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Home My WebLink About12 - Regional Analysis to Fair Housing Choicer 1 � i �� i�: I At IF, u li Agenda Item No. 12 April 26, 2011 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: Community Development Department Dana Smith, Assistant City Manager 949 -644 -3002, dsmith @newportbeachca.gov PREPARED BY: James Campbell, Acting Planning Director APPROVED: L4A1 TITLE: 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice ABSTRACT: The U.S. Department of Housing and Urban Development (HUD) requires the City of Newport Beach to undertake its own - or to participate regionally in - an Analysis of Impediments to Fair Housing Choice (AI) as a condition of continued funding for the Community Development Block Grant (CDBG) program. In accordance with 24 CFR Part 570.601 the City must identify impediments to fair and equal housing opportunities and certify that the City will engage in fair housing planning. The Al addresses this requirement. The Al must be updated every five years (24 CFR Part 91) reflecting the changes in the community since the preparation of the last Al. The City joined with other Cities throughout Orange County and participated in the 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice in order to fulfill this obligation. RECOMMENDATION: 1. Hold a public hearing to receive comments on the 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice; and 2. Approve the 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice; and 3. Adopt Resolution No. 2011- authorizing the City Manager to submit the 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice Certification to HUD. 1 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice April 26, 2011 Page 2 FUNDING REQUIREMENTS: There is no fiscal impact related to this item DISCUSSION: The City receives an entitlement allocation of Federal Community Development Block Grant ( "CDBG ") funds from the U.S. Department of Housing and Urban Development ( "HUD ") each year. In accordance with 24 CFR Part 570.601 the City must identify impediments to fair and equal housing opportunities and certify that the City will engage in fair housing planning. The Regional Al addresses this requirement. Fair housing is a condition in which individuals of similar income levels in the same housing market have like ranges of choice available to them regardless of race, color, ancestry, national origin, religion, sex, disability, marital status, familial status, or any other arbitrary factor. The AI provides an overview of laws, regulations, conditions or other possible obstacles that may affect an individual or household's access to housing. Equal access to housing for all is fundamental to each person in meeting essential needs and pursuing personal, educational, employment, or other goals. Recognizing this, the Federal government and the State of California have each established fair housing as a right protected by law. An impediment to fair housing choice, according to HUD, is: 1) Any actions, omissions, or decisions taken because of race, color, religion, sex, disability, familial status, or national origin which restrict housing choices or the availability of housing choices; and 2) Any actions, omissions or decisions which have the effect of restricting housing choices or the availability of housing choices because of race, color, religion, sex, disability, familial status, or national origin. As identified in the draft Al, there are two (2) types of impediments, including public sector impediments and private sector impediments. Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the Fair Housing Council of Orange County and the City of Newport Beach did not identify any public sector impediments. Therefore, there are no actions to be taken at this time by the City with respect to public sector impediments. The Al did include several private sector impediments throughout the region, including: 2 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice April 26, 2011 Page 3 Housing Discrimination — Regionally, there are approximately 60 complaints filed annually by residents alleging discriminatory practices in rental and ownership housing. Discrimination is based on a particular bias or biases; however, the leading bias identified in the AI for the period studied was physical or mental disability (35 % of all complaints). Discriminatory Advertising — This can be an impediment to fair housing choice because ads can have the effect of discouraging a certain type of renter or buyer. Ads indicating a preference for a certain type of tenant or buyer such as "no pets" "no children" "No Section 8" or "Ideal for Single Adult" have the effect of housing discrimination. Blockbusting — The Regional Al lists this item as "being unlawful' but also states that it "does not appear to be a significant impediment to fair housing choice." Blockbusting is defined by Section 804(e) of the 1968 Fair Housing Act, as "For profit, to induce or attempt to induce any person to sell or rent any dwelling by representations regarding the entry or prospective entry into the neighborhood or a person or persons of a particular race, color, religion, sex, handicap, familial status, or national origin. o Denial of Reasonable Modifications /Reasonable Accommodations — It is unlawful to refuse to make reasonable accommodations for disabled persons. Section 804 (3) of the 1968 Fair Housing Act states that discrimination includes- (A) a refusal to permit, at the expense of the handicapped person, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises, except that, in the case of a rental, the landlord may where it is reasonable to do so condition permission for a modification on the renter agreeing to restore the interior of the premises to the condition that existed before the modification, reasonable wear and tear excepted. (B) a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling. o 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. According to the FBI, the City of Newport Beach experiences approximately five (5) hate crimes per year, not all of which are committed at a residence. 3 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice April 26, 2011 Page 4 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 throughout the region. The Regional Al did not provide Home Mortgage Disclosure Act (HMDA) data specific to the City of Newport Beach. The City of Newport Beach will provide funding each year to the Fair Housing Foundation in an effort to implement fair housing education and enforcement programs geared toward reducing the incidences of impediments to fair housing choice for current and potential Newport Beach residents. ENVIRONMENTAL REVIEW: Staff recommends the City Council find this action is not subject to the California Environmental Quality Act ( "CEQA ") pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly. NOTICING: In accordance with HUD requirements for a 30 -day public review and comment period, notice of the public hearing was published in the Daily Pilot on March 26, 2011. Further, the agenda item has been noticed according to the Brown Act (72 hours in advance of the meeting at which the City Council considers the item). Submitted by: JamesaY m.2maCampK°mOryof Campbell p �s W tc 2011 M.191 Q ] 9.OJ W' W James Campbell Acting Planning Director Attachments: A. Draft Resolution B. Draft 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice ii Attachment A Draft Resolution 0 Page Intentionally Blank 0 CITY COUNCIL RESOLUTION NO. 2011- A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF NEWPORT BEACH APPROVING THE 2010 -2015 ORANGE COUNTY REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE IN CONNECTION WITH THE COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) PROGRAM, AND SUPERCEDING ALL PREVIOUS RESOLUTIONS WHICH ARE INCONSISTENT THEREWITH. WHEREAS, the City of Newport Beach participates in the Department of Housing and Urban Development's (HUD) Community Development Block Grant (CDBG); and WHEREAS, cities participating in federal grant programs are required to develop and follow an Analysis of Impediments to Fair Housing Choice as a condition of receiving funds for HUD Community Planning and Development (CPD) programs, including the CDBG program; and WHEREAS, an Analysis of Impediments to Fair Housing Choice is required to be updated and adopted at least once every five years; and WHEREAS, the City paid $5,750.00 to the Fair Housing Council of Orange County to participate in the Regional Analysis of Impediments for 2010 -2015; and WHEREAS, on March 26, 2011, the City published a public notice in the Daily Pilot newspaper indicating that the draft Regional Analysis of Impediments to Fair Housing Choice would be available to the public for review and comment from March 26, 2011 to April 26, 2011; and WHEREAS, on April 26, 2011, the City Council reviewed and approved the draft Regional Analysis of Impediments to Fair Housing Choice, including any amendments necessary for response to the comments presented at the hearing; and WHEREAS, pursuant to Section 15378 of the State CEQA Guidelines, the proposed project is exempt from the requirements of CEQA. NOW, THEREFORE, the City Council of the City of Newport Beach DOES HEREBY RESOLVE as follows: SECTION 1. The Regional Analysis of Impediments to Fair Housing Choice containing a countywide and city- specific analysis of potential impediments to fair housing choice, is hereby adopted, and the City Council DOES HEREBY AUTHORIZE the City Manager to be the official representative of the City of Newport Beach to submit the City's adoption and certification of the Regional Analysis of Impediments to Fair Housing Choice to HUD. PASSED AND ADOPTED by the City Council of the City of Newport Beach at a regular meeting held on the 26th day of April 2011. 1 7 MAYOR OF THE CITY OF NEWPORT BEACH attest: CITY CLERK OF THE CITY OF NEWPORT BEACH STATE OF CALIFORNIA ) COUNTY OF ORANGE ) SS CITY OF NEWPORT BEACH ) I, LEILANI BROWN, City Clerk of the City of Newport Beach, HEREBY DO CERTIFY that the foregoing resolution was duly adopted at a regular meeting of the City Council of the City of Newport Beach, held on the 26th day of April 2011. AYES: COUNCILMEMBERS: NOES: COUNCILMEMBERS: ABSENT: COUNCILMEMBERS: CITY CLERK OF THE CITY OF NEWPORT BEACH 2 0 Attachment B Draft 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice 9 Page Intentionally Blank 10 ORANGE COUNTY FAIR HOUSING PLAN 2010 -2015 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE FAIR HOUSING ACTION PLAN -1 -t This Page Intentionally Left Blank 12 Table of Contents Section 1 Introduction A. Affirmatively Further Fair Housing (AFFH) Certification ......................... ............................1 -1 B. Meaning and Scope of Fair Housing Impediments ................................. ............................1 -3 C. Participants in the Regional AI ................................................................. ............................1 -4 D. Citizen Participation ................................................................................... ............................1 -6 E. Report Format ........................................................................................... ...........................1 -12 F. Protected Classes 1 -13 ................................................................................. ............................... Attachment A -Fair Housing Protected Classes .................................................. ...........................1 -14 List of Tables 1 -1 Regional Analysis of Fair Housing Impediments: Survey Comparison to 2009 American Community Survey .................................................................. ............................1 -7 1 -2 Regional Analysis of Fair Housing Impediments: Resident Survey Results — Questions #3 and #7 Cross Tab 1 -7 1 -3 Regional Analysis of Fair Housing Impediments: Fair Housing Survey Summary .......... 1 -9 is Table of Contents Section 2 Fair Housing Progress Report A. Introduction 2 -1 .............................................................................................. ............................... 1. Private Sector Impediments ................................................................ ............................2 -1 2. Public Sector Impediments .............................................................. ............................... 2 -1 B. Progress on Eliminating or Ameliorating Impedi 1. Confusion among Residents, Housing Providers and Local Government Officials Regarding the Protection Provided by Fair Housing Laws (both State and Federal) .................................................................... ............................2 -1 2. Intentional Discrimination by Some Members of the Housing Industry Including, but not necessarily Limited to, Rental, Lending, Insurance, Zoning, Appraisals, andAdvertising ................................................................................... ............................2 -3 3. "Color" Blind Policy Causes Disparate Impact (i.e., Credit Scores in Determining a Person's Insurability and Occupancy Restrictions) ...................... ............................2 -3 4. Employer's Lack of Support for Affordable Housing Results in SegregatedHousing ........................................................................... ............................2 -3 5. High Loan Denial Rates are 3 Times among Upper Income Blacks and 2 Times for Equally Situated Hispanics ................................................................. ............................ ? -4 6. CRA Funds are not Targeted in ways Assisting Low Income Persons and Neighborhoods in Home Ownership and Financial Stability ,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,2 -5 7. Some Jurisdictions Underestimate the Extent of Discrimination, Therefore Reducing or not Paying Fair Share of Services Provided by FHCOC, ........................................ 2 -6 List of Tables 2 -1 Orange County - Disparities in Loan Denial Rates for Black and Hispanic Borrowers - 2008 2-4 N94119 Table of Contents Section 3 Fair Housing Action Plan A. Introduction 3 -1 .............................................................................................. ............................... B. Fair Housing Community Profile ........................................................... ............................... 3 -1 1. Orange County Population Growth Trends,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 3 -1 2. Population Characteristics of the Protected Classes ................................................... 3 -2 C. Private Sector Impediments and Actions to be T 1. Housing Discrimination ...................................................................... ...........................3 -12 2. Discriminatory Advertising ................................................................. ...........................3 -14 3. Blockbusting ........................................................................................ ...........................3 -16 4. Denial of Reasonable Modifications /Reasonable Accommodations .......................... 3 -17 5. Hate Crimes ..................................................................................... ............................... 3 -18 6. Unfair Lending... .................................................................................. ...........................3 -19 D. Actions to Address Public Sector Imped 1. Public Sector Impediments Common to Most Participating Jurisdictions,,,,,,,,,,,,,,,,, 3 -21 2. City Identified Public Sector Impediments .................................... ............................... 3 -25 3. Actions to be Taken by the FHCOC and City to Ameliorate or Eliminate Public Sector Impediments ..................................................................... ...........................3 -26 E. Actions to AFFH through the Location of Affordable Housing ......... ............................... 3 -27 List of Tables 3 -1 Regional Analysis of Fair Housing Impediments — Characteristics of the Protected Classes 3 -4 List of Charts 3 -1 Private Sector Impediments Fair Housing Action Plan: 2010 - 2015 .. ............................... 3 -6 15 Table of Contents Section 4 Fair Housing Community Profile A. Introduction 4 -1 B. Population and Housing Characteristics ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,4 -2 1. Population ............................................................................................ ............................4 -2 2. Housing Characteristics ...................................................................... ............................4 -3 C. Population Growth in Orange County ..................................................... ............................4 -4 1. Population by Race and Ethnicity ...................................................... ............................4 -4 2. Projected Population ........................................................................... ............................4 -5 3. Housing Needs .................................................................................... ............................4 -6 D. Population Characteristics of the Protected Classes,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 4 -7 1. Race /Color :• 2. Sex (of Householder) ......................................................................... ...........................4 -16 3. National Origin/ Ancestry .................................................................... ...........................4 -17 4. Familial Status ................................................................................. ............................... 4 -19 5. Handicap / Disability .............................................................................. ...........................4 -20 6. Marital Status ................................................................................... ............................... 4 -23 E. Household Income Characteristics ...................................................... ............................... 4 -23 Median Household Income 4 -23 ............................................................. ............................... Areas of Low /Moderate Income Concentration 4 -27 Attachment A- Definitions of Housing and Population Characteristics and Census Boundaries 4 -29 10 List of Tables 4 -1 Orange County Population by Race and Ethnicity - 2000 and 2007 . ............................... 4 -4 4 -2 Components of Population Change by Race and Ethnicity - 2000 and 2007,,,,,,,,,,,,,,,,, 4 -5 4 -3 County of Orange Population and Race Projections 2000 to 2030 ... ............................... 4 -6 4 -4 Regional Analysis of Fair Housing Impediments - Characteristics of the Protected 17 Classes................................................................................................... ............................... 4 -8 4 -5 Orange County Population by Hispanic /Latino and Race - 2000 and 2008,,,,,,,,,,,,,,,,,, 4 -11 4 -6 Regional Analysis of Fair Housing Impediments - Areas of Minority Population Concentrations Number Census Tracts by City/ Area - 2000,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,4 -14 4 -7 Regional Analysis of Fair Housing Impediments - List and Characteristics of Split Census Tracts with 80.1 %+ Minority Population ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,4 -15 4 -8 Regional Analysis of Fair Housing Impediments - Estimated Sex of Householder — 2008 ...................................................................................................... ............................... 4 -17 4 -9 Orange County - Place of Birth and National Origin - 2008 ................. ...........................4 -18 4 -10 Orange County - City of Residence of Foreign Born Population from Asia and Latin America - 2008 ...................................................................................... ............................... 4 -18 4 -11 Regional Analysis of Fair Housing Impediments - Disabled Population for Entitlement Cities - 2008 4 -22 4 -12 Regional Analysis of Fair Housing Impediments - Median Household Income in 1999 Dollars by Race /Ethnicity of Householder Entitlement Cities - 2000,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,4 -25 4 -13 Regional Analysis of Fair Housing Impediments - Median Household Income in 1999 Dollars by Race /Ethnicity of Householder Urban County Cities - 2000 .........................4 -26 4 -14 Regional Analysis of Fair Housing Impediments - Number of Census Tract Block Groups by City /Location and Percent Low /Mod - 2000 ...................................... ...........................4 -28 17 Table of Contents Section 5 Regional Private Sector Fair Housing Analysis A. Housing Discrimination ............................................................................. ............................5 -1 1. Prohibited Housing Discrimination Practices,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 5 -1 2. Discrimination Complaints .................................................................. ............................5 -3 3. Housing Discrimination Complaint Services ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -10 4. Actions to be Taken 5 -10 ......................................................................... ............................... B. Discriminatory Advertising.. ..................................................................... ...........................5 -11 C. 1. Background ......................................................................................... ...........................5 -11 2. Review of Print Ads and Online Advertising,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 5 -12 3. Examples of Possible Advertising Impediments.......................................................... 5 -14 4. Fair Housing Notices .......................................................................... ...........................5 -18 5. Internet Advertising .............................................. ............................... ...........................5 -18 6. Actions to be Taken 5 -20 ......................................................................... ............................... 1. Background ......................................................................................... ...........................5 -20 2. Actions to be Taken 5 -21 ......................................................................... ............................... D. Denial of Reasonable Accommodations 5 -22 ............................................. ............................... 1. Background ......................................................................................... ...........................5 -22 2. Actions to be Taken 5 -22 ......................................................................... ............................... E. Hate Crimes 5 -22 ........................................................................................... ............................... 1. Background ......................................................................................... ...........................5 -22 2. Hate Crime Events 5 -23 .......................................................................... ............................... 3. Actions to be Taken 5 -27 F. Unfair Lending ...................................................................................... ............................... 5 -28 1. Fair Housing Act, Equal Credit Opportunity Act and the California Holden Act,,,,,,, 5 -28 2. Underwriting, Marketing and Price Discrimination ........................... ...........................5 -29 3. Home Mortgage Disclosure Act,, ,,,,,.. ........................ ......... ......... ............ 5 -30 4. Analysis of 2008 HMDA Data,,,, ......... ......... ......... ......... .......... 5 -30 5. Actions to be Taken ......................................................................... ............................... 5 -38 Attachment A- California Newspaper Publishers Association Guidance on Advertising Words and Phrases ..................................................................... ............................... 5 -40 Attachment B -Hate Crime Glossary ................................................................... ...........................5 -43 12 List of Tables 5 -1 Regional Analysis of Fair Housing Impediments - Housing Discrimination Cases Filed by Year 5 -4 .......................................................................................................... ............................... 5 -2 Regional Analysis of Fair Housing Impediments - Housing Discrimination Cases Closed byYear ....................................................................................................... .............................5. 5 -3 Regional Analysis of Fair Housing Impediments - Housing Discrimination Cases Filed by Bases 2005 -2009 for Entitlement Cities 5 -7 5 -4 Regional Analysis of Fair Housing Impediments - Housing Discrimination Cases Filed by Bases 2005 -2009 for Urban County Cities ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -8 5 -5 Regional Analysis of Fair Housing Impediments - Housing Cases Filed By Alleged Act — 2005 -2009 5 -10 5 -6 Regional Analysis of Fair Housing Impediments - Number of Apartment Complexes Publishing For Rent Ads by Jurisdiction (Apartment.com) — January 2010,,,,,,,,,,,,,,,,,,,,5 -13 5 -7 Analysis of Rental Ads in Entitlement Cities Orange County Register January2010 ............................................................................................. ...........................5 -15 5 -8 Analysis of Rental Ads in Urban County Cities Orange County Register January2010 ............................................................................................. ...........................5 -16 5 -9 Regional Analysis of Fair Housing Impediments - Number of Hate Crime Events by Jurisdiction /City -2004 to 2008. ................................................................. ...........................5 -24 5 -10 State of California Hate Crimes Events and Bias Motivation 5 -25 ............ ............................... 5 -11 Hate Crimes in Orange County 2007 and 2008,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -26 5 -12 State of California Location of Hate Crimes- 2004 to 2008 5 -27 5 -13 HMDA Census Tract Income Categories —2008 .............................................................. 5-32 5 -14 Orange County - Disparities in FHA Loan Denial Rates by Income Group and Race /Ethnicity — 2008 ............................................................... ............................... 5 -15 Orange County - Disparities in Conventional Loan Denial Rates by Income Group and Race /Ethnicity — 2008 ................................................................................ ...........................5 -33 5 -16 Orange County - Denial Rates for Neighborhoods with 20 % -79% Minority Populations by Income Level of Census Tracts — 2008,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -35 5 -17 Analysis of Maximum Likelihood Estimates ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -37 19 Table of Contents Section 6 Public Sector Fair Housing Analysis A. Introduction 6 -1 .............................................................................................. ............................... B. Description of Housing Authority Fair Housing Policies ..................... ............................... 6 -2 1. Fair Housing Policies of Housing Authorities,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 6 -2 2. Section 8 Housing Policies on Reasonable Physical Modifications and Reasonable Accommodations 6 -6 3. Fair Housing and Lead Based Paint,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 6 -7 C. Description of City and County Public Sector Impediments ............... ............................... 6 -9 1. Public Sector Impediments Common to Most Participating Jurisdictions,,,,,,,,,,,,,,,,, 6 -11 2. City Identified Public Sector Impediments,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 6 -15 D. Actions to be Taken by the FHCOC and City to Ameliorate or Eliminate Public Sector Impediments............................................................................................. ...........................6 -16 1. Actions to be Taken by FHCOC ........................................................ ...........................6 -16 2. Actions to be Taken by the City .................................................... ............................... 6 -16 Attachment A - Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice .................................................................... ...........................6 -17 Attachment B — City of La Habra — Reasonable Accommodations in Housing to Disabled Individuals 6 -34 ........................................................................................................... ............................... Attachment C — City of La Habra — Special Needs Housing ......................................................... Attachment D — City of San Francisco — Fair Housing Implementation Ordinance,,,,,,,,,,,,,,,,,,, 6 -47 List of Charts 6 -1 Orange County Regional Analysis of Impediments to Fair Housing Choice Topics Included in the Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice ...... ...........................6 -10 20 Table of Contents Section 7 AFFH Through the Location of Affordable Housing A. Background ........................................................................................... ............................... 7-1 B. Data Sources 7 -2 C. Analysis of the Location of the Affordable Housing Inventory ........... ............................... 7 -3 1. Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Minority Populations ............................................................. ............................... 7 -3 2. Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Minority Populations ........................................................... ............................... 7 -11 3. Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Low Income Populations ....................................................... ...........................7 -14 4. Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Low Income Populations ........................ ............................... ...........................7 -14 D. Analysis of the Location of the Section 8 Housing Inventory ........... ............................... 7 -19 1. Garden Grove Housing Authority ( GGHA),,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,7 -19 2. Santa Ana Housing Authority (SAHA)...... ......... ......... ......... .......... 7 -21 3. Anaheim Housing Authority ( AHA) ..................................................... ...........................7 -24 4. Orange County Housing Authority ( OCHA) .................................. ............................... 7 -24 E. Actions to be Taken 7 -28 .............................................................................. ............................... Attachment A- Census Tracts with 80 %+ Minority Populations ................... ............................... 7 -29 Attachment B- Affordable Housing Inventory Arranged by Census Tract ... ............................... 7 -32 21 List of Tables 7 -1 Regional Analysis of Fair Housing Impediments - Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Minority Populations - 2010,,,,,,,,,,,, 7 -5 7 -2 Regional Analysis of Fair Housing Impediments - Census Tracts with a High Percentage of Affordable Housing Units ..................................................................... ............................7 -7 7 -3 Regional Analysis of Fair Housing Impediments - Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Minority Populations - 2010,,,,,,,,,,, 7 -12 7 -4 Regional Analysis of Fair Housing Impediments - Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Low Income Populations — 2010 7 -15 ....................................................................................................... ............................... 7 -5 Regional Analysis of Fair Housing Impediments - Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Low Income Populations — 2010 7 -16 ....................................................................................................... ............................... 7 -6 Garden Grove Housing Authority — Section 8 Assisted Families by City,,,,,,,,,,,,,,,,,,,,,,, 7 -19 7 -7 Garden Grove Housing Authority — Number of Section 8 Housing Units Located in Census Tracts with a High Percentage ( >80 %) of Minority Populations ....................... 7 -20 7 -8 Santa Ana Housing Authority — Section 8 Assisted Families by Census Tract,,,,,,,,,,,,, 7 -21 7 -9 Santa Ana Housing Authority — Number of Section 8 Housing Units Located in Census Tracts with a High Percentage ( >80 %) of Minority Populations ....................... 7 -23 7 -10 Orange County Housing Authority — Section 8 Assisted Families by Entitlement City, 7 -25 7 -11 Orange County Housing Authority — Section 8 Assisted Families by Urban CountyCity ............................................................................................... ...........................7 -25 7 -12 Orange County Housing Authority — Number of Section 8 Housing Units Located in Census Tracts with a High Percentage ( >80 %) of Minority Populations ....................... 7 -26 7 -13 Orange County Housing Authority — Number of Section 8 Housing Units Located in Census Tracts with a Low Percentage ( >20 %) of Minority Populations ........................ 7 -27 22 Technical Appendix A Orange County Fair Housing Community Profile List of Tables A -1 Regional Analysis of Fair Housing Impediments - Entitlement Cities - Year 2010 Population Estimates by City ................................................................... ............................A -1 A -2 Regional Analysis of Fair Housing Impediments - Urban County - Year 2010 Population Estimatesby City ...................................................................................... ............................A -2 A -3 Regional Analysis of Fair Housing Impediments - Entitlement Cities - Population Growth April 1, 1990, April 1, 2000 and January 1, 2010,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,A -3 A -4 Regional Analysis of Fair Housing Impediments - Urban County - Population Growth April 1, 1990, April 1, 2000 and January 1, 2010,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,A -4 A -5 Regional Analysis of Fair Housing Impediments - Entitlement Cities - Year 2010 Housing SupplyEstimate by City ........................................................................... ............................A -5 A -6 Regional Analysis of Fair Housing Impediments - Urban County - Year 2010 Housing SupplyEstimate by City ........................................................................... ............................A -6 A -7 Regional Analysis of Fair Housing Impediments - Entitlement Cities - Housing Supply Growth April 1, 1990, April 1, 2000 and January 1, 2010, ................................................. A -7 A -8 Regional Analysis of Fair Housing Impediments - Urban County - Housing Supply Growth April 1, 1990, April 1, 2000 and January 1, 20101 ................................................. A-8 A -9 Orange County Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities A -9 A -10 Orange County Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban County Cities ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,A -13 A -11 Regional Analysis of Fair Housing Impediments - Household Type for Entitlement Cities —2008 A -17 ................................................................................................... ............................... A -12 Regional Analysis of Fair Housing Impediments - Household Type for Urban County Cites — 2008 A -18 A -13 Regional Analysis of Fair Housing Impediments - Households with Children under 18 Years of Age by Type of Household Entitlement Cities — 2008 ...... ............................... A -19 A -14 Regional Analysis of Fair Housing Impediments - Households with Children under 18 Years of Age by Type of Household Urban County Cities — 2008,, A -20 A -15 Regional Analysis of Fair Housing Impediments - Poverty Rates for Female Householders and Presence of Children for Entitlement Cities — 2008 A -21 ......................... 23 A -16 Regional Analysis of Fair Housing Impediments -Poverty Rates for Female Householders and Presence of Children for Urban County Cities — 2008,,,,,,,,,,,,,,,,,,,, A -22 A -17 Regional Analysis of Fair Housing Impediments - Marital Status for Entitlement Cities — 2008 A -23 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A -18 Regional Analysis of Fair Housing Impediments - Marital Status for Urban County - 2008 M4i Technical Appendix D 2008 Home Mortgage Disclosure Act Data for Orange County List of Tables D -1 Orange County - Disposition of Loan Applications by Race /Ethnicity — 2008 .................D -1 D -2 Orange County - Disposition of FHA Loan Applications by Race /Ethnicity -2004 and 2008 ................................................................................................. ............................... D -3 D -3 Orange County - Disposition of Conventional Loan Applications By Race /Ethnicity-2004 and 2008 ................................................................. ............................D -4 D -4 Orange County - FHA/VA Denial Rates by Income and Race /Ethnicity — 2008 .............D -5 D -5 Orange County - Conventional Denial Rates by Income and Race /Ethnicity — 2008 ..... D -7 D -6 Orange County - Disposition of FHA Loans by Characteristics of Census Tract in Which Property is Located — 2008............ ............................................... ............................D -9 D -7 Orange County - Disposition of Conventional Loans by Characteristics of Census Tract in Which Property is Located — 2008 ............................................ ...........................D -10 D -8 Orange County Reasons for Loan Denial by Race /Ethnicity — 2008... ..... ......................D -11 25 Technical Appendix E Loan Denial Rates for Census Tracts with a High Number of Loan Applications List of Tables E -1 Entitlement Cities - FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 .......................................................................... ............................... E -1 E -2 Entitlement Cities - Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 .......................................................................... ............................... E -3 E -3 Urban County Cities - FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 .......................................................................... ............................... E -8 E -4 Urban County Cities - Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 .......................................................................... ............................... E -9 20 Technical Appendix F FHA and Conventional Loan Denial Rates by City and Census Tract List of Tables F -1 Entitlement Cities - FHA Loan Application Denial Rates by City and Census Tract — 2008 F -1 .............................................................................. ............................... F -2 Entitlement Cities - Conventional Loan Application Denial Rates by City and Census Tract — 2008 F -13 ............................................................................ ............................... F -3 Urban County Cities - FHA Loan Application Denial Rates by City and Census Tract — 2008 F -4 Urban County Cities - Conventional Loan Application Denial Rates by City and Census Tract — 2008 F -32 ............................................................................ ............................... 27 This Page Intentionally Left Blank 22 Section 1 Introduction & Summary ?9 SECTION 1 INTRODUCTION A. AFFIRMATIVELY FURTHERING FAIR HOUSING (AFFH) CERTIFICATION An Affirmatively Furthering Fair Housing (AFFH) certification is required of communities that administer the following U.S. Department of Housing and Urban Development (HUD) Community Planning and Development (CPD) programs: • Community Development Block Grants (CDBG) • Home Investments Partnership Program (HOME) • Emergency Shelter Grants (ESG) • Housing Opportunities for People with AIDS Program (HOPWA) The AFFH certification states that the community receiving HUD funds: "...will affirmatively further fair housing ... by conducting an analysis to identify impediments to fair housing choice within its jurisdiction, taking appropriate actions to overcome the effects of any impediments identified through the analysis, and maintaining records reflecting the analysis and actions in this regard." The certification is included in the Consolidated Plans and Action Plans that are submitted to HUD by Orange County's Entitlement Cities and the Urban County Program. HUD interprets the board objectives of the AFFH obligation to mean: • Analyze and eliminate housing discrimination in the jurisdiction. • Promote fair housing choice for all persons. • Provide opportunities for inclusive patterns of occupancy regardless of race, color, religion, sex, familial status, disability and national origin. • Promote housing that is structurally accessible to, and usable by, all persons, particularly persons with disabilities. • Foster compliance with the nondiscrimination provisions of the Fair Housing Act. The first requirement of the AFFH certification is satisfied by the following: • Conducting an analysis of impediments to fair housing choice. This is commonly called the AI. • Identify appropriate actions to overcome the effects of identified impediments. This is accomplished through preparation of a fair housing action plan. It is the responsibility of the Entitlement Cities and Urban County Program to "take' the actions identified in the fair housing action plan and to "maintain records on the actions taken ". 30 HUD's Consolidated Plan Review Guidance (i.e., Checklist) explains that the following guidance should be used by HUD CPD representatives to determine if the Certification is not satisfactory: Disregard of regulatory requirements to conduct an analysis of impediments to fair housing choice, take appropriate actions to address identified impediments, or maintain adequate records on the steps taken to affirmatively further fair housing in the jurisdiction. • Lack of action taken on outstanding findings regarding performance under affirmatively furthering fair housing certification requirements of the Consolidated Plan or the Community Development Block Grant Program. More specifically, HUD has issued the following guidance: HUD can require the submission of an Al in the event of a complaint or as part of routine monitoring. If, after reviewing all documents and data, HUD concludes that (1) the jurisdiction does not have an Al; (2) an AI was substantially incomplete; (3) no actions were taken to address identified impediments; (4) the actions taken to address identified impediments were plainly inappropriate; or (5) the jurisdiction has no records the Department would notify the jurisdiction that it believes the certification to be in- accurate, or, in the case of certifications applicable to the CDBG program, the certification is not satisfactory to the Secretary. Source: Memorandum from Nelson R. Bregon, General Deputy Assistant Secretary for Community Planning and Development to CPD Office Directors, FHEO HUB Directors, FHEO Program Center Directors and FHEO Equal Opportunity Specialists, September 2, 2004, page 2 HUD also has stated: Rejection of the certification provides the basis for HUD to disapprove the jurisdiction's Consolidated Plan. Source: U.S. Department of Housing and Urban Development, Office of Community Planning and Development, Fair Housing for HOME Participants, May 2005, page 1 The way HUD determines compliance with the AFFH Certification is through a review of each entitlement city's and the Urban County's Consolidated Plan Annual Performance and Evaluation Report (CAPER). In the CAPER, the entitlement city and Urban County submit a narrative statement on actions taken to affirmatively further fair housing during the prior program year (July 1 to June 30). HUD has issued the following guidance: Once the jurisdiction completes the Al, it must report on its implementation by summarizing the impediments identified in the analysis and describing the actions taken to overcome the effects of the impediments identified through the analysis in its Consolidated Annual Performance and Evaluation Report (CAPER). Although Als are not submitted or approved by HUD, each jurisdiction should maintain its Al and update 31 the Al annually where necessary. Jurisdictions may also include actions the jurisdiction plans to take to overcome the effects of impediments to fair housing choice during the coming year in the Annual Plan that is submitted as part of the Consolidated Plan submission. Source: Memorandum from Nelson R. Bregon, General Deputy Assistant Secretary for Community Planning and Development to CPD Office Directors, FHEO HUB Directors, FHEO Program Center Directors and FHEO Equal Opportunity Specialists, September 2, 2004, page 2 B. MEANING AND SCOPE OF FAIR HOUSING IMPEDIMENTS What is an impediment? According to HUD, impediments are -- Any actions, omissions, or decisions taken because of race, color, religion, sex, disability, familial status, or national origin which restrict housing choices or the availability of housing choices. (Intent) Any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices because of race, color, religion, sex, disability, familial status, or national origin. (Effect) A lack of affordable housing in and of itself, HUD has pointed out, is not an impediment to fair housing choice, unless it creates an impediment to housing choice because of membership in a protected class. Impediments may exist due to one or more of the following: • Saying or doing something openly discriminatory. • Treating some people differently than others because of their protected class. • A policy that on its face seems neutral, but has a disparate impact on members of a protected class. There are two types of impediments — private and public impediments. The nature and scope of private sector impediments are essentially actions or practices that are prohibited by the following fair housing laws: • 1968 Federal Fair Housing Act • 1974 Federal Equal Credit Opportunity Act • 1980 State Fair Employment and Housing Act • 1959 Unruh Civil Rights Act • 1977 Housing Financial Discrimination Act These laws prohibit housing discrimination, discriminatory advertising, blockbusting, steering, denial of reasonable accommodations, redlining, and other unlawful practices. 32 California's Fair Employment and Housing Act states it is unlawful: To discriminate through public or private land use practices, decisions, and authorizations because of race, color, religion, sex, sexual orientation, familial status, marital status, disability, national origin, source of income, or ancestry. Discrimination includes, but is not limited to, restrictive covenants, zoning laws, denials of use permits, and other actions authorized under the Planning and Zoning Law (Title 7 (commencing with Section 65000)), that make housing opportunities unavailable. Examples of public sector impediments include a definition of "family" inconsistent with fair housing laws, conditional use permit requirements for housing for the disabled, and the lack of a reasonable accommodation procedure. C. PARTICIPANTS IN THE REGIONAL Al The lead agency for preparation of the Regional Al is the Fair Housing Council of Orange County ( FHCOC). Under contract to 15 Entitlement Cities and the Urban County Program, FHCOC provides fair housing services and tenant/landlord counseling services to the residents of Orange County. The FHCOC - a nonprofit organization - has been serving Orange County residents since 1965. The FHCOC also was the lead agency for the preparation of the 2000- 2005 and 2005 -2010 Regional Als. The key rationale for preparation of a Regional AI is that private sector impediments are regional in nature and affect multiple communities — that is, they are not limited to a single jurisdiction responsible for AFFH. During HUD's Affirmatively Furthering Fair Housing webcast on July 22, 2009 several participants supported the concept of addressing the AFFH certification through a regional approach, although specific models were not discussed during the webcast. The FHCOC has a wealth of experience in dealing with fair housing impediments that occur in the private sector. HUD guidance indicates that the Regional Al must describe appropriate actions to overcome the effects of the private sector impediments that are identified through the analysis. The FHCOC understands the private sector and is well equipped to analyze impediments, describe appropriate actions, and to follow- through on those actions. The Regional Al also identifies the public sector impediments to fair housing choice and describes the actions that participating cities and the Urban County will take to reduce and ameliorate these impediments. Some of the public impediments were first identified in 2008 and 2009 in the housing element updates of each jurisdiction. According to State law, each jurisdiction must adopt a housing element as part of its General Plan. A housing element must analyze constraints on housing for disabled persons and include a program for providing equal housing opportunity. The Entitlement Cities and the Urban County Program will continue to maintain records and report annually on the actions taken to overcome the public sector impediments. 33 The following jurisdictions participated in the preparation of the Regional Al: Entitlement Cities • Anaheim • Buena Park • Fountain Valley • Fullerton • Garden Grove • Huntington Beach • Irvine • La Habra • Lake Forest • Newport Beach • Orange • Rancho Santa Margarita • Santa Ana • Westminster Urban County Unincorporated County Target Areas, Urban County Program • Aliso Viejo • Brea • Cypress • Dana Point • La Palma • Laguna Beach • Laguna Hills • Laguna Woods • Los Alamitos • Placentia • Seal Beach • Stanton • Villa Park • Yorba Linda Non - Participating Jurisdictions • Costa Mesa • Laguna Niguel • Mission Viejo • San Clemente • San Juan Capistrano • Tustin The scope of work for the Regional Al was developed by the FHCOC in coordination with the Los Angeles Office of the U.S. Department of Housing and Urban Development (HUD -LA). HUD -LA and the FHCOC identified the types of private sector impediments that should be investigated in the Regional Al. The scope of work was developed in part with the Mil understanding that the FHCOC would take the lead for taking actions to ameliorate or eliminate the identified private sector impediments, given adequate support from participating jurisdictions. Additionally, the scope of work incorporated the identification of public sector impediments by each city participating in the Regional Al. Each participating jurisdiction completed a survey of planning and zoning practices that may affect fair housing choices, particularly by disabled persons. The "Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice" was prepared by the FHCOC and approved by HUD -LA. Each jurisdiction participating in the Regional Al completed the 24 question survey and self identified planning and zoning impediments and the actions that would be taken to ameliorate and eliminate the impediments. D. CITIZEN PARTICIPATION HUD has stated that because fair housing planning is a component of the Consolidated Plan, the citizen participation requirements for the Consolidated Plan (24 CFR 91) applies to the preparation of the AI and Fair Housing Action Plan. Source: U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Fair Housing Planning Guide, Volume 1, March 1996, page 4 -3 The major effort undertaken by the Fair Housing Council of Orange County to obtain citizen participation was the completion of a fair housing survey. The purpose of the survey was to obtain resident opinions on housing discrimination. Respondents, for instance, were asked whether they thought housing discrimination exists in Orange County and to give examples of discriminatory practices. Additionally, information was obtained on the characteristics of the respondents in order to compare them to those of Orange County's entire population. The survey respondents differ from Orange County's population. For example, the percentage of respondents having families with children was much higher compared to the Orange County percentage. The disability rate among the survey respondents was twice as high as that of the Orange County population. And a lower percentage of respondents belonged to a minority population compared to the Orange County population characteristics. Table 1 -1 on the next page shows the comparison data. Overall, about 47% of the respondents believe there is housing discrimination in Orange County. A higher percentage (58 %) of the minority population compared to the non - minority population (40 %) believes there is housing discrimination in Orange County. Table 1 -2 shows the responses to the question Do you believe that there is housing discrimination in Orange County? 