37% n/a n/a n/a n/a 33% 34% Santa Ana 0992.47 Low 100% n/a 0% 36% n/a n/a n/a n/a 31% 27% Santa Ana 0992.48 Mod 0% n/a 20% 20% 100% n/a n/a n/a 25% 27% Santa Ana 0992.49 Low n/a n/a 50% 11% n/a n/a n/a n/a 18% 18% Santa Ana Total 16% 29% 23% 22% 33% 100% 25% 19% 20% 23% Tustin 0219.14 Upper 22% n/a 0% 10% n/a 0% n/a 0% 12% 6% Tustin 0524.19 Upper 14% n/a 1 0% 17% n/a n/a n/a 1 29% 16% 13% Tustin 0525.02 Middle 16% n/a 0% 20% n/a n/a n/a 14% 16% 15% Tustin 0525.24 Upper 0% n/a 0% 8% n/a n/a 0% 14% 6% 7% Tustin 0744.06 Mod 0% n/a 33% 0% n/a n/a n/a 100% 30% 29% Tustin 0744.07 Low 45% n/a 75% 0% n/a n/a n/a 0% 44% 50% Tustin 0744.08 Mod 18% 0% 0% 20% n/a n/a n/a 33% 17% 11% Tustin 0754.03 Mod 17% n/a 16% 38% 0% n/a n/a 50% 20% 21% Tustin 0755.04 Middle 9% n/a 17% 0% n/a n/a n/a 17% 10% 8% Tustin 0755.05 Mod 38% 0% 33% 0% n/a n/a n/a 30% 33% 22% Tustin 0755.06 Middle 9% 0%1 14% 22% 0% n/a n/a 50% 15% 17% Tustin 0755.07 Mod 20% n/a 50% 0% 0% n/a n/a n/a 20% 20% Tustin 0755.12 Mod 0% n/a 0% 0% n/a n/a n/a 100% 13% 0% Tustin 0755.13 Mod 11% n/a 40% 11% n/a n/a n/a 40% 24% 26% Tustin 0755.14 Mod 0% n/a 0% 0% n/a n/a 0% 50% 10% 0% Tustin 0755.15 Middle 20% n/a 1 20% 16% 100% n/a n/a 18% 18% 18% Tustin 0756.03 Upper 1 0% n/a I n/a 1 9% 0% n/a n/a 0% 2% 8% Page 13 of 14 Appendix C-2 Percent of Denied Purchase Loans - By Census Tracts - Applicant Race 2013 City Number Tract I Income White I Black I Hispanic I Applicant Race Asian I Haw. I Nat. Am. I Multi I Unk/NA I I Total Min. Tustin 0756.04 Upper 17% n/a 0% 12% n/a 0% 100% 31% 18% 14% Tustin 0756.05 Upper 11% n/a 56% 14% 0% n/a n/a 43% 18% 29% Tustin 0756.06 Upper 16% 0% 0% 20% n/a n/a n/a 25% 17% 16% Tustin 0756.07 Upper 10% n/a 0% 8% n/a n/a 0% 22% 10% 8% Tustin 0757.01 Middle 11% 0% 0% 0% n/a n/a n/a 1 14% 9% 0% Tustin 0757.02 Middle 12% n/a 0% 29% n/a n/a n/a 0% 14% 25% Tustin Total 15% 0% 20% 13% 14% 0% 25% 24% 16% 15% OC County 12% 18% 19% 16% 18% 17% 18% 16% 15% 17% Source: www.lendingpatterns.com, October 2015 Tabulations: GRC Associates, Inc., October 2015 1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications. 2 - Table includes all applications that went through the complete underwriting process, and excludes applications withdrawn or files closed for incompleteness. Page 14 of 14 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Appendix D: HUD Worksheet APPENDIX 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice HUD Worksheet Name of Jurisdiction: City of Newport Beach Completing Department: Community Development Department, Planning Division Completed By: Melinda Whelan Date Completed: September 16, 2015 INTRODUCTION As part of the preparation of an Analysis of Impediments to Fair Housing Choice, which is required for the receipt of certain federal funds, this survey seeks answers to questions regarding local governmental codes or policies and practices that may result in the creation or perpetuation of one or more impediments to fair housing choice. It has a particular focus on land use and zoning regulations, practices and procedures that can act as barriers to the situating, development, or use of housing for individuals with disabilities. However, it also touches on areas that may affect fair housing choice for families with children or otherwise serve as impediments to full fair housing choice. The survey will help with the analysis of the codes and other documents related to land use and zoning decision-making provided by the jurisdiction. Additional information may be sought through interviews with appropriate staff. In identifying impediments to fair housing choice, the survey looks to distinguish between regulatory impediments based on specific code provisions and practice impediments, which arise from practices or implementing policies used by the jurisdiction. APPENDIX D: HUD WORKSHEET D-1 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS QUESTIONS 1. Does the Code definition of "family" have the effect of discriminating against unrelated individuals with disabilities who reside together in a congregate or group living arrangement? Yes No X a. Background Local zoning and land use laws that treat groups of unrelated persons with disabilities less favorably than similar groups of unrelated persons without disabilities violate the Fair Housing Act. For example, suppose a city's zoning ordinance defines "family" to include up to six unrelated persons living together as a household unit, and gives such a group of unrelated persons the right to live in any zoning district without special permission. If that ordinance also disallows a group home for six or fewer people with disabilities in a certain district or requires this home to seek a use permit, such requirements would conflict with the Fair Housing Act. The ordinance treats persons with disabilities worse than persons without disabilities. In 1980, the California Supreme Court in City of Santa Barbara v. Adamson struck down the City's ordinance that permitted any number of related people to live in a house in a R1 zone, but limited the number of unrelated people allowed to do so to five. Under the Santa Barbara ordinance, a group home for individuals with disabilities that functions like a family could be excluded from the R1 zone solely because the residents are unrelated by blood, marriage or adoption. Both State and Federal fair housing laws prohibit definitions of family that either intentionally discriminate against people with disabilities or have the effect of excluding such individuals from housing. Fair housing laws, for instance, prohibit definitions of family that limit the development and siting of group homes for individuals with disabilities (but not families similarly sized and situated). Such definitions are prohibited because they could have the effective of denying housing opportunities to those who, because of their disability, live in a group setting. The failure to modify the definition of family or make an exception for group homes for people with disabilities may also constitute a refusal to make a reasonable accommodation under the Fair Housing Act. For example, the following definition of family would be inconsistent with fair housing laws: "Family" means a householder and one or more other people living in the same household who are related to the householder by birth, marriage or adoption. A definition of family should look to whether the household functions as a cohesive unit instead of distinguishing between related and unrelated persons. APPENDIX D: HUD WORKSHEET D-2 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Newport Beach Zoning Code definition of "family' is: "One or more persons living together as a single housekeeping unit in a dwelling unit." A "single housekeeping unit" is defined by the Newport Beach Zoning Code as: "The functional equivalent of a traditional family, whose members are an interactive group of persons jointly occupying a single dwelling unit, including the joint use of and responsibility for common areas, and sharing household activities and responsibilities such as meals, chores, household maintenance, and expenses, and where, if the unit is rented, all adult residents have chosen to jointly occupy the entire premises of the dwelling unit, under a single written lease with joint use and responsibility for the premises, and the makeup of the household occupying the unit is determined by the residents of the unit rather than the landlord or property manager." The definitions of "family" or "single housekeeping unit" do not make any distinction between the relationships of the individuals, and therefore, does not have the effect of discriminating against unrelated individuals, or individuals with disabilities who reside together in a congregate or group living arrangement. 2. Does the Code or any policy document define "disability', if at all, at least as broadly as the Fair Housing Act? Yes X No a. Background The Fair Housing Act prohibits discrimination on the basis of handicap or disability, and defines persons with disabilities as: "individuals with physical or mental impairments that substantially limit one or more major life activities; has a record of such impairment; or is regarded as having such impairment." The term physical or mental impairments may include conditions such as blindness, hearing impairment, mobility impairment, HIV infections, AIDS, AIDS Related Complex, mental retardation, chronic alcoholism, drug addiction, chronic fatigue, learning disability, head injury, and mental illness. The term major life activities may include walking, talking, hearing, seeing, breathing, learning, performing manual tasks, and caring for oneself. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Newport Beach Zoning Code definition of "individual with a disability' is: "As more specifically defined under the fair housing laws, a person who has a physical or mental impairment that limits one or more major life activities, a person who is regarded as having that type of impairment, or a APPENDIX D: HUD WORKSHEET D-3 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS person who has a record of that type of impairment, not including current, illegal use of a controlled substance." This definition of disability is very similar to the FEHA definition and as a result, it is not considered discriminatory. 