35 Table 1 -1 Regional Analysis of Fair Housing Impediments Survey Comparison to 2009 American Community Survey Question /Reponses Survey Percentage ACS Percentage 1. What is your family status ?' Non - Minority Have Children 60.2% 37.6% Do not have children 39.8% 62.4% 2. Does anyone in your household have a disability?' 5 Yes 14.0% 7.3% No 86.0% 92.7% Minority Status' 40.0% Yes 40.9% 54.7% No 59.1% 45.3% Tenure Status (Excluding Homeless' Own 38.5% 60.1% Rent 61.5% 38.5% 'American Community Survey 1 -Year Estimates 2009, Selected Social Characteristics, Selected Demographic Characteristics, and Selected Housing Characteristics Table 1 -2 Regional Analysis of Fair Housing Impediments Resident Survey Results- Question #3 and #7 Cross Tab Do you believe that there is housing discrimination in Orange County? Answer Options Minority Percent Non - Minority Percent Yes 22 57.9% 22 40.0% No 5 13.2% 11 20.0% Unsure 11 28.9% 22 40.0% Total 38 100.0% 55 100.0% so Table 1 -3 shows the complete survey results. Among the key findings are: • Half of the respondents stated they were "very well informed" or "somewhat informed" about housing discrimination. • Almost 32% of the respondents stated they or someone they know has encountered housing discrimination. • The two most common examples of housing discrimination cited by the respondents were "housing provider refuses to rent or deal with a person," and "different terms and conditions ". • Only 8% of those that believed they encountered housing discrimination reported the incident. • However, almost 47% of the respondents stated they would report housing discrimination if they encountered it in the future. The survey results indicate that a sizeable proportion of the population is "informed" about housing discrimination. Moreover, the general public recognizes examples of discriminatory practices. And in the future more people would report housing discrimination than they have in past. Although the number of survey responses is limited, it appears that a large share of the public are willing to report housing discrimination to agencies such as the Fair Housing Council of Orange County which indicates a continuing need for processing of discrimination complaints. 37 Table 1 -3 Regional Analysis of Fair Housing Impediments Fair Housing Survey Summary 1. What is your family status? Have Children Do not have children 2. Does anyone in your household have a disability Yes No 3. The U.S. Census Bureau considers the following to be "minority groups ": Black, Hispanic, Asian, Pacific Islander, or American India /Alaska Native. Response ercenta a Response Count Answered Question Skipped Question 1 own a home 93 0 60.2% 56 60.2% 39.8% 37 0.0% 0 93 0 14.0 %0 13 5. What is your income level? 86.0% 1 80 4. What type of housing do you currently have? 93 0 1 own a home 37.6% 35 1 rent 60.2% 56 1 live in a hotel /motel 0.0% 0 1 am homeless 2.2% 2 5. What is your income level? 93 0 High Income 9.6% 9 Medium Income 45.2% 42 Low Income 45.2% 42 6. In which Orange County City do you live? Top 5 93 0 Anaheim 6.5% 1 6 Newport Beach Subtotal 7. Do you believe there is housing discrimination in Orange County? Yes No Unsure 10.8% 10 74.4% 69 47.3% 44 17.2% 16 35.5% 33 931 01 3g Table 1 -3 - continued Orange County Regional Fair Housing Impediments Analysis Resident Survey Results Question /Reponses Response Percentage Response Count Answered Question Skipped Question 8. Do you believe that there is housing discrimination in the Orange County city in which you current) /previous) reside? 93 0 Yes 34.4% 32 No 28.0% 26 Unsure 37.6% 35 9. Have you or someone you know ever encountered any forms of housing discrimination described above? Check all that app) 64 29 Yes, I have 15.8% 12 76 total responses 1 think I may have 6.6% 5 No, I have not 30.3% 23 Yes, I know someone who has 15.8% 12 1 think I may know someone who has 2.6% 2 No, I don't know someone who has 19.7% 15 1 don't know 9.2% 7 10. (See examples above) If you believe or think that someone you know encountered housing discrimination, please check the type in the list at the beginning of this page. (Check all that apply). 64 29 A. Housing provider refuses to rent or deal with a person 20.0% 11 55 examples were given by 34 respondents; N/A was stated by 30 respondents B. Housing provider falsely denies that housing was available 10.9% 6 C. Housing provider refuses to make reasonable accommodations for a tenant with one or more disabilities 10.9% 6 D. Housing provider uses discriminatory advertising 10.9% 6 E. Real estate agent refuses to sell or deal with a person 3.6% 2 F. Real estate agent direct persons to certain neighborhoods 7.3% 4 G. Housing mortgage lender discriminates by denying mortgage 7.3% 4 H. Housing lender directs persons to certain neighborhoods 3.6% 2 I. Different terms and conditions 18.2% 10 Other please specify) 7.3% 4 N/A 30 39 Table 1 -3 - continued Orange County Regional Fair Housing Impediments Analysis Resident Survey Results Question /Reponses Response Percentage Response Count Answered Question Skipped Question 11. If you believe you have encountered any form of housing discrimination in question #10 did you report it? 58 35 Yes 3.4% 2 No 39,7% 23 N/A 56.9% 33 12. How well informed are you about housing discrimination 64 29 Very well informed 25.0% 16 Somewhat informed 25.0% 16 A little informed 21.9% 14 Not informed at all 28.1% 18 13. What would you do if you encountered housing discrimination? 64 29 Do nothing and seek other housing options 10.9% 7 Less than 100% due to rounding Tell the person that you believe they are discriminating 23.4% 15 Report it 46.9% 30 Would not know what to do 17.2% 11 Other option 1.6% 1 ION E. REPORT FORMAT Besides this Introduction, the Report includes the following Sections: Section 2 — Fair Housing Progress Report: The prior Analysis of Impediments to Fair Housing Choice contained actions that would be taken during the 2005 -2010 time period. Section 2 describes the actions taken during the past five years to eliminate or ameliorate the identified impediments. Section 3 — Fair Housing Action Plan: This Section presents a new multi -year Fair Housing Action Plan. There are two impediment categories — public sector and private sector impediments. A summary description is given of each identified impediment. The actions the FHCOC plans to undertake to overcome the private sector impediments are described in the Fair Housing Action Plan. Additionally, actions to be taken by the Entitlement Cities and Urban County are described in Section 3. Finally, actions are described to address affirmatively furthering fair housing through the location of affordable housing. Section 4 — Fair Housing Community Profile: This Section presents demographic information on housing and population characteristics, population growth in Orange County, the protected classes, and household income for different racial groups and Hispanic households. Section 5 — Private Sector Fair Housing Analysis: This Section presents information on the following private sector impediments: housing discrimination, discriminatory advertising, blockbusting, denial of reasonable accommodations or modifications, hate crimes and unfair lending. Section 6 - Public Sector Fair Housing Analysis: This Section summarizes the public sector impediments. These impediments were identified through a survey 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. The survey 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. 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. Section 7 — AFFH Through the Location of Affordable Housing: A lack of affordable housing in and of itself, HUD has pointed out, is not an impediment to fair housing choice, unless it creates an impediment to housing choice because of membership in a protected class. However, recent court cases and recent events have demonstrated that the location of affordable housing is regarded as a means of AFFH. This Section presents information on the location of affordable and Section 8 housing in census tracts with a high and low percentage of minority populations. Additionally, the location of affordable and Section 8 housing is analyzed in terms of the income characteristics of the census tracts. Fiji" In addition, the Al contains seven Technical Appendices: Technical Appendix A - Orange County Fair Housing Community Profile Technical Appendix B - Minority Population by Census Tract Technical Appendix C - Low Income Population by Census Tract and Block Group Technical Appendix D - 2008 Home Mortgage Disclosure Act Data for Orange County Technical Appendix E - Loan Denial Rates for Census Tracts with a High Number of Loan Applications Technical Appendix F - FHA and Conventional Loan Denial Rates by City and Census Tract Technical Appendix G — Completed Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice F. PROTECTED CLASSES The Federal and State fair housing laws prohibit discrimination against certain categories of people. These categories are referred to as "protected classes." Attachment A provides definitions for the following protected classes: Federal and State "Protected Classes" • Race • Color • Sex • National Origin • Religion • Familial Status • Handicap /Disability Additional State of California "Protected Classes' • Sexual Orientation • Marital Status • Ancestry • Source of Income • Age Fiji" Attachment A Fair Housing Protected Classes Title VIII of the Civil Rights Act of 1968 (Fair Housing Act), as amended, prohibits discrimination in the sale, rental, and financing of dwellings, and in other housing - related transactions, based on race, color, national origin, religion, sex, familial status (including children under the age of 18 living with parents or legal custodians, pregnant women, and people securing custody of children under the age of 18), and handicap (disability). These categories of persons are "protected classes" under the provisions of the Fair Housing Act. Race: The Fair Housing Act does not define race. Data on race is required for many federal programs and the Census Bureau collects race data in accordance with guidelines provided by the U.S. Office of Management and Budget (OMB) and these data are based on self - identification. The racial categories included in the census form generally reflect a social definition of race recognized in this country, and are not an attempt to define race biologically, anthropologically or genetically. In addition, the Census Bureau recognizes that the categories of the race item include both racial and national origin or socio - cultural groups. Census 2010 and the American Community Survey provide for six race categories: White; Black, African American or Negro; American Indian or Alaska Native; Asian; Native Hawaiian or Other Pacific Islander; and Some Other Race. Color: The Fair Housing Act does not define color. However, it must refer to the complexion of a person's skin color or pigmentation. The 2010 racial categories can be traced to Statistical Policy Directive No. 15, promulgated by the OMB on May 12, 1977. "The four racial categories stipulated in the (1977) directive parallel the classic nineteenth - century color designations of black, white, red (American Indian or Alaska native), and yellow (Asian or Pacific Islander); there is no brown race in the American ethnoracial taxonomy." [Victoria Hattam, "Ethnicity & the Boundaries of Race: Re- reading Directive 15," Daedalus, Winter 2005, page 631 Sex: This basis refers to gender identity. California's Fair Employment and Housing Act defines "sex" as including, but not limited to, pregnancy, childbirth, medical conditions related to pregnancy or childbirth and a person's gender, as defined in Section 422.56 of the Penal Code. Government Code Section 12926(p) National Origin: This basis refers to the real or perceived country of an individual's birth, ancestry, language and /or customs. Religion: According to the United States Department of Justice, this prohibition covers instances of overt discrimination against members of a particular religion as well as less direct actions, such as zoning ordinances designed to limit the use of private homes as places of worship. Gm Familial Status: According to Section 802(k) of the Fair Housing Act, as amended, means one or more individuals (who have not attained the age of 18 years) being domiciled with -- (1) a parent or another person having legal custody of such individual or individuals; or (2) the designee of such parent or other person having such custody, with the written permission of such parent or other person. The protections afforded against discrimination on the basis of familial status shall apply to any person who is pregnant or is in the process of securing legal custody of any individual who has not attained the age of 18 years. Handicap (Disability): According to Section 802(h) of the Fair Housing Act, as amended, handicap /disability means - (1) a physical or mental impairment which substantially limits one or more of such person's major life activities, (2) a record of having such an impairment, or (3) being regarded as having such an impairment, but such term does not include current, illegal use of or addiction to a controlled substance (as defined in section 102 of the Controlled Substances Act (21 U.S.C. 802)). California's Fair Employment and Housing Act (FEHA) is the primary state law which prohibits discrimination in the sale, rental, lease negotiation, or financing of housing. The FEHA has five additional protected classes: sexual orientation, marital status, ancestry, source of income and age. Sexual Orientation: The FEHA defines this basis as heterosexuality, homosexuality, and bisexuality. Government Code Section 12926(q) Marital Status: This basis refers to whether a person is married or not. The U.S. Census Bureau has four major "marital status" categories: never married, married, widowed, and divorced. These terms refer to the marital status at the time of the enumeration. The category married includes "married, spouse present" and "married, spouse absent." RZ9 Ancestry: According to the U.S. Census Bureau, ancestry refers to a person's ethnic origin or descent, "roots," or heritage, or the place of birth of the person or the person's parents or ancestors before their arrival in the United States. Some ethnic identities, such as "German" or "Jamaican" can be traced to geographic areas outside the United States, while other ethnicities such as "Pennsylvania Dutch" or "Cajun" evolved in the United States. The intent of the ancestry question is not to measure the degree of attachment the respondent had to a particular ethnicity. For example, a response of "Irish" might reflect total involvement in an "Irish" community or only a memory of ancestors several generations removed from the individual. A person's ancestry is not necessarily the same as his or her place of birth, i.e., not all people of German ancestry were born in Germany. Source of Income: The FEHA defines this basis as lawful, verifiable income paid directly to a tenant or paid to a representative of a tenant. A landlord is not considered a representative of the tenant. Government Code Section 12955(p) Age: Refers to a person's chronological age. Civil Code Section 51.2 et. seq. Ki This Page Intentionally Left Blank in Section 2 Fair Housing Progress Report 47 SECTION 2 FAIR HOUSING PROGRESS REPORT A. INTRODUCTION The 2005 -2010 Regional Al identified seven impediments to fair housing choice. The purpose of the "progress report" is to describe the progress made on eliminating or ameliorating the identified impediments. The 2005 -2010 Regional Al identified the following private and public sector impediments to fair housing choice. 1. Private Sector Impediments Population and local government can't differentiate landlord /tenant issues vs. discrimination 2. Housing, industry discrimination: zoning, insurance, appraisals, advertising 3. "Color" blind policy causes disparate impact (i.e., credit scores in determining a person's insurability and occupancy restrictions. 4. Employer's lack of support for affordable housing results in segregated housing. 5. High loan denial rates are x3 among upper income Blacks and x2 for equally situated Hispanics. 2. Public Sector Impediments Community Reinvestment Act (CRA) funds are not targeted in ways assisting low income persons and neighborhoods in home ownership and financial stability. (Refer to pages 2 -5 and 2 -6 for an explanation of the CRA.) 2. Some jurisdictions underestimate the extent of discrimination, therefore reducing or not paying fair share of services provided by FHCOC. B. PROGRESS ON ELIMINATING OR AMELIORATING IMPEDIMENTS The following pages describe the nature of the fair housing impediments identified in the 2005- 2010 Regional Al and the progress made in eliminating or ameliorating the adverse impacts caused by the impediments. 1. Confusion among Residents, Housing Providers and Local Government Officials Regarding the Protection Provided by Fair Housing Laws (both State and Federal) Laws regarding landlord and tenant relationships are not covered in State or Federal Fair Housing Laws but are frequently confused by industry professionals, residents and government officials with fair housing. Gaining knowledge of the differences between fair housing laws and tenant/landlord laws is a continuing process. It is necessary for people engaged in real estate transactions and apartment management to have knowledge of fair housing laws. ■ The State Department of Real Estate (DRE) requires real estate brokers and salespersons to complete DRE- approved continuing education including a course on fair housing. The Apartment Association of Orange County (AAOC) represents and supports apartment owners, managers and suppliers. Since 1961, the AAOC has been a major resource for anyone involved in the rental housing industry in Orange County. The AAOC helps it members to stay continually informed on fair housing. The AAOC, for instance, conducts fair housing seminars to educate its members. The AAOC also conducts a Certified Housing Provider Program for apartment owners, property supervisors and resident managers. A review of fair housing laws is one part of this program. With respect to tenant /landlord issues, the California Department of Consumer Affairs has published a 108 -page Guide to Residential Tenant's and Landlords" Rights and Responsibilities. The Guide offers information on a variety of subjects such as rental agreements and leases, landlord disclosures, evictions, and problem resolution. Many cities make this Guide available to the public at the planning or community development department counter. Additionally, the California Apartment Association has published Renting: A User Manual, a 16 -page guide for renters which discusses topics such as Tips for Renters, Moving In, Moving Out, and Rights and Responsibilities. In order to increase public knowledge, the FHCOC has posted on its website a 16 -page Landlord - Tenant Frequently Asked Questions, which provides useful information about the rights and obligations of tenants and landlords. The FAQ discusses important topics such as security deposits, failure to deliver a habitable rental unit, and terminating the tenancy. Although no studies have been completed in Orange County, HUD sponsored studies have shown that the general public has a basic awareness of the nature and scope of fair housing laws. According to a recent study: Both the 2000/1 and 2005 surveys posed a series of scenarios depicting actions taken by rental building owners, a home seller, a real estate agent and mortgage lenders, which might or might not have been discriminatory. Respondents were asked, first, if they agreed with each action and, second, if they believed it to be legal under Federal law. Steps were taken to protect against the scenarios and questions being too test -like, obvious, or patterned. The 2005 survey reveals that for five of the eight scenarios portraying discriminatory behavior under Federal law there is essentially no change in the extent of public knowledge since 2000/1. In a sixth scenario involving use of the words "Christians preferred' in advertising an apartment, fewer people in 2005 than in 2000/1 were aware of the fact that this is unlawful. For the remaining two scenarios —one involving a real estate agent restricting a client's housing search to geographical areas based on racial concentration, and the other an apartment owner restricting a family to a particular building because they had children —more people are aware in 2005 than were aware in 2000/1 that these actions are illegal. When all responses to scenarios depicting illegal actions are summed to create an index representing the number each respondent correctly identified as illegal, there is no difference in the distribution of scores observed in 2005 compared to 2000/1. In both cases, about one -half of the public knew the law with respect to six or more of the scenario depictions. While knowledge of fair housing law may not have expanded since the baseline survey, public support for it has. On a scenario -by- scenario basis support improved by as much as nine percentage points when it comes to opposing restricting home sales based on race, and eight percentage points for opposing real estate agents limiting client home searches based on neighborhood racial composition. Somewhat smaller increases in support for the law are also observed for differential treatment of families with children, advertising a religious preference for an apartment, and restricting rental occupancy based on an applicant's religion. When responses to each of eight scenarios depicting illegal actions are summed, the share of the public expressing support for the law in six or more scenario depictions strengthened from 66 percent in 2000/1 to 73 percent in 2005. Likewise, support for a hypothetical open- housing law that would prohibit home sellers from discriminating on the basis of race, religion or nationality also increased from 67 percent of the population in 2000/1 to 70 percent in 2005. Source: The Urban Institute, Do We Know More Now? Trends in Public Knowledoe. Support and Use of Fair Housing Law, prepared for the U.S. Department of Housing and Urban Development, Office of Policy Development and Research, February 2006, pages i and ii 2. Intentional Discrimination by Some Members of the Housing Industry Including, but not necessarily Limited to, Rental, Lending, Insurance, Zoning, Appraisals, and Advertising Discriminatory practices are likely to persist in these fields. However, 2005 benchmark data are generally unavailable thereby impeding efforts to track changes or progress. Although lending data are available, the significant changes in underwriting practices in the past three years make it unwise to compare 2008 and 2009 Home Mortgage Disclosure Act (HMDA) data to 2004 and 2005 HMDA data. Discriminatory advertising seems to have been reduced as questionable words and phrases pertain mostly to "no pets ", "source of income" and "age ". The 2005 -2010 Regional Al had no specific analysis on zoning - related fair housing issues. The Al update contains an analysis of how zoning impacts fair housing on a jurisdiction -by- jurisdiction basis. 3. "Color" Blind Policy Causes Disparate Impact (i.e., Credit Scores in Determining a Person's Insurability and Occupancy Restrictions) Data are unavailable to demonstrate the degree to which private sector policies have created disparate impacts for persons seeking a home loan, homeowners insurance, or how occupancy standards have reduced housing opportunities for families with children. Information is available on the degree to which "credit history" is a reason for denial of a home loan application. In 2008, 7.1% (White /Minority) to 22.5% (Blacks) of FHA loan applications were denied because of a poor credit history. In 2008, 3.0% (Native Hawaiian /Pacific Islander) to 20% (2 or more races) of conventional loan applications were denied because of poor credit history. However, too high a debt -to- income ratio is the most frequent reason for denial of a home loan application. 4. Employer's Lack of Support for Affordable Housing Results in Segregated Housing Data are unavailable to determine if this impediment has been ameliorated or eliminated between 2005 and 2010. 50 5. High Loan Denial Rates are 3 Times among Upper Income Blacks and 2 Times for Equally Situated Hispanics Evidence from the 2008 Home Mortgage Disclosure Act (HMDA) data indicates that loan denial disparities between White applicants and Black and Hispanic applicants have been reduced to less than 3 times for Blacks and less than 2 times for Hispanics in three of four income groups. With respect to FHA loans, Blacks in all income groups have loan denial rates of less than two times compared to White applicants. With regard to conventional loans, the disparities are not as high as 3 times except for low income Black applicants (2.55). Refer to Table 2 -1 for detailed rates. Moderate- income Hispanics have a loan denial rate for FHA and conventional loans that is two times greater than White applicants. The very low, low and above moderate income Hispanics have loan denial rates less than two times the White applicant rates. Refer to Table 2 -1 for detailed rates. The disparities in loan denial rates between White applicants and Black and Hispanic applicants have been reduced since the 2005 Regional Al was prepared. Table 2 -1 Orange County Disparities in Loan Denial Rates for Black and Hispanic Borrowers -2008 FHA Loans Income Group Blacks Hispanics Very Low N/A 1.64 Low 1.09 1.93 Moderate 1.90 1.87 Above Moderate 1.39 1.46 Conventional Loans Income Group Blacks Hispanics Very Low N/A 1.81 Low 2.55 1.62 Moderate 1.18 2.00 Above Moderate 1.25 1.65 Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 51 6. CRA Funds are not Targeted in ways Assisting Low Income Persons and Neighborhoods in Home Ownership and Financial Stability The Community Reinvestment Act (CRA), Title VIII of the Housing and Community Development Act of 1977, is a federal law designed to encourage commercial banks and savings and loans to meet the needs of borrowers in all segments of their communities, including low- and moderate - income neighborhoods. Congress passed the Act in 1977 to reduce discriminatory credit practices against low- and moderate income neighborhoods, a practice known as redlining. The CRA is implemented by regulations of the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of Thrift Supervision (OTS) (collectively, the agencies). CRA directs the agencies to encourage insured depository institutions to help meet the credit needs of the communities in which they are chartered. Institutions subject to data reporting requirements must report the aggregate number and amount of community development loans originated or purchased during the prior calendar year. A community development loan has community development as its primary purpose. As defined in the regulations, "community development" means— affordable housing (including multifamily rental housing) for low or moderate - income individuals; • community services targeted to low- or moderate - income individuals; All state member banks, state nonmember banks, national banks, and savings associations that are not small or special - purpose institutions are subject to the data collection and reporting requirements of the CRA. Institutions that are not small are considered large institutions. "Small" is defined as follows: "Small bank" or "small saving association" means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.098 billion. "Intermediate small bank" or "intermediate small savings association" means a small institution with assets of at least $274 million as of December 31 of both of the prior two calendar years, and less than $1.098 billion as of December 31 of either of the prior two calendar years. The CRA requires the Federal Deposit Insurance Corporation (FDIC) and other agencies to assess an institution's CRA performance. A financial institution's performance is evaluated in the context of information about the institution (financial condition and business strategies), its community (demographic and economic data), and its competitors. Upon completion of a CRA examination, the FDIC rates the overall CRA performance of the financial institution using a four - tiered rating system consisting of: • Outstanding • Satisfactory • Needs to Improve • Substantial Noncompliance 152 Between 2005 and 2010, 22 assessments have been conducted of financial institutions located in the area covered by the Regional Al. The performance evaluations resulted in the following ratings: • Outstanding = 4 • Satisfactory = 16 • Needs to Improve = 2 Based on these ratings, the institutions covered by the CRA are meeting the objectives of the law. The FHCOC will track whether institutions rated "need to improve' move to "satisfactory" when their next assessment is completed. Some Jurisdictions Underestimate the Extent of Discrimination, Therefore Reducing or not Paying Fair Share of Services Provided by FHCOC Data on the number of housing discrimination complaints filed by residents of each city are included in Section 5 of the 2010 -2015 Regional Al. These data can be used to develop a fair share formula for payment of services provided by the FHCOC. 153 This Page Intentionally Left Blank 54 Section 3 Fair Housing Action Plan 2010 -2015 5,5 SECTION 3 FAIR HOUSING ACTION PLAN A. INTRODUCTION Section 3 describes the following: • A summary of Section 4 - Fair Housing Community Profile which contains information on population and housing trends as well as the characteristics of the "protected classes." • A summary of Section 5 — Regional Private Sector Fair Housing Analysis which includes information on private sector impediments and a description of 25 actions to be taken by the Fair Housing Council of Orange County. • A summary of Section 6 — Public Sector Fair Housing Analysis which includes information on the public sector impediments and a description of the actions to be taken by the Fair Housing Council of Orange County, each participating city that identified impediments, and the County of Orange. • A summary of Section 7 — Affirmatively Furthering Fair Housing through the Location of Affordable Housing which examines if affordable housing is predominantly located outside areas of high minority and high low income population concentrations. B. FAIR HOUSING COMMUNITY PROFILE 1. Orange County Population Growth Trends Demographic information concerning the characteristics of the Entitlement Cities and Urban County Cities is a key element of the Analysis of Impediments to Fair Housing Choice and Fair Housing Action Plan. The Fair Housing Community Profile demonstrates the extensive size and diversity of the Fair Housing Council's service area. The Fair Housing Council provides services to a service area of about 2.7 million persons who reside in 29 jurisdictions and in an area that has recently transitioned to a minority- majority county, which indicates that there will be a continuing need for a variety of housing services. The racial and ethnic composition of Orange County's population has been experiencing dramatic change for the past 40 years but has recently passed a major milestone. In 2000, Whites accounted for more than 50% of Orange County's population. By 2007, the White population accounted for 43.6% of Orange County's population and it is now a minority- majority county. Orange County's Hispanic population has now passed the one - million mark and has grown from 30.9% of the population to 35% of the population. The Asian population has also experienced rapid growth. In 2000, the Asian population stood at 395,994 representing 13.8% of Orange County's population and in 2007 reached 520,401 representing 16.8% of the county's population. Both the Black population and those classified as "All Other Races" have experienced some growth since 2000. Population change is the result of three factors: births, deaths, and migration. The White population in Orange County has decreased since 2000, because the number of births just S0 slightly exceeded number of deaths by approximately 3,000, while at the same time, the number of Whites moving out of Orange County exceeded the number of Whites moving into Orange County by 129,805. The net result was that the White population declined by 126,623. On the other hand, the Hispanic population grew by 157,266 due to births and another 55,144 due to migration, while the total number of deaths was 13,159. The net result was that the Hispanic population grew by nearly 200,000 persons between 2000 and 2007. The pattern of growth for Asians is somewhat different than it is for Hispanics. Migration is the major factor for Asian population increase, while births are the major factor for Hispanic population increase. Between 2000 and 2007, the Asian population grew by 95,388 due to migration, while it added just fewer than 30,000 persons through natural increase (births minus deaths). As Orange County's remaining developable land is consumed, the level of growth will moderate each decade. However, some of the demographic trends that have marked the first decade of the twenty -first century will continue. The Hispanic population will nearly double by 2030 from 2000. Between 2010 and 2020 it will surpass the size of the White population and will be the largest population group in the county. The same factors that have marked change from 2000 to 2007 will also influence the change in the Hispanic population. Even though the Hispanic fertility will decline, numerically higher levels of births will increase the population while migration will play a significant role, but a secondary role, in its growth. The Asian population will also experience significant growth between 2000 and 2030, adding 283,656 persons to its population. Migration will play a larger role than fertility. The fertility rates of Asians have been diverse depending on the Asian group. It is anticipated that rates for those groups with higher fertility rates presently will decline. Thus, the number of Asian births is also expected to decline. Continued declines for the White population can be attributed to the overall aging of the White population. First of all, the number of persons in child bearing ages will decline. Even with constant fertility rates, the number of births will decline. Second of all, the overall level of mortality will rise as the population gets older. Whites are also expected to experience a net out - migration, thus resulting in further declines in their population. Although their impact on the population will not be as great as that of Asians, Hispanics and Whites, the Black population will decline while the population of "All Other Races" will increase. The factors that will influence the change in the White population are the same that will influence the decline in the Black population. For those classified as "All Other Races," it is births that will result in the population increase. The underlying factor will be more interracial couples having children as Orange County's population becomes more racially and ethnically diverse. 2. Population Characteristics of the Protected Classes The Fair Housing Act, 42 U.S.C. 3601 et. seq., prohibits discriminatory practices which make housing unavailable to persons because of: • Race • Color • Religion • Sex • National Origin 57 • Familial Status or • Handicap /Disability The California Fair Employment and Housing Act (Article 2, Section 12955) makes it unlawful: to discriminate against or harass any person because of the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or disability of that person. Under the provisions of Civil Code Section 51.2 et. seq. age is a protected class. Hence, the California law has added the following to the group of protected classes: • Sexual Orientation • Marital Status • Ancestry • Source of Income • Age The Unruh Civil Rights Act, California Civil Code sections 51 through 51.3, provides protection from discrimination by all business establishments in California, including housing and public accommodations. The Unruh Civil Rights Act specifically outlaws discrimination in housing and public accommodations based on sex, race, color, religion, ancestry, national origin, disability, or medical condition. While the Unruh Civil Rights Act specifically lists "sex, race, color, religion, ancestry, national origin, disability, or medical condition" as protected classes, the California Supreme Court has held that protections under the Unruh Act are not necessarily restricted to these characteristics. The Act is meant to cover all arbitrary and intentional discrimination by a business establishment on the basis of personal characteristics similar to those listed above. Part C of Section 4 presents demographic data on the following protected classes: race /color, sex, national origin /ancestry, familial status, handicap /disability, and marital status. Table 3 -1 on the next page is a summary of the demographic characteristics of the protected classes. The data on the number and percentage of housing discrimination complaints is based on the five year period from 2005 through 2009 as compiled for the Regional Al by the State Department of Fair Employment and Housing. The housing discrimination data are discussed in more detail in Section 5. ON Table 3 -1 Regional Analysis of Fair Housing Impediments Characteristics of the Protected Classes 159 Number of Percent of All Housing Housing Demographic Discrimination Discrimination Protected Class Characteristics Complaints Complaints Race /Color Population of 3,119,500 in 76 of 372 20.4% Orange County: 45.9% is White Alone; 54.1 % is Minority Sex 209,600 female householders 20 of 372 5.4% live in Regional Al area; 146,700 male householders live in Regional Al area. Estimates exclude married householders. National Origin/ County's foreign born 53 of 372 14.2% Ancestry population is 936,000, which represents 30% of the total population. Vast majority of foreign born population is from Latin America and Asia. Familial Status Almost 280,000 families with 45 of 372 12.1% children live in the Regional Al area — almost 30% of the families (80,000) reside in Anaheim and Santa Ana. Handicap /Disability 140,000 disabled persons 129 of 372 34.7% reside in Entitlement Cities; 7.4% of non - institutionalized population is disabled. 98,900 disabled persons live outside the Entitlement Cities; 8.1% of non - institutionalized population is disabled. Marital Status About 339,000 married 15 of 372 4.0% couples live in Entitlement Cities; 54% of all households. About 81,200 married couples live in Urban County Cities; 55% of all households. 159 C. PRIVATE SECTOR IMPEDIMENTS AND ACTIONS TO BE TAKEN The Regional Al examines the following private sector impediments: • Housing Discrimination • Discriminatory Advertising • Blockbusting • Denial of Reasonable Accommodation • Hate Crimes • Unfair Lending Part C provides a summary of the detailed information on each impediment contained in Section 5. Additionally, the actions to be taken by the FHCOC to ameliorate or eliminate the impediments are described in this part. The key rationale for preparation of a Regional Al is that private sector impediments are regional in nature and affect multiple communities — that is, they are not limited to a single jurisdiction responsible for AFFH. The FHCOC has a wealth of experience in dealing with fair housing impediments that occur in the private sector. HUD guidance indicates that the Regional Al must describe appropriate actions to overcome the effects of the private sector impediments that are identified through the analysis. The FHCOC understands the private sector and is well equipped to analyze impediments, describe appropriate actions, and to follow- through on those actions. The actions to be taken between 2010 and 2015 to remove or ameliorate impediments to fair housing choice and, thereby, affirmatively further fair housing are organized according to four timelines: • Ongoing: will be accomplished annually • Near -Term: will be accomplished in Program Year 2010 -2011 • Mid -Term: will be accomplished in Program Years 2011- 2012/2012 -2013 • Long -Term: will be accomplished in Program Year 2013 - 2014/2014 -2015 Chart 3 -1 on the following six pages describes each action to be taken according to the above timelines. All the actions will be implemented by the FHCOC. In August of each year, the FHCOC will report its progress on implementing the planned actions for the prior program year to the Entitlement Cities and County of Orange. A summary of the private sector impediments and list of planned actions follows Chart 3 -1. W Chart 3 -1 Regional Analysis of Fair Housing Impediments Private Sector Analysis Private Sector Impediments Fair Housing Action Plan: 2010 -2015 Fair Housing Action Ongoing Near -Term Mid -Term Long -Term Annually Program Year Program Years Program Years 2010 -2011 2011 - 2012!2012 -2013 2013 - 2014/ 2014 -2015 Housing Discrimination Continue to process Conduct testing of housing housing discrimination provider practices to complaints filed by city and determine whether there county residents. are differences in treatment based on a protected class. The 2005- 2009 housing discrimination complaint data and the fair housing community profile can be used to identify the protected classes and locations of housing providers that should be tested. Revise its website to provide direct access to a housing discrimination complaint form and provide a diagram or brief explanation of the process for investigating and resolvin a com taint. Revise its website to add more information on how residents can detect whether they have been victims of unlawful housing discrimination. 01 Chart 3- 1- continued Fair Housing Action Ongoing Near -Term Mid -Term Long -Term Annually Program Year Program Years Program Years 2010 -2011 2011 - 201212012 -2013 2013 - 2014/ 2014 -2015 Housing Discrimination Publish a quarterly report on the FHCOC website summarizing the remedies pertaining to filed housing discrimination complaints. Ensure that all jurisdictions provide a link to the FHCOC website Compile an Annual Report on housing discrimination complaints filed with the FHCOC, the State Department of Fair Employment and Housing (DFEH) and HUD. The report will include housing discrimination complaints unique to each participating jurisdiction as well as those of the entire County. The Annual Report will describe emerging trends within the cities and County. (Annually beginning in Program Year 2011 -2012 02 Chart 3- 1- continued Fair Housing Action Ongoing Annually Near -Term Program Year 2010 -2011 Mid -Term Program Years 2011 - 201212012 -2013 Long -Term Program Years 2013 - 2014/ 2014 -2015 Housing Discrimination Transmit the Annual Report to the participating jurisdictions by August of each calendar year. This schedule allows the jurisdictions to include a summary of the report findings in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. (Annually beginning in Pro ram Year 2011 -2012 Discriminatory Encourage the Orange Support an amendment to Advertising County Register to publish the Communications a Fair Housing Notice in Decency Act of 1996 to the for rent classified ad state no provider or user of section and to identify the an interactive computer FHCOC as an agency that service shall be treated as can respond to fair housing the publisher or speaker of questions. any information provided by another information Encourage apartment content provider, except rental websites to display for notices, statements, or more prominently their advertisements with Fair Housing Notice. respect to the sale, rental, financing or insuring, or any other service of a dwelling that violate the Fair Housing Act, 42 U.S.C. § 3601 et seq. (03 Chart 3- 1- continued Fair Housing Action Ongoing Near -Term Mid -Term Long -Term Annually Program Year Program Years Program Years 2010 -2011 2011 - 2012/2012 -2013 2013 - 2014/ 2014 -2015 Discriminatory Prepare a summary of the Encourage the Los Periodically review for rent Advertising accomplishments each Angeles Times and and for sale ads published year and transmit to the Orange County Register to in the print media. Entitlement Cities and publish a "no pets' Urban County in August of disclaimer that indicates each year. This schedule rental housing owners allows the Entitlement must provide reasonable Cities and Urban County to accommodations, including include a summary of the "service animals" and accomplishments in the "companion animals" for Consolidated Plan Annual disabled persons. Performance and Evaluation Report. That Report is published in Se tember of each year. Blockbusting Provide information on the FHCOC website on the unlawful practice of blockbusting including examples of this illegal practice. Work with the California Department of Real Estate to determine if any Orange County licensees have had their licenses suspended or revoked because of the illegal practice of blockbustin . =1 Chart 3- 1- continued Fair Housing Action Ongoing Near -Term Mid -Term Long -Term Annually Program Year Program Years Program Years 2010 -2011 2011 - 201212012 -2013 2013 - 2014/ 2014 -2015 Blockbusting In the event, a licensee has been found to have committed blockbusting, provide education and information on this practice to the responsible broker and all related salespersons. Denial of Reasonable Provide education and Modification /Reasonable information on why this Accommodation practice is unlawful to the owners and managers of apartment complexes and homeowner associations. Provide information on the unlawful practice of denying reasonable modifications and reasonable accommodations at fair housing seminars conducted by the Apartment Association of Orange County. Hate Crimes Coordinate with the Orange County Human Relations Commission, Center OC and the Orange County Victim Assistance Partnership. Provide affected residents — when needed - with referrals to hate crime victim resources. 05 Chart 3- 1- continued Fair Housing Action Ongoing Annually Near -Term Program Year 2010 -2011 Mid -Term Program Years 2011- 201212012 -2013 Long -Term Program Years 2013 - 2014/2014 -2015 Unfair Lending Monitor the HMDA data Complete a HMDA Conduct a follow -up annually using the 2008 analysis of the top 10 analysis of loan denial HMDA analysis as a lenders in Orange County rates at the neighborhood benchmark. to compare and contrast level to determine to what loan denial rates. 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. Conduct outreach to Provide homebuyer cultural, ethnic and education programs in minority organizations to neighborhoods with high potentially increase denial rates, high minority interest and readiness in population concentrations home purchases. and limited English speaking proficiency to help increase loan approval rates. 1. Housing Discrimination a. Impediment Housing discrimination, especially in the rental housing market, is an impediment to fair housing choice because 60 complaints annually are filed by residents of the participating entitlement cities and Urban County. The California Department of Fair Employment and Housing (DFEH) compiled data on housing discrimination complaints for this Regional Al. In the five -year period since the prior AI, about 300 housing discrimination complaints have been filed with DFEH. Annually, the number of housing discrimination complaints averaged 60 per year. The number of cases ranged from a low of 46 in 2005 to a high of 78 in 2006. The vast majority — 244 of 302 housing discrimination complaints — have been filed in the Entitlement Cities. Irvine (58) and Anaheim (40) accounted for the highest number of complaints. A housing discrimination complaint can have more than one basis. The bases include: • Physical Disability • Mental Disability • Race /Color • National Origin • Familial Status • Sex • Marital Status • Other - Retaliation; Religion; Source of Income; Association and Age About 35% of the housing discrimination complaints were based on a physical or mental disability. Since the prior Regional Al was completed, disability has been increasing as a basis for a housing discrimination complaint. Race and color (20 %) and national origin (14 %) rank second and third as a basis for making a housing discrimination complaint. Although Individual cities vary in terms of the basis for a housing discrimination complaint, disability, race /color and national origin comprise the basis for the highest number of complaints. The DFEH compiles data on number of housing discrimination cases according to nine types of alleged acts: • Refusal to Rent • Eviction • Refusal to Show • Loan Withheld Unequal Terms • Harassment • Unequal Access to Facilities • Denied Reasonable Modification /Accommodation A summary of the highest number and percentage of alleged acts is presented below: About 22% (101) of the housing discrimination complaints occurred during the eviction process. 07 • About 19% each of the alleged acts pertained to unequal terms (88) and to denial of a reasonable modification and /or accommodation (87). • About 15% each of the housing cases were filed because of harassment (72) and the refusal to rent (68). It appears that most of the alleged acts affect renters or persons seeking rental housing. This mirrors HUD's national study which found that about 70% of the persons who thought they were victims of discrimination were looking to rent at the time. b. Actions to be Taken During the 2010 -2015 period, the FHCOC will undertake the following actions: 1. Continue to process housing discrimination complaints filed by city and county residents. 2. Conduct testing of housing provider practices to determine whether there are differences in treatment based on a protected class. The 2005 -2009 housing discrimination complaint data and the fair housing community profile can be used to identify the protected classes and locations of housing providers that should be tested. 3. Revise its website to provide direct access to a housing discrimination complaint form and provide a diagram or brief explanation of the process for investigating and resolving a complaint. 4. Revise its 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 State Department of Fair Employment and Housing (DFEH) and HUD. The report will include housing discrimination complaints unique to each participating jurisdiction as well as those of the entire County. The Annual Report will describe emerging trends within the City and County. 8. Transmit the Annual Report to the participating jurisdictions by August of each calendar year. This schedule allows the jurisdictions to include a summary of the report findings in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. M 2. Discriminatory Advertising a. Impediment 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. Section 804 (c) of the 1968 Fair Housing Act prohibits discriminatory advertising; it is unlawful: To make, print, or publish, or cause to be made, printed, or published any notice, statement, or advertisement, with respect to the sale or rental of a dwelling that indicates any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. The California Fair Employment and Housing Act contains similar language prohibiting discriminatory advertising. To demonstrate whether discriminatory advertising meets the threshold for being considered a regional impediment to fair housing choice, print and online advertising was reviewed during the month of January 2010. Classified ads printed in the Los Angeles Times and Orange County Register were reviewed for words and phrases that might be viewed as discriminatory. During this period, however, few for -rent ads were published in either newspaper. Because of limited newspaper print advertising, an online search of apartment ads was conducted via Apartments. com, which is provided by the Los Angeles Times. Each ad was reviewed to determine if it might any indicate a "preference, limitation or discrimination." Advertisements which describe the property being advertised or the services available at the property are generally considered acceptable. The review, then, focused on words and phrases that deviated from physical descriptions of the property and available services. 1. Source of Income: Source of income is a protected class under California's fair housing law, effective January 1, 2000. Thus, it is unlawful to print or publish an advertisement that prefers, limits or discriminates on the basis of the source of the tenant's income. An ad stating "No Section 8" would not be illegal because under the California Fair Employment and Housing Act, "source of income" refers to income paid directly to a tenant or tenant's representative. A landlord that receives a Section 8 rental payment on behalf of a tenant from a housing authority is not considered a representative of the tenant. The rental housing market is currently accepting tenants that receive Section 8 rental assistance. Many ads contained phrases such as "Section 8 OK "; "HUD OK "; "Section 8 Welcome "; and "Section 8 Accepted ". When the rental housing market vacancy rates become significantly lower, landlords may not have an incentive to attract tenants receiving Section 8 assistance. Under these conditions, "No Section 8" ads may become an impediment to fair housing choice because, in part, they could make such housing unavailable disproportionately to a protected class such as persons with disabilities. i • 2. No Pets: An analysis was completed of the print ads with respect to the Entitlement City in which the apartment complex is located; number of ads placed; ads with non - property related words and phrases; and the number of ads published with those words and phrases. Forty seven of the 223 apartment ads contained non - property related words or phrases. The overwhelming majority of the non - property related words or phrases was "No Pets" which occurred in 38 (17 %) of the 223 apartment ads. Twenty -eight of the 204 homes for rent ads contained non - property related words or phrases. Once again, "no pets" was the most frequent non - property related word or phrase, having occurred in 26 (12.7 %) of the 204 ads. There were 62 unique ads for apartments and homes for rent in the Urban County jurisdictions. Ten ads had words and phrases that did not pertain to the physical description of the property: seven stated "no pets," two were "Section 8" related and one ad stated "Senior Citizen ". Under Federal and State fair housing laws, individuals with disabilities may ask their housing provider to make reasonable accommodations in the "no pets" policy to allow for their use of a companion /service animal. The housing provider may ask the disabled applicant/tenant to provide verification of the need for the animal from a qualified professional. Once that need is verified, the housing provider must generally allow the accommodation. Some disabled persons are unaware of their fair housing rights and, as a consequence, may not consider as available to them apartments with ads that state "no pets." 3. Age: Federal regulations specify that unless the housing being offered meets government requirements for "senior" or "senior only" housing, advertisers may not express a preference or limitation on the basis of age. A few ads contained phrases indicating a preference for seniors. One ad stated "senior citizen ". It appears that this ad was placed by an individual owner of a condominium. However, it is not known if the condominium complex met the requirements of a senior only complex. Two apartment complexes placed ads stating that a 5% discount was given to seniors. The complexes are located in Orange and Westminster and are managed by the same company. b. Actions to be Taken During the five -year of the Consolidated Plan, the FHCOC will undertake the following actions: 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, 70 financing or insuring, or any other service of a dwelling that violate the Fair Housing Act, 42 U.S.C. § 3601 et seq. 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 Entitlement Cities and Urban County in August of each year. This schedule allows the Entitlement Cities and Urban County to include a summary of the accomplishments in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. 3. Blockbusting a. Impediment Blockbusting is unlawful; however, it does not appear to be a significant impediment to fair housing choice. Section 804(e) of the 1968 Fair Housing Act makes the following act, commonly referred to as blockbusting, unlawful: For profit, to induce or attempt to induce any person to sell or rent any dwelling by representations regarding the entry or prospective entry into the neighborhood of a person or persons of a particular race, color, religion, sex, handicap, familial status, or national origin. With respect to blockbusting, the California law has more protected classes than the Federal Fair Housing Act. There is no local or county agency that maintains records on actual or potential blockbusting incidents. Such incidents would take place primarily as real estate agents attempt to solicit or induce homeowners to sell their homes. The California Real Estate Commissioner is authorized to take disciplinary action against licensees who have committed the prohibited discriminatory practice of blockbusting and panic selling. The Department of Real Estate stated in June 2010 that no Orange County licensee has had their license suspended or revoked because of the illegal practice of blockbusting. b. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: 1. Provide information on the FHCOC website on the unlawful practice of blockbusting including examples of this illegal practice. 2. Work with the California Department of Real Estate to determine if any Orange County licensees have had their licenses suspended or revoked because of the illegal practice of blockbusting. 71 3. In the event, a licensee has been found to have committed blockbusting, provide education and information on this practice to the responsible broker and all related salespersons. 4. Denial of Reasonable Modification /Reasonable Accommodation a. Impediment 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. It is unlawful to refuse to make reasonable accommodations for disabled persons. Section 804 (3) of the 1968 Fair Housing Act states that discrimination includes -- (A) a refusal to permit, at the expense of the handicapped person, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises, except that, in the case of a rental, the landlord may where it is reasonable to do so condition permission for a modification on the renter agreeing to restore the interior of the premises to the condition that existed before the modification, reasonable wear and tear excepted. (B) a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling. The DFEH compiles data on the number of housing discrimination cases according to nine types of alleged acts. During the 2005 -2009 period, 461 alleged discriminatory acts were committed in the cases processed by the DFEH. Of this total, 87 or 18.9% involved denial of a reasonable modification /reasonable accommodation. About 17 -18 denials of reasonable modification /reasonable accommodation occurred per year during the five -year period. b. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: 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. 72 5. Hate Crimes a. Impediment 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. Hate crime events were reviewed for the 5 -year period from 2004 to 2008 as reported by Criminal Justice Statistics Center of the California Department of Justice (DOJ). The annual average of events was 73 and, during the five -years there was a narrow low (69) to high (79) range. Except for the City of Huntington Beach, on a city -by -city basis, the number of hate crime events is low. In 2008, according to the Orange County Human Rights Commission ( OCHRC), there were 79 cases of hate crimes in Orange County, essentially unchanged from the 80 cases in 2007. Despite the fact that the African American population makes up less than 2% of Orange County's population, this group continues to be the most frequent target for hate crimes. Hate crimes against Latinos continues to increase. In fact, since 2006 there has been almost a 100% increase in the number of cases reported. After a four -year downward trend, hate crimes against Jews increased. Additionally, while there was a slight decrease in hate crimes reported against Gays and Lesbian, this group frequently underreports. In 2008, 29% and 19% of the hate crimes in Orange County had an anti - African American and anti - Latino bias motivation. The California DOJ reports the location of hate crime events for the entire state by 25 categories (e.g., church, park, college, etc). During the past five years two locations are predominant, accounting for about 60% of all hate crime locations: Highway /Road /Alley /Street (29.1 %) and Residence /Home /Driveway (29.7 %). The application of the statewide housing location average of 29.7% to the annual Orange County average of hate crime events of 73 yields at estimate of 22 annual events occurring at a residence, home or driveway. The application of the 40% factor cited by the OCHRC yields an estimate of 29 events occurring at a housing location. On an individual city basis, the number of hate crime events occurring at a housing location is small. However, the number at the countywide level is significant and, as a result, the resources to monitor and alleviate this impediment are best handled at the regional level. b. Actions to be Taken During the five -year of the Fair Housing Action Plan, the FHCOC will take the following actions 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. 73 6. Unfair Lending a. Impediment 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. Section 805 of the Fair Housing Act (42 U.S.C. 3605) states that it is "unlawful for any person or other entity whose business includes ... the making or purchasing of loans or providing other financial assistance for purchasing, constructing, improving, repairing, or maintaining a dwelling... to discriminate against any person... because of race, color, religion, sex, handicap, familial status, or national origin." The Equal Credit Opportunity Act (ECOA) 15 U.S.C. 1691 et seq. prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age, because an applicant receives income from a public assistance program, or because an applicant has in good faith exercised any right under the Consumer Credit Protection Act. To supplement federal legislation, state laws have been enacted to forbid the discriminatory practice known as "redlining;' a practice results in blanket refusals by some lenders to make loans in whole neighborhoods or geographic areas. Redlining is illegal in California pursuant to the Housing Financial Discrimination Act of 1977 (Holden Act). (Health & Safety Code Section 35800 - 35833) The Holden Act prohibits the consideration of race, color, religion, sex, marital status, national origin, or ancestry in lending for the purchase, construction, improvement, or rehabilitation of housing. Further, lenders cannot deny loan applications because of ethnic composition, conditions, characteristics, or expected trends in the neighborhood or geographic area surrounding the property. An analysis of the 2008 Home Mortgage Disclosure Act (HMDA) data was completed in order to determine loan denial rates by census tract, race /ethnicity and income. HMDA requires lenders to report on the action taken on each loan application, as follows: • Loan Originated • Application Approved, Not Accepted • Application Denied • Application Withdrawn • Filed Closed for Incompleteness Many determinants of a loan decision — such as borrower credit history, debt -to- income -ratio and loan -to -value ratio - are not included in the HMDA data. Although the loan denial rates do not support definitive conclusions regarding discrimination on the bases of race or ethnicity, they are a useful screen to identify disparities in loan approval rates by the race and ethnicity of applicants and geographic markets where differences in denial rates warrant further investigation. Additionally, identifying census tracts /neighborhoods with high loan denial rates helps to target credit counseling and homebuyer education programs. 74 Evidence from the 2008 Home Mortgage Disclosure Act (HMDA) data reveals the loan denial disparities between White applicants and Black and Hispanic applicants. Moderate income Blacks have an FHA loan denial rate almost two times greater than moderate income White applicants. Above moderate income Blacks have an FHA loan denial rate about 1.4 times greater than White applicants with identical incomes. The conventional loan disparities are lower for moderate and above moderate income applicants than for FHA loans. However, low income Blacks have a conventional loan denial rate 2.55 times greater than White applicants. Moderate - income Hispanics have a loan denial rate for FHA and conventional loans that is two times greater than White applicants. The very low, low and above moderate income Hispanics have loan denial rates 1.46 to 1.93 higher than White applicants. Unfair lending is manifested more in the loan denial disparities experienced by different racial /ethnic borrowers than by the denial rate disparities experienced in neighborhoods with 20 % -79% minority populations, regardless of income. Additionally, a regression analysis was completed to determine if race /ethnicity is associated with the denial of loan applications. Two types of loans applications were considered in the analysis: (1) home purchases with conventional loans and (2) home purchases with FHA loan. A logit regression was used to "predict' if a loan was denied based on the minority population and income ratio of the census tract, as well as the loan amount. These variables were chosen because the results of a preliminary analysis utilizing census tract level data suggested each of these variables were influencing denials. Each of the three variables was significant predictors of loan denials for conventional loan applications, while the percent minority and the income ratio of a census tract were significant predictors of denials for FHA loan applications. For conventional loans, the probability of a loan being denied increased as the percentage minority population in the census tract increased, as the income increased the probability of a denial decreased, and as the amount of the loan increased the probability of a loan denial increased. b. 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. 75 D. ACTIONS TO ADDRESS PUBLIC SECTOR IMPEDIMENTS 1. Public Sector Impediments Common to Most Participating Jurisdictions As part of the preparation of an Analysis of Impediments to Fair Housing Choice participating cities responded to a 24- question survey 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. The survey 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. 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. 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 Disabilit 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. 70 Government Code Section 65582(f) states: "'Supportive housing' has the same meaning as defined in subdivision (b) of Section 50675.14 of the Health and Safety Code" Health and Safety Code Section 50675.14(b) states: "For purposes of this section, 'supportive housing' means housing with no limit on length of stay, that is occupied by the target population as defined in subdivision (d) of Section 53260, and that is linked to onsite or offsite services that assist 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." Health and Safety Code Section 53260(d) states: "'Target population' means adults with low incomes having one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Act (Division 4.5 (commencing with Section 4500) of the Welfare and Institutions Code) and may, among other populations, include families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, or homeless people." [emphasis added] Government Code Section 65582(g) states: "'Transitional housing' has the same meaning as defined in subdivision (h) of Section 50675.2 of the Health and Safety Code." Health and Safety Code Section 50675.2(h) states: "'Transitional housing' and 'transitional housing development' means buildings configured as rental housing developments, but operated under program requirements that call for the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months." Health and Safety Code Section 50801(i) states: "'Transitional housing' means housing with supportive services for up to 24 months that is exclusively designated and targeted for recently homeless persons. Transitional housing includes self- sufficiency development services, with the ultimate goal of moving recently homeless persons to permanent housing as quickly as possible, and limits rents and service fees to an ability -to -pay formula reasonably consistent with the United States Department of Housing and Urban Development's requirements for subsidized housing for low- income persons. Rents and service fees paid for transitional housing may be reserved, in whole or in part, to assist residents to move to permanent housing." 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. 77 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. The federal Departments of Justice (DOJ) and Housing and Urban Development (HUD) as well as the California Attorney General have encouraged local governments to adopt a reasonable accommodation procedure. The DOJ and HUD have stated: "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 the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 5. On May 15, 2001 the State Attorney General transmitted a letter to all local governments advising the localities to consider adoption of a reasonable accommodation procedure. In that letter, the Attorney General stated: "Both the federal Fair Housing Act ('FHA') and the California Fair Employment and Housing Act ('FEHA') impose an affirmative duty on local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning laws and other land use regulations and practices when such accommodations 'may be necessary to afford' disabled persons 'an equal opportunity to use and enjoy a dwelling. "' Many jurisdictions currently handle requests for relief from the zoning ordinance through variance or conditional use permits. The Attorney General remarked that: "...the criteria for determining whether to grant a variance or conditional use permit typically differ from those which govern the determination whether a requested accommodation is reasonable within the meaning of fair housing laws. "Thus, municipalities relying upon these alternative procedures have found themselves in the position of having refused to approve a project as a result of considerations which, while sufficient to justify the refusal under the criteria applicable to grant of a variance or conditional use permit, were insufficient to justify the denial when judged in light of the fair housing laws' reasonable accommodations mandate." The Attorney General also stated that the variance and conditional use permit procedures — with their different governing criteria — serve to encourage community opposition to projects housing the disabled. The Attorney General wrote: "Yet this is the very type of opposition that, for example, the typical conditional use permit procedure, with its general health, safety and welfare standard, would seem rather predictably to invite, whereas a procedure conducted pursuant to the more focused criteria applicable to the reasonable accommodation determination would not." M The advice of the Attorney General is to establish a reasonable accommodation procedure instead of relying on the conditional use permit and variance procedures to process a request for disabled persons seeking specific exceptions to zoning and land -use rules (variances) necessary for them to be able to fully use and enjoy housing. A public hearing is not required for approval of a reasonable accommodation request. 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. Attachment B in Section 6 (page 6 -34) is an example of a reasonable accommodation procedure. d. Special Needs Zoning Question #20 asks: Does the zoning code or other planning document address housing for "special needs" populations. 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. There is a high incidence of disability in the homeless population, domestic violence overwhelmingly impacts women, and people with HIV /AIDS are considered disabled under fair housing law. While age is not a characteristic protected under federal fair housing law, it is covered under state law, and the higher incidence of disability in the frail elderly introduces possible fair housing implications for that population as well. Entitlement cities and the Urban County should consider enacting special needs housing zoning regulations. Attachment C in Section 6 (page 6 -37) provides an example of such zoning regulations. e. Fair Housing Discussion Question 24 asks: Does the zoning ordinance or other planning or policy document include a discussion of fair 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. Attachment D in Section 6 (page 6 -47) provides an example of such zoning regulations. �9 2. City Identified Public Sector Impediments Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the City of Newport Beach did not identify any public sector impediments. Reference: Technical Appendix G: Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice W 3. 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. b. Actions to be Taken by the City Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the City of Newport Beach did not identify any public sector impediments. Therefore, there are no actions to be taken at this time by the City with respect to public sector impediments. Reference: Technical Appendix G: Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice W1 E. ACTIONS TO AFFH THROUGH THE LOCATION OF AFFORDABLE HOUSING As explained in Section 7, the location of affordable housing is central to fulfilling the commitment to AFFH because it determines whether such housing will reduce or perpetuate residential segregation. The data analysis shows that affordable housing is predominantly located outside areas of high minority and high low income population concentrations. Many of the developments were constructed before localities were required to develop policies to guide the location of affordable housing. During the 2010 -2015 period, the FHCOC will take the following actions: • Provide technical assistance to participating jurisdictions on how the location of affordable housing contributes to AFFH. This action will be accomplished on an as needed, as requested basis Aggregate - for each census tract - the number of voucher holders assisted by all four housing authorities. This action will be accomplished in calendar year 2011. Conduct an analysis of the location of affordable housing in census tracts with a low concentration of minority and low income populations for purposes of determining whether they offer sufficient affordable housing opportunities. This action will be accomplished either in calendar year 2011 or as soon as Census 2010 and American Community Survey data are available. Extend the analysis to include census tracts with minority populations in the range of 60 to 80 %. This action will be accomplished either in calendar year 2011 or as soon as Census 2010 and American Community Survey data are available. Suggest policies that the Housing Authorities and/or entitlement cities and the Urban County Program can implement to promote affordable housing opportunities outside of census tracts with high percentages of poverty and minority populations. This action will be accomplished during the Fair Housing Council of Orange County's review of the housing authority annual plans. Additionally, the Council will provide input to the entitlement cities and Urban County Program on an as needed, as requested basis. :. Section 4 Fair Housing Community Profile 2S SECTION 4 FAIR HOUSING COMMUNITY PROFILE A. INTRODUCTION Demographic information concerning the characteristics of the Entitlement Cities and Urban County Cities is a key element of the Analysis of Impediments to Fair Housing Choice and Fair Housing Action Plan for the reasons explained below. First of all, the Fair Housing Community Profile demonstrates the extensive size and diversity of the Fair Housing Council's service area. The Fair Housing Council provides services to a service area of about 2.7 million persons who reside in 29 jurisdictions and in an area that has recently transitioned to a minority- majority county, which indicates that there will be a continuing need for a variety of housing services. Second, demographic data provide benchmark data for the entire service area, individual cities and the County of Orange. Emerging trends can be pinpointed as Census 2010 and the 2010 American Community Survey data are released. Future year data can be contrasted to the statistics presented in this Fair Housing Community Profile to detect emerging trends. Third, the Fair Housing Community Profile establishes a database that the Fair Housing Council can utilize for a number of purposes. For instance, information contained in the Profile can be used to compete for grants under HUD "s competitive Fair Housing Initiatives Program as well as other public and private grant programs. Fourth, the information in the Profile and future updates can be used to adjust and re -focus the delivery of fair housing services by the Fair Housing Council. For example, the data provide a basis to target or focus fair services geographically within Council's expansive service area. Another example is that the current and projected population characteristics indicate that a greater proportion of the population may have limited English speaking proficiency. And, fifth, individual cities may extract information from the Fair Housing Community Profile to develop a city- specific profile that includes some or all of the characteristics included in Section 4 and Technical Appendix A. The Regional Al's Fair Housing Community Profile presents an overview of the demographic characteristics of the 14 Entitlement Cities, the 14 Urban County Cities and unincorporated Orange County. The total population of the communities included in the Regional Al is almost 2,700,000 persons. The housing stock is comprised of about 873,600 housing units. The Profile contains information on the following: • Population and Housing Characteristics • Population Growth in Orange County • Population Characteristics of the Protected Classes • Household Income Characteristics Three Technical Appendices include the detailed tables referenced in Section 4: • Technical Appendix A —Fair Housing Community Profile • Technical Appendix B — Minority Population by Census Tract M Technical Appendix C— Low Income Population by Census Tract and Block Group B. POPULATION AND HOUSING CHARACTERISTICS 1. Population a. 2010 Population Table A -1 in Technical Appendix A shows that the 2010 population of the Entitlement Cities is almost 2,105,300 persons. Santa Ana (357,754) and Anaheim (353,643) have the largest populations of the 14 Entitlement Cities. Five cities have populations between 138,610 and 217,686 (Fullerton, Garden Grove, Orange, Irvine and Huntington Beach). Seven cities have populations ranging between 58,741 and 94,294. Table A -1 in Technical Appendix A also shows that the vast majority of people live in households; only a few people (1.6 %) live in group quarters. The average household sizes range from a low of 2.21 (Newport Beach) to a high of 4.74 (Santa Ana). Table A -2 in Technical Appendix A shows that the 2010 population of the Urban County is almost 594,000 persons. The unincorporated area comprises one -fifth (20.2 %) of the total Urban County population. Of the 14 cities in the Urban County, two have populations of more than 50,000 (Placentia, Yorba Linda) and 12 have populations of less than 50,000. Table A -2 in Technical Appendix A shows that 99.2% of the Urban County population lives in households. The average household sizes range from a low of 1.47 (Laguna Woods) to a high of 3.58 (Stanton). Attachment A on pages A -28 and A -29 contains definitions of population related terms. b. Population Growth Trends Table A -3 in Technical Appendix A shows that during the 10 -year period between the April 1990 and April 2000 Censuses, about 266,200 persons were added to the populations of 13 of the 14 Entitlement Cities. The City of Lake Forest was unincorporated in 1990. Additionally, the City of Rancho Santa Margarita was a Census Division Place (CDP) and not an incorporated city at the time of the 1990 Census. Thus, 1990 data for this city is based on the CDP population. Table A -3 in Technical Appendix A indicates that almost 230,450 persons were added to the populations of the Entitlement Cities between the April 2000 Census and January 1, 2010. The largest numerical gains between 2000 and 2010 were experienced in Irvine (74,614), Anaheim (25,269) and Lake Forest (20,013). In fact, these three cities accounted for 52% of the total population growth of the 14 Entitlement Cities. In the same period, the highest population growth rates occurred in Irvine (52 %), Lake Forest (34 %), and Newport Beach (24 %). The Newport Beach growth rate was not due to the occupancy of newly built housing, but rather to the annexation of the existing communities of Del Mar and Santa Ana Heights. Table A -4 in Technical Appendix A shows the growth trends for the Urban County. As of January 1, 2010, the Urban County population was almost 594,000 persons. M Three of the 14 Urban County Cities were unincorporated at the time of the 1990 Census ( Aliso Viejo, Laguna Hills and Laguna Woods). Only Aliso Viejo was unincorporated when the Census 2000 was taken. Table A -4 shows that the highest numerical population increases for the 11 cities incorporated at the time of the 1990 and 2000 Censuses occurred in Stanton (6,912), Yorba Linda (6,496) and Placentia (5,229). These cities also had the highest percentage increases at 22.7 %, 12.4% and 12.7% respectively. Between the April 2000 Census and January 2010, the highest numerical and percentage changes in population occurred in Yorba Linda (10,355, 17.6 %), Placentia (5,817, 12.5 %), Brea (4,967, 14.0 %) and Laguna Hills (3,702, 12.4 %). 2. Housing Characteristics a. 2010 Housing Supply Table A -5 in Technical Appendix A shows that as of January 2010 the housing supply of the Entitlement Cities was about 655,450 housing units. The cities of Anaheim (103,242), Irvine (81,011), Huntington Beach (78,060), and Santa Ana (75,943) have the largest housing stocks. Single - family detached dwellings comprise slightly less than one half (48 %) of housing units for the 14 Entitlement Cities. However, in nine of the 14 Entitlement Cities single family detached homes comprise the majority of the housing stock. The lowest percentage of single family detached homes occurred in Irvine (35 %) while Fountain Valley had the highest (66 %) Table A -6 in Technical Appendix A shows that the Urban County's housing stock is comprised of about 218,160 dwelling units. Of the incorporated cities, Yorba Linda (22,103) and Aliso Viejo (18,207) have the largest housing supplies among the Urban County Cities. Unincorporated Orange County has about 38,500 housing units. b. Housing Growth Trends Lake Forest was unincorporated at the time of the 1990 Census. Regarding the remaining 13 incorporated cities, Table A -7 in Technical Appendix A shows that between 1990 and 2000 almost 43,800 housing units were added to housing stock of those cities. Irvine, by far, had the highest housing growth, adding 11,490 (27.2 %) dwellings between 1990 and 2000. Between the April 2000 Census and January 1, 2010, the cities of Irvine (27,300, 33.7 %), Newport Beach (6,227, 14.3 %) and Lake Forest (5,898, 22.4 %) had the largest increases in the housing stock. Rancho Santa Margarita had an increase of some 234 %; however, it must be noted that it was a Census Division Place and not an incorporated city at the time of the 1990 Census Changing boundaries and incorporations make trend analysis difficult. However, the 2010 housing supply estimate for the Urban County is 218,158 dwellings. Between the 1990 and 2000 censuses, two cities (Yorba Linda and Placentia) had growth rates above 10 %. From the April 2000 Census to January 1, 2010 only Yorba Linda had a growth rate over 10 %. Yorba Linda has the largest housing stock at 22,103 units, while Villa Park has the smallest at 2,023. Single - family detached homes comprise about 55.6% of the housing stock in the 14 Urban County cities and the unincorporated area of Orange County. However, on a city -by -city basis it varies widely. Only about 5% of the housing stock in Laguna Woods is comprised of single family detached units. On the other hand, nearly 99% of Villa Park's housing stock is single family detached dwellings. MR Table A -8 in Technical Appendix A provides the more detailed data. Attachment A on page A -28 contains definitions of housing related terms. c. Vacancy Rates Vacancy rates reflect the supply /demand conditions that are unique to each community. Irvine has a 4.52% vacancy rate, which may be due to a significant portion (40 %) of its housing stock comprised of multiple family (5+ units) and unsold housing inventory. Newport Beach has a high vacancy rate at 10.87 %. This may be due to 24% of its stock being comprised of multiple family units in addition to vacation, second home and seasonal use of the housing stock. Some of the higher vacancy rates of Urban County communities reflect beach and retirement communities. Four cities, for instance, have higher than average vacancy rates: Laguna Beach, 11.2 %; Seal Beach, 8.2 %; Dana Point, 7.8 %; and Laguna Woods, 7.6 %. C. POPULATION GROWTH IN ORANGE COUNTY 1. Population by Race and Ethnicity The racial and ethnic composition of Orange County's population has been experiencing dramatic change for the past 40 years but has recently passed a major milestone. In 2000, Whites accounted for more than 50% of Orange County's population. By 2007, the White population accounted for 43.6% of Orange County's population and it is now a minority- majority county. Orange County's Hispanic population has now passed the one - million mark and has grown from 30.9% of the population to 35% of the population. The Asian population has also experienced rapid growth. In 2000, the Asian population stood at 395,994 representing 13.8 % of Orange County's population and in 2007 reached 520,401 representing 16.8% of the county's population. Both the Black population and those classified as "All Other Races" have experienced some growth since 2000. Refer to Table 4 -1. Table 4 -1 Orange County Population by Race and Ethnicity — 2000 and 2007 Race/Ethnicity 2000 2007 Number Percent Number Percent Asian 395,994 13.8% 520,401 16.8% Black 44,191 1.5% 50,556 1.6% Hispanic 885,377 30.9% 1,084,628 35.0% White 1,475,045 51.5% 1,348,422 43.6% All Other Races 62,761 2.2% 90,865 2.9% Total 2,863,368 100.0% 3,094,872 100.0% Source: California State Department of Finance Table construction by Castaneda & Associates Population change is the result of three factors: births, deaths, and migration. The White population in Orange County has decreased since 2000, because the number of births just slightly exceeded number of deaths by approximately 3,000, while at the same time, the number M of Whites moving out of Orange County exceeded the number of Whites moving into Orange County by 129,805. The net result was that the White population declined by 126,623. On the other hand, the Hispanic population grew by 157,266 due to births and another 55,144 due to migration, while the total number of deaths was 13,159. The net result was that the Hispanic population grew by nearly 200,000 persons between 2000 and 2007. The pattern of growth for Asians is somewhat different than it is for Hispanics. Migration is the major factor for Asian population increase, while births are the major factor for Hispanic population increase. Between 2000 and 2007, the Asian population grew by 95,388 due to migration, while it added just fewer than 30,000 persons through natural increase (births minus deaths). Refer to Table 4- 2. Table 4 -2 Components of Population Change By Race and Ethnicity — 2000 and 2007 Race/Ethnicity Births Deaths Net-Migration Net Change Asian 38,610 9,591 95,388 124,407 Black 2,505 1,459 5,319 6,365 Hispanic 157,266 13,159 55,144 199,251 White 96,375 93,193 - 129,805 - 126,623 All Other Races 19,058 773 9,799 28,084 Total 313,814 118,175 35,845 231,484 Source: California State Department of Finance Table construction by Castaneda & Associates 2. Projected Population As Orange County's remaining developable land is consumed, the level of growth will moderate each decade. However, some of the demographic trends that have marked the first decade of the twenty -first century will continue. The Hispanic population will nearly double by 2030 from 2000. Between 2010 and 2020 it will surpass the size of the White population and will be the largest population group in the county. The same factors that have marked change from 2000 to 2007 will also influence the change in the Hispanic population. Even though the Hispanic fertility will decline, numerically higher levels of births will increase the population while migration will play a significant role, but a secondary role, in its growth. The Asian population will also experience significant growth between 2000 and 2030, adding 283,656 persons to its population. Migration will play a larger role than fertility. The fertility rates of Asians have been diverse depending on the Asian group. It is anticipated that rates for those groups with higher fertility rates presently will decline. Thus, the number of Asian births is also expected to decline. Refer to Table 4 -3 on the next page. Continued declines for the White population can be attributed to the overall aging of the White population. First of all, the number of persons in child bearing ages will decline. Even with constant fertility rates, the number of births will decline. Second of all, the overall level of mortality will rise as the population gets older. Whites are also expected to experience a net out - migration, thus resulting in further declines in their population. :: Table 4 -3 Orange County Population and Race Projections 2000 to 2030 Year Total Asian Black Hispanic White All Other Races 2000 2,863,834 395,994 44,191 885,377 1,475,045 62,761 2010 3,227,836 517,787 44,873 1,158,270 1,419,887 87,019 2020 3,520,265 616,929 43,893 1,465,316 1,294,712 99,415 2030 3,705,322 679,650 40,410 1,765,105 1,107,029 113,128 Numerical Change 841,488 283,656 -3,781 879,728 - 368,016 50,367 Percent Change 29.4% 71.6% 1 -8.6% 99.4% -24.9% 80.3% Source: State of California, Department of Finance, Population Projections for California and Its Counties 2000 -2050, Sacramento, California, July 2007 Table construction by Castaneda & Associates Although their impact on the population will not be as great as that of Asians, Hispanics and Whites, the Black population will decline while the population of "All Other Races" will increase. The factors that will influence the change in the White population are the same that will influence the decline in the Black population. For those classified as "All Other Races," it is births that will result in the population increase. The underlying factor will be more interracial couples having children as Orange County's population becomes more racially and ethnically diverse. 3. Housing Needs Immigration has been and will continue to influence Orange County's population change. It is expected that most of the immigrants settling in Orange County will come from the same areas of the globe as those that now reside in the county: Asia and Central America. They will probably share similar characteristics as today's immigrants. They will be younger, have lower levels of education, have higher poverty rates, and have lower levels of English proficiency. Thus, the need for programs that assist immigrants in helping to provide safe and adequate housing will still persist, including fair housing services. D. POPULATION CHARACTERISTICS OF THE PROTECTED CLASSES The Fair Housing Act, 42 U.S.C. 3601 et. seq., prohibits discriminatory practices which make housing unavailable to persons because of: • Race • Color • Religion • Sex • National Origin • Familial Status or • Handicap /Disability The California Fair Employment and Housing Act (Article 2, Section 12955) makes it unlawful: to discriminate against or harass any person because of the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or disability of that person. Under the provisions of Civil Code Section 51.2 et. seq. age is a protected class. Hence, the California law has added the following to the group of protected classes: • Sexual Orientation • Marital Status • Ancestry • Source of Income • Age The Unruh Civil Rights Act, California Civil Code sections 51 through 51.3, provides protection from discrimination by all business establishments in California, including housing and public accommodations. The Unruh Civil Rights Act specifically outlaws discrimination in housing and public accommodations based on sex, race, color, religion, ancestry, national origin, disability, or medical condition. While the Unruh Civil Rights Act specifically lists "sex, race, color, religion, ancestry, national origin, disability, or medical condition" as protected classes, the California Supreme Court has held that protections under the Unruh Act are not necessarily restricted to these characteristics. The Act is meant to cover all arbitrary and intentional discrimination by a business establishment on the basis of personal characteristics similar to those listed above. Part D presents demographic data on the following protected classes: race /color, sex, national origin /ancestry, familial status, handicap /disability, and marital status. Table 4 -4 on the next page is a summary of the demographic characteristics of the protected classes. The data on the number and percentage of housing discrimination complaints is based on the five year period from 2005 through 2009 as compiled for the Regional Al by the State Department of Fair Employment and Housing. The housing discrimination data are discussed in more detail in Section 5. Table 4 -4 Regional Analysis of Fair Housing Impediments Characteristics of the Protected Classes 91 Number of Percent of All Housing Housing Demographic Discrimination Discrimination Protected Class Characteristics Complaints Complaints Race /Color Population of 3,119,500 in 76 of 372 20.4% Orange County: 45.9% is White Alone; 54.1 % is Minority Sex 209,600 female householders 20 of 372 5.4% live in Regional Al area; 146,700 male householders live in Regional Al area. Estimates exclude married householders. National Origin/ County's foreign born 53 of 372 14.2% Ancestry population is 936,000, which represents 30% of the total population. Vast majority of foreign born population is from Latin America and Asia. Familial Status Almost 280,000 families with 45 of 372 12.1% children live in the Regional Al area — almost 30% of the families (80,000) reside in Anaheim and Santa Ana. Handicap /Disability 140,000 disabled persons 129 of 372 34.7% reside in Entitlement Cities; 7.4% of non - institutionalized population is disabled. 98,900 disabled persons live outside the Entitlement Cities; 8.1% of non - institutionalized population is disabled. Marital Status About 339,000 married 15 of 372 4.0% couples live in Entitlement Cities; 54% of all households. About 81,200 married couples live in Urban County Cities; 55% of all households. 91 1. Race /Color During the 2005 through 2009 period, race /color was the basis for 20% of all housing discrimination complaints filed by residents of the cities covered by the Regional Al, according to statistics compiled by the State Department of Fair Employment and Housing (DFEH). The State Department of Justice (DOJ) reports that during the 2004 through 2008 period race /ethnicity /national origin was the bias motivation in about two- thirds of all hate crime events. Hate crime events with an anti -Black and anti - Hispanic bias motivation accounted for 34.6% and 10.7% respectively of all hate crime events in California during the five -year period. a. Race Categories and Definitions 1) Race Categories: The Fair Housing Act does not define race. Data on race is required for many federal programs and the Census Bureau collects race data in accordance with guidelines provided by the U.S. Office of Management and Budget (OMB) and these data are based on self- identification. The racial categories included in the census form generally reflect a social definition of race recognized in this country, and are not an attempt to define race biologically, anthropologically or genetically. In addition, the Census Bureau recognizes that the categories of the race item include both racial and national origin or socio - cultural groups. Census 2010 and the American Community Survey provide for six race categories: • White Alone • Black, African American or Negro Alone • American Indian or Alaska Native Alone • Asian Alone • Native Hawaiian or Other Pacific Islander Alone • Some Other Race Alone Individuals who chose more than one of the six race categories are referred to as the Two or more races population, or as the group that reported more than one race. All respondents who indicated more than one race can be collapsed into the Two or more races category, which combined with the six alone categories, yields seven mutually exclusive and exhaustive categories. Thus, the six race alone categories and the Two or more races category sum to the total population. 2) Race Category and Hispanic Definitions: Census 2000 adheres to the federal standards for collecting and presenting data on race and Hispanic origin as established by the Office of Management and Budget (OMB) Policy Directive No. 15 (May 12, 1977) and the revisions published in the Federal Register Notice on October 30, 1997 — Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity. The OMB's efforts are to standardize the racial and ethnic categories so that federal government agencies can monitor discrimination, as required by the Civil Rights Act of 1964, the Voting Rights Act of 1965, the Fair Housing Act of 1968, the Equal Credit Opportunity Act of 1974, and the Home Mortgage Disclosure Act of 1975. Source: Victoria Hattam, "Ethnicity & the American Boundaries of Race: Rereading Directive 15," Daedalus — Journal of the American Academy of the Arts & Sciences, Winter 2005, pgs. 61 -62. 92 The Census 2000 race and Hispanic definitions are given below: White — A person having origins in any of the original peoples of Europe, the Middle East, or North Africa. It includes people who indicate their race as "White' or report entries such as Irish, German, Italian, Lebanese, Near Easterner, Arab, or Polish. Black or African American — A person having origins in any of the Black racial groups of Africa. It includes people who indicate their race as 'Black, African American or Negro", or provide written entries such as African American, Afro - American, Nigerian, or Haitian. American Indian or Alaska Native — A person having origins in any of the original peoples of North and South America (including Central America) and who maintain tribal affiliation or community attachment. People who classified themselves as "American Indian or Alaska Native" were asked to report their enrolled or principal tribe. Asian — A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam. It includes "Asian Indian," "Chinese," "Filipino," "Korean," "Japanese," "Vietnamese," or "Other Asian." Native Hawaiian and Other Pacific Islander — A person having origins in any of the original peoples of Hawaii, Guam, Samoa or other Pacific Islands. It includes people who indicated their race as "Native Hawaiian," "Guamanian or Chamorm," "Samoan," and other "Pacific Islander." Some Other Race — Includes all other responses not included in the above race categories. Respondents providing write -in entries such as multiracial, mixed, interracial, or a Hispanic /Latino group (for example, Mexican, Puerto Rican, or Cuban) in the "Some other race' write -in space are included in this category. According to Census 2000, the terms "Hispanic," "Latino," and "Spanish" are used interchangeably. Hispanic or Latino origin include people who classify themselves in one of the specific Hispanic or Latino categories listed on the Census 2000 questionnaire — "Mexican," "Puerto Rican," or "Cuban" — as well as those who indicate that they are of "another Hispanic, Latino, or Spanish origin." People in the latter group include those whose origins are from Spain, the Spanish- speaking countries of Central or South America, the Dominican Republic, or people identifying themselves generally as Spanish, Spanish- American, Hispanic, Hispano, Latino, and so on. In data collection and presentation, federal agencies are required to use a minimum of two ethnicities — "Hispanic or Latino' and "Not Hispanic or Latino." b. Non - Hispanic White and Minority Population Characteristics The racial and ethnic groups comprising the "minority" populations are defined in essentially the same way by the Federal Office of Management and Budget, Department of Transportation, Federal Financial Institutions Examination Council (HMDA data), and Council on Environmental Quality (environmental justice guidelines). For instance, the FFIEC, for purposes of HMDA data collection, states that: 93 "...the percentage minority population means, for a particular census tract, the percentage of persons of minority races and whites of Hispanic or Latino Origin, in relation to the census tract's total population." The CEO environmental justice guidelines provide the following definition: "Minority individuals — Individuals who are members of the following population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, multiracial minority (two or more races, at least one of which is a minority race)." The non - minority population is White, Non - Hispanic or Latino. Table 4 -5 shows Orange County's 2000 and 2008 population by Hispanic /Latino and seven race categories. During the eight year period, there was a net decrease in the White alone population and this race category now comprises less than one -half (46 %) of the County's population. The Hispanic and Asian populations comprise 33.8% and 16.1% respectively of the County's population. All other minority populations equal 4.2% of Orange County's population. Table 4 -5 Orange County Population by Hispanic /Latino and Race -2000 and 2008 2000 1 Mid -Year 2008 Hispanic /Latino or Race Number Percent Number Percent Numerical Change Percent Change Hispanic or Latino of any race 875,579 30.8% 1,054,375 33.8% 189,209 21.6% White alone 1,458,978 51.3% 1,431,829 45.9% - 13,009 -0.9% Black or African American alone 42,639 1.5% 49,911 1.6% 7,765 18.2% American Indian and Alaska Native alone 8,414 0.3% 9,358 0.3% 1,037 12.3% Asian alone 383,810 13.5% 502,232 16.1% 123,382 32.1% Native Hawaiian and Other Pacific Islander alone 8,086 0.3% 9,358 0.3% 1,365 16.9% Some other race alone 4,525 0.2% 9,358 0.3% 4,926 108.9% Two or more races 64,258 2.3% 53,031 1.7% - 10,704 -16.7% Total 2,846,289 100.0% 3,119,452 100.0% 303,970 10.7% Note: The mid -year number is derived from applying the ACS 1 -Year Estimates to an average of the total population numbers from California Department of Finance (DOF) for January 1, 2008 and January 1, 2009 Source: American Community Survey 1 -Year Estimate, 2008: Select Demographic Characteristics. Census 2000, Summary File 1, Table P4 Hispanic or Latino by Race, Not Hispanic or Latino Table construction by Castaneda & Associates Between 2000 and 2008, Orange County's population increased by nearly 304,000 people. Two population groups accounted for most of the growth: Hispanic or Latino of any race (189,209) and Asian alone (123,382). 