3. Are the personal characteristics of the (disabled) residents considered? Yes No X a. Background Under the Fair Housing Act, cities may have reasonable restrictions on the maximum number of occupants permitted to occupy a dwelling; however, the restrictions cannot be based on the characteristics of the occupants; the restrictions must apply to all citizens, and are based upon health and safety standards. Similarly, a conditional use permit or variance requirement triggered by the number of people with certain characteristics (such as a disability) who will be living in a particular dwelling, is prohibited. Because licensed residential care facilities serve people with disabilities, imposing a variance requirement on family -like facilities of a certain size and not similarly sized housing for people without disabilities violates fair housing laws. According to the DOJ and HUD, "group home" does not have a specific legal meaning. In the DOJ/HUD Joint Statement* - "...the term group home refers to housing occupied by groups of unrelated individuals with disabilities. Sometimes, but not always, housing is provided by organizations that also offer services for individuals with disabilities living in the group home. Sometimes it is this group home operator, rather than the individuals who live in the home, that interacts with local government in seeking permits and making requests for reasonable accommodations on behalf of those individuals." "The term group home is also sometimes applied to any group of unrelated persons who live together in a dwelling — such as a group of students who voluntarily agree to share the rent on a house. The Act does not generally affect the ability of local governments to regulate housing of this kind, as long as they do not discriminate against residents on the basis of race, color, national origin, religion, sex, handicap (disability) or familial status (families with minor children)." "Local zoning and land use laws that treat groups of unrelated persons with disabilities less favorably than similar groups of unrelated persons without disabilities violate the Fair Housing Act." [*Joint Statement of DOJ and HUD, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 3] APPENDIX D: HUD WORKSHEET D-4 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: Except when granting access to disabled individuals or groups that exceeds housing access granted to other similarly situated groups, the Municipal Code and Zoning Code do not consider the characteristics of the residents of a dwelling. Instead, the code considers whether or not a group of individuals are residing in the dwelling as a single housekeeping unit. A group of individuals living as a single housekeeping unit, whether disabled or nondisabled, can live together in any district zoned for residential use in the City. 4. Does the zoning ordinance restrict housing opportunities for individuals with disabilities and mischaracterize such housing as "boarding or rooming house" or "hotel'? Yes No X a. Background Housing for disabled persons in some communities is limited to certain residential zones. Often, housing for disabled persons is included in how cities define a boarding house or hotel. Under California State law, licensed facilities serving six persons or fewer receive special land use protection. California requires that many types of licensed facilities serving six persons or fewer be treated for zoning purposes like single-family homes. Except in extraordinary cases in which even single-family home requires a conditional use permit, these laws bar conditional use permits for facilities that serve six or fewer persons. The land use protection applies to — o Intermediate care facilities for individuals who have developmental disabilities o Residential facilities for persons with disabilities and for abused children o Residential care facility for the elderly o Alcoholism and drug treatment facilities o Residential facilities for persons with chronic life threatening illness For example, Health and Safety Code Section 11834.23 (Zoning Laws) states: "Whether or not unrelated persons are living together, an alcoholism or drug abuse recovery or treatment facility, which serves six or fewer persons shall be considered a residential use of property for the purposes of this article. In addition, the residents and operators of such a facility shall be considered a family for the purposes of any law or zoning ordinance which relates to the residential use of property..." Furthermore: "No conditional use permit, zoning variance, or other zoning clearance shall be required of an alcoholism or drug abuse recovery or treatment facility which serves six or fewer persons that is not required of a single —family residence in the some zone." APPENDIX D: HUD WORKSHEET D-5 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Essentially, identical provisions are stated with regard to a residential facility, which serves six or fewer persons. A residential facility "...means any family home, group care facility, or similar facility for 24-hour nonmedical care of persons in need of personal services, supervision, or assistance essential for sustaining the activities of daily living or for the protection of the individual." Health and Safety Code Section 1566.3 states: "No conditional use permit, zoning variance, or other zoning clearance shall be required of a residential facility which serves six or fewer persons which is not required of a family dwelling of the same type in the same zone." Further: "'family dwelling' includes, but is not limited to, single-family dwellings, units in multi -family dwellings, including units in duplexes and units in apartment dwellings, mobile homes, including mobile homes located in mobile home parks, units in cooperatives, units in condominiums, units in townhouses, and units in planned developments." State law requires that residential care facilities not be defined within the meaning of boarding house, rooming house, institution or home for the care of minors, the aged, or the mentally infirm, foster care home, guest home, rest home, sanitarium, mental hygiene home, or other similar term which implies that a residential facility is a business run for profit. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: For groups not living as a single housekeeping unit, the code provides more favorable treatment to disabled groups than non -disabled groups. Licensed residential care facilities housing six or fewer individuals can locate in any residential zone in the City while all other groups not living as single housekeeping units are prohibited in all residential zones of the City. In this way, the City makes a favorable exception for groups of individuals with disabilities. The Zoning Code also provides both a use permit and reasonable accommodation procedure that allow groups of disabled individuals not living as single housekeeping units to establish residences in residential zones within the City. 5. Does the zoning ordinance deny housing opportunities for disabled individuals with on site housing supporting services ? Yes No X APPENDIX D: HUD WORKSHEET D-6 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS a. Background Housing for disabled persons often must incorporate on-site supportive services. Zoning provisions that limit on-site supportive services will, in effect curtail the development of adequate housing for the disabled. As the joint statement by DOJ and HUD indicates: "Sometimes, but not always, housing is provided by organizations that also offer services for Individuals with disabilities living in the group home." b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Zoning Code places no restrictions on the provision of any on-site supportive services required by disabled individuals, and therefore, they would be allowed. 6. Does the jurisdiction policy allow any number of unrelated persons to reside together, but restrict such occupancy, if the residents are disabled? Yes No X a. Background The joint statement by DOJ and HUD describes this issue as follows: "A local government may generally restrict the ability of groups of unrelated persons to live together as long as the restrictions are imposed on all such groups. Thus, in the case where a family is defined to include up to six unrelated people, an ordinance would not, on its face, violate the Act if a group home of seven unrelated people with disabilities was not allowed to locate in single-family zoned neighborhood, because a group of seven unrelated people without disabilities would also not be allowed." b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Zoning Code makes no distinction between and does not consider whether groups living together are related or unrelated to each other. In addition, for groups not living as a single housekeeping unit, the code provides more favorable treatment to disabled groups than non - disabled groups. Licensed residential care facilities housing six or fewer individuals can locate in any residential zone in the City. Although all other groups not living as single housekeeping units are prohibited in all residential zones of the City. In this way, the City makes a favorable exception for groups of disabled individuals. The Zoning Code provides use permit and reasonable accommodation procedures that allow groups of disabled individuals not living as single housekeeping units to establish residences in residential zones within the City. APPENDIX D: HUD WORKSHEET D-7 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 7. Does the jurisdiction policy not allow disabled persons to make reasonable modifications or provide reasonable accommodation for disabled people who live in municipal -supplied or managed residential housing? Yes No X or N/A a. Background A joint statement by DOJ and HUD explains this issue as follows: "As a general rule, the Fair Housing Act makes it unlawful to refuse to make 'reasonable accommodations' (modifications or exceptions) to rules, policies, practices, or services, when such accommodations may be necessary to afford persons with disabilities an equal opportunity to use or enjoy a dwelling." "Even though a zoning ordinance imposes on group homes the same restrictions it imposes on other groups of unrelated people, a local government may be required, in individual cases and when requested to do so, to grant a reasonable accommodation to a group home for persons with disabilities. For example, it may be a