94 c. Hispanic Population Growth Trends According to the State Department of Finance, the Hispanic share of Orange County's total population increased from 30.9% in 2000 to 35% in 2007. The American Community Survey estimates that the Hispanic population comprised 33.8% of the County's population in 2008. The Hispanic population will nearly double by 2030 from the 2000 level. Between 2010 and 2020 it will surpass the size of the White alone population and will be the majority population group in the county. Entitlement Cities vary greatly in terms of growth trends and their 2008 racial and ethnic compositions. Table A -9 in Technical Appendix A provides the following information: • Population by race and Hispanic or Latino in 2000 and 2008 • Percentage of the total population by race and Hispanic or Latino in 2000 and 2008 • Numerical change by race and Hispanic or Latino in 2000 and 2008 • Percentage change by race and Hispanic or Latino in 2000 and 2008 The Entitlement Cities with the largest Hispanic populations are noted below: CCU Santa Ana Anaheim Garden Grove Orange Fullerton Hispanic Population Total 284,234 187,122 69,476 56,037 44,988 Percent of Total City Population 80.5% 54.0% 40.1% 39.8% 32.8% Table A -10 in Technical Appendix A contains Hispanic population data for the Urban County Cities. The Urban County Cities with the largest Hispanic populations are noted below: Hispanic Percent of city Population Total Total City Population Stanton 19,743 50.3% Placentia 19,664 38.1% d. Asian Population Growth Trends The Asian population will experience significant growth between 2000 and 2030, adding 283,656 persons to its population. Migration will play a larger role in population growth than fertility. The Entitlement Cities with the largest Asian populations are listed below and on the next page. Asian Percent of CCU Population Total Total City Population Irvine 75,844 36.1% Garden Grove 58,215 33.6% Anaheim 46,087 13.3% 95 Asian Percent of Citv Population Total Total City Population Westminster Fullerton Santa Ana 38,112 29,489 29,306 41.0% 21.5% 8.3% Table A -10 in Technical Appendix A contains Asian population data for the Urban County Cities. The Urban County Cities with the largest Asian populations are noted below: e. Black Population Growth Trends Between 2000 and 2007 Orange County's Black population increased by nearly 6,400 persons. However, this population group is projected to decrease by almost 3,800 persons between 2000 and 2030. The population decline will be due to fewer births, higher mortality and net out - migration from the County. The Entitlement Cities with the largest Black populations are noted below: Black Citv Population Total Anaheim Asian Percent of Citv Population Total Total City Population Cypress 13,842 28.0% Yorba Linda 9,390 13.8% Stanton 8,007 20.4% e. Black Population Growth Trends Between 2000 and 2007 Orange County's Black population increased by nearly 6,400 persons. However, this population group is projected to decrease by almost 3,800 persons between 2000 and 2030. The population decline will be due to fewer births, higher mortality and net out - migration from the County. The Entitlement Cities with the largest Black populations are noted below: Black Citv Population Total Anaheim 10,049 Fullerton 5,486 Santa Ana 3,885 Percent of Total City Population 2.9% 4.0% 1.1% Table A -10 in Technical Appendix A contains Black population data for the Urban County Cities. The Urban County Cities with a Black population of more than 1,000 persons include Aliso Viejo, Cypress, Stanton and Yorba Linda. f. Areas of Minority Pooulation Concentrations Census 2010 and 2008 American Community Survey data are unavailable at the census tract level. Thus, Technical Appendix B presents the race and ethnicity of the population residing in the Entitlement Cities and Urban County's 252 census tracts based on Census 2000 data. In 2000, "minority" persons comprised 45.3% of the County's population. The census tracts were grouped according to five intervals: • 0.0 -20.0% • 20.1 -45.3% • 45.4 -60.0% • 60.1 -80.0% • 80.1 - 100.0% M Table 4 -6 shows that 64 census tracts had "minority" population percentages greater than 80 %. Thirty-seven of the 64 census tracts are located in Santa Ana. Anaheim had 11 census tracts and Garden Grove had four census tracts exceeding the 80% threshold. Therefore, just over four -fifths of the census tracts with "high" minority population concentrations are located in these three large cities of Orange County. Ten of the 64 census tracts are split tracts — that is, the tract boundaries are located in two cities. Three of the 10 split tracts are located in Santa Ana /Garden Grove. Table 4 -7 lists the 10 split census tracts and the population living in each city. Ninety -four census tracts had "minority" population percentages ranging between 60% and 80 %. Twenty of the census tracts are located in Anaheim and 13 are located in Garden Grove. Santa Ana and Westminster each have eight census tracts with minority populations ranging between 60% and 80 %. Forty -five census tracts are located in other Orange County cities. Table 4 -6 Regional Analysis of Fair Housing Impediments Areas of Minority Population Concentrations Number of Census Tracts by City /Area - 2000 City/Area Census Tract Minority Population Percentages 80.1%-100.0% 60.1%-80.0% Santa Ana 37 8 Anaheim 11 20 Garden Grove 4 13 Santa Ana /Garden Grove 3 1 Stanton 1 2 Buena Park 1 4 Santa Ana /Tustin 1 0 Santa Ana /Fountain Valley 1 0 Anaheim /Placentia 1 1 Anaheim /Stanton 1 1 Anaheim /Fullerton 1 0 Garden Grove/Westminster 1 1 La Habra/Unincorporated 1 0 Fullerton 0 6 Westminster 0 8 La Habra 0 4 La Palma 0 2 Orange 0 3 Irvine 0 1 Huntington Beach 0 1 Seal Beach 0 1 Cypress 0 1 Placentia 0 1 Other 0 15 Total Census Tracts 64 94 'Includes split Census Tracts between two and three jurisdictions. Source: Technical Appendix B Table construction by Castaneda & Associates 97 Table 4 -7 Regional Analysis of Fair Housing Impediments List and Characteristics of Split Census Tracts With 80.1 %+ Minority Population Census Tract City Total Population Percent Minority 744.07 Santa Ana 3,822 98.56% Tustin 3,865 98.52% Total 7,687 92.55% 117.2 Placentia 5,339 93.73% Anaheim 2,196 89.66% Total 7,535 92.54% 891.04 LGarden Grove 3,687 93.38% Santa Ana 2,387 91.41% Total 6,074 92.31% 12.01 La Habra 7,974 80.76% County 397 91.44% Total 8,371 81.55% 889.03 Garden Grove 6,656 84.84% Santa Ana 1,938 88.85% Total 8,594 85.75% 878.03 Stanton 4,821 88.76% Anaheim 1,621 80.26% Total 6,442 86.62% 116.02 Fullerton 3,306 86.48% Anaheim 2,456 77.89% Total 5,762 82.82% 992.02 Santa Ana 7,232 85.26% Fountain Valley 885 62.03% Total 8,117 82.23% 889.04 Westminster 5,142 82.52% Garden Grove 667 78.41% Total 5,809 82.05% 891.02 Garden Grove 4,418 1 82.01% Santa Ana 2,536 80.80% Total 6,954 81.56% Source: California Department of Finance, Demographic Research Unit, Census 2000, Summary File 1, Population by Race /Ethnicity for Split Tracts in Orange County Table construction by Castaneda & Associates 2. Sex (of Householder) In the sale and rental of housing, fair housing laws protect several "classes" from discrimination. State and federal fair housing laws prohibit discrimination based a person's based sex. During the 2005 through 2009 period, "sex" was the basis for 5% of all housing discrimination complaints filed by residents of the cities covered by the Regional Al, according to statistics provided by the State DFEH to the FHCOC. The State DOJ reports that during the 2004 to 2008 period, "gender" was the bias motivation of 1.2% of all hate crime events. The DOJ also reports that "sexual orientation" was the bias motivation of 18.9% of all hate crime events. In Technical Appendix A, Tables A -11 and A -12 present estimates of the sex of householders for the Entitlement Cities and Urban County Cities. The estimates in the two tables are for: • Married - couple family. This category includes a family in which the householder and his or her spouse are enumerated as members of the same household. • Male householder, no wife present. This category includes a family with a male maintaining a household with no wife of the householder present. • Female householder, no husband present. This category includes a family with a female maintaining a household with no husband of the householder present. • Nonfamily household. This category includes a householder living alone or with nonrelatives only. The above are Census 2000 definitions of each household type. Table 4 -8 on the next page summarizes male and female householders for the Entitlement Cities and Urban County Cities. The counts exclude married couple families as homes are typically owned or rented in both spouses' names. The number of non - family householders — those who live alone or with nonrelatives — exceeds the number of family householders. The sex of the non - family householders was based on the Census 2000 ratios of 46% male and 54% female. Excluding married couples, there are an estimated 356,300 householders of which 59% (209,610) are female and 41% (146,709) are male. Female non - family householders — living alone or with nonrelatives - comprise about one -third of all householders. In Table 4 -8, the Urban County numbers are only for the cities that have American Community Survey data and exclude the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park all of which have populations of less than 20,000. The American Community Survey 3 -Year estimates are available for cities having populations between 20,000 and 65,000 persons. American Community Survey data for cities with populations of less than 20,000 should be available in late 2010 or early 2011. Table 4 -8 Regional Analysis of Fair Housing Impediments Estimated Sex of Householder — 2008 Location /Household Type Male Female Total Entitlement Cities Family 38,453 76,553 115,006 Non-Family 81,232 93,836 175,068 Sub -Total 119,685 170,389 290,074 Urban County Family 5,654 14,535 20,189 Non-Family 21,370 24,686 46,056 Sub -Total 27,024 39,221 66,245 Total 146,709 1209,610 1356,319 Source: Technical Appendix A, Tables A -11 and A -12 Table construction by Castaneda & Associates The United States Department of Justice has stated: The Fair Housing Act makes it unlawful to discriminate in housing on the basis of sex. In recent years, the Department's focus in this area has been to challenge sexual harassment in housing. Women, particularly those who are poor, and with limited housing options, often have little recourse but to tolerate the humiliation and degradation of sexual harassment or risk having their families and themselves removed from their homes. In addition, pricing discrimination in mortgage lending may also adversely affect women, particularly minority women. This type of discrimination is unlawful under both the Fair Housing Act and the Equal Credit Opportunity Act. Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, pages 2 and 3 During the 2005 -2009 period, harassment accounted for 15.9% of all alleged housing discriminatory acts in the jurisdictions covered by the Regional Al. 3. National Origin /Ancestry The Fair Housing Act and California Fair Employment and Housing Act prohibit discrimination based upon national origin. According to the United States Department of Justice, such discrimination can be based either upon the country of an individual's birth or where his or her ancestors originated. During the 2005 through 2009 period, "national origin" was the basis for 14% of all housing discrimination complaints filed by residents of the cities covered by the Regional Al, according to statistics provided by the State DFEH. The DFEH data reveal that the national origin housing discrimination complaints included 16 countries; for instance, anti -South Korea or anti - Romania. However, anti - Mexico accounted for 58% of all national origin housing discrimination complaints. 100 Table 4 -9 shows that the vast majority (70 %) of the county's population was born in the United States, Puerto Rico, a United States Island Area or abroad to American parents. Thus, 30% of the county's inhabitants are foreign -born. Orange County's foreign born population totals almost 936,000 people. The largest portions of the foreign -born population come from Latin America or Asia, which together account for more than 90% of the foreign -born population. Table 4 -9 Orange County: Place of Birth and National Origin — 2008 Place of Birth /National Origin Number Percent Born in the United States 2,152,421 69.0% Born in Puerto Rico, U.S. Island Area or Born Abroad to American Parent (s) 31,195 1.0% Foreign Born 128,628 13.7% Europe 53,031 1.7% Asia 380,573 12.2% Africa 12,478 0.4% Oceania 3,119 0.1% Latin America 474,157 15.2% North America 12,478 0.4% Subtotal 935,836 30.0% Total 3,119,452 100.0% Source: 2008 American Community Survey 1 -Year Estimates Selected Social Characteristics. Midpoint of 2008 and 2009 California Department of Finance (DOF) Population Estimates Table construction by Castaneda & Associates Data on a city -by -city basis is limited from the American Community Survey. However, data was available for three of the Entitlement Cities (Anaheim, Huntington Beach and Irvine). These three cities have a total foreign -born population of 231,148 persons. Table 4 -10 shows that Irvine has nearly 15% of the population that was born in Asia. Anaheim has about 18% of the population that was born in Latin America. Table 4 -10 Orange County: City Residence of Foreign Born Population from Asia and Latin American — 2008 Location ■ Total Population Total Foreign Born Percent of the Count Born in Asia Percent of the Count Born in Latin America Percent of the Count Anaheim 346,908 128,628 13.7% 33,983 8.9% 86,702 18.3% Huntington Beach 201,804 31,445 3.4% 16,047 4.2% 7,845 1.7% Irvine 210,321 71,075 7.6% 56,391 14.8% 5,104 1.1% Other 2,360,419 704,688 75.3% 274,152 72.1% 374,506 78.9% Orange County Total 3,119,452 935,836 100.0% 380,573 100.0% 474,157 15.1% Source: 2008 American Community Survey 1 -Year Estimates Selected Social Characteristics for Anaheim, Huntington Beach, Irvine and Orange County. Midpoint of 2008 and 2009 California Department of Finance (DOF) Population Estimates Table construction by Castaneda & Associates 101 4. Familial Status The Fair Housing Amendments Act of 1988 prohibits discriminatory housing practices based on familial status. In most instances, according to the United States Department of Justice, the Act prohibits a housing provider from refusing to rent or sell to families with children. However, housing may be designated as Housing for Older Persons (55 years + of age). This type of housing, which meets the standards set forth in the Housing for Older Persons Act of 1995, may operate as "senior housing" and exclude families with children. The Act protects families with children less than 18 years of age, pregnant women, or families in the process of securing custody of a child under 18 years of age. The Department of Justice has stated: In addition to prohibiting the outright denial of housing to families with children, the Act also prevents housing providers from imposing any special requirements or conditions on tenants with children. For example, landlords may not locate families with children in any single portion of a complex, place an unreasonable restriction on the number of persons who may reside in a dwelling, or limit their access to recreational services provided to other tenants. Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, page 3 In Orange County, complaints filed on the bases of familial status comprise 12% of all complaints filed with the State DFEH during the 2005 -2009 period. Numerically speaking, families with children are a large fair housing protected class. The Entitlement Cities have a combined total of 233,726 families with children. Table A -13 in Technical Appendix A shows, however, that families with children in the Entitlement Cities comprise less than one -half of all householders except in the City of Santa Ana. Stated another way, Santa Ana is the only Entitlement City where families with children comprise a majority (51.3 %) of all households. Anaheim, Buena Park and Rancho Santa Margarita are the only other cities where families with children comprise 40% or more of all households. The same pattern is true for the Urban County communities, as Table A -14 in Technical Appendix A shows. For the cities where data is available, none have families with children comprising more than 40% of all households. In fact, two cities, Laguna Beach and Seal Beach, have very low percentages of families with children with 17.2% and 11.8% respectively. Overall, in the area covered by the Regional Al there are an estimated 279,917 families with children: • Entitlement Cities 233,726 • Urban County* 46,191 *Excludes the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park Anaheim and Santa Ana are home to almost 30% of all the families with children living in the combined area of the Entitlement Cities and Urban County Cities. 102 There are nearly 39,400 and 7,200 female householders with children residing in the Entitlement Cities and Urban County Cities, respectively. Tables A -15 and A -16 in Technical Appendix A show that female householders with children less than 18 years of age experience high poverty rates. Many of these householders will have difficulty finding adequate housing not only because of their poverty incomes but also due to housing discrimination against women and /or families with children. 5. Handicap /Disability a. Background The Fair Housing Amendments Act of 1988 prohibits discriminatory housing practices based on handicap /disability status in all types of housing transactions. Among other prohibitions, the Act is intended to prohibit the application of special restrictive covenants and conditional or special use permits that have the effect of limiting the ability of such individuals to live in the residence of their choice. Fair housing laws, therefore, make it illegal to deny a housing opportunity on the basis of disabilities. In addition, the law prohibits applying one standard to one class of individuals while applying a different standard to another class of individuals. For example, it would be illegal to ask a disabled individual applying for an apartment to provide a credit report if non - disabled applicants did not have to provide one. In Orange County, complaints filed on the bases of disability status comprise 35% of all complaints filed with the State DFEH. A physical or mental disability bias motivation accounted for 0.2% of all hate crime events in California in 2008, according to the State DOJ. Housing opportunities for disabled persons are impeded by practices in both the private and public sectors. For instance, "denied reasonable modification /accommodation" comprise 18.9% of the alleged acts cited in housing discrimination complaints. Additionally, apartment rental ads often state "no pets allowed," even though disabled persons may have service or companion animals. In the public sector, housing opportunities can be impeded because a city has not adopted a reasonable accommodation procedure, or if adopted has not made the procedure widely known in the community. The United States Department of Justice has indicated a major focus of its efforts is on public sector impediments that may restrict housing opportunities for disabled persons. The Department has stated: The Division's enforcement of the Fair Housing Act's protections for persons with disabilities has concentrated on two major areas. One is insuring that zoning and other regulations concerning land use are not employed to hinder the residential choices of these individuals, including unnecessarily restricting communal, or congregate, residential arrangements, such as group homes. The second area is insuring that newly constructed multifamily housing is built in accordance with the Fair Housing Act's accessibility requirements so that it is accessible to and usable by people with disabilities, and, in particular, those who use wheelchairs. Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, page 4 ]LOS b. Disability Defined The disabled are defined as persons with a physical or mental impairment which substantially limits one or more of such person's major life activities. People who have a history of, or are regarded, as having a physical or mental impairment that substantially limits one or more major life activities, are also covered by fair housing laws. It should be noted that California law does not include the term "substantially" with regard to "major life activities' and "impairments." Major life activities include, but are not limited, to: • Caring for one's self • Walking • Seeing • Hearing • Speaking • Breathing • Working • Performing manual tasks • Learning Some examples of impairments, which may substantially limit major life activities, even with the help of medication or aids /devices, include, but are not limited, to: • AIDS • Alcoholism • Blindness or visual impairment Cancer • Deafness or hearing impairment • Diabetes • Drug addiction • Heart disease • Mental illness • Paraplegia • Multiple scleroses c. Disabled Population Estimates The 2008 American Community Survey asks questions regarding six types of disability: • Hearing disability • Vision disability • Cognitive disability • Mobility disability • Self -care disability • Independent living disability The ACS disability questions differ from the Census 2000 and therefore cannot be compared to the decennial census results. In effect, the ACS data provide a benchmark for comparisons in the future. Data on disability status are available for all of Orange County and 11 of the 14 Entitlement Cities. However, no data are available for any of the Urban County Cities. WON There are an estimated 238,900 disabled persons among Orange County's non - institutionalized population. The disability prevalence rate for the entire Orange County area is 7.7 %, according to the 2008 American Community Survey. Table 4 -11 shows the disability status for 11 of the 14 Entitlement Cities participating in the Regional Al. According to the 2008 ACS estimates, there are almost 140,000 disabled persons residing in the 11 Entitlement Cities. The overall disability prevalence rate was 7.4 %. Buena Park and Westminster had significantly higher rates at 11.1% and 11.8% respectively. Based on the data in the preceding two paragraphs, it can be estimated that there are about 98,900 (238,900 minus 140,000) disabled persons residing in areas outside the boundaries of the 11 Entitlement Cities. The disability rate for areas outside the Entitlement Cities is 8.1 %. Table 4 -11 Regional Analysis of Fair Housing Impediments Disabled Population for Entitlement Cites - 2008 city Non - Institutionalized Population' Disability Rate Number Disabled Anaheim 345,618 7.9% 27,304 Buena Park 82,576 11.1% 9,166 Fountain Valley 57,322 NA NA Fullerton 136,282 7.0% 9,540 Garden Grove 172,737 9.1% 15,719 Huntington Beach 201,308 7.8% 15,702 Irvine 210,201 5.3% 11,141 La Habra 61,943 NA NA Lake Forest 77,602 6.0% 4,656 Newport Beach 84,815 5.2% 4,410 Orange 137,571 7.0% 9,630 Rancho Santa Margarita 49,435 NA NA Santa Ana 350,095 6.2% 21,706 Westminster 92,758 11.8% 10,945 Total3 1,891,563 7.4% 139,919 N/A means disability data are unavailable for these three cities. iNon- Institutionalized population is calculated from Census 2000 Summary File 1 (SF1), Table PCT16 "Group Quarters Population" 2Disability rate is from 2008 American Community Survey (ACS), Select Social Characteristics. 3Totals are for the cities where data are available and percentages are based on the total for known cities Source: Census 2000, Summary File 1 (SF1), Table PCT Group Quarters Population. 2008 American Community Survey (ACS) 1 -Year Estimates, Select Social Characteristics State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates 105 During the 2005 through 2009 period, "disability" was the basis for 35% of all housing discrimination complaints filed by residents of the jurisdictions covered by the Regional Al. Therefore, disabled persons represent a much larger share of complainants than of the general population. This may be due to a greater understanding by disabled persons of their fair housing rights than other protected classes. 6. Marital Status California's fair housing law prohibits housing discrimination on the basis of marital status. This basis refers to whether a person is married or not. The U.S. Census Bureau has four major .,marital status" categories: never married, married, widowed, and divorced. These terms refer to the marital status at the time of the enumeration. A married couple includes a family in which the householder and his or her spouse are enumerated as members of the same household. The DFEH reports that 4% of the cases filed were discrimination complaints based marital status. Table A -17 in Technical Appendix A shows that there are about 339,000 married couples residing in the Entitlement Cities, or about 54% of all households. Married couples comprise a majority of all households in 13 of the 14 Entitlement Cities. In Newport Beach less than 50% of the City's households are married. In Fountain Valley and Rancho Santa Margarita more than 60% of all households are married couples. Table A -18 in Technical Appendix A shows that there are about 81,200 married couples living in the Urban County Cities, or 55% of all households. Married couples are the majority of all households in eight of the 10 cities for which data are available. Married couples comprise more than 70% of all households residing in Yorba Linda and more than 60% of all households having a home in Cypress and Laguna Hills. Married couples comprise less than one -half of all households in Laguna Beach and Seal Beach. E. HOUSEHOLD INCOME CHARACTERISTICS `Fair housing choice', according to HUD, means the ability of persons of similar income levels regardless of race, color, religion, sex, national origin, handicap and familial status to have available to them the same housing choices. [emphasis added] This means, for instance, that households of different races but with similar income levels should have available to them the same housing choices. Another example is that female householders, male householders and married couples with similar income levels should have available to them the same housing choices. A housing market that treats female and male householders with incomes of $60,000 differently would not be providing fair housing choice. 1. Median Household Income According to Census 2000, the median household income is based on the total number of households including those with no income. The median divides the income distribution in two equal parts — one -half of the cases falling below the median and one -half above the median. 100 Table 4 -12 on the next page shows the median household income for the following householders for each Entitlement City: • Black or African American Alone Householder • American Indian and Alaska Native Alone Householder • Asian Alone Householder • Native Hawaiian and Other Pacific Islander Alone Householder • Some Other Race Alone Householder • Two or More Races Householder • Hispanic or Latino Householder • White Alone, Not Hispanic or Latino Householder • All Householders The entries in Table 4 -12 show that the Entitlement Cities differ from one another. The general patterns are: • Non - Hispanic White households generally have among the highest median household income, generally ranking first, second or third among the various jurisdictions. • The Asian population usually has slightly lower medians than the Non - Hispanic White householders, but typically rank first, second or third in the various cities. • The householders with the lowest median incomes are the Black or African American householders and Hispanic householders. • The Hispanic householders typically have incomes slightly higher the Black/African American householders. Table 4 -13 on page 4 -26 shows the median household income for the Urban County Cities. The general patterns are: • On the whole, the median incomes of each racial /ethnic category are higher in the Urban County as compared to the Entitlement Cities. • The relative ranks of each race /ethnic category show more variation than among the Entitlement Cities. For instance, the Non Hispanic White householders rank the highest in only two of the 14 jurisdictions. The Asian and Black /African American householders rank among the highest median income householders in most communities. • The median income of Hispanic householders is generally higher in the Urban County compared to the Entitlement Cities. Cities with a large percentage of retirees, such as Laguna Woods and Seal Beach, have comparatively low median household incomes. 107 Table 4 -12 Regional Analysis of Fair Housing Impediments Median Household Income in 1999 Dollars by Race /Ethnicity of Householder Entitlement Cities - 2000 Entitlement City BAA AI/AN Asian NHOPI SCR TOMR Hispanic White All HH Anaheim 39,335 48,750 52,343 53,750 39,272 41,675 39,430 53,056 47,122 Buena Park 41,418 45,625 56,171 79,355 43,750 45,114 43,984 52,048 50,336 Fountain Valley 39,432 66,705 66,066 51,563 56,033 51,734 62,026 72,056 69,734 Fullerton 36,000 49,167 50,817 85,643 39,991 40,030 41,587 54,359 50,269 Garden Grove 45,966 38,819 44,111 41,111 44,169 45,338 44,080 52,260 47,754 Huntington Beach 57,656 65,852 66,077 43,594 50,979 53,113 53,111 66,377 64,824 Irvine 52,443 69,125 67,246 54,444 51,163 53,156 62,616 76,742 72,057 La Habra 40,595 45,750 67,171 30,833 42,120 49,236 44,157 49,293 47,652 Lake Forest 64,732 46,618 71,094 85,124 68,438 57,656 59,633 68,949 67,967 Newport Beach 55,729 60,469 72,578 61,518 72,159 65,500 61,766 85,549 83,455 Orange 61,875 46,563 65,678 58,036 43,321 56,068 43,486 63,927 58,994 Rancho Santa Margarita 80,776 100,470 85,935 32,083 52,917 64,286 65,431 80,716 78,475 Santa Ana 47,083 39,718 47,993 44,708 41,891 42,156 41,558 48,658 43,412 Westminster 37,750 56,875 44,395 47,750 45,849 52,000 45,933 53,614 49,450 Sources: Census 2000 Summary File 3, Median Household Income (by Race /Ethnicity), Tables P152 A, B, C, D, E, F, G, H and L Table P53 Median Household Income in 1999 (Dollars) Table construction by Castaneda & Associates Notes: BAA Black or African American Alone Householder AI /AN American Indian and Alaska Native Alone Householder Asian Asian Alone Householder NHOPI Native Hawaiian and Other Pacific Islander Alone Householder SOR Some Other Race Alone Householder TOMR Two or More Races Householder Hispanic Hispanic or Latino Householder White White Alone, Not Hispanic or Latino Householder All HH All Households I: Table 4 -13 Regional Analysis of Fair Housing Impediments Median Household Income in 1999 Dollars by Race /Ethnicity of Householder Urban County - 2000 Urban County city BAA AI /AN Asian NHOPI SOR TOMR Hispanic White All HH AlisoVieo 53,125 71,983 76,610 72,250 61,250 61,447 72,170 78,915 76,409 Brea 54,375 30,682 62,760 66,250 49,653 50,391 52,118 61,453 59,759 Cypress 65,948 85,917 66,635 29,167 52,188 54,063 55,465 65,762 64,377 Dana Point 51,083 49,519 65,278 46,810 41,042 48,594 48,368 66,584 63,043 Laguna Beach 81,947 96,916 87,409 44,792 20,924 37,969 66,923 76,239 75,808 Laguna Hills 111,382 28,125 86,682 97,467 46,450 50,978 61,055 70,630 70,234 Laguna Woods 6,250 38,750 21,359 0 49,500 22,321 37,689 30,582 30,493 La Palma 71,250 42,000 68,750 57,969 63,884 70,446 64,183 71,172 68,438 Los Alamitos 65,500 63,205 47,440 0 49,135 55,903 60,966 54,344 55,286 Placentia 41,389 42,375 72,375 11,250 43,922 63,750 48,364 69,100 62,803 Seal Beach 50,781 51,528 95,556 36,250 51,538 46,964 44,219 40,676 42,079 Stanton 44,274 12,100 45,052 60,278 37,450 33,750 36,823 40,422 39,127 Villa Park 200,000+ 0 114,850 200,000+ 26,250 101,435 68,092 120,361 116,203 Yorba Linda 107,474 100,827 88,532 69,453 70,156 70,833 74,728 91,303 89,593 Sources: Census 2000 Summary File 3, Median Household Income (by Race /Ethnicity), Tables P152 A, B, C, D, E, F, G, H and I. Table P53 Median Household Income in 1999 (Dollars) Table construction by Castaneda & Associates Notes: BAA Black or African American Alone Householder AI /AN American Indian and Alaska Native Alone Householder AA Asian Alone Householder NHOPI Native Hawaiian and Other Pacific Islander Alone Householder SORA Some Other Race Alone Householder TOMR Two or More Races Householder Hispanic Hispanic or Latino Householder White White Alone, Not Hispanic or Latino Householder All HH All Households tog Table 4 -13 shows that the Laguna Woods' Black or African American householders had a median household income of $6,250. Although this figure seems low, Census 2000 does report that median household income for Black or African American householders living in Laguna Woods. The last column in Tables 4 -12 and 4 -13 shows the median household income for all householders. The median household incomes of each racial /ethnic group can be compared to that of all householders to determine a relative ranking of each group to all households in each jurisdiction. 2. Areas of Low /Moderate Income Concentration Census 2010 and 2008 American Community Survey data are unavailable at the census tract level. Thus, Technical Appendix C presents the low- and moderate - income population residing in the Entitlement Cities and Urban County's census tracts and block groups based on Census 2000 data. The census tracts /block groups were grouped according to five intervals: • 0 % -25% • 25.1%-50% • 50.1%-65.0% • 65.1%-80.0% • 80.1%-100.0% Table 4 -14 shows that within the area included in the Regional Al, there are 112 block groups with more than 80% of the population in the low /mod income category. Sixty percent of these block groups are located in Santa Ana (41) and in Anaheim (26). There are 227 block groups where 65.1% to 80% of the population has low /mod incomes. Six cities have 15 or more block groups where the percentage of the population having low /mod incomes is between 65.1% and 80.0 %. Again, both Santa Ana and Anaheim have the highest numbers of block groups with 56 and 44 respectively. Technical Appendix C contains the detailed low /mod income population by census tract and block group. The income data are presented in rank order from highest to lowest percentage of low /mod income population. For example, Block Group 2 of Census Tract 746.01 ranks as the 14`h highest block group with 97.7% of the population having low /moderate incomes. 110 Table 4 -14 Regional Analysis of Fair Housing Impediments Number of Census Tract Block Groups by City /Location and Percent Low /Mod -2000 City/Area # of Block Groups and Percent Low /Mod 80.1%-100.0% 65.1%-80.0% Anaheim 26 44 Buena Park 3 7 Fullerton 10 17 Garden Grove 9 18 La Habra 1 15 Laguna Woods 2 9 Orange 3 8 Santa Ana 41 56 Stanton 3 7 Westminster 4 11 Other Cities /Areas 9 27 Unincorporated 1 8 Total 112 227 Source: Technical Appendix C Table construction by Castaneda & Associates 111 Attachment A Definitions of Housing and Population Characteristics And Census Boundaries Housing Characteristics Housing Structure: A structure is a separate building that either has open spaces on all sides or is separated from other structures by dividing walls that extend from ground to roof. In determining the number of units in a structure, all housing units, both occupied and vacant, are counted. Stores and office space are excluded. The statistics are presented for the number of housing units in structures of specified type and size, not for the number of residential buildings. 1 -unit, detached: This is a 1 -unit structure detached from any other house; that is, with open space on all four sides. Such structures are considered detached even if they have an adjoining shed or garage. A 1 -unit structure that contains a business is considered detached as long as the building has open space on all four sides. Mobile homes to which one or more permanent rooms have been added or built are also included. 1 -unit, attached: This is a 1 -unit structure that has one or more walls extending from ground to roof separating it from adjoining structures. In row houses (sometimes called townhouses), double houses, or houses attached to nonresidential structures, each house is a separate, attached structure if the dividing or common wall goes from ground to roof. 2 or more units: These are units in structures containing 2 or more housing units, further categorized as units in structures with 2, 3 or 4, 5 to 9, 10 to 19, 20 to 49, and 50 or more units. Mobile Home: Both occupied and vacant mobile homes to which no permanent rooms have been added are counted in this category. Mobile homes used only for business purposes or for extra sleeping space and mobile homes for sale on a dealer's lot, at the factory, or in storage are not counted in the housing inventory. Boat, RV, Van, etc.: This category is for any living quarters occupied as a housing unit that does not fit in the previous categories. Examples that fit in this category are houseboats, railroad cars, campers, and vans. Population Group Quarters: The group quarters population includes all people not living in households. Two general categories of people in group quarters are recognized: (1) the institutionalized population and (2) the non institutionalized population. Institutionalized Population: The institutionalized population includes people under formally authorized, supervised care or custody in institutions at the time of enumeration, such as correctional institutions, nursing homes, and juvenile institutions. 112 Noninstitutionalized Population: The noninstitutionalized population includes all people who live in group quarters other than institutions, such as college dormitories, military quarters, and group homes. Also included is staff residing at institutional group quarters. Household: A household includes all of the people who occupy a housing unit. (People not living in households are classified as living in group quarters.) A housing unit is a house, an apartment, a mobile home, a group of rooms, or a single room occupied (or if vacant, intended for occupancy) as separate living quarters. Separate living quarters are those in which the occupants live separately from any other people in the building and that have direct access from the outside of the building or through a common hall. The occupants may be a single family, one person living alone, two or more families living together, or any other group of related or unrelated people who share living quarters. In 100 - percent tabulations, the count of households or householders always equals the count of occupied housing units. In sample tabulations, the numbers may differ as a result of the weighting process. Census Boundaries Census Tract: Designed to be relatively homogeneous units with respect to population characteristics, economic status, and living conditions at the time of establishment, census tracts average about 4,000 inhabitants. Census tract boundaries follow visible features, but may follow governmental unit boundaries and other non - visible features in some instances; they always nest within counties. For example, the area generally bounded by Pine Street, Main Street, Edinger Avenue, and Flower Street is census tract 746.01 in Santa Ana. Block Group: A subdivision of a census tract, a block group is the smallest geographic unit for which the Census Bureau tabulates sample data. A block group consists of all the blocks within a census tract with the same beginning number. For example, in Census Tract 746.01, the area bounded by West Pine Street, South Cypress Avenue, West Bishop Street, and South Birch Street is Block Group 2. Block Group 2 is comprised of all the individual blocks with a beginning numbering in the 2000 range. 113 This Page Intentionally Left Blank 114 Section 5 Regional Private Sector Fair Housing Analysis 115 SECTION 5 REGIONAL PRIVATE SECTOR FAIR HOUSING ANALYSIS Pursuant to a Scope of Work approved by HUD -LA, the Regional Al examines the following private sector impediments: • Housing Discrimination • Discriminatory Advertising • Blockbusting • Denial of Reasonable Accommodation • Hate Crimes • Unfair Lending A. HOUSING DISCRIMINATION 1. Prohibited Housing Discriminatory Practices Sections 804 (a), (b) and (d) of the 1968 Fair Housing Act describe several prohibited housing discriminatory practices such as the following: (a) To refuse to sell or rent after the making of a bona fide offer, or to refuse to negotiate for the sale or rental of, or otherwise make unavailable or deny, a dwelling to any person because of race, color, religion, sex, familial status, or national origin. (b) To discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of race, color, religion, sex, familial status, or national origin. (d) To represent to any person because of race, color, religion, sex, handicap, familial status, or national origin that any dwelling is not available for inspection, sale, or rental when such dwelling is in fact so available. Sections 804(f)(1), (2) and (3) prohibit the following practices because of a handicap: (1) To discriminate in the sale or rental, or to otherwise make unavailable or deny, a dwelling to any buyer or renter because of a handicap. (2) To discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection with such dwelling, because of a handicap. (3)(A) a refusal to permit, at the expense of the handicapped person, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises. (3)(B) a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling. 110 (3)(C) failure to comply with accessible design and construction requirements The California Fair Employment and Housing Act (FEHA) prohibits unlawful practices similar to those that are described in the Federal Fair Housing Act. For example, Article 2 — Housing Discrimination - Section 12955 of FEHA states the following are unlawful practices: (a) For the owner of any housing accommodation to discriminate against or harass any person because of the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or disability of that person. (b) For the owner of any housing accommodation to make or to cause to be made any written or oral inquiry concerning the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, or disability of any person seeking to purchase, rent or lease any housing accommodation. (f) For any owner of housing accommodations to harass, evict, or otherwise discriminate against any person in the sale or rental of housing accommodations when the owner's dominant purpose is retaliation against a person who has opposed practices unlawful under this section, informed law enforcement agencies of practices believed unlawful under this section, has testified or assisted in any proceeding under this part, or has aided or encouraged a person to exercise or enjoy the rights secured by this part. Nothing herein is intended to cause or permit the delay of an unlawful detainer action. (k) To otherwise make unavailable or deny a dwelling based on discrimination because of race, color, religion, sex, sexual orientation, familial status, source of income, disability, or national origin. HUD, the State Department of Fair Employment and Housing (DFEH) and FHCOC handle housing discrimination complaints. However, it is not known whether the number of complaints is a true measure of the incidents of housing discrimination. Housing discrimination may be underreported; therefore, the number of complaints may not accurately measure the extent of this private sector fair housing impediment. Evidence on underreporting is supported by a HUD - sponsored study conducted by The Urban Institute. That research study concluded: "Another finding with implications for fair housing programs involves the fact that so few people who believed they had been discriminated against took any action, with most seeing little point in doing so." The Urban Institute, How Much Do We Know: Public Awareness of the Nation's Fair Housing Laws, prepared for the U.S. Department of Housing and Urban Development, Office of Policy Development and Research, April 2002, pg. 7 A follow -up study finds that between 2001 and 2005 knowledge of fair housing laws has increased in two areas — discrimination against families with children and steering of prospective homebuyers by race — but declined in one area — discrimination based on religion. On a composite index of overall knowledge, there was no change between 2001 and 2005. There was, however, a significant increase in overall support for fair housing laws. 117 The study also explores whether people know what to do to address perceived discrimination and why so few people who perceive they have been discriminated against do anything about it. "Four of every five persons who believed they had experienced housing discrimination plausibly covered by the federal Act profess not ... to have done anything at all in response. Many alleged victims maintain they did not take action because they presumed doing so would not have been worth it or would not have helped. Some, however, did not know where or how to complain, supposed it would cost too much money or take too much time, were too busy, or feared retaliation. The minority who did respond mainly complained to the person thought to be discriminating or to someone else, but a small proportion also talked to or hired a lawyer or sought help from or filed a complaint with a fair housing or other group or government agency." The Urban Institute, Do We Know More Now? Trends in Public Knowledge. Support and Use of Fair Housing Law, prepared for the U.S. Department of Housing and Urban Development, Office of Policy Development and Research, February 2006, pg. iii 2. Discrimination Complaints a. Background With respect to housing discrimination complaints, the 2006 HUD study found: "About 17 percent of the adult public claims to have suffered discrimination at some point when trying to buy or rent a house or apartment. If, however, the explanations given about the nature of the perceived discrimination are taken into account, about eight percent of the public had experiences that might plausibly have been protected by the Act. While the frequency, actions, and bases for the alleged discrimination are diverse, majorities of this group believe they were discriminated against more than one time, were looking to rent more frequently than to buy, and identified race more so than any other attribute or characteristic as the basis of the discrimination." b. Number of Housing Discrimination Complaints The California Department of Fair Employment and Housing (DFEH) provided data to the FHCOC on housing discrimination complaints. The FHCOC compiled the statistics for this Regional Al. In the five -year period since the prior AI, about 300 housing discrimination complaints have been filed with DFEH. Table 5 -1 shows the number of housing discrimination cases by Entitlement Cities and Urban County Cities. The number of housing discrimination complaints averaged 60 per year. The number of cases ranged from a low of 46 in 2005 to a high of 78 in 2006. The vast majority — 244 of 302 housing discrimination complaints — have been filed in the Entitlement Cities. Irvine (58) and Anaheim (40) accounted for the highest number of complaints. Table 5 -2 shows the number of closed housing discrimination cases by entitlement and urban county cities. Once again, the Irvine (61) and Anaheim accounted for the highest number of closed cases (37). Closed cases refer to cases that have been completely investigated and resolved. 118 Table 5 -1 Regional Analysis of Fair Housing Impediments Housing Discrimination Cases Filed by Year Jurisdiction 2005 1 2006 2007 2008 2009 Total Entitlement Cities Anaheim 3 8 8 14 7 40 Buena Park 2 1 5 4 2 14 Fountain Valley 1 1 3 1 2 8 Fullerton 0 5 3 2 0 10 Garden Grove 5 2 0 0 6 13 Huntington Beach 2 8 5 2 1 18 Irvine 9 14 12 10 13 58 La Habra 0 2 0 0 1 3 Lake Forest 0 3 1 1 2 7 Newport Beach 4 8 3 5 3 23 Orange 2 3 3 3 4 15 Rancho Santa Margarita 0 1 0 1 0 2 Santa Ana 3 5 5 8 1 22 Westminster 0 2 4 1 4 11 Subtotal 31 63 52 52 46 244 Urban C unty Cities and Unincorporated Areas Aliso Viejo 1 1 2 0 1 5 Brea 0 0 0 3 0 3 Cypress 2 0 1 0 2 5 Dana Point 0 2 1 0 0 2 Foothill Ranch 1 0 0 0 0 1 La Palma 0 0 1 0 0 1 Ladera Ranch 1 2 0 0 0 3 Laguna Beach 1 1 2 1 0 5 Laguna Hills 2 3 1 1 0 7 Laguna Woods 1 0 1 0 0 2 Los Alamitos 0 0 1 0 0 1 Placentia 0 4 2 0 0 6 Seal Beach 0 1 3 0 0 4 Stanton 4 0 0 0 0 4 Villa Park 0 0 0 0 0 0 Yorba Linda 2 1 2 3 0 8 Subtotal 15 15 17 8 3 58 TOTAL 46 78 69 60 49 302 Unincorporated area Source: California Department of Fair Employment and Housing Table construction by Castaneda & Associates 119 Table 5 -2 Regional Analysis of Fair Housing Impediments Housing Discrimination Cases Closed by Year Jurisdiction 2005 2006 2007 2008 2009 Total Entitlement Cities Anaheim 4 2 7 13 11 37 Buena Park 3 0 4 2 5 14 Fountain Valley 0 1 2 3 2 8 Fullerton 1 3 2 5 0 11 Garden Grove 3 2 2 0 5 12 Huntington Beach 2 5 4 4 3 18 Irvine 9 14 7 13 18 61 La Habra 0 1 1 0 1 3 Lake Forest 2 2 1 1 1 7 Newport Beach 7 6 1 5 6 25 Orange 3 2 3 4 5 17 Rancho Santa Margarita 0 0 1 0 1 2 Santa Ana 1 6 7 7 3 24 Westminster 1 1 2 3 2 9 Subtotal 36 45 44 60 63 248 Urban County Cities and Unincorporated Areas Aliso Viejo 1 1 1 1 1 5 Brea 0 0 0 0 3 3 Cypress 2 1 0 1 0 4 Dana Point 0 0 2 1 0 3 Foothill Ranch 1 0 0 0 0 1 La Palma 0 0 0 1 0 1 Ladera Ranch 0 1 2 0 0 3 Laguna Beach 1 0 1 0 3 5 Laguna Hills 2 1 3 0 1 7 Laguna Woods 1 0 0 1 0 2 Los Alamitos 0 0 0 1 0 1 Placentia 0 0 3 2 1 6 Seal Beach 0 1 3 0 0 4 Stanton 0 2 0 9 0 11 Villa Park 0 0 0 0 0 0 Yorba Linda 1 1 1 2 3 8 Subtotal 9 8 16 19 12 64 TOTAL 45 53 60 79 75 312 Unincorporated area Source: California Department of Fair Employment and Housing Table construction by Castaneda & Associates 120 c. Bases for Housing Discrimination Complaints Tables 5 -3 and 5 -4 show the bases for the housing discrimination complaints for the Entitlement Cities and Urban County Cities. A housing discrimination complaint can have more than one basis. The bases include: • Physical Disability • Mental Disability • Race /Color • National Origin • Familial Status • Sex • Marital Status • Other - Retaliation; Religion; Source of Income; Association and Age About 35% of the housing discrimination complaints were based on a physical or mental disability. Since the prior Regional Al was completed, disability has been increasing as a basis for a housing discrimination complaint. Race and color (20 %) and national origin (14 %) rank second and third as a basis for making a housing discrimination complaint. Although Individual cities vary in terms of the basis for a housing discrimination complaint, disability, race /color and national origin also comprise the basis for the highest number of complaints. The bases for housing discrimination complaints in Orange County vary considerably from those found in the HUD studies. HUD's 2006 study found that 58% of those who believe they experienced discrimination think it was due to their race, followed by familial status (27 %) and ethnicity (17 %). According to the HUD study: "Surprisingly, less than one percent of the HUD survey respondents indicated disability as a reason for the perceived discrimination, whereas discrimination based on disability is among the most common complaints received by HUD." However, it should be noted that the Orange County findings are based on actual complaints filed, whereas the HUD study refers to persons who perceived housing discrimination but may not have filed a complaint. 