reasonable accommodation to waive a setback required so that a paved path of travel can be provided to residents who have mobility impairments. A similar waiver might not be required for a different type of group home where residents do not have difficulty negotiating steps and do not need a setback in order to have an equal opportunity to use and enjoy a dwelling." "Where a local zoning scheme specifies procedures for seeking a departure from the general rule, courts have decided, and the Department of Justice and HUD agree, that these procedures must ordinarily be followed. If no procedure is specified, persons with disabilities may, nevertheless, request a reasonable accommodation in some other way, and a local government is obligated to grant it if it meets the criteria discussed above. A local government's failure to respond to a request for reasonable accommodation or an inordinate delay in responding could also violate the Act." "Local governments are encouraged to provide mechanisms for requesting reasonable accommodations that operate promptly and efficiently, without imposing significant costs or delays. The local government should also make efforts to insure that the availability of such mechanisms is well known within the community."* [*Joint Statement of DOJ and HUD, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 3 and 4] The Fair Housing Act requires housing providers to make reasonable accommodations for persons with disabilities. A reasonable accommodation is a change in rules, policies, practices, or services so that a person with a disability will have an equal opportunity to use and enjoy a dwelling unit or common space. A housing provider should do everything s/he can to assist, but s/he is not required to make changes that would fundamentally alter the program or create an undue financial and administrative burden. Reasonable accommodations may be necessary at all stages of the housing process, including application, tenancy, or to prevent eviction. APPENDIX D: HUD WORKSHEET D-8 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Example: A housing provider would make a reasonable accommodation for a tenant with mobility impairment by fulfilling the tenant's request for a reserved parking space in front of the entrance to their unit, even though all parking is unreserved. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The City does not own or manage any housing units. 8. Does the jurisdiction require a public hearing to obtain public input for specific exceptions to zoning and land use rules for disabled applicants and is the hearing only for disabled applicants rather than for all applicants? Yes X No a. Background Persons with disabilities cannot be treated differently from non -disabled persons in the application, interpretation and enforcement of a community's land use and zoning policies. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The City does not require disabled individuals to apply for a variance in order to obtain an exception from zoning and land use rules. Instead, the Zoning Code provides reasonable accommodation procedures for disabled individuals and groups. Like variances, reasonable accommodations involve a public hearing, but the matter is heard before a hearing officer rather than the Planning Commission. Unlike the variance application, the reasonable accommodation application does not require a fee. APPENDIX D: HUD WORKSHEET D-9 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 9. Does the zoning ordinance address mixed uses? Yes X No How are the residential land uses discussed? What standards apply? a. Background Housing for disabled persons in a mixed-use development that includes commercial and residential land uses in a multi -story building could be a challenge. In such a development, it is especially important to correctly interpret the Title 24 accessibility requirements. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: Yes, the Zoning Code allows for mixed uses consistent with the General Plan. The ordinance considers the ability of mixed-use development to enhance housing affordability and the Building Code includes standards for mixed -uses taking into consideration the challenges of providing housing accessible to persons with disabilities in such mixed-use buildings. Building disability standards are consistently applied to all like buildings and structures. 10. Does the zoning ordinance describe any areas in this jurisdiction as exclusive? Yes No X Are there exclusions or discussions of limiting housing to any of the following groups? Yes No -X If yes, check any of the following that apply: Race _Color _Sex Marital or Familial Status a. Background Religion _Age _Disability Creed or National Origin Fair housing means the ability of persons of similar income levels to have available to them the same housing choices. The City's land use and zoning policies cannot exclude persons from living in the neighborhoods in which they want to reside. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Zoning Code and adopted Planned Communities do not exclude anyone from residing in any neighborhood based upon race, color, creed or national origin, sex, gender affiliation, religious beliefs, age, disability, or marital/familial status. APPENDIX D: HUD WORKSHEET D-10 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS 11. Are there any restrictions for Senior Housing in the zoning ordinance? Do the restrictions comply with Federal law on housing for older persons (i.e., solely occupied by persons 62 years of age or older or at least one person 55 years of age or older and has significant facilities or services to meet the physical or social needs of older people?) Yes X No a. Background According to HUD, the Fair Housing Act protests all citizens from discrimination on the basis of familial status — that is, families with children under the age of 18 living with parents or legal guardians; pregnant women; and people trying to secure custody of children under 18. However, housing that meets the Fair Housing Act's definition of 'housing for older persons' is exempt from the law's familial status requirements, provided that: o HUD has determined that the dwelling is specifically designed for and occupied by elderly persons under a Federal, State or local government program, or o It is occupied by persons who are 62 or older, or o It houses at least one person who is 55 or older in at least 80% of the occupied units, and adheres to a policy that demonstrates intent to house persons who are 55 or older. The Housing for Older Persons Act of 1995 eliminated the requirements for "significant services and facilities" (mentioned in Q. 11) within designated senior housing units or areas. In California, Section 51 of the Unruh Civil Rights Act, also defines seniors as meaning persons 62 years of age or older, or 55 years of age and older in a senior citizen housing development. A senior citizen housing development is one for senior citizens that has at least 35 dwelling units. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: Senior housing is not treated differently than any other rental or for -sale housing and is allowed in any zoning district that allows residential uses. The City makes two favorable accommodations for senior housing. First, Section 20.48.200 of the Zoning Code allows for the creation of "granny units" pursuant to California Government Code Section 65852.2 in zoning districts where there is only one dwelling unit permitted. This specific accommodation is not provided to other populations. Second, Section 20.40.040 of the Zoning Code allows a lower parking ratio for senior housing based upon the premise that seniors drive less. These two favorable accommodations are in response to the City's high senior population and current National demographic trends attempting to facilitate increased senior housing. 12. Does the zoning ordinance contain any special provisions for making housing accessible to persons with disabilities? Yes No X APPENDIX D: HUD WORKSHEET D-11 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS a. Background Fair housing laws that require accessible units apply to "covered multifamily dwellings" constructed for first occupancy after March 13, 1991. First occupancy is defined as a "building that has never been used for any purpose". There is no timetable for the production of accessible housing; as such housing is constructed when residential projects are built. The Fair Housing Act does not require any renovations to existing buildings. Its design requirements apply to new construction only. Both privately owned and publicly assisted housing — including rental and for sale units — must meet the accessibility requirements when they are located in 1) buildings of four or more dwellings if such buildings have one or more elevators, and 2) all ground floor dwellings in other buildings containing four or more units. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The provision for making housing accessible to persons with disabilities is found within the 2013 Edition of the California Building Code. Fair Housing is referenced within the Building Code Sections but the Fair Housing Amendments Act of 1988 is not specifically cited. 