121 Table 5 -3 Regional Analysis of Fair Housing Impediments Housing Discrimination Cases Filed by Bases 2005 -2009 For Entitlement Cities Jurisdiction Physical Disability Mental Disability Race/ Color Nat. Origin Familial Status Sex Marital Status Other' Total Anaheim 14 3 5 5 7 3 5 4 46 Buena Park 4 0 7 1 3 0 0 2 17 Fountain Valley 1 2 3 1 3 0 0 0 10 Fullerton 8 0 1 1 1 0 0 1 12 Garden Grove 1 2 1 5 5 2 0 0 16 Huntington Beach 9 0 1 5 6 1 1 3 26 Irvine 18 5 18 16 1 2 4 8 72 La Habra 0 1 1 1 0 0 0 0 3 Lake Forest 3 1 1 2 0 0 0 0 7 Newport Beach 9 3 7 2 4 0 1 3 29 Oran e 3 0 5 2 5 0 1 0 16 Rancho Santa Mar g. 2 0 0 0 0 0 0 0 2 Santa Ana 9 1 9 2 1 3 0 0 25 Westminster 1 2 1 4 1 3 0 3 15 Subtotal 82 20 60 47 37 14 12 24 296 Note: The number of bases exceeds the number of cases because a housing discrimination complaint can have more than one basis. Source: California Department of Fair Employment and Housing Other included Retaliation (9); Religion (8); Source of Income (3); Association (3) and Age (1) Table construction by Castaneda & Associates 122 Table 5 -4 Regional Analysis of Fair Housing Impediments Housing Discrimination Cases Filed by Bases 2005 -2009 For Urban County Cities Jurisdiction Physical Disability Mental Disability Race/ Color Nat. Origin Familial Status Sex Marital Status Other' Total Aliso Viejo 4 0 0 1 0 0 0 1 6 Brea 0 0 3 0 0 0 0 0 3 Cypress 3 1 2 0 0 2 0 2 10 Dana Point 1 0 0 0 1 2 1 0 5 Foothill Ranch 0 0 1 0 0 0 0 0 1 La Palma 0 0 0 0 0 1 1 1 3 Ladera Ranch 2 0 1 0 0 0 0 0 3 Laguna Beach 1 0 2 1 0 0 1 2 7 Laguna Hills 3 0 3 2 3 0 0 1 12 Laguna Woods 2 0 0 0 0 0 0 0 2 Los Alamitos 0 0 0 0 0 1 0 0 1 Placentia 1 3 0 2 0 0 0 0 6 Seal Beach 1 0 3 0 0 0 0 0 4 Stanton 2 0 1 0 2 0 0 0 5 Villa Park 0 0 0 0 0 0 0 0 0 Yorba Linda 3 0 0 0 2 0 0 3 8 Subtotal 23 4 16 6 8 6 3 10 76 TOTAL 105 24 76 53 45 1 20 15 1 341 372 Note: The number of bases exceeds the number of cases because a housing discrimination complaint can have more than one basis. Source: California Department of Fair Employment and Housing 'Other includes Retaliation (3); Religion (2); Source of Income (3); Association (2) Table construction by Castaneda & Associates 12S d. Alleged Acts The DFEH compiles data on number of housing discrimination cases according to nine types of alleged acts: • Refusal to Rent • Eviction • Refusal to Show • Refusal to Sell • Loan Withheld • Unequal Terms • Harassment • Unequal Access to Facilities • Denied Reasonable Modification /Accommodation Table 5 -5 shows the number of housing cases filed by alleged acts between 2005 and 2009. A summary of the highest number and percentage of alleged acts is presented below: • About 22% (101) of the housing discrimination complaints occurred during the eviction process. • About 19% each of the alleged acts pertained to unequal terms (88) and to denial of a reasonable modification and /or accommodation (87). • About 15% each of the housing cases were filed because of harassment (72) and the refusal to rent (68). It appears that most of the alleged acts affect renters or persons seeking rental housing. This mirrors HUD's national study which found that about 70% of persons who thought they were victims of discrimination were looking to rent at the time. In summary, progress on reducing housing discrimination probably cannot be measured by a reduction in the number of complaints because so few people who believe they have been victims of discrimination actually file a complaint. Therefore, progress — at least in the short run — could be measured by an increase in complaints as more people: • Become aware that they can file a complaint • Know where to file a complaint • Believe that their complaint will produce tangible results W0119 Table 5 -5 Regional Analysis of Fair Housing Impediments Housing Cases Filed By Alleged Act — 2005 -2009 Alleged Act 2005 2006 2007 2008 2009 Total Percent Refusal to Rent 8 16 20 15 9 68 14.7% Eviction 20 28 19 19 15 101 21.9% Refusal to Show 1 2 0 0 0 3 0.7% Refusal to Sell 5 4 1 0 1 11 2.4% Loan Withheld 0 3 1 1 1 6 1.3% Unequal Terms 13 27 23 12 13 88 19.1% Harassment 13 23 18 8 10 72 15.6% Unequal Access to Facilities 3 4 8 4 6 25 5.4% Denied Reasonable Modification /Accommodations 10 14 25 18 20 87 18.9% Total 73 121 115 77 75 461 100.0% Source: California Department of Fair Employment and Housing Note: includes alleged acts occurring in the cities participating in the Regional Al Total acts reported exceed the total number of cases filed because some cases are filed under more than one act Table construction by Castaneda & Associates 3. Housing Discrimination Complaint Services The Fair Housing Council of Orange County is a private non - profit organization formed in 1965 in the wake of the civil rights movement that resulted in the Civil Rights Act of 1964. The Council incorporated in 1968, the same year that Congress extended civil rights protections to cover housing with the adoption of the Fair Housing Act. Under the direction of a volunteer board of directors and with a paid staff of 14, the agency works to fulfill a mission of protecting the quality of life in Orange County by ensuring equal access to housing opportunities, fostering diversity and preserving dignity and human rights. Contracting to serve 15 Entitlement Cities and the Urban County Program for the provision of fair housing services for their residents, the Fair Housing Council handles more than 100 cases of alleged housing discrimination in the county each year. 4. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: • Continue to process housing discrimination complaints filed by city and county residents. Conduct testing of housing provider practices to determine whether there are differences in treatment based on a protected class. The 2005 -2009 housing discrimination complaint data and the fair housing community profile can be used to identify the protected classes and locations of housing providers that should be tested. 125 • Revise its website to provide direct access to a housing discrimination complaint form and provide a diagram or brief explanation of the process for investigating and resolving a complaint. • Revise its website to add more information on how residents can detect whether they have been victims of unlawful housing discrimination. Publish a quarterly report on the FHCOC website summarizing the remedies pertaining to filed housing discrimination complaints. • Ensure that all jurisdictions provide a link to the FHCOC website. Compile an Annual Report on housing discrimination complaints filed with the FHCOC, the State Department of Fair Employment and Housing (DFEH) and HUD. The report will include housing discrimination complaints unique to each participating jurisdiction as well as those of the entire County. The Annual Report will describe emerging trends within the City and County. • Transmit the Annual Report to the participating jurisdictions by August of each calendar year. This schedule allows the jurisdictions to include a summary of the report findings in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. B. DISCRIMINATORY ADVERTISING 1. Background Section 804 (c) of the 1968 Fair Housing Act prohibits discriminatory advertising; it is unlawful: To make, print, or publish, or cause to be made, printed, or published any notice, statement, or advertisement, with respect to the sale or rental of a dwelling that indicates any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. The California Fair Employment and Housing Act contains similar language prohibiting discriminatory advertising. To demonstrate whether discriminatory advertising meets the threshold for being considered a regional impediment to fair housing choice, print and online advertising was reviewed during the month of January 2010. Classified ads printed in the Los Angeles Times and Orange County Register were reviewed for words and phrases that might be viewed as discriminatory. During this period, however, few for -rent ads were published in either newspaper. Because of limited newspaper print advertising, an online search of apartment ads was conducted via Apartments. com, which is provided by the Los Angeles Times. Each ad was reviewed to determine if it might discrimination." Advertisements which describe the available at the property are generally considered any indicate a "preference, limitation or property being advertised or the services acceptable. The review, then, focused on 120 words and phrases that deviated from physical descriptions of the property and available services. Guidance on specific words and phrases that are or could be interpreted as discriminatory was obtained from the following: • Roberta Achtenberg, Assistant Secretary for Fair Housing and Equal Opportunity, HUD, "Guidance Regarding Advertisements under Section 804 (c) of the Fair Housing Act," January 9, 1995 • Bryan Green, Deputy Assistant Secretary for Enforcement, Fair Housing Act Application to Internet Advertising, September 20, 2006 [memorandum to FHEO Regional Directors] • California Newspaper Publishers Association, Fair Housing Advertising Manual, Fourth Edition, Copyright, 2001 • 24 CFR 109.30 Appendix I to Part 109 — Fair Housing Advertising. Part 109 is no longer officially part of the Code of Regulations having been withdrawn effective May 1, 1996. However, it is still published on HUD's website • State Department of Fair Employment and Housing, Guidance Memorandum These sources provide guidance on the specific words and phrases that are or could be considered discriminatory with respect the following: • Race /Color /National Origin /Ancestry • Sex • Disability • Familial /Marital Status • Religion • Source of Income • Sexual Orientation • Senior Housing Attachment A is a summary of the California Newspaper Publishers Association guidance on advertising words and phrases. 2. Review of Print Ads and Online Advertising The newspaper print and online ads were reviewed and organized by Entitlement City and Urban County jurisdiction and a data base was developed — by city — of the number of ads, the number that contained "questionable language" and the frequency of the ads. Questionable language refers to words and phrases that deviated from the physical description of the for -rent unit and services available. Table 5 -6 shows the number of ads placed by apartment complexes located in each city. A total of 177 apartment complexes were advertised online at Apartments.com for Entitlement Cites. There were 44 online ads for complexes in Urban County Cities. 127 Table 5 -6 Regional Analysis of Fair Housing Impediments Number of Apartment Complexes Publishing For Rent Ads by Jurisdiction and Unincorporated Area ( Apartment.com) — January 2010 Entitlement Cities Number of Complexes Anaheim 43 Buena Park 8 Fountain Valley 6 Fullerton 13 Garden Grove 9 Huntington Beach 14 Irvine 10 Lake Forest 8 La Habra 10 Newport Beach 6 Orange 9 Rancho Santa Margarita 8 Santa Ana 14 Tustin 13 Westminster 6 Urban County Cities /Area Aliso Viejo 11 Brea 6 Cypress 4 Dana Point/Ca istrano Beach 2 Foothill Ranch 2 una Beach 1 -Lag Hills 4 -Laguna Los Alamitos N/A La Palma 2 Ladera Ranch 3 Woods N/A -Laguna Midway City' 0 Placentia 4 Seal Beach 1 Stanton 1 Trabuco Canyon' N/A Villa Park N/A Yorba Linda 3 'Unincorporated area Source: Apartment.com website search conducted on January 4, 2010 Note: 0 denotes no listings available from Apartments.com. N/A denotes no information available from Apartments.com Table construction by Castaheda & Associates 122 The overwhelming number of ads in the Entitlement Cities conveyed information that was limited to the location of the apartment, number of bedrooms and bathrooms, and monthly rent. Very few ads — about 8% - contained language that did not pertain to the physical description of the property. The most frequent words or phrases included: "Section 8 Vouchers Accepted" • "No pets allowed" In the Urban County Cities, only three ads had questionable language. Two ads stated income restrictions and one noted its proximity to "places of worship ". Table 5 -7 provides an analysis of the print ads with respect to the city in which the apartment complex is located; number of ads placed; ads with non - property related words and phrases; and the number of ads published with those words and phrases. There was a total of 427 unique print ads published in The Orange County Register in the four January Sunday editions for apartments (223) and homes for rent (204) in Entitlement Cities. (January 3, January 10, January 17 and January 24, 2010) The number of unique print ads corresponds to the number of apartment complexes or homes publishing an ad. Forty seven of the 223 apartment ads contained non - property related words or phrases. The overwhelming majority of the non - property related words or phrases was "No Pets" which occurred in 38 (17 %) of the 223 apartment ads. There were also references to rental assistance such as "Section 8 ok" and "HUD ok ". Some ads were published multiple times during the four week period. Twenty -eight of the 204 homes for rent ads contained non - property related words or phrases. Once again, the "no pets' was the most frequent non - property related word or phrase, having occurred in 26 (12.7 %) of the 204 ads. Table 5 -8 shows the same analysis for the Urban County Cities. There were 62 unique ads for apartments and homes for rent. Ten ads had words and phrases that did not pertain to the physical description of the property: seven stated "no pets' two were "Section 8" related and one ad stated "Senior Citizen ". 3. Examples of Possible Advertising Impediments a. Source of Income Source of income is a protected class under California's fair housing law, effective January 1, 2000. Thus, it is unlawful to print or publish an advertisement that prefers, limits or discriminates on the basis of the source of the tenant's income. However, according to the California Newspaper Publishers Association, an ad referring to a government program in which an agency makes payments directly to landlords, e.g. the federal government's Section 8 housing program, would probably not be unlawful so long as the tenant's benefit or "income" is not paid directly to the "tenant or the tenant's representative ". Thus, unless an ad taker knows the term is being used as a code word for unlawful discrimination, an ad that says "Section 8 ok ", or "No Section 8" would probably not expose the newspaper to liability under the law's definition. 129 Table 5 -7 Analysis of Rental Ads in Entitlement Cities Orange County Register January 2010 Table construction by Castaneda & Associates ISO Apartment Ads Homes /Condos/Town Home Ads City Total # of Ads Ads With Non - Property Related Words /Phrases # of Ads Total # of Ads Ads With Non - Property Related Words /Phrases # of Ads Anaheim 38 No Pets /Sect. 8 ok 1 25 No Pets 3 No Pets 4 HUD OK 1 Section 8 Housing Accepted 1 Section 8 welcome 1 HUD ok 1 Total Ads 8 4 Buena Park 10 Sec. 8 welcome /Income Qualification Apply 1 3 Section 8 ok 1 No Pets 1 Total Ads 2 1 Fountain Valley 2 No Pets 2 8 No Pets 1 Total Ads 2 1 Fullerton 23 Section 8 Housing ok/No Pets 1 11 None N/A No Dos 1 No Pets 2 Total Ads 4 0 Garden Grove 24 No Pets 1 8 No Pet 3 Section 8 welcome 1 Total Ads 2 3 Huntington Beach 64 No Do 3 60 No Pets 10 No Pets 13 Total Ads 16 10 Irvine 2 None N/A 24 No Pets 4 Total Ads 0 4 La Habra 3 No Pets 1 3 None N/A Sect. 8 ok 1 Total Ads 2 0 Lake Forest 0 N/A N/A 4 No Pets 1 Total Ads 0 1 Newport Beach 12 HUD OK 1 17 No Pets 1 No Pets 1 Total Ads 2 1 Orange 27 No Pets 3 23 No Pets 2 Good Residents Wanted /No Pets 1 Total Ads 4 2 Rancho St. Margarita 2 None NIA 0 N/A N/A Total Ads 0 0 Santa Ana 8 Near Church /School 1 7 None N/A No Pets 1 Total Ads 2 0 Westminster 8 No Pets 2 11 No Pets 1 HUD OK 1 Total Ads 3 1 ALL ADS 223 47 204 28 Table construction by Castaneda & Associates ISO Table 5 -8 Analysis of Rental Ads in Urban County Cities Orange County Register January 2010 Source: Print ads in the four Sunday editions of the Orange County Register on January 3, January 10, January 17 and January 24, 2010 Table construction by Castaneda & Associates 'The ad appeared twice, once without the No Pets comment 2The ad appears four times, once with the No Dogs comment 2S2 Apartment Ads Homes /Condos/Town Home Ads Total # of Ads Ads With Non Property Related Language # of Ads Total # of Ads Ads With Non Property Related Language # of Ads Aliso Viejo 0 N/A N/A 4 None N/A Total Ads 0 0 Brea 3 No Pet 1 7 No Pets 2 Total Ads 1 2 C press 1 None N/A 3 None N/A Total Ads 0 0 Dana Point 1 Section 8 welcome 1 4 None N/A Total Ads 1 0 Foothill Ranch D N/A N/A 1 None N/A Total Ads 0 0 Laguna Beach 0 N/A N/A 1 None N/A Total Ads 0 0 Laguna Hills 0 N/A N/A 4 No Pets 1 Total Ads 0 1 Laguna Woods 0 N-/A N/A 4 No Pets 1 Total Ads 0 1 La Palma 0 N/A N/A 2 None N/A Total Ads 0 0 Los Alamitos 0 N/A N/A 0 N/A N/A Total Ads 0 0 Midway City 17N-one N/A 2 None N/A Total Ads 0 0 Placentia 6 Section 8 ok 1 4 No Dogs 1 Total Ads 1 1 Seal Beach 0 N/A N/A 0 N/A N/A Total Ads 0 0 Stanton 1 None N/A 2 None N/A Total Ads 0 0 Villa Park 0 N/A N/A 1 None N/A Total Ads 0 0 Yorba Linda 6 SR. CITIZEN 1 4 None N/A No Pets 1 Total Ads 2 0 ALL ADS 19 5 43 5 Source: Print ads in the four Sunday editions of the Orange County Register on January 3, January 10, January 17 and January 24, 2010 Table construction by Castaneda & Associates 'The ad appeared twice, once without the No Pets comment 2The ad appears four times, once with the No Dogs comment 2S2 The rental housing market is accepting tenants that receive Section 8 rental assistance. Most of the ads contained phrases such as "Section 8 OK "; "HUD OK "; "Section 8 Welcome "; and "Section 8 Accepted ". When the rental housing market vacancy rates become significantly lower, landlords may not have an incentive to attract tenants receiving Section 8 assistance. Under these conditions, "No Section 8" ads may become an impediment to fair housing choice because, in part, it could make such housing unavailable disproportionately to a protected class such as persons with disabilities. However, an ad stating "No Section 8" would not be illegal because under the California Fair Employment and Housing Act, "source of income" refers to income paid directly to a tenant or tenant's representative. A landlord that receives a Section 8 rental payment on behalf of a tenant from a housing authority is not considered a representative of the tenant. b. No Pets Persons with a disability are one of the classes protected from discrimination in housing. Apartments must allow, under certain conditions, "service animals' and "companion animals ". A service animal is one trained to do work or perform tasks for the benefit of a person with a disability. A service animal can be of varying species, breed or size. It might wear specialized equipment such as a backpack, harness, special collar or leash, but this is not a legal requirement. Companion animals, also referred to as assistive or therapeutic animals, can assist individuals with disabilities in their daily living and as with service animals, help disabled persons overcome the limitations of their disabilities and the barriers in their environment. They are typically for individuals with mental disabilities and can assist the person with depression, anxiety or provide emotional support. Under Federal and State fair housing laws, individuals with disabilities may ask their housing provider to make reasonable accommodations in the "no pets" policy to allow for their use of a companion /service animal. The housing provider may ask the disabled applicant/tenant to provide verification of the need for the animal from a qualified professional. Once that need is verified, the housing provider must generally allow the accommodation. Some disabled persons are unaware of their fair housing rights and, as a consequence, may not consider as available to them apartments with ads that state "no pets." Therefore, an action to affirmatively further fair housing is to persuade the Los Angeles Times, Orange County Register and Apartments.com to publish a concise "no pets" notice that indicates rental housing owners must provide reasonable accommodations, including "service animals' and "companion animals" for disabled persons. c. Acme Federal regulations specify that unless the housing being offered meets government requirements for "senior" or "senior only" housing, advertisers may not express a preference or limitation on the basis of age. A few ads contained phrases indicating a preference for seniors. One ad stated "senior citizen ". It appears that this ad was placed by an individual owner of a condominium. However, it is not known if the condominium complex met the requirements of a senior only complex. Two apartment complexes placed ads stating that a 5% discount was given to seniors. The complexes are located in Orange and Westminster and are managed by the same company. I32 4. Fair Housing Notices The Los Angeles Times and Apartments.com publish fair housing notices. The Los Angeles Times notice is published on the same page as the rental ads and states that it is illegal to indicate any preference, limitation or discrimination because a person belongs to one of the protected classes. It also refers readers to the Housing Rights Center and the Fair Housing Council of Orange County. Apartments.com states in its disclaimer that it and all home sellers and landlords must adhere to fair housing laws such as the Civil Rights Act of 1964, the American with Disabilities Act, and the Equal Credit Opportunity Act. It also states that those seeking to rent an apartment "have the right to expect... reasonable accommodation in rules, policies and procedures for persons with disabilities." However, the fair housing notice is difficult to find on the website and persons placing an ad are not required to read the notice before an ad is placed. In a review of the rental ads in both print and online editions of The Orange County Register, a fair housing disclaimer was not located. Typically, such a disclaimer is located at the beginning of the real estate classified ads section. S. Internet Advertising The National Fair Housing Alliance (NFHA) completed a study in 2009 of discriminatory ads placed by housing providers on various websites. The most common Fair Housing Act violation that NFHA and its members found on the Internet was advertising discriminating against families with children. NFHA found ads stating preferences for tenants who were "single' or "a couple of individuals." Phrases such as "perfect for young couple" or "three adults" were found in ads for houses or apartments with multiple bedrooms. These ads indicate an illegal preference or limitation and discourage families with children from even considering contacting a landlord. The investigation also found discriminatory ads stating preferences based on national origin, religion and sex. In California, the following are examples of ads that were placed on websites: • .quiet complex of responsibles without kids" • "no kids" • "no pets, no children According to the NFHA study, Craigslist, the source of the overwhelming majority of housing advertising in today's market, and other Internet sites provide a convenient forum for illegal housing discrimination. Under current court decisions, these websites are not considered to be publishers and thus can neither be held liable under the Fair Housing Act nor be required to screen out illegal housing advertisements. Only the individual landlords who create and post discriminatory ads online can be held responsible. The Communications Decency Act (CDA) is Title V of the Telecommunications Act of 1996 and was intended to protect families from online pornography and other forms of indecency. It states that operators of Internet services are not to be construed as publishers, and thus are not legally liable for the words of third parties who use their services. The CDA makes exceptions to i33 this rule as it relates to federal criminal statutes and intellectual property law, but does not make explicit exceptions for civil rights laws like the Fair Housing Act. Private fair housing organizations, according to the NFHA study, have brought two lawsuits against online housing advertisers for publishing discriminatory housing advertisements. In each instance, the Court accepted the website's argument that the CDA protected it from liability under the Fair Housing Act to the extent that users provided content. In reaching these decisions, the Courts relied upon Section 230(c) of the CDA to find that operators of interactive websites are not to be construed as "publishers' of the words posted by users of their websites. This section, entitled Protection for 'Good Samaritan' Blocking and Screening of Offensive Material, "aim[s] to protect interactive computer service providers 'who take (steps to screen indecent) and offensive material for their customers. "' Ironically, in refusing to take responsibility for discriminatory advertisements, these websites have screened nothing, opting instead to facilitate widespread distribution of discriminatory ads. The NFHA states that the most effective way to stop discrimination in online housing ads is to hold all housing advertisers and publishers to the same standard. In order to hold accountable websites advertising housing, just as newspapers are currently held accountable, the Communications Decency Act of 1996 must be amended. Specifically, Section 230(c)(1) is the section of the CDA that provides immunity to websites for third party content. 47 U.S.C. § 230(c)(1) currently reads: "TREATMENT OF PUBLISHER OR SPEAKER- 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." The NFHA recommends that this section of the CDA should be amended to accommodate the requirements of the Fair Housing Act. An exemption could be made specifically for Fair Housing Act claims and amend 47 U.S.C. § 230(c)(1) as follows: "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, 42 U.S.C. § 3601 et seq." If the CDA is amended, websites will be responsible for the discriminatory advertisements they publish on the Internet and, therefore, will have an incentive to implement filtering systems to prevent discriminatory advertisements from ever reaching the public. 9=r 6. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: • 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. • 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. • 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, 42 U.S.C. § 3601 at seq. • Periodically review for rent and for sale ads published in the print media. • Prepare a summary of the accomplishments each year and transmit to the Entitlement Cities and Urban County in August of each year. This schedule allows the Entitlement Cities and Urban County to include a summary of the accomplishments in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. C. BLOCKBUSTING 1. Background Section 804(e) of the 1968 Fair Housing Act makes the following act, commonly referred to as blockbusting, unlawful: For profit, to induce or attempt to induce any person to sell or rent any dwelling by representations regarding the entry or prospective entry into the neighborhood of a person or persons of a particular race, color, religion, sex, handicap, familial status, or national origin. Blockbusting and panic selling can occur when an individual, possibly a real estate licensee, claims that an impending change in the demographic composition of a neighborhood will cause property values to fall, crime to increase or schools to decline in quality. Section 10177(1)(1) of the Business and Professions Code states that the Real Estate Commissioner may revoke or suspend the license of a real estate licensee if he /she has done the following: i35 Solicited or induced the sale, lease, or listing for sale or lease of residential property on the ground, wholly or in part, of loss of value, increase in crime, or decline of the quality of the schools due to the present or prospective entry into the neighborhood of a person or persons having a characteristic listed in subdivision (a) or (d) of Section 12955 of the Government Code, as those characteristics are defined in Sections 12926 and 12926.1, subdivision (m) and paragraph (1) of subdivision (p) of Section 12955, and Section 12955.2 of the Government Code. Government Code Section 12955 states it shall be unlawful: (a) For the owner of any housing accommodation to discriminate against or harass any person because of the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or disability of that person. (d) For any person subject to the provisions of Section 51 of the Civil Code, as that Section applies to housing accommodations, to discriminate against any person on the basis of sex, sexual orientation, color, race, religion, ancestry, national origin, familial status, marital status, disability, source of income, or on any other basis prohibited by that section. With respect to blockbusting, the California law has more protected classes than the Federal Fair Housing Act. There is no local or county agency that maintains records on actual or potential blockbusting incidents. Such incidents would take place primarily as real estate agents attempt to solicit or induce homeowners to sell their homes. As previously noted, the California Real Estate Commissioner is authorized to take disciplinary action against licensees who have committed the prohibited discriminatory practice of blockbusting and panic selling. The Department of Real Estate stated in June 2010 that no Orange County licensee has had their license suspended or revoked because of the illegal practice of blockbusting. 2. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: • Provide information on the FHCOC website on the unlawful practice of blockbusting including examples of this illegal practice. • Work with the California Department of Real Estate to determine if any Orange County licensees have had their licenses suspended or revoked because of the illegal practice of blockbusting. • In the event, a licensee has been found to have committed blockbusting, provide education and information on this practice to the responsible broker and all related salespersons. ISO D. DENIAL OF REASONABLE MODIFICATION /ACCOMMODATION 1. Background It is unlawful to refuse to make reasonable accommodations for disabled persons. Section 804 (3) of the 1968 Fair Housing Act states that discrimination includes -- (A) a refusal to permit, at the expense of the handicapped person, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises, except that, in the case of a rental, the landlord may where it is reasonable to do so condition permission for a modification on the renter agreeing to restore the interior of the premises to the condition that existed before the modification, reasonable wear and tear excepted. (B) a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling. The DFEH compiles data on the number of housing discrimination cases according to nine types of alleged acts. During the 2005 -2009 period, 461 alleged discriminatory acts were committed in the cases processed by the DFEH. Of this total, 87 or 18.9% involved denial of a reasonable modification /reasonable accommodation. About 17 -18 denials of reasonable modification /reasonable accommodation occurred per year during the five -year period. 2. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: • Provide education and information on why this practice is unlawful to the owners and managers of apartment complexes and homeowner associations. • Provide information on the unlawful practice of denying reasonable modifications /reasonable accommodations at fair housing seminars conducted by the Apartment Association of Orange County. E. HATE CRIMES 1. Background Hate crime means — ,.a criminal act committed, in whole or in part, because of one or more of the following actual or perceived characteristics of the victim: (1) disability, (2) gender, (3) nationality, (4) race or ethnicity, (5) religion, (6) sexual orientation, (7) association with a person or group with one or more of these actual or perceived characteristics." [Source: California Penal Code section 422.55] 137 According to the California Department of Justice (DOJ), hate crimes are not separate distinct crimes but rather traditional offenses motivated by the offender's bias. A bias is — A preformed negative opinion or attitude toward a group of persons based on their race, ethnicity, national origin, religion, gender, sexual orientation and /or physical /mental disability. Police and Sheriff Department's report to the DOJ hate crime events which are - An occurrence where a hate crime is involved. In the DOJ report, the information about the event is a crime report or source document that meets the criteria for a hate crime. There may be one or more suspects involved, one or more victims targeted, and one or more offenses involved for each event. A hate crime victim — May be an individual, a business or financial institution, a religious organization, government, or other. For example, if a church or synagogue is vandalized and /or desecrated, the victim would be a religious organization. According to HUD, Regional Als should analyze housing related hate crimes; that is; where an event takes place at a residence, home or driveway. When hate crimes occur at a home, the victims can feel unwelcome and threatened. The victims may feel that they have no choice other than to move from the dwelling and neighborhood of their choice. It is under these circumstances that hate crimes create a lack of fair housing choice. 2. Hate Crime Events Hate crime events were reviewed for the 5 -year period from 2004 to 2008 as reported by Criminal Justice Statistics Center of the California Department of Justice. Table 5 -9 shows the number of hate crime events by city during the five -year period. The annual average of events was 73 and, during the five -years there was a narrow low (69) to high (79) range. Except for the City of Huntington Beach, on a city -by -city basis, the number of hate crime events is low. In 2008, according to the Orange County Human Rights Commission (OCHRC), there were 79 cases of hate crimes in Orange County, essentially unchanged from the 80 cases in 2007. Despite the fact that the African American population makes up less than 2% of Orange County's population, this group continues to be the most frequent target for hate crimes. Hate crimes against Latinos continues to increase. In fact, since 2006 there has been almost a 100% increase in the number of cases reported. After a four -year downward trend, hate crimes against Jews increased. Additionally, while there was a slight decrease in hate crimes reported against Gays and Lesbian, this group frequently underreports. Table 5 -10 shows the number of hate crime events by bias motivation for the period from 2004 to 2008. Almost two - thirds of all hate crime events in California had race /ethnicity /national origin as the bias motivation. Just over one -third of all hate crime events in the State have a anti -Black bias motivation. Sexual orientation and anti - religion were the bias motivation of 18.9% and 16 %, respectively, of all hate crime events in California. 138 Table 5 -9 Regional Analysis of Fair Housing Impediments Number of Hate Crime Events by Jurisdiction /City -2004 to 2008 City/Jurisdiction 2004 2005 2006 2007 2008 Average Percent Sheriffs Department 9 2 0 5 6 4.4 6.0% Aliso Viejo 0 1 1 1 0 0.6 0.8% Anaheim 6 3 6 4 3 4.4 6.0% Brea 0 3 3 1 1 1.6 2.2% Buena Park 0 1 0 1 1 0.6 0.8% Costa Mesa 1 0 3 0 2 1.2 1.6% Cypress 1 1 0 2 2 1.2 1.6% Dana Point 0 0 0 1 0 0.2 0.3% Fountain Valley 3 0 8 2 1 2.8 3.8% Fullerton 2 2 4 2 1 2.2 3.0% Garden Grove 6 6 9 9 4 6.8 9.3% Huntington Beach 11 27 11 9 9 13.4 18.3% Irvine 3 2 5 2 9 4.2 5.7% La Habra 3 2 0 3 4 2.4 3.3% Laguna Beach 2 0 1 0 1 0.8 1.1% Laguna Hills 1 3 1 1 1 1.4 1.9% Laguna Niguel 0 0 1 0 0 0.2 0.3% Lake Forest 3 0 1 0 0 0.8 1.1% Los Alamitos 0 1 2 5 1 1.8 2.5% Mission Viejo 1 1 2 0 3 1.4 1.9% Newport Beach 4 5 2 7 7 5.0 6.8% Orange 0 2 5 4 3 2.8 3.8% Placentia 0 1 2 0 0 0.6 0.8% Rancho Santa Margarita 2 2 2 1 0 1.4 1.9% San Clemente 1 2 1 2 1 1.4 1.9% San Juan Capistrano 0 0 0 2 0 0.4 0.5% Santa Ana 2 4 3 0 1 2.0 2.7% Stanton 0 0 0 3 1 0.8 1.1% Tustin 0 0 0 1 4 1.0 1.4% Villa Park 1 1 0 0 0 0.4 0.5% Westminster 6 4 4 0 2 3.2 4.4% Yorba Linda 3 2 0 1 0 1.2 1.6% CSU Fullerton 0 0 1 1 1 0.6 0.8% UC Irvine 0 1 0 0 0 0.2 0.3% Total 71 79 78 70 69 73 100.0% Source: California Department of Justice, Division of California Justice Information Services, Bureau of Criminal Information and Analysis, Criminal Justice Statistics Center "Hate Crimes in California, 2004, 2005, 2006, 2007 and 2008" Table construction by Castaneda & Associates 139 Table 5 -10 State of California Hate Crimes Events and Bias Motivation Bias Motivation 2004 2005 2006 2007 2008 Average Percent Total 1,409 1,397 1,306 1,426 1,397 1,387 100.0% Race/Ethnicity/National Origin 921 916 844 932 800 883 63.7% Anti -White 61 77 64 73 42 63 4.5% Anti -Black 500 490 462 498 457 481 34.6% Anti - Hispanic 138 147 153 160 147 149 10.7% Anti - American Indian /Alaska Native 3 2 4 1 1 2 0.1% Anti - Asian /Pacific Islander 69 50 52 53 37 52 3.7% Anti-Multiple Race Groups 45 61 45 51 47 50 3.6% Anti -Other Ethnicity/National Origin 105 89 94 96 69 91 6.5% Religion 205 205 205 203 294 222 16.0% Anti - Jewish 142 141 129 134 184 146 10.5% Anti - Catholic 9 10 11 10 12 10 0.7% Anti - Protestant 3 10 13 11 8 9 0.6% Anti - Islamic Muslim 29 12 14 13 11 16 1.2% Anti -Other Religion 19 25 23 24 63 31 2.2% Anti-Multiple Religious, Group 3 6 14 9 15 9 0.7% Anti-Atheism/Agnosticism/etc. 0 1 1 2 1 1 0.1% Sexual Orientation 263 255 246 263 283 262 18.9% Anti-Gay 188 161 163 132 154 160 11.5% Anti - Lesbian 37 40 23 26 22 30 2.1% Anti-Gay and Lesbian 36 49 57 101 102 69 5.0% Anti - Heterosexual 1 1 0 2 3 1 0.1% Anti - Bisexual 1 4 3 2 2 2 0.2% Physical/Mental Disability 4 3 3 3 4 3 0.2% Anti-Physical Disability 2 3 1 2 2 2 0.1% Anti - Mental Disability 2 1 0 21 1 1 2 1 1 0.1% Gender 16 18 8 25 16 17 1.2% Anti -Male 1 1 0 0 0 0 0.0% Anti - Female 0 4 0 2 3 2 0.2% Anti -Trans ender 15 13 8 23 13 14 1.0% Source: California Department of Justice, Division of California Justice Information Services, Bureau of Criminal Information and Analysis, Criminal Justice Statistics Center "Hate Crimes in California, 2007 and 2008" Table construction by Castaneda & Associates 140 Table 5 -11 shows the hate crime bias motivation in 2007 and 2008, according to the Orange County Human Relations Commission. Table 5 -11 Hate Crimes in Orange County 2007 and 2008 Basis of Bias 2007 Percent 2008 Percent African American 18 22.4% 23 29.5% Latino 12 15.0% 15 19.5% Gay/Lesbian 14 17.4% 11 13.9% Jewish 7 8.8% 10 12.7% Muslim /Middle Eastern 4 5.0% 4 5.1% Christian 1 71 8.8% 1 1 1 1.3% Asian 2 2.5% 2 2.5% White 3 3.8% 0 0.0% Multiple 13 16.3%1 13 16.5% Total 80 100.0% 1 79 100.0% Source: Orange County Human Relations Commission, 2008 Orange County Hate Crime Report Table construction by Castaneda & Associates According to the OCHRC, there was an increase in crimes occurring at residential locations, the majority of which involved vandalism. One -third of the hate crimes reported in 2007 were at a residential location. That number increased to 40% in 2008. There was a significant increase in the number of hate crimes taking place on school campuses. Again the majority of these were acts of vandalism. More than one half of all hate crimes reported in both 2007 and 2008 involved acts of destruction or vandalism. The vandalism most frequently involved graffiti. The California DOJ reports the location of hate crime events for the entire state by 25 categories (e.g., church, park, college, etc). Table 5 -12 indicates the location of hate crimes for the period from 2004 to 2008. During the past five years two locations are predominant, accounting for about 60% of all hate crime locations: Highway /Road /Alley /Street (29.1 %) and Residence /Home /Driveway (29.7 %). The application of the statewide housing location average of 29.7% to the annual Orange County average of hate crime events of 73 yields at estimate of 22 annual events occurring at a residence, home or driveway. The application of the 40% factor cited by the OCHRC yields an estimate of 29 events occurring at a housing location. On an individual city basis, the number of hate crime events occurring at a housing location is small. However, the number at the countywide level is significant and, as a result, the resources to monitor and alleviate this impediment are best handled at the regional level. The agencies best equipped to assist cities to ameliorate and reduce the impact of hate crimes on families already living in their neighborhood of choice include: • Fair Housing Council of Orange County • Orange County Human Relations Commission • Center OC • Orange County Victim Assistance Partnership 141 Table 5 -12 State of California Location of Hate Crimes- 2004 to 2008 Location 2004 2005 2006 2007 2008 Average Percent Total 1,770 1,691 1,702 1931 1,397 1,698 100.0% Air /Bus/Train Terminal 31 17 6 16 14 17 1.0% Bank/Savings and Loan 3 4 2 3 2 3 0.2% Bar/Night Club 27 24 21 41 25 28 1.6% Church /Synagogue /Temple 74 84 84 72 107 84 5.0% Commercial /Office Building 48 38 30 38 32 37 2.2% Construction Site 3 1 3 3 2 2 0.1% Convenience Store 27 27 12 7 9 16 1.0% Department/Discount Store 10 9 4 10 7 8 0.5% Drug Store /Dr.'s Office/Hospital 11 6 5 5 5 6 0.4% FieldNVoods /Park 31 38 38 83 41 46 2.7 % Government/Public Building 10 17 25 29 29 22 1.3% Grocery/Supermarket 11 14 11 18 8 12 0.7% Highway/Road/Alley/Street 536 456 545 569 363 494 29.1% Hotel /Motel /etc 13 8 9 10 7 9 0.6% Jail /Prison 18 14 10 33 17 18 1.1% Lake/Waterway/Beach— 12 15 9 11 4 10 0.6% Liquor Store 4 7 5 11 1 6 0.3% Parkin Lot/Garage 86 138 135 117 110 117 6.9% Rental Storage Facility 3 0 0 0 0 1 0.0% Residence/Home/Driveway 551 511 504 571 388 505 29.7% Restaurant 49 48 40 48 42 45 2.7% School/College 155 176 152 182 148 163 9.6% Service /Gas Station 11 11 7 13 13 11 0.6% Special Store TV, Furn, etc. 38 19 12 13 4 17 1.0% Other /Unknown 8 9 33 28 19 19 1.1% Source: California Department of Justice, Division of California Justice Information Services, Bureau of Criminal Information and Analysis, Criminal Justice Statistics Center "Hate Crimes in California, 2007 and 2008" Table construction by Castaneda & Associates 3. Actions to be Taken During the five -year of the Fair Housing Action Plan, the FHCOC will take the following actions: • Coordinate with the Orange County Human Relations Commission, Center OC and the Orange County Victim Assistance Partnership. • Provide affected residents — when needed - with referrals to hate crime victim resources. (Attachment B provides definitions of key hate crime terms such as bias, event, physical and mental disability bias, and victim.) 142 F. UNFAIR LENDING 1. Fair Housing Act, Equal Credit Opportunity Act and the California Holden Act In cases involving discrimination in mortgage loans or home improvement loans, the United States Department of Justice may file suit under both the Fair Housing Act and the Equal Credit Opportunity Act. Section 805 of the Fair Housing Act (42 U.S.C. 3605) states that it is "unlawful for any person or other entity whose business includes ... the making or purchasing of loans or providing other financial assistance for purchasing, constructing, improving, repairing, or maintaining a dwelling... to discriminate against any person... because of race, color, religion, sex, handicap, familial status, or national origin." The Equal Credit Opportunity Act (ECOA) 15 U.S.C. 1691 et seq. prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age, because an applicant receives income from a public assistance program, or because an applicant has in good faith exercised any right under the Consumer Credit Protection Act. To supplement federal legislation, state laws have been enacted to forbid the discriminatory practice known as `redlining," a practice that results in blanket refusals by some lenders to make loans in whole neighborhoods or geographic areas. Redlining is illegal in California pursuant to the Housing Financial Discrimination Act of 1977 (Holden Act). (Health & Safety Code Section 35800 - 35833) The Holden Act prohibits the consideration of race, color, religion, sex, marital status, national origin, or ancestry in lending for the purchase, construction, improvement, or rehabilitation of housing. Further, lenders cannot deny loan applications because of ethnic composition, conditions, characteristics, or expected trends in the neighborhood or geographic area surrounding the property. The Holden Act places restrictions on redlining by making it illegal for lenders to consider the racial, ethnic, religious, or national origin composition of a neighborhood or geographic area surrounding a housing accommodation. To ensure that prospective borrowers are aware of their rights under this law, lenders must notify all applicants of the provisions of the Holden Act at the time of the loan application. The notice must include the address where complaints may be filed and where information may be obtained. The notice must be in at least 10 -point type and also must be posted in a conspicuous location in the lender's place of business. A notice would state the following: IT IS ILLEGAL TO DISCRIMINATE IN THE PROVISION OF OR IN THE AVAILABILITY OF FINANCIAL ASSISTANCE BECAUSE OF THE CONSIDERATION OF: 1. TRENDS, CHARACTERISTICS OR CONDITIONS IN THE NEIGHBORHOOD OR GEOGRAPHIC AREA SURROUNDING A HOUSING ACCOMMODATION UNLESS THE FINANCIAL INSTITUTION CAN DEMONSTRATE IN THE PARTICULAR CASE THAT SUCH CONSIDERATION IS REQUIRED TO AVOID UNSAFE AND UNSOUND BUSINESS: OR 143 2. RACE, COLOR, RELIGION, SEX, MARITAL STATUS, NATIONAL ORIGIN OR ANCESTRY IT IS ILLEGAL TO CONSIDER THE RACIAL, ETHNIC, RELIGIOUS, OR NATIONAL ORIGIN COMPOSITION OF A NEIGHBORHOOD OR GEOGRPAHIC AREA SURROUNDING A HOUSING ACCOMMODATION OR WHETHER OR NOT SUCH COMPOSITION IS UNDERGOING CHANGE, OR IS EXPECTED TO UNDERGO CHANGE, IN APPRAISING A HOUSING ACCOMMODATION OR IN DETERMINING WHETHER OR NOT, OR UNDER WHAT TERMS AND CONDITIONS, TO PROVIDE FINANCIAL ASSISTANCE. THESE PROVISIONS GOVERN FINANCIAL ASSISTANCE FOR THE PURPOSE OF THE PURCHASE, CONSTRUCTION, REHABILITATION, OR REFINANCING OF ONE - TO- FOUR -UNIT RESIDENCE. 2. Underwriting, Marketing and Pricing Discrimination Unfair lending refers to underwriting, marketing, and pricing discrimination. Underwriting discrimination refers to the process of evaluating home purchase loan applicants and is measured by the outcome of that process — i.e., the approval /denial decision. Marketing discrimination is more commonly known as redlining where a lender is alleged to provide unequal access to credit because of the income, race or ethnicity of the residents in the area where the property is located. Pricing discrimination means that loans are approved but with higher fees and interest rates. The Regional Al examines underwriting and marketing discrimination through the use of 2008 Home Mortgage Disclosure Act (HMDA) data. HMDA grew out of public concern over credit shortages in certain urban neighborhoods. Congress believed that some financial institutions had contributed to the decline of some geographic areas by their failure to provide adequate home financing to qualified applicants on reasonable terms and conditions. Thus, one purpose of HMDA is to provide the public with information that will help show whether financial institutions are serving the housing credit needs of the neighborhoods and communities in which they are located. The 1989 amendments to HMDA require the collection and disclosure of data about applicant and borrower characteristics to assist in identifying possible discriminatory lending patterns and enforcing antidiscrimination statutes. Underwriting discrimination refers principally to loan denials because of the non - economic characteristics of the applicant (i.e., gender and race /ethnicity). HMDA requires lenders to report on the income of home purchase loan applicants. Income means the gross income used by the lenders to make a loan decision. Lenders also must report the race of the borrower according to five categories: American Indian /Alaskan Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, and White. Two ethnic categories must be noted: Hispanic or Latino and Not Hispanic or Latino. Marketing discrimination refers to loan denials because of the characteristics of the area in which the property is located. The following property location information is reported by lenders: Metropolitan Statistical Area, State, County and 2000 census tract. Lenders only report the location of the property and not, for example, the housing and population characteristics of the census tract in which the property is located. 1K' =9 Notably, sometimes both forms of discrimination - underwriting and marketing - are linked because a borrower's loan application could be denied because of both their characteristics and those of the neighborhood. 3. Home Mortgage Disclosure Act HMDA requires lenders to report on the action taken on each loan application, as follows: • Loan Originated • Application Approved, Not Accepted • Application Denied • Application Withdrawn • Filed Closed for Incompleteness Many determinants of a loan decision — such as borrower credit history, debt -to- income -ratio and loan -to -value ratio - are not included in the HMDA data. Although the loan denial rates do not support definitive conclusions regarding discrimination on the bases of race or ethnicity, they are a useful screen to identify disparities in loan approval rates by the race and ethnicity of applicants and geographic markets where differences in denial rates warrant further investigation. Additionally, identifying census tracts /neighborhoods with high loan denial rates helps to target credit counseling and homebuyer education programs. Underwriting discrimination is examined in the Regional Al by the loan denial rates experienced by home purchase loan applicants in Orange County and its cities. Marketing discrimination is examined by reviewing the denial rates at the census tract level and determining whether there is a correlation between high census tract denial rates and minority populations residing in those census tracts. It should be reiterated that HMDA data alone cannot be used to prove unlawful discrimination. 4. Analysis of 2008 HMDA Data Three Technical Appendices contain the detailed HMDA data: • Technical Appendix D — 2008 Home Mortgage Disclosure Act Data for Orange County • Technical Appendix E — Loan Denial Rates for Census Tracts with a High Number of Loan Applications • Technical Appendix F — FHA and Conventional Loan Denial Rates by City and Census Tract a. Sources for the Analysis of the HMDA Data The key sources for the analysis of the HMDA data include: • Robert B. Avery, et.al., The 2008 HMDA Data: The Mortgage Market during a Turbulent Year, Federal Reserve Bulletin, October 2009 • Federal Reserve Board, Frequently Asked Questions About the New HMDA Data, April 3, 2006, 9 pages -1 4.5 Paul Huck, Federal Reserve Bank of Chicago, Home Mortgage Lending by Applicant Race: Do HMDA Data Figures Provide a Distorted Picture, Housing Policy Debate, 2001, Volume 12, Issue 4, pages 719 -736 Mortgage Bankers Association, Fair Lending and Home Mortgage Disclosure Act Guide, Handbook 2008 -1, 35 pages The Urban Institute, Kathryn L.S. Pettit and Audrey E. Droesch, A Guide to Home Mortgage Disclosure Act Data, December 2008, 35 pages b. Loan Denial Rates by Race /Ethnicit Data on home purchase loan applications by the race /ethnicity of the applicant were calculated for the entire Orange County area. In order to determine the denial rate, only applications where a final determination was made were used. The loan denial rate is based on the number of loans denied as a percentage of loans originated + applications approved but not accepted + applications denied. Withdrawn or incomplete applications are not included in the denominator. Of the 4,540 FHA loan applications, 47.4% (2,153) were made by White, Non - Hispanic applicants and 27.3% (1,239) were made by Hispanic borrowers. The White, Non Hispanic and Hispanic denial rates were 15.4% and 27.4 %, respectively. Race was unavailable for 459 applicants. The balance of the 689 loan applications were made by borrowers belonging to seven racial groups. Black or African borrowers represented 2% of all FHA loan applicants. This racial group had a loan denial rate of 20.6 %. Detailed data are presented in Tables D -1 and D -2 in Technical Appendix D 2008 HMDA data are available for almost 29,400 conventional loan applications. The racial /ethnic composition of the applicants was 45.3% White Non - Hispanic, 24.1% Asian, and almost 13% Hispanic. Almost one -third of Hispanic borrowers were denied compared to 17.9% of the Asian and 18.8% of the White, Non- Hispanic loan applicants. Black or African borrowers represented 0.7% of all conventional loan applicants. This racial group had a loan denial rate of 27.6 %. Detailed data are presented in Table D -3 in Technical Appendix D. c. Loan Denials by Income and Race /Ethnicity 1. FHA Loan Applications: Table 5 -13 on the next page shows the four income categories reported in the HMDA data. The four income categories are expressed in terms of a percentage of the median income for Orange County. //10 Table 5 -13 HMDA Census Tract Income Categories — 2008 Census Tract Income Categories Percent of Median MSA Income Very Low <50% Low >50% - <80% Moderate >80% - <120% Above Moderate 120 %+ Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act Table construction by Castaneda & Associates Loan denial rates decrease as incomes increase. White, Non - Hispanic borrowers have lower loan denial rates than those experienced by other racial /ethnic groups. Table 5 -14 shows the disparities in loan denial rates by income and race /ethnicity. Almost one half (49 %) of the 4,540 FHA loan applications were made by above moderate income borrowers. Within this income group, the majority of applications were made by White, Non - Hispanic borrowers who had a denial rate of 14.8 %. Hispanic, Asian and Black/African American applicants all had loan denial rates of more than 20 %. About one -third of FHA applications were made by moderate income borrowers. Within this income group, White, Non - Hispanic and Hispanic borrowers had almost the same volume of loan applications. The Hispanic loan denial rate of 27.1% was considerably higher than the White Non - Hispanic denial rate of 13.6 %. The Asian loan denial rate was 17.6 %. The volume of loan applications by each of the other race /ethnicity groups was small. About one -sixth of all FHA loan applications were made by low income borrowers. Within this income group, White, Non - Hispanic and Hispanic borrowers had almost the same volume of loan applications. The Hispanic loan denial rate of 32.2% was considerably higher than the White Non - Hispanic denial rate of 16.7 %. The Asian loan denial rate was 33.3 %. However, the number of loan applications made by Asians and each of the other race /ethnicity groups was small. Very few (2.5 %) applications were made by very low income borrowers. Detailed data are presented in Table D-4 in Technical Appendix D. 147 Table 5 -14 Orange County Disparities in FHA Loan Denial Rates By Income Group and Race /Ethnicity - 2008 Income Group All' White Non - Hispanic Hispanic Asian Black /African American Very Low 33.9% 20.0% 32.8% NA NA Low 27.5% 16.7% 32.2% 33.3% 18.2% Moderate 20.2% 13.6% 27.1% 17.6% 25.9% Above Moderate 17.5% 14.8% 21.4% 22.5% 20.5% 'All includes these other groups: Joint Hispanic, American Indian /Alaska Native, Native Hawaiian /Other Pacific Islander, 2 or More Minority Races, Joint White /Minority, and Race Not Available Note: very few loans in the NA cells Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Table construction by Castaneda & Associates 2. Conventional Loan Applications: Conventional loan denial rates also decrease as incomes increase. However, Asian borrowers (with the exception of the very-low income category) have lower denial rates than White, Non - Hispanic borrowers. Hispanic borrowers have the highest loan denial rates experienced by the other racial /ethnic groups. In general, Black/African American borrowers had lower denial rates than Hispanic loan applicants. However, this population group comprised less than one percent of all loan applicants. Table 5 -15 shows the disparities in loan denial rates by income and race /ethnicity. Table 5 -15 Orange County Disparities in Conventional Loan Denial Rates By Income Group and Race /Ethnicity- 2008 Income Group All' White Non - Hispanic Hispanic Asian Black/African American Very Low 36.4% 24.8% 44.9% 33.0% NA Low 21.7% 18.5% 30.0% 14.9% 47.2% Moderate 20.4% 16.4% 32.9% 16.1% 19.4% Above Moderate 20.3% 19.1% 31.5% 18.7% 23.9% 'All includes these other groups: Joint Hispanic, American Indian /Alaska Native, Native Hawaiian /Other Pacific Islander, 2 or More Minority Races, Joint White /Minority, and Race Not Available Note: very few loans in the N/A cell Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Table construction by Castaneda & Associates 142 Almost 60% of the 29,000 conventional loan applications were made by above moderate income borrowers. Within this income group, about one -half of applications were made by White, Non - Hispanic borrowers who had a denial rate of 19.1 %. Within this income group, 21.4% of the conventional loan applications were made by Asian borrowers, who had a loan denial rate of 18.7 %. Hispanic borrowers experienced a loan dental rate of 31.5% and comprised 7.4% of all above moderate income loan applicants About one -fourth of conventional loan applications were made by moderate income borrowers. Within this income group, the largest numbers of applicants were White, Non - Hispanic (39 %); Asian (28 %); and Hispanic (18 %). The Hispanic loan denial rate of 32.9% was considerably higher than Asian denial rate of 16.1% and the White Non - Hispanic denial rate of 16.4 %. The volume of loan applications by each of the other race /ethnicity groups was small. About 13% of conventional loan applications were made by low income borrowers. Within this income group, the largest numbers of applicants were White, Non - Hispanic (34 %); Asian (28 %); and Hispanic (23 %). The Hispanic loan denial rate of 30% was considerably higher than Asian denial rate of 14.9% and the White Non - Hispanic denial rate of 18.5 %. The volume of loan applications by each of the other race /ethnicity groups was small. Very few (3 %) applications were made by very low income borrowers. Within this income group, the largest numbers of applications were made, in order, by White, Non - Hispanic, Hispanic and Asian borrowers. All racial /ethnic groups experience loan denial rates of more than 25 %. Detailed data are presented in Table D -5 in Technical Appendix D. d. Loan Denials by Census Tract Characteristics of Income and Minority Concentration HMDA data are available on the loan denials by two census tract characteristics - income categories and minority population concentration levels. The census tract characteristics are based on demographic information from Census 2000 and they are not based on the applicant characteristics. Minority means all races other than White and Whites of Hispanic or Latino Origin. Table 5 -13 shows census tract income categories. For FHA loans, the data reveal that very low income borrowers reside in census tracts where the minority population exceeds 80% of the population. In these very low income /high minority census tracts, 39% of the loan applications were denied. In low income neighborhoods, the loan denial rate increases as the minority population increases. In moderate and above moderate income neighborhoods, they do not always increase as the percentage of the minority population increases. Detailed FHA loan data are presented in Table D -6 in Technical Appendix D. For conventional loans, the data also reveal that very low income borrowers reside in census tracts where the minority population exceeds 80% of the population. In these neighborhoods, 36.2% of the loan applications were denied. In low income neighborhoods, the loan denial rates increase as the percentage of the minority population increases. For instance, in low income / <10% minority population neighborhoods, 2.6% of the loan applications are denied. In contrast, in low income / >80% minority population neighborhoods, 31.2% of the loan applications are denied. These numbers and percentages, though, need to be interpreted with caution 1-" because the number of applications for home purchases in <10% minority neighborhoods is very small. In moderate income neighborhoods, denial rates generally increase as the percentage of the minority population increases. For example, in moderate income / <10% minority population neighborhoods, 13.7% of the loan applications are denied. By comparison, in moderate income / >80% minority population neighborhoods, 24.7% of the loan applications are denied. These numbers and percentages again need to be interpreted with caution because the number of applications for home purchases in <10% and > 80% minority neighborhoods is very small. Detailed conventional loan data are presented in Table D -7 in Technical Appendix D. Perhaps, more representative of Orange County is the loan applications for homes located in census tracts where the minority population ranges from 20 % -79 %. In fact, 73% of the 29,400 conventional loan applications were made in these census tracts. Table 5 -16 shows that the denial rates in neighborhoods with 20 % -79% minority populations are about the same for low and moderate income neighborhoods and somewhat lower for above moderate income neighborhoods. Table 5 -16 Orange County Denial Rates for Neighborhoods with 20 % -79% Minority Populations by Income Level of Census Tracts - 2008 Census Tract Income Level Number of Applications Number Denied Percent Denied Low 4,911 1,080 22.0% Moderate 8,321 1,729 20.8% Above Moderate 8,133 1,432 17.6% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 7 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Characteristics of Census Tract in Which Property is Located, 2008. Table 7 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Characteristics of Census Tract in Which Property is Located, 2008 Table construction by Castaneda & Associates e. Reasons for Loan Denial Reasons for loan denial are summarized on a county -wide basis in Table D -8 in Technical Appendix D. There are eight "known" reasons for a loan denial and one "other' category. With respect to FHA loans, the most frequent reason for a loan denial was "debt -to- income ratio ". The percentage of loans denied for this reason ranged from 27.3% for Black or African American applicants to 57.1 % for Native Hawaiian /Other Pacific Islander applicants. It must be noted, however, that there were few applications for these two groups. White and Hispanic /Latino applicants were denied because of debt to income ratio at nearly the same percentages - 37.9% and 40.2% respectively. 150 The second most frequent known reason for denial of FHA loan applications was credit history. These denials ranged from a low of 7.1% for joint applicants to 22.7% for Black/African American applicants. Again there were few applications for these groups. Credit history was the reason for denial for 13.3% of White applicants and 16.0% of Hispanic applicants. Similar to FHA loans, conventional loans were most frequently denied due to "debt -to- income" ratio as the known reason. These denials ranged from 20.9% for Asian applicants to 40.0% for applicants of two or more races. There were, however, only five applications denied for the group two or more races. Nearly 4,100 White applicants were denied conventional loans with 23.1 % denied due to "debt -to- income ratio'. Hispanic applicants were slightly lower at 21.1 %. Unlike FHA loans however, the second most frequent known reason for denial in most instances is "collateral'. Nearly 20% of the joint applicants, 15.4% of Asian applicants and 10.3% of the Hispanic applicants were denied due to "collateral'. It is unclear exactly what "collateral' encompasses; however, it could refer to declining home values and the inability for homes to meet appraisal requirements. About 9,250 refinance loans were denied for White applicants. About one half of the loans were denied because of "debt -to- income" or "collateral' reasons. More than half of the refinance applications for Asian and Hispanic applicants were denied for these two reasons. For seven out of the 10 groups, "collateral' was more frequently the reason for denial rather than "debt -to- income". Again this may be due to homes not meeting appraisal requirements. County -wide there are relatively few home improvement loan applications. The two most frequent reasons for loan denial for most groups was "debt -to- income" and "credit history". f. Association of High Denial Rates and Minority Population Concentrations As previously noted, HMDA was designed so that the public and regulators could better determine whether or not individuals or specific neighborhoods were being unfairly denied access to credit. A fair housing issue is whether there is an association between neighborhoods with high minority population concentrations and high denial rates. That is, do applicants for home purchases in minority neighborhoods experience high loan denial rates compared to applicants in non - minority neighborhoods? This issue was examined for the following: • Entitlement and Urban County census tracts with 15 or more FHA loan applications • Entitlement and Urban County census tracts with 50 or more conventional loan applications • Percent minority population for each census was determined • Census tracts were ranked ordered in terms of denial rates (high to low) A preliminary analysis was completed to determine if race /ethnicity is associated with the denial of loan applications. The percent minority, percent of the median county income, and the loan denial rates were determined for each census tract in Orange County where there was loan activity in 2008. The initial analysis indicated that there was no relationship between the percent minority in a census tract and the percent of loans that were denied in that census tract. However, inspection of the data suggested that there were some confounding factors in that there were -151 high denial rates in very high income areas. Often these areas have loan applications for very large sums of money to finance the purchase of very expensive homes. Although the loan amount was not in the data set, there was a "proxy' variable in the income of the census tract. It was assumed that higher income areas were more likely to have more expensive homes. A second regression analysis was conducted only on those areas where the median income was at or below 100% of the median income. Focusing on this sub - sample of the data did reveal a relationship between denial rates and percent minority. The R2 value was .2 which is statistically significant. Another regression analysis was performed on a subset of the data where the income was at 80% or below the median income. The resulting R2 was .33. [The value r is a fraction between 0.0 and 1.0, and has no units. An r2 value of 0.0 means that knowing X does not help you predict Y. There is no linear relationship between X and Y, and the best -fit line is a horizontal line going through the mean of all Y values. When r2 equals 1.0, all points lie exactly on a straight line with no scatter. Knowing X lets you predict Y perfectly.] The results suggested that further analysis was warranted. Each record in the HMDA Loan Application Register includes the Census Tract Minority Population Percentage and the Census Tract Percentage of the Metropolitan Statistical Area Median Family Income, as well as the loan amount. An analysis was completed to determine if race /ethnicity is associated with the denial of loan applications. Two types of loans applications were considered in the analysis: (1) home purchases with conventional loans and (2) home purchases with FHA loan. A logit regression was used to "predict' if a loan was denied based on the minority population and income ratio of the census tract, as well as the loan amount. These variables were chosen because the results of a preliminary analysis utilizing census tract level data suggested each of these variables were influencing denials. Each of the three variables was significant predictors of loan denials for conventional loan applications, while the percent minority and the income ratio of a census tract were significant predictors of denials for FHA loan applications. The key to Iogit regression is the analysis of maximum likelihood estimates. It estimates the log odds of an event occurring (loan denial) given a one unit increase in a variable. The statistical significance of these log odds are measured using a Wald chi - square, which would be zero or near zero if the two events and the predictor variable were independent. The chi - square values are presented in Table 5 -17. Table 5 -17 Analysis of Maximum Likelihood Estimates Parameter Conventional Loans FHA Loans Wald Chi- Square Pr >Chi- Square Wald Chi- Square Pr >Chi- Square Percent Minority Population 39.99 <.0001 24.05 <.0001 Tract to MSA Median Family Income 8.83 0.003 4.05 0.0441 Loan Amount 114.57 <.0001 0.73 0.3935 1152 By way of elaboration, the logit regression is based on the probability of an event occurring, i.e. loan denial. It measures the likelihood that the probability of the event increases as the independent variables increase. For conventional loans, the probability of a loan being denied increased as the percentage minority population in the census tract increased, as the income increased the probability of a denial decreased, and as the amount of the loan increased the probability of a loan denial increased. It should be noted that the association analysis suffers because the data sets are from two different points in time: loan activity in 2008 and minority population characteristics per Census 2000. Since 2000, the census tract income, racial and ethnic characteristics are likely to have changed since the time the census data was collected. With more current data, a more robust analysis of the relationship between the probability of a denial and the independent variables can be developed. Consequently, a more definitive analysis should be conducted when the 2010 census tract information is available on income, racial and ethnic characteristics. HMDA data for 2010 will be available in September 2011. 5. Actions to be Taken A summary of the examination of the 2008 HMDA data is given below • Disparities exist in loan approval /denial rates among the racial and ethnic borrowers. In particular, Hispanic applicants have higher loan denial rates than White, Non - Hispanic borrowers. • Black /African American borrowers also have high loan denial rates compared to White alone loan applicants. • Loan denial rates in neighborhoods with 20 % -79% minority populations are about the same regardless of census tract income level (low, moderate and above moderate). • Unfair lending is manifested more in the loan denial disparities experienced by different racial /ethnic borrowers than by the denial rate disparities experienced in neighborhoods with 20 % -79% minority populations, regardless of income. Unfair lending is a fair housing issue best addressed at the regional level rather on a city -by -city basis. The FHCOC will undertake the following actions during the 2010 -2015 period: • Monitor the HMDA data annually using the 2008 HMDA analysis as a benchmark. • Complete a HMDA analysis of the top 10 lenders in Orange County to compare and contrast loan denial rates. • 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. 1153 • Conduct outreach to cultural, ethnic and minority organizations to potentially increase interest and readiness in home purchases. 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. •iJi Attachment A California Newspaper Publishers Association Guidance on Advertising Words and Phrases The Civil Rights Act of 1968 is a federal law that prohibits discrimination in many different sectors, including housing and employment. Title VIII of the Civil Rights Act of 1968 is the section that is popularly referred to as the Fair Housing Act, and applies to everyone in the United States. Title VIII [42 U.S.C. Section 3604 9(c)] as amended, makes it unlawful to: Make, print, or publish, or cause to be made, printed or published any notice, statement or advertisement, with respect to the sale or rental of a dwelling that indicated any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. California has enacted a similar anti - discrimination provision. California Government Code Section 12955 (a), part of the Fair Employment and Housing Act, makes it unlawful: For the owner of any housing accommodation to discriminate against any person because of the race, color, religion, sex, marital status, national origin, ancestry, familial status, sexual orientation, source of income, or disability of that person. California Government Code Section 12955 (c) further makes it unlawful: For any person to make, print, or publish, or cause to be made, printed or published any notice, statement or advertisement, with respect to the sale or rental of housing that indicates any preference, limitation, or discrimination based on race, color, religion, sex, marital status, national origin, ancestry, familial status, disability, sexual orientation, source of income, or an intention to make any such preference, limitation, or discrimination. California's Unruh Civil Rights Act (Civil Code Section 51 et. seq.) further prohibits discrimination in housing based on age. The Act has also been interpreted by the courts in California to protect individuals based on sexual orientation. More broadly, the Unruh law prohibits discrimination based on any of the characteristics listed above as well as any other arbitrary basis. The FEHA expressly incorporates the anti - discrimination housing provisions (Government code Section 12955[d]). 1. Race/ Color/ National Origin/ Ancestry These four classes are generally discussed together. Race and color refer to a person's skin color and to ethnological (e.g. Asian, African American) as well as unscientific distinctions (e.g. "Middle Eastern "). National origin and ancestry refer to one's country of origin and ethnic heritage. The following are some words and terms that state and federal regulators discourage because they discriminate based on race, color, ancestry, or national origin: white, black, asian, 155 integrated, restricted, private, board approval, ethnic landmarks, executive, exclusive, membership approval, a specific nationality such as Chinese and any specific race. Federal and state regulations and guidelines discourage words and terms such as "membership approval," "restricted," "integrated," and "exclusive." These and other words and phrases may be discriminatory, according to regulators, because someone reading the advertisement is likely to believe that people of a certain race or national origin will be preferred over others in the sale or rental of the advertised housing. 2. Sex Discrimination on the basis of sex protects both men and women. It is illegal to specify either "male "preferred" or "female preferred." No preference on the basis of sex should be stated in an advertisement. DFEH stated that terms such as "bachelor pad," "granny flat," "mother -in -law suite" and others are commonly used as physical descriptions of housing units do not violate the Act. 3. Disability The following are a few of the words and phrases that federal regulations state convey an overt or tacit discriminatory preference and should be avoided: crippled, blind, deaf, mentally ill, retarded, impaired, alcoholic, handicapped, able- bodied, and physically fit. Physical descriptions of property (e.g. "great view," "walk -in closet" and second floor walk -up ") or descriptions of services or facilities (e.g. "jogging trails') are not facially discriminatory 4. Marital Status /Familial Status Marital status, as the term suggests, protects people from discrimination based on whether or not they are married. Familial status refers to whether or not an individual has minor children living with them. Words and phrases that, according to state and federal regulators, bring up the issue of discrimination on the basis of marital or familial status: retired, one child, one person, number of people, family, (`great for family," etc.) family park, adult, adults only, children, single, single person, student, two people, seniors, senior discount, couples (e.g. "ideal for couples'), and older person. Advertisements which describe the property being advertised or the services or facilities available at the property are generally considered to be acceptable. Examples include "family room" and "playground" It may be unlawful to limit the number of persons who can live in a housing unit if it would have the effect of discriminating on the basis of familial or marital status. CNPA recommends rejecting any advertisement that limits the number of occupants, even where the owner specifies that the limitation is required by local law. The reason is that a newspaper publisher cannot investigate the facts surrounding every proposed advertisement to determine if the advertiser's claim is correct. 150 5. Religion Discrimination in housing on the basis of religion is prohibited under both state and federal law. According to the state Guidance Memorandum, "advertisements should not contain an explicit preference, limitation or discrimination on account of religion (i.e. "no Jews," "Christian home ")." Some of the words and phrases that regulators say may draw a complaint based on religious discrimination include Jewish, Mormon Temple, Catholic Church, Christian home, religious name, any religious landmark. 6. Sexual Orientation Any reference to an individual's sexual orientation, e.g. lesbian, gay, and straight, etc. should be eliminated from housing ads. Publishing an ad that says, "lesbian, vegetarian seeking roommate," would expressly indicate a preference for a person on the basis of her sexual orientation. 7. Age Federal regulations specify that unless the housing being offered meets government requirements for "senior" or "senior only" housing, advertisers may not express a preference or limitation on the basis of age. Federal and state guidance memorandums specifying that if an advertiser represents to the newspaper that the housing meets the requirements of "senior housing," the newspaper is allowed to rely on the representation. 157 Attachment B Hate Crimes Glossary Bias — A preformed negative opinion or attitude toward a group of persons based on their race, ethnicity, national origin, religion, gender, sexual orientation and /or physical /mental disability. Ethnic Bias — A preformed negative opinion or attitude toward a group of persons of the same race or national origin that share common or similar traits in language, custom, and tradition, such as Arabs or Hispanics. Event — An event is an occurrence where a hate crime is involved. (In this DOJ report, the information about the event is a crime report or source document that meets the criteria for a hate crime.) There may be one or more suspects involved, one or more victims targeted, and one or more offenses involved for each event. Known Suspect(s) — A suspect can be any person alleged to have committed a criminal act(s) or attempted criminal act(s) to cause physical injury, emotional suffering, or property damage. The known suspect category contains the number of suspects that have been identified and /or alleged to have committed hate crimes as stated in the crime report. For example, witnesses observe three suspects fleeing the scene of a crime. The word "known" does not necessarily refer to specific identities. Offenses — Offenses that are recorded are as follows; murder, forcible rape, robbery, aggravated assault, burglary, larceny -theft, motor vehicle theft, arson, simple assault, intimidation, and destruction /vandalism as defined in the national UCR and the national Hate Crimes Statistics Report. Physical /Mental Disability Bias — A preformed negative opinion or attitude toward a group of persons based on physical or mental impediments /challenges, whether such disabilities are congenital or acquired by heredity, accident, injury, advanced age, or illness. Racial Bias — A preformed negative opinion or attitude toward a group of persons such as Asians, blacks, or whites, based on common physical characteristics. Religious Bias — A preformed negative opinion or attitude toward a group of persons that share the same religious beliefs regarding the origin and purpose of the universe and the existence or nonexistence of a supreme being, such as Catholics, Jews, Protestants, or Atheists. Sexual- Orientation Bias — A preformed negative opinion or attitude toward a group of persons based on sexual preferences and /or attractions toward and responsiveness to members of their own or opposite sexes. Victim — A victim may be an individual, a business or financial institution, a religious organization, government, or other. For example, if a church or synagogue is vandalized and /or desecrated, the victim would be a religious organization. 152 Section 6 Public Sector Fair Housing Analysis 2�9 SECTION 6 PUBLIC SECTOR FAIR HOUSING ANALYSIS A. INTRODUCTION The United States Department of Justice has indicated a major focus of its efforts is on public sector impediments that may restrict housing opportunities for disabled persons. The Department has stated: The Division's enforcement of the Fair Housing Act's protections for persons with disabilities has concentrated on two major areas. One is insuring that zoning and other regulations concerning land use are not employed to hinder the residential choices of these individuals, including unnecessarily restricting communal, or congregate, residential arrangements, such as group homes. The second area is insuring that newly constructed multifamily housing is built in accordance with the Fair Housing Act's accessibility requirements so that it is accessible to and usable by people with disabilities, and, in particular, those who use wheelchairs. Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, page 4 California's Fair Employment and Housing Act states that it is unlawful: To discriminate through public or private land use practices, decisions, and authorizations because of race, color, religion, sex, sexual orientation, familial status, marital status, disability, national origin, source of income, or ancestry. Discrimination includes, but is not limited to, restrictive covenants, zoning laws, denials of use permits, and other actions authorized under the Planning and Zoning Law (Title 7 (commencing with Section 65000)), that make housing opportunities unavailable. [emphasis added] The analysis of public sector impediments involves following: • A description of the actions taken by the County's four housing authorities to affirmatively further fair housing • A description of the housing authorities policies on reasonable physical modifications and reasonable accommodations • A discussion on the most frequent land use and zoning impediments identified by the Entitlement Cities and the County of Orange • An identification of the land use and zoning impediments identified by each participating Entitlement City and the County of Orange • A description of the actions to be taken by the FHCOC and the participating jurisdictions to ameliorate or eliminate public sector impediments 100 B. DESCRIPTION OF HOUSING AUTHORITY FAIR HOUSING POLICIES Orange County's four housing authorities provide rental assistance through the Housing Choice Voucher Program (HCVP) to an estimated 21,000 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 FHCOC. 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 Eight 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% or greater. The Orange County Housing Authority has consistently received five bonus points in SEMAP for de- concentration. 1. Fair Housing Policies of Housing Authorities The paragraphs below summarize key fair housing policies of the housing authorities a. Anaheim Housina Authoritv (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. 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 101 • 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 b. Garden Grove Housina Authoritv (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. 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. c. 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. 102 • 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. d. Oranoe County Housino 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: 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 1('03 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 it 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. • 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. 7 N 2. Section 8 Housing Policies on Reasonable Physical Modifications and Reasonable Accommodations Question #8 of the Zoning and Planning Survey (Attachment A) asks: If the jurisdiction supplies or manages housing, is there a clear policy to allow disabled persons residing in or seeking to reside in the housing to make or request reasonable physical modifications or to request reasonable accommodations? As previously noted, four housing authorities administer the Section 8 Housing Choice Voucher Program: • Anaheim Housing Authority • Garden Grove Housing Authority • Santa Ana Housing Authority • Orange County Housing Authority The Anaheim Housing Authority administers about 6,300 Section 8 Housing Choice Voucher units. As a consequence, this rental assistance program represents a significant segment of the rental housing market. The Garden Grove Housing Authority administers about 2,500 Section 8 Housing Choice Voucher units. Of this total, 2,026 Section 8 families reside in rental housing located in Garden Grove, a number that represents 10% of the City's rental housing stock. The Santa Ana Housing Authority administers about 2,600 Section 8 Housing Choice Voucher units. The Orange County Housing Authority administers about 9,600 Section 8 Housing Choice Vouchers. The housing units are located in the unincorporated area and 31 participating cities in Orange County. HUD stipulates a number of reasonable accommodations that can be made available to persons with disabilities who are recipients of Housing Choice Vouchers. Examples of the types of accommodations include: • Approval to perform annual reexaminations of household income by telephone • Approval to add a live -in aide /care provider • Approval to rent a unit owned by a relative • Approval of an extra bedroom for large, intrusive medical equipment • Approval to use a voucher in special housing types such as shared housing, group homes, congregate housing and assisted living Each housing authority has adopted policies - as part of their Administrative Plans - related to persons with disabilities, including reasonable accommodation. For example, the Anaheim Housing Authority has the following policy: If you or anyone in your family is a person with disabilities, and you require specific accommodation in order to fully utilize our programs and services, please contact the housing authority. 105 Another example is the Garden Grove Housing Authority policy which states: The GGHA shall make reasonable adjustments to their rules, policies, practices and procedures in order to enable an applicant or participant with a disability to have an equal opportunity to access the HCVP. If providing the accommodations would result in a fundamental alteration in the nature of the HCVP or an undue financial or administrative burden, then the GGHA need not provide the accommodation, however it may present an alternate accommodation that will still meet the need of the person. An undue administrative burden is one that requires a fundamental alteration of the essential functions of the GGHA (i.e., waiving a family obligation). An undue financial burden is one that when considering the available resources of the agency as a whole, the requested accommodation would pose a severe financial hardship on the GGHA. A participant with a disability must request a change to a policy or practice as an accommodation of his or her disability before the GGHA will treat a person differently than anyone else. The GGHA's policies and practices will be designed to provide assurances that persons with disabilities will be given reasonable accommodations, upon request, so that they may fully access and utilize the housing program and related services. This policy is intended to afford persons with disabilities an equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement as those who do not have disabilities. 3. Fair Housing and Lead -Based Paint The issue of lead based paint in housing is recognized as a fair housing concern because of the overconcentration of housing containing lead based paint in very low and low income neighborhoods coupled with the over concentration of protected classes residing in these neighborhoods. Lead based paint also is a fair housing issue because it relates especially to rental housing for children. Under the Fair Housing Act, it is illegal to not rent to families unless the housing is exempt because it is housing for older persons. The Orange County Childhood Lead Poisoning Prevention Program ( CLPPP) explains that high blood lead levels are a concern because they may cause harmful effects to a child's developing organ systems such as the kidneys, brain, liver, and blood- forming tissues. This may affect a child's ability to learn. Very high blood levels can cause devastating health consequences, including seizures, coma, and even death. Children are much more vulnerable to lead poisoning than adults because they put many kinds of items into their mouths. Their bodies absorb up to 40% of the lead with which they come into contact as opposed to only 10% absorbed by adults. Lead enters the body through breathing or ingestion. Some possible sources of lead include • Living in an older home painted with lead -based paint • Ceramic pottery • Lead -based paint dust from a household contact's work clothing • A home remedy • A crib painted with lead -based paint The CLPPP follows children with abnormal or high blood lead levels. CLPPP receives reports of abnormal lead results from the State, laboratories, or physicians /clinics who have ordered the test. 100 In order to better protect children and families against lead poisoning; in 1999 HUD instituted revised lead -based paint regulations focused on the following five activities: • Notification — disclosure, distribution of pamphlet, notice of lead hazard evaluation or presumption, and notice of lead hazard reduction activity • Lead Hazard Evaluation — visual assessment, paint testing, and risk assessment or lead hazard screen • Lead Hazard Reduction — paint stabilization, interim controls, and abatement • Ongoing Maintenance — inspect and maintain lead hazard reduction work • Response to Children with Environmental Intervention Blood Lead Level — sharing and comparing information, risk assessment, interim controls or abatement, and notices of disclosure On April 22, 2008, EPA issued a rule requiring the use of lead -safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead -based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination. Starting on April 22, 2010, the rule affected paid renovators who work in pre -1978 housing and child- occupied facilities, including: • Renovation contractors Maintenance workers in multi - family housing Painters and other specialty trades Under the rule, child- occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule does not apply to minor maintenance or repair activities where less than six square feet of lead -based paint is disturbed in a room or where less than 20 square feet of lead -based paint is disturbed on the exterior. Window replacement is not minor maintenance or repair. HUD has indicated that lead -based paint in assisted housing occupied by families with children is a fair housing concern. The County's four housing authorities provide rental assistance to a combined total of about 21,000 households /housing units. Many of the assisted households are families with children. Efforts to reduce lead based paint hazards are integrated into the County's four housing authority's administrative procedures. For example, as of May, 2010 the Orange County Housing Authority was assisting 1,226 families that include one or more children under the age of six. The Housing Authority developed a report listing the address of the assisted units with children under the age of six. The County's Health Care Agency (HCA) then compared the assisted unit addresses with the address of any children in their records that had an elevated blood level. HCA completed a check of current, open State - defined cases against OCHA's list. These are children with one blood lead level (BLL) of 20 mcg /dL or greater or two BLLs of 15 -19 mcg /dL) There have been no matches at this time. HCA is continuing to compare the addresses for other identified elevated blood lead levels for those addresses. 2O7 C. DESCRIPTION OF CITY AND COUNTY PUBLIC SECTOR IMPEDIMENTS As part of the preparation of an Analysis of Impediments to Fair Housing Choice participating cities responded to a 24- question survey 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. The survey 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. 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. Attachment A is the complete Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice. The survey provides background information that explains the fair housing issues and concerns posed by each question. Three examples of background information are provided below: • The City of Santa Barbara v Adamson case explains why cities should not have a definition of "family" that restricts housing opportunities for disabled persons living in a group home. The U.S. ex re. Anti - Discrimination Center v. Westchester County indicates that in appropriate circumstances affordable housing can be a tool to address a lack of fair housing choice in highly segregated communities. The Housing for Older Persons Act explains the conditions under which senior housing is exempt from the prohibition against familial discrimination. Chart 6 -1 on the next page lists the 24 topics /questions included in the Survey of Zoning and Planning Codes, Policies and Practices. The results of the Zoning and Planning Survey are presented in the following pages. The analysis is presented in two parts: • First, a summary is presented of public sector impediments that are common to most participating jurisdictions. • Second, the public sector impediments unique to each participating jurisdiction are identified. m Chart 6 -1 Orange County Regional Analysis of Impediments to Fair Housing Choice Topics Included in the Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice 1. Lack of a Family Definition Consistent with Fair Housing Laws 2. Mischaracterize Housing for the Disabled as 'Boarding or Rooming house' 3. Lack of a Definition of Disability Consistent with Fair Housing Laws 4. Treating Housing for Disabled Persons Differently than Other Housing 5. Restrict On -Site Supportive Services for Housing for Disabled Persons 6. Occupancy Limits on Housing for Disabled Persons 7. Lack of a Reasonable Accommodation Procedure 8. Lack of Reasonable Modifications /Accommodations in Section 8 Housing 9. Public Hearing Requirements on Requests for Exceptions to Zoning Rules 10. CUP Requirement for Housing for Disabled Persons 11. Lack of Disabled - Accessible Parking for Multiple - Family Projects 12. Lack of Development Standards for Making Housing Accessible to Disabled Persons 13. Plan Check for Accessibility Compliance of Covered Multi - Family New Construction 14. Zoning Ordinance or Policy for Inclusionary Housing 15. Zoning Ordinance or Policy for Mixed Use Development 16. Development Incentives for the Provision of Affordable Housing 17. Ordinance or Policy Limiting Housing to Fair Housing Protected Classes 18. Zoning Development Standards for Senior Housing /Compliance with Unruh Civil Rights Act 19. CUP Requirements for Senior Housing Developments 20. Zoning and Policies for Special Needs Housing 21. Occupancy Standards More Restrictive than State Law 22. Policy on Admission Preference to Persons Already Residing in the Jurisdiction 23. Impact of Redevelopment Activities on Fair Housing Choice 24. Zoning Ordinance or Policies that Discuss Fair Housing log 1. Public Sector Impediments Common to Most Participating Jurisdictions 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 Disabilit 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. Jurisdictions planning to define disability in either or both the zoning regulations and a reasonable accommodation procedure need to be aware of what the Fair Housing Act (FHA) and American with Disabilities Act (ADA) cover. The ADA covers the activities of state and local governments, their buildings as well as public accommodations in movie theaters, restaurants, hotels, etc. The FHA applies to residential dwellings. Because of this difference, at one time both builders and developers believed that they were meeting the guidelines of the ADA and, therefore, believed that they were fulfilling all of their responsibilities in regards to accessibility, which was not necessarily true. Also, the protections for persons with disabilities are very different from protections provided for other protected cases under the FHA in that the provisions actually call for affirmative actions to be taken by housing providers, municipalities and others in removing barriers to fair housing choice for people with disabilities. That is why some cities have adopted an ordinance incorporating provisions to provide people with disabilities reasonable accommodations in rules, policies, practices and procedures that may be necessary to ensure equal access to housing. 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. 170 Government Code Section 65582(f) states: "'Supportive housing' has the same meaning as defined in subdivision (b) of Section 50675.14 of the Health and Safety Code." Health and Safety Code Section 50675.14(b) states: "For purposes of this section, 'supportive housing' means housing with no limit on length of stay, that is occupied by the target population as defined in subdivision (d) of Section 53260, and that is linked to onsite or offsite services that assist 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." Health and Safety Code Section 53260(d) states: "'Target population' means adults with low incomes having one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Act (Division 4.5 (commencing with Section 4500) of the Welfare and Institutions Code) and may, among other populations, include families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, or homeless people." [emphasis added] Government Code Section 65582(g) states: "'Transitional housing' has the same meaning as defined in subdivision (h) of Section 50675.2 of the Health and Safety Code." Health and Safety Code Section 50675.2(h) states: "'Transitional housing' and `transitional housing development' means buildings configured as rental housing developments, but operated under program requirements that call for the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months." Health and Safety Code Section 50801(i) states: "'Transitional housing' means housing with supportive services for up to 24 months that is exclusively designated and targeted for recently homeless persons. Transitional housing includes self- sufficiency development services, with the ultimate goal of moving recently homeless persons to permanent housing as quickly as possible, and limits rents and service fees to an ability -to -pay formula reasonably consistent with the United States Department of Housing and Urban Development's requirements for subsidized housing for low- income persons. Rents and service fees paid for transitional housing may be reserved, in whole or in part, to assist residents to move to permanent housing." 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. 171 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. The federal Departments of Justice (DOJ) and Housing and Urban Development (HUD) as well as the California Attorney General have encouraged local governments to adopt a reasonable accommodation procedure. The DOJ and HUD have stated: "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 the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 5. On May 15, 2001 the State Attorney General transmitted a letter to all local governments advising the localities to consider adoption of a reasonable accommodation procedure. In that letter, the Attorney General stated: "Both the federal Fair Housing Act ('FHA') and the California Fair Employment and Housing Act ('FEHA') impose an affirmative duty on local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning laws and other land use regulations and practices when such accommodations 'may be necessary to afford' disabled persons 'an equal opportunity to use and enjoy a dwelling. "' Many jurisdictions currently handle requests for relief from the zoning ordinance through variance or conditional use permits. The Attorney General remarked that: " ...the criteria for determining whether to grant a variance or conditional use permit typically differ from those which govern the determination whether a requested accommodation is reasonable within the meaning of fair housing laws. "Thus, municipalities relying upon these alternative procedures have found themselves in the position of having refused to approve a project as a result of considerations which, while sufficient to justify the refusal under the criteria applicable to grant of a variance or conditional use permit, were insufficient to justify the denial when judged in light of the fair housing laws' reasonable accommodations mandate." The Attorney General also stated that the variance and conditional use permit procedures — with their different governing criteria — serve to encourage community opposition to projects housing the disabled. The Attorney General wrote: "Yet this is the very type of opposition that, for example, the typical conditional use permit procedure, with its general health, safety and welfare standard, would seem rather 272 predictably to invite, whereas a procedure conducted pursuant to the more focused criteria applicable to the reasonable accommodation determination would not." The advice of the Attorney General is to establish a reasonable accommodation procedure instead of relying on the conditional use permit and variance procedures to process a request for disabled persons seeking specific exceptions to zoning and land -use rules (variances) necessary for them to be able to fully use and enjoy housing. A public hearing is not required for approval of a reasonable accommodation request. 