13. Does the ordinance establish occupancy standards or maximum occupancy limits? Yes X No, Do the restrictions exceed those imposed by state law? Yes _ No a. Background Occupancy standards sometimes can impede the development of housing for disabled persons. Some zoning regulations limit occupancy to five related persons occupying a single family home. Such regulations can prevent the development of housing for disabled persons. The Fair Housing Act provides that nothing in the Act "limits the applicability of any reasonable local, State or Federal restrictions regarding the maximum number of occupants permitted to occupy a dwelling". HUD implements section 589 of the QHWRA by adopting as its policy on occupancy standards for purposes of enforcement actions under the Fair Housing Act, the standards provided in the Memorandum of General Counsel Frank Keating to Regional Counsel dated March 20, 1991. Specifically, HUD believes that an occupancy policy of two persons in a bedroom, as a general rule, is reasonable under the Fair Housing Act. However, HUD has pointed out, that there is nothing in the legislative history which indicates any intent on the part of Congress to provide for the development of a national occupancy code. APPENDIX D: HUD WORKSHEET D-12 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS Thus, HUD believes that in appropriate circumstances, owners and managers may develop and implement reasonable occupancy requirements based on factors such as the number and size of sleeping areas or bedrooms and the overall size of the dwelling unit. In this regard, it must be noted, in connection with a complaint alleging discrimination on the basis of familial status, HUD will carefully examine any such nongovernmental restriction to determine whether it operates unreasonably to limit or exclude families with children. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Zoning Code does not generally limit the number individuals who may occupy a residential unit. However, Zoning Code Section 20.52.030.G.2.b states: "There shall be no more than two residents per bedroom, plus one additional resident. Notwithstanding, upon request by the applicant for additional occupancy, the Hearing Officer has discretion to set occupancy limits based upon the evidence provided by the applicant that additional occupancy is appropriate at the site. In determining whether to set a different occupancy limit, the Hearing Officer shall consider the characteristics of the structure, whether there will be an impact on traffic and parking and whether the public health, safety, peace, comfort, or welfare of persons residing in the facility or adjacent to the facility will be impacted." The standard above does not apply generally to residential units and it only applies when a hearing officer is reviewing a use permit for certain uses within residential districts. Specifically, the hearing officer reviews requests for bed and breakfast inns, general day care uses, and residential care facilities with the exception of State licensed facilities with 6 or fewer residents. The standard does allow flexibility for an applicant to request and receive a different number of occupants when appropriate and the specific facts of each living situation inform the final determination through the discretionary use permit process. 14. Does the zoning ordinance include a discussion of fair housing? Yes No X If yes, how does the jurisdiction propose to further fair housing? a. Background Affirmatively furthering fair housing is an important responsibility of local government. Although a city may have numerous plans, policies, and standards, fair housing is rarely discussed in a zoning ordinance. Other documents of a city may further fair housing. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Zoning Code does not provide general discussion of fair housing but it provides a definition of applicable fair housing laws. In accordance with federal and state Fair Housing laws NBMC Section 20.52.070 provides reasonable accommodations in the City's zoning and land use regulations, APPENDIX D: HUD WORKSHEET D-13 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS policies and practices, when needed to provide an individual with a disability an equal opportunity to use and enjoy a dwelling. 15. Describe the minimum standards and amenities required by the ordinance for a multiple family project with respect to handicap parking? a. Background Federal and State laws require handicap parking. To further fair housing for disabled persons, a city's requirements should equal or exceed the minimum standards of Federal and State laws. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Zoning Code requires that parking for the disabled be properly stripped and marked. The number of disabled parking spaces is provided consistent with the 2013 Edition of the California Building Code adopted by reference by the City. 16. Does the zoning code distinguish senior citizen housing from other single- and multifamily residential uses by the application or a conditional use permit (CUP)? Yes No X a. Background Senior housing is an important component of the community's housing stock. As a population ages, seniors need a variety of housing opportunities. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Zoning Code distinguishes between convalescent housing and residential uses but not between senior citizen housing and residential uses. 17. How are "special group residential housing units" defined in the jurisdiction's zoning code? a. Background The term group home does not have a specific legal meaning. According to the DOJ/HUD Joint Statement the term 'group home' is sometimes applied to any group of unrelated persons who live together in a dwelling — such as a group of students who voluntarily agree to share the rent on a house. The Fair Housing Act does not generally affect the ability of local governments to regulate housing of this kind, as long as they do not discriminate against residents on the basis of race, color, national origin, religion, sex, handicap (disability) or familial status (families with minor children). APPENDIX D: HUD WORKSHEET D-14 16 ORANGE COUNTY CITIES REGIONAL ANALYSIS OF IMPEDIMENTS b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The Zoning Code includes a definition for "Group Residential" uses as "meaning shared living quarters, occupied by two or more persons not living together as a single housekeeping unit ("Single housekeeping unit"). Includes, without limitation, boarding or rooming houses (see "Boarding or rooming house"), dormitories, fraternities, sororities, parolee -probationer homes (see "Parolee - probationer home"), and private residential clubs. Excludes residential care facilities (see "Residential care facilities")" (emphasis added). "Residential Care Facilities" allow for a place, site or building, or groups of places, sites or buildings, licensed or unlicensed by the State, in which individuals with a disability reside who are not living together as a single housekeeping unit (see "Single housekeeping unit") and in which every person residing in the facility (excluding the licensee, members of the licensee's family, or persons employed as facility staff) is an individual with a disability. Housing Element Goal H5 and Housing Programs 5.1.1 through 5.1.8 found in the Housing Element also address the housing needs of the special needs population within the City. 18. Do the jurisdiction's planning and building codes presently make a specific reference to the accessibility requirements contained in the 1988 amendments to the Fair Housing Act? Yes No X Is there any provision for monitoring compliance? Yes No X a. Background The Fair Housing Act establishes accessibility requirements for new housing. Title 24 of the California Code of Regulations, known as the California Building Standards Code or just 'Title 24', contains the regulations that govern the construction of buildings in California. Chapter 11A contains the regulations governing housing accessibility. The City enforces the Title 24 accessibility regulations. b. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at your answer: The provision for making new housing accessible to persons with disabilities is found within the 2013 Edition of the California Building Code that has been adopted by reference by the City. Fair Housing is referenced within the Building Code but the 1988 Amendments of the Fair Housing Act are not specifically cited. APPENDIX D: HUD WORKSHEET D-15 Exhibit 2b BIG CANYON HABITAT RESTORATION AND WATER QUALITY IMPROVEMENT PROJECT Mitigation Monitoring and Reporting Program Prepared for April 2016 City of Newport Beach Public Works Department i:• ;r I` !' F7 ;r*` TABLE OF CONTENTS Section 1: Introduction.........................................................................................................1 Section 2: Project Description..............................................................................................2 Section 3: Mitigation Monitoring And Reporting Program.....................................................3 Table 1: Mitigation Monitoring Reporting Program................................................................4 Project Description The proposed project is located within the City of Newport Beach, on a site in the eastern portion of the 60 -acre Big Canyon Nature Park. 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N_aFL m O W •aWm.`� «0mQW @.n oN E v -Z �awm:02'0da m {Up y mm2mio° 0 m U O W W- L LY W� ad«� m m .oms�w m�C.2 0M530 i a'nma m=NLp=ma ++ +E maa c @O 8 m' - LWN O0E'a0NamZ m_WU m LW pO mN wUm m.c U ULW >N2QVQE ❑� :5J STATE OF CALIFORNIA } COUNTY OF ORANGE } ss. CITY OF NEWPORT BEACH } I, Leilani I. Brown, City Clerk of the City of Newport Beach, California, do hereby certify that the whole number of members of the City Council is seven; that the foregoing resolution, being Resolution No. 2016-58 was duly and regularly introduced before and adopted by the City Council of said City at a regular meeting of said Council, duly and regularly held on the 10`h day of May, 2016, and that the same was so passed and adopted by the following vote, to wit: AYES: Council Member Peotter, Council Member Duffield, Council Member Selich, Council Member Curry, Council Member Petros, Mayor Pro Tem Muldoon, Mayor Dixon NAYS: None IN WITNESS WHEREOF, I have hereunto subscribed my name and affixed the official seal of said City this 11 m day of May, 2016. Leilani I. Brown, MMC ` City Clerk Newport Beach, California (Seal)