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. Attachment B on page 6 -34 is an example of a reasonable accommodation procedure (City of La Habra). d. Special Needs Zoning Question #20 asks: Does the zoning code or other planning document address housing for "special needs" populations. 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. There is a high incidence of disability in the homeless population, domestic violence overwhelmingly impacts women, and people with HIV /AIDS are considered disabled under fair housing law. While age is not a characteristic protected under federal fair housing law, it is covered under state law, and the higher incidence of disability in the frail elderly introduces possible fair housing implications for that population as well. Entitlement cities and the Urban County should consider enacting special needs housing zoning regulations. Attachment C on page 6 -37 is an example of such zoning regulations (City of La Habra). e. Fair Housing Discussion Question 24 asks: Does the zoning ordinance or other planning or policy document include a discussion of fair 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. Attachment D on page 6 -47 is an example of such zoning regulations (City of San Francisco Fair Housing Implementation Ordinance). 1�3 2. City Identified Public Sector Impediments Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the City of Newport Beach did not identify any public sector impediments. Reference: Technical Appendix G: Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice 174 D. ACTIONS TO BE TAKEN BY THE FHCOC AND CITY TO AMELIORATE OR ELIMINATE PUBLIC SECTOR IMPEDIMENTS 1. 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 consistent of providing background information on the above impediments and model ordinances or regulations that adequately address the fair housing concerns posed by the impediments. 2. Actions to be Taken by the City Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the City of Newport Beach did not identify any public sector impediments. Therefore, there are no actions to be taken at this time by the City with respect to public sector impediments. Reference: Technical Appendix G: Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice ij 5 /_[ice IT i -- iiw_1 SURVEY OF ZONING AND PLANNING CODES, POLICIES AND PRACTICES THAT MAY POSE AN IMPEDIMENT TO FAIR HOUSING CHOICE 170 FAIR HOUSING COUNCIL OF ORANGE COUNTY 201 S. Broadway • Sams Ana, CA 92701 7141569 -0823 • Fax 714/835 -0281 • www.fairhousingoc.org SURVEY OF ZONING AND PLANNING CODES, POLICIES AND PRACTICES THAT MAY POSE AN IMPEDIMENT TO FAIR HOUSING CHOICE Name of Jurisdiction: Completing Department: Completed By: Date Completed: 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 24 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 and local developers of housing. 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. QUESTIONS [NOTE: For document automation please enable macros and then double click check boxes to check or uncheck ] 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 0 No O Background 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 situating of group homes for individuals with disabilities (but not families similarly sized and 2�� situated). Such definitions are prohibited because they could have the effect 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. 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 who were allowed to do so to five. Under the invalidated 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. For example, a city may have a definition of `family' as follows: "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. [emphasis added] A definition of family should look to whether the household functions as a cohesive unit instead of distinguishing between related and unrelated persons. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 2. Does the code definition of "dwelling unit" or "residential unit" have the effect of discriminating against unrelated individuals with disabilities who reside together in a congregate or group living arrangement? Yes ❑ No ❑ Background The definition of a "dwelling unit" or "residential unit" may exclude or restrict housing opportunities for individuals with disabilities by mischaracterizing congregate or group living arrangements as "boarding or rooming house' a "hotel' or a "residential care facility ". Both State and Federal fair housing laws prohibit definitions of dwelling that either intentionally discriminate against people with disabilities or have the effect of excluding such individuals from housing. Generally, all dwellings are covered by fair housing laws, with a "dwelling" being defined as "a temporary or permanent dwelling place, abode or habitation to which one intends to return as distinguished from the place of temporary sojourn or transient visit." Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 172 3. Does the code or any policy document define "disability ", if at all; at least as broadly as the federal Fair Housing Act? Yes ❑ No ❑ Background The federal Fair Housing Act (FHA) defines disability /handicap as follows: "Handicap" means, with respect to a person- - (1) a physical or mental impairment which substantially limits one or more of such person's major life activities, (2) a record of having such an impairment, or (3) being regarded as having such an impairment, but such term does not include current, illegal use of or addiction to a controlled substance (as defined in section 102 of the Controlled Substances Act (21 U.S.C. 802)). The term "physical or mental impairment" 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. The California Fair Employment and Housing Act (FEHA) definition is somewhat broader, in that removes the word "substantially ". The FEHA definition is: (1) A physical or mental impairment that limits one or more of a person's major life activities (2) A record of having, or being perceived as having, a physical or mental impairment. It does not include current illegal use of, or addiction to, a controlled substance (as defined by Section 102 of the Federal Controlled Substance Act, 21 U.S.C. Sec. 802). Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 4. Are personal characteristics of residents, including, but not necessarily limited to, disability, considered? Yes ❑ No ❑ 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 people, 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 conditional use permit or variance requirement on family -like facilities of a certain size and not similarly sized housing for people without disabilities, violates fair housing laws. 179 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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 2 and 3. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 5. Does the code limit housing opportunities for disabled individuals through restrictions on the provision of on -site supportive services? Yes ❑ No ❑ Background Housing for disabled persons, to be sustainable, successful and to allow them to fully use and enjoy the housing, 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." Joint Statement of the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 2. m Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 6. Does the jurisdiction policy have more restrictive limits for occupancies involving disabled residents than for other occupancies of unrelated, non - disabled persons? Yes ❑ No ❑ 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." Joint Statement of the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 3. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 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? Yes ❑ No ❑ 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 121 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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 4 and 5. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: B. If the jurisdiction supplies or manages housing, is there a clear policy to allow disabled persons residing in or seeking to reside in the housing to make or request reasonable physical modifications or to request reasonable accommodations? Yes ❑ No ❑ N/A ❑ If 'Yes', is the policy communicated to applicants or residents? Yes ❑ No ❑ Explanation of Answer Given Above Please provide a brief description of the policy, its dissemination and its process: 182 9. Does the jurisdiction require a public hearing for disabled persons seeking specific exceptions to zoning and land -use rules (variances) necessary for them to be able fully use and enjoy housing? Yes ❑ No ❑ If `Yes', is the process the same as for other applications for variances, or does it impose added requirements? 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. In acting consistently with "affirmatively furthering fair housing," it is considered preferable to have a reasonable accommodation procedure intended to facilitate a disabled applicant's request for exceptions to zoning and land use rules, that does not require a public hearing process. As previously explained in the joint statement by DOJ and HUD: "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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 5. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer, and an explanation of any differences for persons with disabilities: 10. Does the zoning code distinguish housing for persons with disabilities from other residential uses by requiring an application for a conditional use permit (CUP)? Yes ❑ No ❑ Background See the Background section for questions 7 and 9 above. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and what aspects of use trigger the need for a permit: 11. Describe the development standards, if any, for the provision of disabled - accessible parking for multiple - family projects. 122 12. Does the code contain any development standards or special provisions for making housing accessible to persons with disabilities? Yes O No O Does it specifically reference the accessibility requirements contained in the Fair Housing Amendments Act of 1988? Yes ❑ No ❑ Background Generally, under the federal Fair Housing Amendments Act of 1988, both privately owned and publicly assisted single -story, multi - family housing units built for first occupancy on or after March 13, 1991— including both 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, or 2) are ground floor units in non - elevator buildings containing four or more units. These standards, encompassing seven basic provisions, are codified at Code of Federal Regulations Title 24, Part 100.205. Additionally, under Section 504 of the Rehabilitation Act of 1973, it is unlawful to discriminate based on disability in federally assisted programs. This section provides that no otherwise qualified individual shall, solely by reason of his or her disability, be excluded from participation (including employment), denied program benefits, or be subjected to discrimination on account of disability under any program or activity receiving federal funding assistance. Section 504 also contains accessibility provisions for dwellings developed or substantially rehabilitated with federal funds. For the purposes of compliance with Section 504, "accessible" means ensuring that programs and activities, when viewed in their entirety, are accessible to and usable by individuals with disabilities. For housing purposes, the Section 504 regulations define an accessible dwelling unit as a unit that is located on an accessible route and can be approached, entered, and used by individuals with physical disabilities. A unit that is on an accessible route and is adaptable and otherwise in compliance with the standards set forth in Code of Federal Regulations Title 24, Part 8.32 is accessible. In addition, the Section 504 regulations impose specific accessibility requirements for new construction and alteration of housing and non - housing facilities in HUD assisted programs. Section 8.32 of the regulations states that compliance with the appropriate technical criteria in the Uniform Federal Accessibility Standards (UFAS), or a standard that is equivalent to or stricter than the UFAS, is an acceptable means of meeting the technical accessibility requirements in Sections 8.21, 8.22, 8.23 and 8.25 of the Section 504 regulations. However, meeting Section 504 accessibility requirements does not exempt housing from other accessibility requirements that may be required under fair housing laws. The following Section 504 requirements apply to all federally assisted newly constructed housing and to substantial rehabilitation of housing with 15 or more units: A minimum of five percent of total dwelling units (but not less than one unit) accessible for individuals with mobility impairments; An additional two percent of dwelling units (but not less than one) accessible for persons with hearing or vision impairments; and All units made adaptable that are on the ground level or can be reached by an elevator. r Fair housing laws do not impose a duty on local jurisdictions to include accessibility provisions in their codes, or to enforce the accessibility provisions of fair housing laws. However, the inclusions of accessibility standards and /or plan checking for accessibility compliance are significant ways that jurisdictions can affirmatively further fair housing choice for persons with disabilities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and of the standards, if any: 13. Does the jurisdiction conduct plan checking for accessibility compliance of covered multi - family new construction? Yes ❑ No ❑ Background See the final paragraph of the Background section of question 12. If `Yes', please give a brief description of process and what items are checked. 14. Is there a zoning ordinance or other development policy that encourages or requires the inclusion of housing units affordable to low and/or moderate income households (so- called `inclusionary housing')? Yes ❑ No ❑ Background An analysis of impediments to fair housing choice must be careful to not substitute or conflate housing affordability policy with policies intended to affirmatively further fair housing. While household income is not a characteristic addressed by fair housing laws, it is appropriate to recognize that a lack of affordable housing can have a disparate impact on housing choice, on the basis of characteristics protected by fair housing laws. As demonstrated in the outcome in the recent court case of U.S, ex reL Anti - Discrimination Center v. Westchester County, which involved failures to affirmatively further fair housing by Westchester County, New York, in appropriate circumstances the provision and situation of affordable housing can be a tool to address a lack of fair housing choice in highly segregated communities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: ig5 15. Does the zoning ordinance allow for mixed uses? Yes ❑ No ❑ If 'Yes', does the ordinance or other planning policy document consider the ability of mixed -use development to enhance housing affordability? Also, do development standards for mixed -uses take into consideration the challenges of providing housing accessible to persons with disabilities in such mixed uses? Background The purpose of this inquiry relates to housing affordability and fair housing choice as discussed in the Background section of question 14. Also, 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 CFR Title 24, Part 100.205 and CCR Title 24 accessibility requirements. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief overview of the development standards: 16. Does the zoning ordinance provide for any of the following: 1) development incentives for the provision of affordable housing beyond those provided by state law; 2) development by right of affordable housing; or, 3) a zoning overlay to allow for affordable housing development? Yes ❑ No ❑ Background The purpose of this inquiry relates to housing affordability and fair housing choice as discussed in the Background section of the question 14. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief overview of the development standards: 17. Does the zoning ordinance describe any areas in this jurisdiction as exclusive? Yes ❑ No ❑ Are there exclusions or discussions in the ordinance or any planning policy document of limiting housing on the basis of any of the following characteristics covered by fair housing laws? Yes ❑ No ❑ If `Yes', check all of the following that apply: Race ❑ Color ❑ Sex ❑ Religion ❑ Age ❑ Disability ❑ Familial Status ❑ National Origin ❑ 120 Explanation of Answer Given Above Please provide a brief explanation of the how you arrived at the answer: 18. Are there any standards for Senior Housing in the zoning ordinance? Yes ❑ No ❑ If `Yes', do the standards comply with state or federal law on housing for older persons (i.e., solely occupied by persons 62 years of age or older, or occupied by at least one person 55 years of age, or other qualified permanent resident pursuant to Civil Code §51.3)? Yes ❑ No ❑ Is the location of Senior Housing treated differently than that other rental or for -sale housing? Yes ❑ No ❑ If `Yes', explain. Background Under federal law housing discrimination against families with children is permitted only in housing in which all the residents are 62 years of age or older or where at least 80% of the occupied units have one person who is 55 years of age or older. Generally, California law states that a housing provider using the lower age limitation of 55 years must have at least 35 units to use the familial status discrimination exemption. Also, California law, with narrow exceptions, requires all residents to be "senior citizens' or "qualified permanent residents ", pursuant to Civil Code §51.3. The 1988 amendments to the federal Fair Housing Act exempt "housing for older persons" from the prohibitions against familial discrimination. This means that housing communities and facilities that meet the criteria for the federal Housing for Older Persons Act (HOPA) may legally exclude families with children. Such housing is still bound by all other aspects of fair housing law (such as prohibition of discrimination based on race, national origin or disability). Section 3607(b)(2) defines "housing for older persons" as housing: (A) provided under any State or Federal program that the Secretary determines is specifically designed and operated to assist elderly persons (as defined in the State of Federal program); or (B) intended for, and solely occupied by, persons 62 years of age or older; or (C) intended and operated for occupancy by persons 55 years of age or older and — (i) at least 80 percent of the occupied units are occupied by at least one person who is 55 years of age or older; (ii) the housing facility or community publishes and adheres to policies and procedures that demonstrate the intent required under this subparagraph; and (iii) the housing facility or community complies with rules issued by the Secretary for verification of occupancy, which shall — 187 (1) provide for verification by reliable surveys and affidavits, and (II) include examples of the types of policies and procedures relevant to a determination of compliance with the requirement of clause (ii). Such surveys and affidavits shall be admissible in administrative and judicial proceedings for the purposes of such verification. Subsection (C) was changed by the Housing for Older Persons Act of 1995 (HOPA) to remove some of the uncertainties created by a provision in the 1988 Amendments that required the "existence of significant facilities and services specifically designed to meet the physical and social needs of older persons." The HOPA also provides for a good faith defense in an action for monetary damages under this subsection. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief overview of the development standards, if any: 19. Does the zoning code distinguish senior citizen housing from other residential uses by the application of a conditional use permit (CUP)? Yes ❑ No ❑ Background Senior housing is an important component of the community's housing stock. Demographic projections show that many communities will experience a growth in the elderly population. As a population ages, seniors need a variety of housing opportunities. Also, there is a higher prevalence of persons with disabilities within the senior population. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and what aspects of use trigger the need for a permit: 20. Does the zoning code or other planning policy document address housing for "special needs" populations? Yes ❑ No ❑ Background Special needs populations typically are considered to be homeless people, victims of domestic violence, people with disabilities (including those recovering from substance abuse), youth in crisis, people living with HIV /AIDS and the frail elderly. Of these groups, homeless people, victims of domestic violence, people with disabilities, and people living with HIV /AIDS have direct fair housing implications. There is a high incidence of disability in the homeless population, domestic violence overwhelming impacts women; and people living with HIV /AIDS are considered disabled under fair housing laws. While age is not a characteristic protected under federal fair housing law, it is covered under state law, and the higher incidence of disability in the frail elderly introduces possible fair housing implication for that population as well. :: These populations often rely on group homes or service - enriched multi - family settings for housing opportunities. To the extent that zoning and other planning policy documents fail to provide for, or impose barriers to, these types of housing an impediment to fair housing choice might exist. As previously noted, according to the DOJ and HUD, the term 'group home' does not have a specific legal meaning. While it often implies a living situation for people with disabilities, it also applies to any group of unrelated persons, often sharing common characteristics, who live together in a dwelling. This broader use of the term encompasses 'special needs' individuals. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief explanation of 'special needs' provisions, if any: 21. Does the zoning ordinance establish occupancy standards or maximum occupancy limits that are more restrictive than state law, which incorporates the Uniform Housing Code(UHC)? Yes 0 No O Background Occupancy standards sometimes can impede housing choice for families with children or for disabled persons. For example, some jurisdiction's zoning regulations have attempted to limit occupancy to five related persons occupying a single family home, or to strictly establish an occupancy standard of no more than two persons per bedroom. Such regulations can limit housing availability for some families with children, or prevent the development of housing for disabled persons. The federal Fair Housing Act (FHA) also 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." [Section 807(b)(1)] HUD implements section 589 of the Quality Housing and Work Responsibility Act (QHWRA) of 1988 by adopting as its policy on occupancy standards for purposes of enforcement actions under the FHA, the standards provided in the Memorandum of General Counsel Frank Keating to Regional Counsel dated March 20, 1991. The purpose of that Memorandum was "to articulate more fully the Department's position on reasonable occupancy policies and to describe the approach that the Department takes on its review of occupancy cases." The Memorandum states the following: "Specifically, the Department believes that an occupancy policy of two persons in a bedroom, as a general rule, is reasonable under the Fair Housing Act. [. .] However, the reasonableness of any occupancy policy is rebuttable, and neither the February 21 [1991] memorandum nor this memorandum implies that Department will determine compliance with the Fair Housing Act based solely on the number of people permitted in each bedroom." [emphasis added] The memorandum goes on to reiterate statements taken from the final rule implementing the Fair Housing Amendments Act of 1988 as follows: "[T]here is nothing in the legislative history that indicates any intent on the part of Congress to provide for the development of a national occupancy code ...." "Thus, the Department 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 that, in connection with a complaint alleging discrimination on the basis of familial status, the Department will carefully examine any such nongovernmental restriction to determine whether it operates unreasonably to limit or exclude families with children. " *U.S. Department of Housing and Urban Development, Memorandum to All Regional Counsel from Frank Keating on the subject of Fair Housing Enforcement Policy: Occupancy Cases, March 20, 1991. Essentially, HUD has established a starting point for assessing the reasonableness of occupancy restrictions, but has stated that the specific facts of each living situation must inform the final determination of reasonableness. While the above discussion relates to matters of discrimination affecting families with children, a similar analysis applies to standards that may limit housing choice for persons with disabilities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and the standards, if any: 22. Does the jurisdiction encourage or require affordable housing developments to give an admission preference to individuals already residing within the jurisdiction? Yes ❑ No ❑ If `Yes', is it a requirement? Yes ❑ No ❑ Background This practice may have fair housing implications if the population of the jurisdiction lacks diversity or does not reflect the demographic makeup of the larger region in which it is located. There may be a barrier to fair housing choice, in that the policy can have a discriminatory affect on the basis of characteristics considered by fair housing laws. For example if a jurisdiction already lacks housing suitable to people with mobility - related disabilities, the local population may have an under representation of such individuals, when compared to the population generally. Newly developed accessible housing that could meet the needs of such individuals, but which has a local resident admission preference, would be less likely to improve the ability of people with mobility - related disabilities to live in the jurisdiction. Likewise, a jurisdiction with an under representation of minority residents is likely to perpetuate that situation if a local resident admission preference is implemented for new affordable housing development. ;19L-) Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 23. Does the jurisdiction have any redevelopment areas? Yes ❑ No ❑ If `Yes', does the jurisdiction analyze possible impacts on fair housing choice resulting from its redevelopment activities? Yes ❑ No ❑ Background Redevelopment activities can result in the permanent displacement of residents. If the housing opportunities created by the redevelopment activity could result in a different demographic mix of residents, consideration needs to be given as to whether this difference represents an impediment, an enhancement or is neutral with respect to fair housing choice. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 24. Does the zoning ordinance or other planning or policy document include a discussion of fair housing? Yes ❑ No ❑ If 'Yes', how does the jurisdiction propose to further fair housing? Background Affirmatively furthering fair housing is an important responsibility of local government. In order to receive certain federal funds a jurisdiction must certify that it is taking actions to "affirmatively further fair housing" (AFFH). Although a jurisdiction may have numerous plans, policies, and standards, fair housing is rarely discussed in a zoning ordinance. Other documents of a jurisdiction may discuss the need to affirmatively further fair housing and the policies and actions that are in place to do so. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer, a description of where AFFH discussions, if any, may be found, and a brief summary of how AFFH is accomplished: X91 IDENTIFIED IMPEDIMENTS AND PROPOSED CORRECTIVE ACTIONS Based on your responses to questions 1 -24, please: a) provide a concise list of the zoning and planning impediments to fair housing choice that you have identified b) describe the actions that will be taken over the next five years to remove or ameliorate the identified impediments. ACKNOWLEDGMENTS: Thanks go to David A. Acevedo and Jesus Velo, of the HUD Los Angeles Fair Housing and Equal Opportunity Office, and Ralph Castaneda, Jr., of Castaneda & Associates, for providing substantial content that went into the preparation of this survey. PLEASE RETURN COMPLETED SURVEY VIA E -MAIL TO DAVID LEVY AT: dlevy(a)fairhousingoc.org 192 Attachment B City of La Habra Chapter 18.09 Reasonable Accommodations in Housing to Disabled Individuals 18.09.010 Purpose. It is the purpose of this chapter, pursuant to Fair Housing Laws, to provide individuals with disabilities reasonable accommodation in the application of the city's rules, policies, practices and procedures, as necessary to ensure equal access to housing. The purpose of this chapter is to provide a process for individuals with disabilities to make requests for, and be provided, reasonable accommodation from the various land use, zoning, or building laws, rules, policies, practices and /or procedures of the city, where warranted. (Ord. 1684 § 22 (part), 2007) 18.09.020 Definitions. A. Applicant. A person, business, or organization making a written request to city for reasonable accommodation in the strict application of land use or zoning provisions of this title. B. City. The city of La Habra. C. Code. The La Habra Municipal Code. D. Department. The community development department of city. E. Director. The community development director of city. F. Disabled or Handicapped Person. An individual who has a physical or mental impairment that substantially limits one or more of that person's major life activities; anyone who is regarded as having such impairment; or anyone who has a record of having such an impairment, but not including an individual's current, illegal use of a controlled substance. G. Fair Housing Laws. The "Fair Housing Amendments Act of 1988" (42 U.S.C. § 3601, et seq.), including reasonable accommodation required by 42 U.S.C. § 3604(f)(3)(B), and the "California Fair Employment and Housing Act" (California Government Code Section 12900, et seq.), including reasonable accommodation required specifically by California Government Code Sections 12927(c)(1) and 12955(1), as any of these statutory provisions now exist or may be amended from time to time. (Ord. 1684 § 22 (part), 2007) 18.09.030 Notice to the public of availability of accommodation process. The department shall prominently display in the public areas of the planning and building and safety department at city hall a notice advising those with disabilities or their representatives that they may request a reasonable accommodation in accordance with the procedures established in this chapter. City employees shall direct individuals to the display whenever they are requested to do so or reasonably believe that individuals with disabilities or their representatives may be entitled to a reasonable accommodation. (Ord. 1684 § 22 (part), 2007) 18.09.040 Requesting reasonable accommodation. A. In order to make specific housing available to an individual with a disability, a disabled person or representative may request reasonable accommodation, pursuant to this chapter, relating to the application of various land use, zoning, or building laws, rules, policies, practices and /or procedures of the city. B. If an individual or representative needs assistance in making a request for reasonable accommodation, or appealing a determination regarding reasonable accommodation, 4J°3 the department will endeavor to provide the assistance necessary to ensure that the process is accessible to the applicant or representative. The applicant may be represented at all stages of the proceeding by a person designated by the applicant as his or her representative. C. A request for reasonable accommodation in laws, rules, policies, practices and /or procedures must be filed on an application form provided by the department and shall include the following information: 1. A description of how the property will be used by the disabled individual(s); 2. The basis for the claim that the Fair Housing Laws apply to the individual(s) and evidence supporting the claim, which may be in the form of a letter from a medical doctor or other licensed healthcare professional, a handicapped license, or other appropriate evidence; and 3. The specific reason the requested accommodation is necessary to make particular housing available to the disabled individual(s). D. A filing fee in an amount as determined from time to time by resolution of the city council, but not to exceed the reasonable estimated costs to the city in processing the application. (Ord. 1684 § 22 (part), 2007) 18.09.050 Decision on application. A. The director shall have the authority to consider and act on requests for reasonable accommodation. The director shall issue a written determination within thirty days of the date of receipt of a completed application and may (1) grant the accommodation request, (2) grant the accommodation request subject to specified nondiscriminatory conditions, (3) deny the request, or (4) may refer the matter to the planning commission, which shall render a decision on the application in the same manner as it considers an appeal. All written determinations shall give notice of the right to appeal and the right to request reasonable accommodation on the appeals process, if necessary. The notice of determination shall be sent to the applicant by first class mail. B. If necessary to reach a determination on the request for reasonable accommodation, the director may request further information from the applicant consistent with this chapter, specifying in detail what information is required. In the event a request for further information is made, the thirty -day period to issue a written determination shall be stayed until the applicant reasonably responds to the request. (Ord. 1684 § 22 (part), 2007) 18.09.060 Required findings. The following findings must be made in order to approve a request for reasonable accommodation: A. The housing, which is the subject of the request for reasonable accommodation, will be used by an individual protected under the Fair Housing Laws. B. The request for reasonable accommodation is necessary to make specific housing available to one or more individuals protected under the Fair Housing Laws. C. The requested reasonable accommodation will not impose an undue financial or administrative burden on the city. D. The requested accommodation will not require a fundamental alteration of the zoning or building laws, policies and /or procedures of the city. If, based upon all of the evidence presented to the director, the above findings may reasonably be made, the director shall grant the requested reasonable accommodation. (Ord. 1684 § 22 (part), 2007) 294 18.09.070 Appeals. A. Within thirty days of the date the director issues a written determination, any person aggrieved or affected by a decision on an application requesting the accommodation may appeal such determination in writing to the planning commission or to the city council, as applicable. B. All appeals shall contain a statement of the grounds for the appeal. C. No such appeal shall be accepted unless there is, paid contemporaneously with the filing of such letter, a filing and processing fee in a sum to be set by resolution of the city council. Upon receipt of a timely filed appeal, together with the filing and processing fee, the secretary of the planning commission or the city clerk shall set the matter for a de novo hearing before the planning commission or city council, as applicable, at its next most convenient meeting. D. Appeals shall be to the planning commission, or the city council as applicable, which shall hear the matter and render a determination as soon as reasonably practicable, but in no event later than sixty days after an appeal has been filed, or after an application has been referred to it by the director. All determinations shall address and be based upon the same findings required to be made in the original determination from which the appeal is taken. E. An applicant may request reasonable accommodation in the procedure by which an appeal will be conducted. F. Any determination by the planning commission or city council on an application or appeal shall be by a de novo hearing. G. An applicant requesting the accommodation may appeal an adverse determination or any conditions or limitations imposed by the director to the planning commission and the planning commission's decision to the city council, in accordance with this section. In the case of an appeal of the director's decision to the planning commission or the planning commission's decision to the city council, the planning commission and city council decisions shall be final. (Ord. 1684 § 22 (part), 2007) 18.09.080 Waiver of time periods. Notwithstanding any provisions in this chapter regarding the occurrence of any action within a specified period of time, the applicant may request additional time beyond that provided for in this chapter or may request a continuance regarding any decision or consideration by the city of the pending appeal. Extensions of time sought by applicants shall not be considered delay on the part of the city, shall not constitute failure by the city to provide for prompt decisions on applications and shall not be a violation of any required time period set forth in this chapter. (Ord. 1684 § 22 (part), 2007) 195 Attachment C City of La Habra Chapter 18.21 Special Needs Housing 18.21.010 Puroose. The purpose of this chapter is to establish uniform standards, land use regulations and permit processes for the development of congregate housing, domestic violence shelters, homeless shelters, senior hotel, single -room occupancy housing (SROs), and transitional housing; and to implement general plan policies regarding special needs households. (Ord. 1460 § 1 (part), 1993) 18.21.020 Definitions. "Congregate housing" means a residential facility with shared common living areas, restricted by an agreement approved by the city for occupancy by low and very low income households, providing services which may include meals, housekeeping, child care, and other services as well as common areas for residents of the facility. "Domestic violence shelter" means a residential facility which provides temporary accommodations to persons and /or families who have been the victims of domestic violence. Such a facility may provide meals, child care, counseling, and other services. The term "temporary accommodations" means that a person or family will be allowed to reside at the shelter for a time period not to exceed six months. "Homeless shelter" means a residential facility which provides temporary accommodations to homeless persons and /or families and which meet standards for shelters contained in Title 25 California Administrative Code, Part 1, Chapter F, Subchapter 12, Section 7972. The facility may provide, or contract with recognized community organizations to provide, emergency or temporary shelter, and may also provide meals, child care, counseling, and other services. Such facility may have individual rooms, but is not developed with individual dwelling units, with the exception of manager units. The term "temporary accommodations" means that a person or family will be allowed to reside at the shelter for a time period not to exceed six months. "Low income family" means any household whose income exceeds fifty percent but does not exceed eighty percent of median income adjusted for household size as defined by the U.S. Department of Housing and Urban Development for the Anaheim -Santa Ana Primary Metropolitan Statistical Area. "Senior hotel" means a cluster of guest units with shared common living areas, restricted for occupancy by persons who are sixty -two years of age or older, providing services which may provide meals, housekeeping and other services. "Single -room occupancy housing" means a cluster of guest units within a residential hotel providing sleeping and living facilities restricted by an agreement approved by the city for occupancy by low and very low income individuals, designed for occupancy for periods of one month or longer. ?90 "Transitional housing" means a residential facility that provides accommodations to low and very low income persons and families for periods of up to two years, and which also may provide meals, child care, counseling, and other services, as well as common areas for residents of the facility. The intent of this type of facility is to provide a stable environment for the homeless and to facilitate self - sufficiency. This type of facility typically involves a situation wherein the resident is accountable to the owner /operator for his location and conduct among other factors. "Very low income" means any household whose income does not exceed fifty percent of median income adjusted for household size as defined by the U.S. Department of Housing and Urban Development for the Anaheim -Santa Ana Primary Metropolitan Statistical Area. (Ord. 1684 § 13, 2007; Ord. 1460 § 1 (part), 1993) 18.21.030 Applicability, A. The specific requirements of this chapter are applicable to the development of congregate housing, domestic violence shelters, homeless shelters, senior hotels, single -room occupancy housing (SROs), and transitional housing as defined in Section 18.21.020. B. Congregate housing, domestic violence shelters, homeless shelters, senior hotels, single - room occupancy (SROs), and transitional housing projects are permitted within commercial, industrial, and high density land use designated areas within multiple family zone with an approved conditional use permit pursuant to the procedures established in Chapter 18.58. (Ord. 1460 § 1 (part), 1993) 18.21.040 General provisions. A. All facilities shall maintain a scale, character, and design consistent with the area and compatible with the surrounding developments. B. All congregate housing, domestic violence shelter, homeless shelter, senior hotel, single room occupancy (SROs) and transitional housing projects within permitted commercial, industrial, and residential zones shall be subject to the special development standards established in Section 18.18.070. C. Site Access. A single controlled entryway for routine ingress to the site shall be situated adjacent to and in full view of the manager's office. D. Laundry Facilities. Washer and dryer shall be provided in a separate room in a location accessible to all the residents of the facility. Washers and dryers may be coin - operated. E. Child Care Area. All facilities providing child care on -site shall provide yard area in compliance with all state regulations. The yard area required for child care shall be provided in addition to the required usable yard area for the facility. F. Pay Telephone. A minimum of two pay telephones shall be provided in the facility. G. On -site Manager. Each congregate housing, domestic violence shelter, homeless shelter, single room occupancy (SROs), senior citizen hotel and transitional housing project shall have a twenty -four hour on -site manager. 197 H. Management Plan. A management plan the conditional use permit application. The information, as applicable: shall be submitted for review and approval with management plan shall contain the following 1. Child care; 2. Emergency procedures; 3. Maintenance plans; 4. Management policies; 5. Operation of the facility; 6. Rental procedures and policies; 7. Residency rules; 8. Screening of residents to insure compatibility with services provided at the facility; 9. Security programs; 10. Services, training, counseling, and treatment programs for residents to be provided by the facility, including services to assist resident to obtain permanent income and shelter; 11. Staffing needs; 12. Staff training; 13. Tenants responsibility. Project Review. 1. Annual Review. Each project shall be subject to annual review by the city which includes the review of management services. The project owner shall be responsible for filing an annual report to the city which includes the range of monthly rents, average length of tenancy, range of monthly income of residents, occupancy rates, number of family served, the number of vehicles owned by the residents, and services provided at the facility; 2. Management Plan Revisions. Management plan revisions shall be reviewed and approved by the chief planner, before implementation of changes. Substantive changes or revisions as determined by the chief planner shall be approved by the planning commission. (Ord. 1460 § 1 (part), 1993) 18.21.050 Congregate housing, domestic violence shelter and transitional housing. Congregate housing, domestic violence shelter and transitional housing shall conform to all standards of development of the zoning in which it is located except as provided in this section. A. Density. 1. In high density residential land use designated areas within multiple family residential zones, the number of families shall not exceed the number of families permitted pursuant to the appropriate zoning designation provided for in Table 18.18.060.1 -C, plus twenty -five percent. 2. In all commercial and industrial zones, the number of families shall not exceed that pursuant to the zoning designation provided in Table 18.21.050A, plus twenty -five percent. The maximum floor area ratio (FAR), shall not exceed that established within the appropriate land use designation of the general plan land use element. Table 18.21.050A Total Area Of Parcel Being Developed Minimum Area Per Family Within: CP; C -1; C -2; C -3; PC -I; M -1 Under 10,000 square feet 1,980 10,001 through 20,000 square feet 1,742 20,001 square feet and over 1,555 B. Building Design. 1. Each facility within the high density residential, commercial, and industrial land use designated areas shall contain common kitchen, dining and living room areas adequate for the number of residents serviced. a. Bathrooms shall contain lavatory, toilet, and shower or bathtub adequate for the number of residents serviced, b. Each bedroom shall have access to a bathroom, C. Each bedroom shall have a minimum of eighteen square feet of closet/storage space, d. Bedroom occupancy shall be determined in accordance with the Uniform Building Code or as limited by the planning commission; 2. Each facility shall provide private sleeping areas per families serviced in accordance with the requirements of the building code. C. Recreational and Usable Yard Area. 1. Minimum Area Per Parcel. Such usable yard area shall have no dimension of less than fifteen feet. This area may be provided at any location on the lot except in the required front yard or in a required side yard abutting a street. This area may be divided into not more than two separate subareas. a. Within the multiple family zone, no parcel of land shall have less than one thousand square feet of usable yard area plus one hundred square feet per bedroom, b. Within commercial and industrial zones, no parcel of land shall have less than eight hundred square feet of usable yard area plus eighty square feet per bedroom. D. Parking. 1. Automobiles. For each facility located within an allowed designation, a minimum of two parking spaces shall be provided per the standards established in Chapter 18.56. (Ord. 1693 § 2(b), 2008; Ord. 1460 § 1 (part), 1993) 18.21.060 Homeless shelter. Homeless shelters shall conform to all standards of development of the zoning in which it is located except as provided in this section. 199 A. Density 1. In high density residential land use designated areas within a multiple family zone, the number of beds shall be limited to three times the maximum units permitted within the zoning designation in which the facility is located as established in Table 18.18.060.1 -C; 2. In all commercial and industrial zones, the number of beds shall be limited to three times the maximum number of units allowed within the commercial /industrial zone as provided in Table 18.21.050A. The proposed development shall not exceed the maximum floor area ratio (FAR) established within the general plan land use element for the appropriate land use designation. B. Building Design. 1. Each facility shall provide common kitchen and dining room area adequate for the number of residents serviced; 2. Each facility shall provide bathroom with lavatory, toilet, and showers adequate for the number of residents serviced. C. Recreational and Usable Yard Area. 1. Minimum Area Per Parcel. Such usable yard area shall have no dimension of less than fifteen feet. This area may be provided at any location on the lot except in the required front yard or in a required side yard abutting a street. Subareas may be divided into not more than two separate subareas. a. Within multiple family zones, no parcel of land shall have less than one thousand square feet of usable yard area plus sixty -two square feet per bed, b. Within the commercial and industrial zones, no parcel of land shall have less than five hundred square feet of usable yard area plus ten square feet of additional usable yard area per each additional bed over twenty -five. D. Parking. (See Chapter 18.56.) E. Operating and Location Requirements. 1. No more than one federal, state or youth authority parolee shall be allowed to live in a homeless shelter at any one time. 2. The conditional use application submitted for any homeless shelter shall provide information, including identifying information such as the full name and age of the parolee and the proposed time of residency at the facility, regarding any proposed residents who will be, at the time of proposed residency in the homeless shelter, federal, state or youth authority parolees. Such information shall be updated with the city by the owner or landlord of the facility as to each lessee, renter, resident or occupant upon the signing, entering into, or otherwise commencing any rental or lease agreement, arrangement or accommodation within three business days. 3. All homeless shelters shall require residents or occupants to sign an agreement that provides that a conviction for any criminal violation, not including infractions and minor traffic 200 violations, during residency or occupancy in the transitional shelter /house, is grounds for termination of the residency, tenancy, occupancy or accommodations of that resident or occupant, whether the rental, lease, or sublease agreement is written or oral. 4. Homeless shelters shall be in compliance with all requirements of the city's zoning code at all times, as well as any other applicable provisions of this code, including obtaining any other permits or licenses, such as building permits or a business license, required before establishing, expanding or maintaining the use. 5. No homeless shelter shall be maintained as a nuisance. The conduct of any homeless shelter within the city in violation of any of the terms of this chapter or other applicable provisions of this code found and declared to be a public nuisance, and the city attorney or the district attorney may, in addition or in lieu of prosecuting a criminal action hereunder, commence an action or proceeding for the abatement, removal and enjoinment thereof, in the manner provided by law; and shall take other steps and shall apply to such courts as may have jurisdiction to grant such relief as will abate or remove such homeless shelter and restrain and enjoin any person from conducting, operating or maintaining a homeless shelter contrary to the provisions of this chapter or code. 6. Any violation of any local, state or federal laws by residents or occupants of homeless shelters while on the premises shall be grounds for revocation of the homeless shelter's conditional use permit, including but not limited to any violations of this section, California Penal Code Section 3003.5 or Chapter 9.66 of this code, where the property owner contributed to or did not take all reasonable steps to protect against or prevent the violation. 7. Any owner, operator, manager, employee or independent contractor of a homeless shelter violating or permitting, counseling, or assisting the violation of any of the provisions of this chapter or applicable provisions of this code regulating homeless shelters shall be subject to any and all civil remedies, including conditional permit revocation, criminal penalties pursuant to Chapter 1.08 of this code, and /or administrative citations pursuant to Chapter 1.09. All remedies provided herein shall be cumulative and not exclusive. Any violation of these provisions shall constitute a separate violation for each and every day during which such violation is committed or continued. (Ord. 1693 § 2(c), 2008; Ord. 1684 § 14, 2007; Ord. 1460 § 1 (part), 1993) 18.21.070 Senior hotel. Senior hotels shall conform with all local state and federal requirements for senior housing. Each facility shall conform to all property development standards of the zoning in which it is located except as provided in this section. A. Density. 1. In high density residential land use designated areas within multiple family residential zoned areas, the number of units shall not exceed that pursuant to the zoning designation provided in Table 18.18.060.1 -C, plus twenty -five percent; 2. In all commercial and industrial zones, the number of units shall be limited by the maximum floor area ratio (FAR) as established within the general plan land use element for the appropriate land use designation. 201 B. Building Design. Each guest unit shall contain a bathroom. 1. Bathrooms shall contain a lavatory, toilet, and shower or bathtub; 2. Each unit shall have a minimum forty -eight cubic feet of closet/storage space. C. Recreational and Usable Yard Area. 1. Minimum Area Per Parcel. Such usable yard area shall have no dimension of less than fifteen feet. This area may be provided at any location on the lot except in the required front yard or in a required side yard abutting a street. a. Within multiple family zones, no parcel of land shall have less than one thousand square feet of usable yard area plus one hundred square feet per bedroom. b. Within the commercial and industrial zones, no parcel of land shall have less than one thousand square feet of common usable yard area plus fifteen square feet of common recreational area per guest unit for projects over twenty -five units. 2. Common recreational space may be indoor or outdoor provided there is at least forty percent allotted towards outdoor space; the balance may be indoors or outdoors. D. Parking. (See Chapter 18.56.) E. Common Facilities. The development may provide one or more of the following common facilities for the exclusive use of the senior citizen residents: 1. Central cooking and dining room; 2. Recreation room; 3. Library; 4. Beauty salon and barber shop; 5. Small pharmacy; 6. Laundry facilities or laundry services. F. Occupancy. 1. No more than one person shall be permitted to reside in any unit which is less than two hundred twenty square feet in size. No more than two persons shall be permitted to reside in any unit. 2. Residential occupancy shall be limited to single persons sixty -two years of age or older, or to couples in which one person is sixty -two years of age or older. (Ord. 1693 § 2(d), 2008; Ord. 1460 § 1 (part), 1993) 202 18.21.080 Sinale -room occuoancv housina (SROs). SRO projects shall conform to all standards of development of the zoning in which it is located except as provided below. A. Density. 1. In high density residential land use designated areas with multiple family residential zones, the number of units shall not exceed that pursuant to the zoning designation provided in Table 18.18.060.1 -C, plus twenty -five percent; 2. In all commercial and industrial zones, the number of units shall be limited by the maximum floor area ratio (FAR), as established within the appropriate land use designation of the general plan land use element. B. Building Design. 1. Unit Size. Minimum unit size for all SROs shall be one hundred seventy square feet and maximum unit size for all SROs shall be four hundred square feet; 2. Each unit shall contain a kitchen and bathroom. a. Kitchens shall contain a sink with garbage disposal, counter top minimum sixteen by twenty -four inch, refrigerator, and stove or microwave oven, b. If stoves are not provided in each unit, then stoves shall be provided in a common C. Bathrooms shall contain a lavatory, toilet, and shower or bathtub, d. Each unit shall have a minimum forty -eight cubic feet of closet/storage space. C. Recreational and Usable Yard Area 1. Minimum Area Per Parcel a. Within multiple - family zones, no parcel of land shall have less than one thousand square feet of usable yard area plus one hundred square feet per unit, b. Within the commercial and industrial zones, no parcel of land shall have less than five hundred square feet of common usable yard area plus fifteen square feet of common recreational area per unit for projects over twenty -five units. Such usable yard area shall have no dimension of less than fifteen feet. This area may be provided at any location on the lot except in the required front yard or in a required side yard abutting a street; 2. Common recreational space may be indoor or outdoor provided there is at least forty percent allotted towards outdoor space; the balance may be indoors or outdoors. D. Parking. (See Chapter 18.56.) E. Occupancy. No more than one person shall be permitted to reside in any unit which is less than two hundred twenty square feet in size. No more than two persons shall be permitted to reside in any unit. (Ord. 1693 § 2(e), 2008; Ord. 1460 § 1 (part), 1993) 203 18.21.090 Transitional housing project. Transitional housing projects shall also comply with the following operating and location requirements: A. No more than one federal, state or youth authority parolee shall be allowed to live in a transitional housing project at any one time. B. No transitional housing project shall be within five hundred feet of any other transitional housing project. The distance requirement herein shall be measured from property line to property line, along a straight line extended between the two points. C. The conditional use application submitted for any transitional housing project shall provide information, including identifying information such as the full name and age of the parolee and the proposed time of residency at the facility, regarding any proposed residents who will be, at the time of proposed residency in the transitional housing project, federal, state or youth authority parolees. Such information shall be updated with the city by the owner or landlord of the facility as to each lessee, renter, resident or occupant upon the signing, entering into, or otherwise commencing any rental or lease agreement, arrangement or accommodation within three business days. D. All transitional housing projects shall require residents or occupants to sign an agreement that provides that a conviction for any criminal violation, not including infractions and minor traffic violations, during residency or occupancy at the transitional housing project, is grounds for termination of the residency, tenancy, occupancy or accommodations of that resident or occupant, whether the rental, lease, or sublease agreement is written or oral. E. Transitional housing projects shall be in compliance with all requirements of the city's zoning code at all times. F. No transitional housing project shall be maintained as a nuisance. The conduct of any transitional housing project within the city in violation of any of the terms of this chapter or other applicable provisions of this code found and declared to be a public nuisance, and the city attorney or the district attorney may, in addition or in lieu of prosecuting a criminal action hereunder, commence an action or proceeding for the abatement, removal and enjoinment thereof, in the manner provided by law, and shall take other steps and shall apply to such courts as may have jurisdiction to grant such relief as will abate or remove such transitional housing project and restrain and enjoin any person from conducting, operating or maintaining a transitional housing project contrary to the provisions of this chapter or code. G. Any violation of any local, state or federal laws by residents or occupants of transitional housing projects while on the premises shall be grounds for revocation of the transitional housing project's conditional use permit, including but not limited to any violations of this section, California Penal Code Section 3003.5 or Chapter 9.66 of this code, where the property owner contributed to or did not take all reasonable steps to protect against or prevent the violation. H. Any owner, operator, manager, employee or independent contractor of a transitional housing project violating or permitting, counseling, or assisting the violation of any of the provisions of this chapter or applicable provisions of this code regulating transitional housing projects shall be subject to any and all civil remedies, including conditional permit revocation, i�ZJr criminal penalties pursuant to Chapter 1.08 of this code, and /or administrative citations pursuant to Chapter 1.09. All remedies provided herein shall be cumulative and not exclusive. Any violation of these provisions shall constitute a separate violation for each and every day during which such violation is committed or continued. (Ord. 1684 § 15, 2007) 205 Attachment D City of San Francisco Chapter 87 Fair Housing Implementation Ordinance SEC. 87.1. - SHORT TITLE. This ordinance shall be entitled the "Fair Housing Implementation Ordinance." (Added by Ord. 303 -99, File No. 990494, App. 12(3199) SEC. 87.2. - FINDINGS. The Board of Supervisors finds that: (a) Federal, state and local fair housing laws protect certain classes of individuals from housing discrimination that may occur through zoning laws, land use authorizations, funding decisions and other activities of local government. These laws include, but are not limited to: (1) The federal Fair Housing Act, 42 U.S.C. §§ 3601 et seq. This law prohibits, among other things, local government from making dwellings unavailable because of the race, color, religion, sex, familial status, national origin, or handicap of the individual(s) seeking such dwellings. (2) California Government Code Section 12955 (the "California Fair Employment and Housing Act'). This law prohibits local government from (i) making housing unavailable, and (ii) discriminating through land use practices, decisions, and authorizations, because of race, color, religion, sex, familial status, marital status, disability, national origin, or ancestry. Prohibited practices include, but are not limited to, zoning laws, denials of use permits, and other actions under the Planning and Zoning Law, Government Code § 65000 et seq., that make housing opportunities unavailable because of protected class status. (3) California Government Code Section 12955.8(a) (the "California Fair Employment and Housing Act'). This law establishes that a local government engages in unlawful housing discrimination if race, color, religion, sex, familial status, marital status, disability, national origin, or ancestry is a motivating factor when a land use practice, decision, authorization, or other local action makes housing unavailable to members of a protected class. (4) California Government Code Section 12955.8(b) (the "California Fair Employment and Housing Act'). This law establishes that a local government engages in unlawful housing discrimination if a land use practice, decision, authorization, or other local action has an unjustified discriminatory effect, regardless of intent, on the basis of race, color, religion, sex, familial status, marital status, disability, national origin, or ancestry. (5) California Government Code Section 65008 (the "California Planning and Zoning Law "). This law prohibits, among other things, local government, in the enactment or administration of zoning laws, from discriminating against a residential development because the development is intended for occupancy by low and moderate income persons. This Act also prohibits local government from imposing different requirements on residential developments because of race, sex, color, religion, ethnicity, national origin, ancestry, lawful occupation or age of the intended occupants of the development, or because of the income 200 level of the intended occupants of the development, unless the local government imposes those requirements on developments generally or the requirements promote the availability of the residential development for lower income persons. (6) California Government Code Section 65589.5 (the "California Planning and Zoning Law "). This law prohibits a local government agency from disapproving a housing development for low- and moderate - income households or conditioning approval in a manner which renders the project infeasible for development for use by low- and moderate- income households unless the local agency makes one of six findings justifying such disapproval or conditions. (7) Section 3604(f)(B)(3) of Title 42 of the United State Code (the "Fair Housing Act ") and Section 12927(c)(1) of the California Government Code (the "California Fair Employment and Housing Act'). These laws prohibit local government from refusing to make reasonable accommodations in policies and practices when these accommodations are necessary to afford persons with disabilities equal opportunity to use and enjoy a dwelling. (8) Section 3304 of Article 33 of the San Francisco Police Code. This ordinance establishes, among other things, that local government engages in unlawful housing discrimination if the inclusion of restrictions, terms or conditions on real property transactions, the imposition of different conditions on financing for the construction, rehabilitation, or maintenance of real property, or the restriction of facilities for any tenant or lessee is based wholly or partially on race, religion, color, ancestry, age, sex, sexual orientation, gender identity, disability or place of birth. (b) Federal, state and local fair housing laws require that departments, agencies, commissions, officers, and employees of the City and County of San Francisco shall not base any decision about housing development on evidence that discriminates against the classes protected by these laws. (c) Federal, state and local fair housing laws require that departments, agencies, commissions, officers and employees of the City and County of San Francisco shall not impose, when approving a housing development, any conditions that discriminate against the classes protected by these laws. (d) This ordinance will facilitate compliance with federal, state and local fair housing laws, and promote housing opportunities for residents of San Francisco. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.3. - DEFINITIONS. (a) Protected Class. 'Protected class" means those groups that receive protection from housing discrimination under the Fair Housing Act, 42 U.S.C. §§ 3601 et seq., the California Fair Employment and Housing Act, Government Code §§ 12900 et seq., Sections 65008 and 65589.5 of the Government Code, and Section 3304 of Article 33 of the San Francisco Police Code. (b) City Entity. "City entity" includes the Board of Supervisors, the Executive Branch as described in Articles III, IV, and V of the Charter of the City and County of San Francisco, and any department, agency, commission, officer, employee, or advisory group of the City and County of San Francisco. (c) Dwelling. "Dwelling" shall have the same meaning as the definition of "dwelling" in Section 3602 of Title 42 of the United States Code (the "Fair Housing Act'). 20 j (d) Fair Housing Laws. "Fair housing laws" shall mean those laws described in Section 87.2, above, together with any other federal, State or local laws related to housing discrimination. (e) Family. "Family" shall have the same meaning as in Section 401 of the San Francisco Housing Code. (f) Supportive Services. "Supportive services" means services that are provided to residents of a housing development and that are based on their particular needs and circumstances. These services include, but are not limited to, counseling, vocational training, case management, medical services, peer -based services, rehabilitative services, skills development, and recreational activities. The use of a portion of a residential building to provide supportive services for the building's residents shall be a permissible accessory use to the building. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.4. - COMPLIANCE WITH FAIR HOUSING LAWS. When any City entity considers an application or proposal for the development, use, or funding of dwellings in which protected class members are likely to reside, or when any City entity applies existing City codes, regulations, or other standards to such dwellings, the City entity shall comply with all applicable fair housing laws and administer local policies, procedures, and practices in a manner that affirmatively furthers those laws. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.5. - NO DECISIONS BASED ON DISCRIMINATORY INFORMATION With respect to applications or proposals for the development, use, or funding of dwellings in which protected class members are likely to reside, a City entity shall not base any decision regarding the development, use, or funding of the dwellings on information which may be discriminatory to any member of a protected class. This discriminatory information includes, but is not limited to, the following: (a) That the dwellings will lower the property values of surrounding parcels of land because members of a protected class will reside in the dwellings; (b) That the dwellings will increase crime in the neighborhood because members of a protected class will reside in the dwellings; (c) That the dwellings will generate an increased demand for parking or generate more traffic because members of a protected class will reside in the dwellings; (d) That the dwellings will not be compatible with a neighborhood or community because members of a protected class will reside in the dwellings; (e) That the dwellings will increase the concentration of dwellings or services for members of a protected class in a particular neighborhood or area of the city; (f) That the dwellings will be detrimental to, or have a specific, adverse impact upon, the health, safety, convenience or general welfare of persons residing or working in the vicinity because members of a protected class will reside in the dwellings; (g) That the dwellings will be injurious to property, improvements or potential development in the vicinity because members of a protected class will reside in the dwellings; (h) That the dwellings will generate an increased demand for city services because members of a protected class will reside in the dwellings. I: (i) That the dwellings will not be appropriate for the neighborhood because supportive services will be provided to members of a protected class residing in the dwellings. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.6. - NONDISCRIMINATORY CONDITIONS OF APPROVAL. With respect to applications or proposals for the development, use, or funding of dwellings in which protected class members are likely to reside, a City entity shall not impose on the approval of the dwellings (a) any condition that it does not impose on other dwellings of similar scale and size in the use district or zoning classification specified in the San Francisco Planning Code, or (b) any conditions of approval which are based on the fact that protected class members are likely to reside in the dwellings, including but not limited to restrictions on the activities of residents in or around the dwellings, restrictions on visitors to the dwellings, requirements for additional off - street parking, special review or monitoring of the dwellings by a City entity or neighborhood group, restrictions on services provided to residents, special design or maintenance requirements for the dwellings, and restrictions on future development on or near the site. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.7. - REASONABLE ACCOMMODATIONS. With respect to applications or proposals for the development, use, or funding of dwellings in which protected class members are likely to reside, a City entity shall make reasonable accommodations in its rules, policies, practices, or services when those accommodations may be necessary to afford persons with disabilities equal opportunities to use and enjoy the dwellings. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.8. - NONDISCRIMINATORY APPLICATION OF STANDARDS. Nothing in this Chapter shall be construed to prohibit a City entity from applying building and planning standards, design review, health and safety standards, environmental standards, or any other standards within the jurisdiction of the City entity as long as those standards are identical to those applied to other dwellings of similar scale and size in the use district or zoning classification specified in the San Francisco Planning Code, unless the City entity is required to make a reasonable accommodation under Section 87.7 of this Chapter. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.9. - APPLICABILITY. This Chapter shall, among other things, apply to all actions, practices, and other decisions of any City entity having discretionary authority over permits, funding, conditions of approval, or other matters related to the development of dwellings. These actions, practices, and decisions include, but are not limited to, conditional use authorizations under Section 303 of the San Francisco Planning Code, variances under Section 305 of the San Francisco Planning Code, permits under Article 1 of Part III of the San Francisco Municipal Code, discretionary review of permits under Section 26 of Article 1 of Part III of the San Francisco Municipal Code, subdivision approvals under the San Francisco 209 Subdivision Code, permit approvals under the San Francisco Public Works Code, and any actions authorized under law by the Board of Appeals, the Building Inspection Commission, the Health Commission, and other city entities, regardless of whether the laws or regulations describing such discretionary authority specifically refer to the City entity's obligations under this Chapter. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.10. - COMPLIANCE BY STATE - AUTHORIZED AGENCIES. Upon the effective date of this ordinance, the Mayor shall request, in writing, compliance with this ordinance by any state - authorized agency operating solely within the City and County of San Francisco and having authority over permits, funding, conditions of approval, or other matters related to the development of dwellings. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.11. - SEVERABILITY. If any part or provision of this Chapter, or the application thereof to any person or circumstance, is held invalid, the remainder of the Chapter, including the application of such part or provision to other persons or circumstances, shall not be affected thereby and shall continue in full force and effect. To this end, provisions of this Chapter are severable. (Added by Ord. 303 -99, File No. 990494, App. 1213199) 210 Section 7 AFFH Through the Location of Affordable Housing 211 SECTION 7 AFFH THROUGH THE LOCATION OF AFFORDABLE HOUSING A. BACKGROUND A lack of affordable housing in and of itself, HUD has pointed out, is not an impediment to fair housing choice, unless it creates an impediment to housing choice because of membership in a protected class. However, recent court cases and recent events have demonstrated that the location of affordable housing is regarded as a means of AFFH. As a result of a court settlement, Westchester County (New York) must adopt a policy statement providing that "the location of affordable housing is central to fulfilling the commitment to AFFH because it determines whether such housing will reduce or perpetuate residential segregation." (United States of America ex rel. Anti - Discrimination Center of Metro New York, Inc. v. County of Westchester, New York) In order to meet the requirements of the settlement agreement, Westchester County must develop an implementation plan that includes, but is not limited, to: • A model ordinance that the County will promote to municipalities to advance fair housing that shall include: ✓ A model inclusionary housing ordinance that requires new development projects to include a certain percentage of affordable units, including criteria and standards for the affordable housing units and definitions of who is eligible for affordable housing; ✓ Standards for affirmative marketing of new housing developments to ensure outreach to racially and ethnically diverse households; • Standards for expedited review of proposals for affordable housing that AFFH including procedures for streamlining the approval process for the design, permitting, and development of these units; and • Standards for legal mechanisms to ensure the continued affordability of new affordable units. Housing developed pursuant to the plan: • Must be located predominantly in municipalities where the African American and Hispanic population comprise less than 3% and 7% of the population, respectively. • Not be developed in any census block which has an African American population of more than 10% and a total population of 20 or more. • Not be developed in any census block which has a Hispanic population of more than 10% and total population of 20 or more. The Westchester County settlement agreement demonstrates that a means to AFFH is by the development of affordable housing outside of areas with concentrations of minority populations. 212 Another example is the State of North Carolina which added "affordable housing" to the group of protected classes. The State passed an act providing that it is a violation of the State's fair housing act to discriminate in land use decisions or the permitting of development based on the fact that a development contains affordable housing units. The Act states: It is an unlawful discriminatory housing practice to discriminate in land -use decisions or in the permitting of development based on race, color, religion, sex, national origin, handicapping condition, familial status, or, except as otherwise provided by law, the fact that a development or proposed development contains affordable housing units for families or individuals with incomes below eighty percent (80 %) of area median income. It is not a violation of this Chapter if land -use decisions or permitting of development is based on considerations of limiting high concentrations of affordable housing. In 2000, Florida's Affordable Housing Study Commission adopted a proposal made by 1000 Friends of Florida to amend the Florida Fair Housing Act by extending protection to affordable housing developments. Florida Statute 760.26 reads: It is unlawful to discriminate in land use decisions or in the permitting of development based on race, color, national origin, sex, disability, familial status, religion, or, except as otherwise provided by law, the source of financing of a development or proposed development. The decision to not specifically use the term "affordable housing" in statutory language has not diminished the intended application of Fair Housing Act protection, according to its advocates. Since enactment, county and city attorneys have regularly advised their commissions that affordable housing developments cannot be treated differently from market -rate developments in land use or permitting decisions. In California, Government Code Section 65008 expressly prohibits localities from discriminating against residential development or emergency shelters if the intended occupants are low - income or if the development is subsidized (i.e., the method of financing). B. DATA SOURCES The purpose of the analysis was to determine whether affordable housing developments are concentrated in neighborhoods with a high concentration of minority populations and low income populations. Neighborhoods with "high concentrations" were determined as follows: • Census tracts with 80% or more minority population • Census tracts with 80% or more of the population having low incomes (that is, incomes less than 80% of the County's median income) Census 2000 is the data source for the minority population data. The low income population is based on HUD calculations, which are based on the Census 2000 data. The statistical information used by HUD in the calculation of the estimates comes from three tables in Summary File (SF) 3: P9 — Household Type (Including Living Alone) by Relationship; P76 — Family Income in 1999; and P79 — Non - family Household Income in 1999. 213 The inventory of affordable housing was determined primarily from two data sources: County of Orange, Orange County Community Services, 2009 County of Orange Affordable Rental Housing List California Tax Credit Allocation Committee, Active Projects Receiving Tax Credits 1987- 2010 Year to Date, May 2010 The affordable housing developments from these two sources were merged and duplicates were eliminated. The overall inventory was further refined by consulting the affordable housing lists maintained by the cities of Anaheim, Garden Grove and Santa Ana. Consulting these lists resulted in adding projects and eliminating a few in cases of duplicates due to different project names with same address. Field surveys were necessary in a few cases because more than one project was located within in the same address range. Lastly, phone calls became necessary to confirm the city location of a project and the number of housing units. The census tract location of each affordable housing development is identified in the CTAC list. The census tract location of all other projects was identified by using American Factfinder: U.S. Census Bureau, American Factfinder Website, Advanced Geography Search, Census Program Year, Address Search. An analysis also was completed on the extent to which Section 8 assisted housing (families) is located in census tracts /neighborhoods with a high percentage (80 %) of minority populations. Housing authorities encourage Section 8 voucher holders to find housing located outside areas of poverty and minority concentration. The Los Angeles Area Office of the U.S. Department of Housing and Urban Development reviewed the Draft Regional Al and requested the analysis of the location of Section 8 housing. Data on the census tract location of Section 8 voucher holders was provided by: • Garden Grove Housing Authority (GGHA) • Santa Ana Housing Authority (SAHA) • Orange County Housing Authority (OCHA) Data was unavailable from the Anaheim Housing Authority (AHA). C. ANALYSIS OF THE LOCATION OF THE AFFORDABLE HOUSING INVENTORY 1. Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Minority Populations Altogether there are 64 census tracts with a minority population of 80% or more. Attachment A on page 7 -29 describes the population composition of the 64 census tracts. Table 7 -1 (pages 7- 5 and 7 -6) shows the number of affordable housing units located in these "high concentration" census tracts as well as the percentage of affordable housing units located in those tracts and each tract's percentage of all affordable housing units. 2-14 The merged database has a total of 20,379 affordable housing units located within the geographic area covered by the Regional Al. Attachment B (page 7 -32) shows the affordable housing stock arranged by census tract. Within this Regional Al area, the affordable housing stock is not concentrated in neighborhoods with a high percentage (80 % +) of minority populations for the reasons cited below: • Forty -two of the high concentration census tracts have no affordable housing units • Almost 16% (3,200) of all affordable housing units (20,379) are located in 22 of 64 high concentration census tracts. • 84% of the affordable housing stock is located in census tracts with less than 80% minority population. • About 8% of the affordable housing stock is located in three census tracts: 744.03 (Santa Ana); 751.02 (Santa Ana); and Anaheim (866.01). There are five census tracts where affordable housing units represent a high percentage of tract's total housing stock: • Santa Ana 744.03 38.2 %, 500 of 1,310 • Santa Ana 745.01 23.4 %, 326 of 1,391 • Santa Ana 750.02 21.1 %, 496 of 2,348 • Anaheim 866.01 24.5 %, 576 of 2,348 • Stanton /Anaheim 878.03 21.6 %, 298 of 1,379 Table 7 -2 on page 7 -7 lists the individual developments which are located in these five census tracts. The three developments located in census tracts 744.03 and 745.01 are located in close proximity. Refer to Map 1 on page 7 -8. The rear property line of Minnie Street is essentially the boundary between the two census tracts. 21 5 Table 7 -1 Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a High Percentage ( >80 %) of Minority Populations -2010 Census Tract City Percent Minority Total Housing Units 2008' Number of Affordable Housing Units2 Percent of Units in Census Tract Percent of All Affordable Units 12.01 La Habra/County 81.55% 1,461 0 0.0% 0.0% 116.02 Fullerton /Anaheim 82.82% 1,647 16 1.0% 0.1% 117.14 Anaheim 80.79% 82 0 0.0% 0.0% 117.2 Anaheim /Placentia 92.54% 1,518 54 3.6% 0.3% 740.03 Santa Ana 94.97% 810 6 0.7% 0.0% 740.05 Santa Ana 86.27% 1,478 0 0.0% 0.0% 741.02 Santa Ana 92.95% 1,301 0 0.0% 0.0% 741.03 Santa Ana 92.59% 918 0 0.0% 0.0% 741.08 Santa Ana 94.08% 887 0 0.0% 0.0% 741.09 Santa Ana 95.04% 663 0 0.0% 0.0% 741.11 Santa Ana 80.83% 1,370 0 0.0% 0.0% 742 Santa Ana 94.76% 1,747 0 0.0% 0.0% 743 Santa Ana 96.67% 797 0 0.0% 0.0% 744.03 Santa Ana 95.32% 1,310 500 38.2% 2.5% 744.05 Santa Ana 94.67% 1,468 24 1.6% 0.1% 744.06 Santa Ana 91.90% 847 0 0.0% 0.0% 744.07 Santa Ana/Tustin 92.55% 1,866 0 0.0% 0.0% 745.01 Santa Ana 99.00% 1,391 326 23.4% 1.6% 745.02 Santa Ana 97.17% 1,010 0 0.0% 0.0% 746.01 Santa Ana 92.94% 1,675 3 0.2% 0.0% 746.02 Santa Ana 97.06% 1,691 0 0.0% 0.0% 747.01 Santa Ana 97.82% 1,410 0 0.0% 0.0% 747.02 Santa Ana 95.96% 1,096 0 0.0% 0.0% 748.01 Santa Ana 98.29% 986 8 0.8% 0.0% 748.02 Santa Ana 93.79% 1,109 60 5.4% 0.3% 748.03 Santa Ana 92.24% 1,781 0 0.0% 0.0% 748.05 Santa Ana 97.68% 1,123 112 10.0% 0.5% 748.06 Santa Ana 98.70% 910 0 0.0% 0.0% 749.01 Santa Ana 98.17% 1,924 204 10.6% 1.0% 749.02 Santa Ana 98.60% 1,184 12 1.0% 0.1% 750.02 Santa Ana 95.57% 2,348 496 21.1% 2.4% 750.03 Santa Ana 96.37% 1,729 48 2.8% 0.2% 750.04 Santa Ana 95.73% 1,316 4 0.3% 0.0% 752.01 Santa Ana 97.28% 1,107 0 0.0% 0.0% 752.02 Santa Ana 94.75% 1,186 0 0.0% 0.0% 753.02 Santa Ana 81.51% 1,125 0 0.0% 0.0% 864.04 Anaheim 81.97% 1,503 0 0.0 % 0.0% 210 Table 7 -1 continued Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a High Percentage ( >80 %) of Minority Populations -2010 Census Tract City Percent Minority Total Housing Units 2008' Number of Affordable Housing Units2 Percent of Units in Census Tract Percent of All Affordable Units 864.05 Anaheim 82.83% 1,658 0 0.0% 0.0% 865.01 Anaheim 84.58% 1,172 0 0.0% 0.0% 865.02 Anaheim 92.36% 1,3891 0 0.0% 0.0% 866.01 Anaheim 87.29% 2,348 576 24.5% 2.8% 873 Anaheim 85.04% 2,839 151 5.3% 0.7% 874.03 Anaheim 85.78% 813 0 0.0% 0.0% 874.04 Anaheim 91.47% 786 0 0.0% 0.0% 874.05 Anaheim 89.23% 1,609 0 0.0% 0.0% 875.04 Anaheim 87.42% 1,937 0 0.0% 0.0% 878.03 Stanton /Anaheim 86.62% 1,379 298 21.6% 1.5% 879.02 Stanton 82.08% 1,311 0 0.0% 0.0% 888.01 Garden Grove 81.15% 2,604 0 0.0% 0.0% 889.02 Garden Grove 81.33% 1,199 80 6.7% 0.4% 889.03 Garden Grove /Santa Ana 85.75% 1,942 0 0.0% 0.0% 889.04 Westminster /Garden Grove 82.05% 1,418 0 0.0% 0.0% 890.01 Santa Ana 89.52% 1,668 0 0.0% 0.0% 890.03 Garden Grove 88.55% 862 0 0.0% 0.0% 890.04 Santa Ana 89.08% 1,791 60 3.4% 0.3% 891.02 Garden Grove /Santa Ana 81.56% 1,607 0 0.0% 0.0% 891.04 Santa Ana /Garden Grove 92.61% 1,358 194 14.3% 1.0% 891.05 Santa Ana 96.72% 1,132 12 1.1% 0.1% 891.06 Garden Grove 81.79% 930 0 0.0% 0.0% 992.02 Santa Ana /Fountain Valley 82.73% 1,832 0 0.0% 0.0% 992.47 Santa Ana 88.88% 798 0 0.0% 0.0% 992.48 Santa Ana 88.67% 1,420 0 0.0% 0.0% 992.49 Santa Ana 97.28% 820 0 0.0% 0.0% 1106.1 Buena Park 83.52% 1,303 0 0.0% 0.0% Total 87,6991 3,232 3.7% 15.9% Note: The merged database has a total of 20,379 affordable units in the area covered by the Regional Al 'California State University, Fullerton, Center for Demographic Research, Orange County Population & Dwelling Unit Estimates by Census Tract, January 1, 2008 2Number of affordable housing units per census tract is obtained from Attachment B on page 7 -32. Table construction by Castaneda & Associates 217 Table 7 -2 Regional Analysis of Fair Housing Impediments Census Tracts with a High Percentage of Affordable Housing Units City/Location Census Tract Project (s) Number of Affordable Units Santa Ana 744.03 Warwick Square 500 Santa Ana 745.01 Wakeham Grant Apartments 126 Cornerstone Village 200 Santa Ana 750.02 Henin er Village Apartments 58 Santa Ana Towers 198 Rosswood Villas 198 Garden Court 42 Anaheim 866.01 Park Vista Apartments 390 Paseo Village 174 Casa Delia 12 Stanton /Anaheim 878.03 Continental Garden Apartments 298 Although near one another, Warwick Square is physically separated from the Minnie Street developments by physical barriers (Metrolink and the Santa Ana -Santa Fe Channel). More importantly, all three complexes were constructed before State law required localities to conduct housing policy planning (i.e., the housing element of the general plan). Warwick Square was built in 1969. The Wakeman Grant Apartments were built in 1961. The Cornerstone Village dwellings were constructed in 1959 and rehabilitated in 2000. In effect, at least for the last two developments, the housing complexes probably accommodated the population already residing in the developments at the time of rehabilitation or the population living near the developments. 212 Map 1 Santa Ana: Warwick Square and Minnie Street Developments Census Tracts 744.03 and 745.01 2 9 Map 2 below shows the locations of the four affordable housing developments located in downtown Santa Ana. Three developments contain a total of 454 senior (62 +) housing units. Two developments (Santa Ana Towers and Rosswood Villas) were built in the mid- 1970s. The third senior housing complex (Heninger Village) was constructed in 1988 and rehabilitated in 2001. Built in 1986, the Garden Court complex has 42 of the 84 family housing units rent restricted. Map 2 Santa Ana: Downtown Santa Ana Affordable Housing Developments Census Tract 750.02 220 Census tract 866.01, which is located in Anaheim, contains three family projects having a total of 576 housing units. Map 3 below shows the locations of the three developments. The construction dates for these developments are: Park Vista, 1958; Paseo Village, 1957; and Casa Delia, 1961. These developments, like many others located in high concentrations areas, were built before local housing policy planning was required and probably became affordable as a result of acquisition /rehabilitation programs. As a result, the housing complexes probably accommodated the population already residing in the developments at the time of rehabilitation or the population living near the developments. Map 3 Anaheim: Park Vista, Paseo Village and Casa Delia Census Tract 866.01 221- 2. Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Minority Populations This part examines the existence of affordable housing opportunities in neighborhoods (census tracts) with a low percentage ( <20 %) of minority populations. Altogether there are 74 census tracts that meet the definition of a neighborhood with a low percentage of minority populations. Thirteen of the 74 census tracts have affordable housing units. In sum, there are 1,108 affordable housing units located in the 13 census tracts, which represents 5.4% of all the affordable housing located within the area covered by the Regional Al. Consequently, it can be stated that affordable housing opportunities exist in neighborhoods with a low percentage of minority populations. The affordable housing units are located in the following cities and communities: • Newport Beach 442 • Huntington Beach 185 • Laguna Beach 135 • Irvine 118 • Yorba Linda 100 • Dana Point 84 • Ladera Ranch 44 Table 7 -3 on the next two pages lists the number of affordable housing units located in these "low concentration" census tracts as well as the percentage of affordable housing units located in those tracts and each tract's percentage of all affordable housing units. 222 Table 7 -3 Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage ( <20 %) of Minority Populations -2010 Census Tract City/Area Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Tract Percent of All Affordable Housing Units 993.10 Huntington Beach 19.79% 2,227 0 0.0% 0.0% 994.07 Huntington Beach 19.75% 968 11 1.1% 0.1% 423.25 Laguna Beach 19.75% 1,550 0 0.0% 0.0% 992.20 Huntington Beach 19.68% 2,407 68 2.8% 0.3% 993.06 Huntington Beach 19.63% 2,836 0 0.0% 0.0% 219.12 Orange/Unincorporated 19.46% 1,379 0 0.0% 0.0% 524.15 Lake Forest 19.32% 1,315 0 0.0% 0.0% 114.02 Fullerton 19.24% 874 0 0.0% 0.0% 992.43 Huntington Beach 19.17% 1,844 0 0.0% 0.0% 320.42 Rancho Santa Mar arita /Uninc. 19.14% 1,778 0 0.0% 0.0% 631.02 Unincorporated 19.11% 2,803 0 0.0% 0.0% 993.07 Huntington Beach 18.38% 1,457 0 0.0% 0.0% 993.11 Huntington Beach 18.10% 2,230 0 0.0% 0.0% 995.12 Seal Beach 18.08% 1,776 0 0.0% 0.0% 218.09 Yorba Linda 18.04% 881 100 11.4% 0.5% 757.03 Unincorporated 17.94% 1,384 0 0.0% 0.0% 219.17 Orange/Unincorporated 17.71% 1,195 0 0.0% 0.0% 1100.06 Unincorporated 17.56% 1,102 0 0.0% 0.0% 626.45 Newport Beach /Uninc. 17.35% 2,692 0 0.0% 0.0% 218.16 Yorba Linda /Uninc. 17.26% 1,770 0 0.0% 0.0% 1100.08 Seal Beach 17.19% 1,731 0 0.0% 0.0% 995.14 Huntington Beach 17.09% 2,455 0 0.0% 0.0% 992.17 Huntington Beach 16.67% 891 0 0.0% 0.0% 320.23 Unincorporated 16.45% 4,345 0 0.0% 0.0% 626.05 Laguna Beach 16.31% 2,183 65 3.0% 0.3% 421.03 Unincorporated 15.74% 3,430 0 0.0% 0.0% 423.28 Laguna Hills 15.17% 843 0 0.0% 0.0% 1100.07 Los Alamitos 14.72% 1,686 0 0.0% 0.0% 320.43 Rancho Santa Margarita 14.65% 1,249 0 0.0% 0.0% 993.09 Huntington Beach 14.64% 1,702 106 6.2% 0.5% 636.03 Newport Beach 14.39% 3,293 91 2.8% 0.4% 995.13 Huntington Beach /Uninc. 14.35% 1,337 0 0.0% 0.0% 995.11 Seal Beach 14.26% 2,032 0 0.0% 0.0% 423.38 Dana Point 13.86% 2,050 0 0.0% 0.0% 320.46 Coto de Caza 13.68% 1,878 0 0.0% 0.0% 421.13 Dana Point 13.56% 1,851 0 0.0% 0.0% 633.02 Newport Beach 13.40% 1,727 0 0.0% 0.0% 630.10 Newport Beach 13.29% 3,372 0 0.0% 0.0% 223 Table 7 -3 continued Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage ( <20 %) of Minority Populations -2010 Census Tract City/Area Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Tract Percent of All Affordable Housing Units 995.06 Seal Beach /Uninc. 12.71% 863 0 0.0% 0.0% 320.52 Ladera Ranch 12.67% 8,124 44 0.5% 0.2% 320.44 Coto de Caza 12.60% 2,013 0 0.0% 0.0% 626.44 Newport Beach 12.52% 3,479 99 2.8% 0.5% 995.04 Seal Beach 12.47% 999 0 0.0% 0.0% 626.32 Laguna Beach 12.40% 2,191 70 3.2% 0.3% 630.09 Newport Beach 12.27% 752 0 0.0% 0.0% 992.44 Huntington Beach 12.19% 1,928 0 0.0% 0.0% 630.07 Newport Beach 12.04% 3,326 133 4.0% 0.7% 631.03 Newport Beach /Uninc. 11.64% 1,097 0 0.0% 0.0% 423.23 Dana Point 11.64% 2,717 0 0.0% 0.0% 423.24 Dana Point 11.51% 2,282 84 3.7% 0.4% 635.00 Newport Beach 11.48% 3,586 0 0.0% 0.0% 626.42 Newport Beach 11.32% 1,611 0 0.0% 0.0% 630.08 Newport Beach 11.29% 658 0 0.0% 0.0% 626.20 Laguna Beach 11.26% 2,663 0 0.0% 0.0% 626.22 Laguna Hills/Laguna Woods 10.75% 2,992 0 0.0% 0.0% 422.06 Dana Point 10.65% 1,459 0 0.0% 0.0% 626.04 Irvine 10.53% 6,267 118 1.9% 0.6% 320.11 Unincorporated 10.33% 826 0 0.0% 0.0% 630.04 Newport Beach 10.23% 3,491 119 3.4% 0.6% 628.00 Newport Beach 9.78% 3,031 0 0.0% 0.0% 320.37 Unincorporated 9.30% 2,437 0 0.0% 0.0% 423.05 Laguna Beach /Dana Point 8.59% 1,991 0 0.0% 0.0% 626.19 Laguna Beach 8.56% 2,063 0 0.0% 0.0% 627.02 Newport Beach 8.35% 2,702 0 0.0% 0.0% 995.10 Seal Beach 8.13% 3,644 0 0.0% 0.0% 630.05 Newport Beach 8.13% 1,023 0 0.0% 0.0% 626.23 Laguna Beach /Laguna Hills/Laguna Woods 8.07% 4,584 0 0.0% 0.0% 627.01 Newport Beach 7.86% 1,651 0 0.0% 0.0% 421.06 Dana Point/Uninc. 7.49% 738 0 0.0% 0.0% 634.00 Newport Beach 7.37% 2,207 0 0.0% 0.0% 626.46 Laguna Woods 6.84% 2,979 0 0.0% 0.0% 630.06 Newport Beach 6.83% 2,148 0 0.0% 0.0% 995.09 Seal Beach 6.48% 2,950 0 0.0% 0.0% 629.00 Newport Beach 5.33% 944 0 0.0% 0.0% Total 1 160,939 1 1,1081 0.7% 1 5.4% M0,19 3. Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Low Income Populations Table 7 -4 on the next page shows the number of affordable housing units located in 18 census tracts with a high percentage (80 % +) of low income population. As previously indicated, the merged database has a total of 20,379 affordable housing units located within the geographic area covered by the Regional Al. Within this geographic area, the affordable housing stock is not concentrated in neighborhoods with a high percentage (80 % +) of low income population for the reasons cited below: • Nine of the 18 high percentage census tracts have zero or less than 12 affordable housing units. • Only about 10% (2,055) of all affordable housing units (20,379) are located in census tracts with a high percentage of low income population. • About 90% of all affordable housing units are located outside census tracts with a high percentage of low income population. There are three census tracts that have high percentages of both minority and low income populations and a large percentage of affordable housing units located within the tracts: 744.03, 745.01 and 750.02. These tracts are located in Santa Ana and Maps 1 and 2 show the locations of the affordable housing developments. 4. Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Low Income Populations Table 7 -5 (on pages 7 -16 to 7 -18) shows that affordable housing opportunities exist in census tracts with a low percentage of low income populations. Fourteen of the 101 census tracts with a low percentage of low income populations have affordable housing units. Almost 6% of all the affordable housing units are located in neighborhoods having 20% or less of its population with low incomes. However, the number of affordable housing units (1,205) represents a very small percentage (0.6 %) of the housing stock (186,329) located in these census tracts. The affordable housing opportunities are located in the following cities and communities • Aliso Viejo 174 • Anaheim 157 • Cypress 13 • Dana Point 84 • Fullerton 24 • Irvine 183 • Ladera Ranch 44 • Laguna Beach 70 • Newport Beach 232 • Yorba Linda 224 225 Table 7-4 Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a High Percentage ( >80 %) of Low Income Populations -2010 City Census Tract # Low /Mod Total Pop. Percent Low /Mod Total Housing Units 2008' Number of Affordable Housing UnitS2 Percent of Units in Census Tract Percent of All Affordable Units Anaheim/ Placentia 117.20 6,097 7,535 80.9% 1,518 54 3.6% 0.3% Santa Ana 744.03 5,556 6,374 87.2% 1,310 500 38.2% 2.5% Santa Ana 744.05 6,024 6,766 89.0% 1,468 24 1.6% 0.1% Santa Ana 744.06 3,132 3,706 84.5% 847 0 0.0% 0.0% Santa Ana/ Tustin 744.07 6,651 7,687 86.5% 1,866 0 0.0% 0.0 % Santa Ana 745.01 10,197 12,055 84.6% 1,391 326 23.4% 1.6% Santa Ana 748.05 5,577 6,710 83.1% 1,123 112 10.0% 0.5% Santa Ana 748.06 5,080 6,136 82.8% 910 0 0.0% 0.0% Santa Ana 749.01 8,512 10,102 84.3% 1,924 204 10.6% 1.0% Santa Ana 749.02 6,122 7,243 84.5% 1,184 12 1.0% 0.1% Santa Ana 750.02 8,000 9,466 84.5% 2,348 496 21.1% 2.8% Santa Ana 750.03 7,198 8,200 87.8% 1,729 48 2.8% 0.2% Santa Ana 750.04 4,865 5,713 85.2% 1,316 4 0.3% 0.0% Orange/ Villa Park* 758.11 1,354 1,569 86.3% 828 0 0.0% 0.0% Anaheim 865.02 5,488 6,669 82.3% 1,389 0 0.0% 0.0% Anaheim 874.05 5,489 6,580 83.4% 1,609 0 0.0% 0.0% Santa Ana/ Garden Grove 891.04 4,303 5,085 84.6% 1,358 194 14.3% 1.0% Santa Ana 891.05 5,935 6,991 84.9% 1,132 12 1.1% 0.1% Total 105,580 1 124,5871 84.7% 1 25,2501 2,055 1 8.1% 1 10.1% *All of the Low /Mod population is located within the City of Orange, 1,354 of 1,490 (90.9 %). Note: The merged database has a total of 20,379 affordable units in Orange County. 'California State University, Fullerton, Center for Demographic Research, Orange County Population & Dwelling Unit Estimates by Census Tract, January 1, 2008 2Number of affordable housing units per census tract is obtained from Attachment B on page 7 -28. Table construction by Castaneda & Associates 220 Table 7 -5 Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage (<20 %) of Low Income Populations -2010 Census Tract City Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Census Tract Percent of All Affordable Units 16.02 Fullerton 13.8% 1,858 0 0.0% 0.0% 17.06 Fullerton 19.1% 1,373 24 1.7% 0.1% 114.02 Fullerton 16.4% 874 0 0.0% 0.0% 117.15 Placentia /Unincorporated 14.6% 2,058 0 0.0% 0.0% 117.18 Placentia/Unincorporated 17.8% 1,110 0 0.0% 0.0% 218.09 Yorba Linda 19.8% 881 100 11.4% 0.5% 218.10 Yorba Linda /Placentia 19.8% 1,226 0 0.0% 0.0% 218.20 Yorba Linda /Placentia 19.2% 1,380 0 0.0% 0.0% 218.23 Yorba Linda 17.5% 1,057 0 0.0% 0.0% 218.24 Yorba Linda 11.0% 867 0 0.0% 0.0% 218.25 Yorba Linda 16.3% 1,158 124 10.7% 0.6% 218.27 Yorba Linda 11.7% 1,079 0 0.0% 0.0% 218.28 Yorba Linda 5.4% 1,331 0 0.0% 0.0% 218.29 Yorba Linda 11.4% 1,812 0 0.0% 0.0% 218.30 Yorba Linda 12.1% 2,037 0 0.0% 0.0% 219.05 Anaheim 19.5% 1,803 27 1.5% 0.1% 219.12 Orange 10.3% 1,379 0 0.0% 0.0% 219.15 Anaheim/Orange 19.7% 1,501 0 0.0% 0.0% 219.17 Oran a /Unincor orated 13.7% 1,195 0 0.0% 0.0% 219.20 Anaheim 12.9% 2,326 0 0.0% 0.0% 219.21 Anaheim 11.7% 1,427 0 0.0% 0.0% 219.22 Anaheim 15.1% 2,266 130 5.7% 0.6% 219.23 Anaheim 13.2% 2,322 0 0.0% 0.0% 219.24 Anaheim/Unincorporated 15.3% 1,532 0 0.0% 0.0% 320.11 Unincorporated 15.4% 826 0 0.0% 0.0% 320.34 Rancho Santa Margarita 14.5% 1,852 0 0.0% 0.0% 320.41 Unincorporated 12.1% 411 0 0.0% 0.0% 320.42 Rancho Santa Margarita 13.6% 1,778 0 0.0% 0.0% 320.43 Rancho Santa Margarita 6.9% 1,249 0 0.0% 0.0% 320.44 Coto de Caza 9.0% 2,013 0 0.0% 0.0% 320.45 Coto de Caza 11.3% 922 0 0.0% 0.0% 320.46 Coto de Caza 5.5% 1,878 0 0.0% 0.0% 320.48 Rancho Santa Margarita 11.5% 2,255 0 0.0% 0.0% 320.49 Rancho Santa Mar arita /Unincor orated 11.9% 3,106 0 0.0% 0.0% 320.50 Rancho Santa Margarita 16.6% 1,740 0 0.0% 0.0% 320.52 Ladera Ranch 19.2% 8,124 44 0.5% 0.2% 227 Table 7 -5 continued Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage (<20 %) of Low Income Populations -2010 Census Tract city Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Census Tract Percent of All Affordable Units 320.53 Rancho Santa Mar arita /Unincor orated 18.5% 3,095 0 0.0% 0.0% 320.56 Rancho Santa Margarita/Unincorporated 6.5% 2,002 0 0.0% 0.0% 423.05 Laguna Beach /Dana Point 18.6% 1,991 0 0.0% 0.0% 423.07 Laguna Hills 19.0% 2,316 0 0.0% 0.0% 423.24 Dana Point 14.3% 2,282 84 3.7% 0.4% 423.27 Laguna Hills 15.7% 1,735 0 0.0% 0.0% 423.28 Laguna Hills 14.7% 843 0 0.0% 0.0% 423.33 Laguna Hills 5.4% 1,332 0 0.0% 0.0% 423.35 Unincorporated 17.0% 2,300 0 0.0% 0.0% 524.04 Unincorporated 0.0% 979 0 0.0% 0.0% 524.08 Lake Forest 15.8% 2,153 0 0.0% 0.0% 524.15 Lake Forest 12.5% 1,315 0 0.0% 0.0% 524.17 Irvine 18.7% 2,302 0 0.0% 0.0% 524.20 Irvine 6.1% 6,304 0 0.0% 0.0% 524.21 Irvine 13.3% 1,964 0 0.0% 0.0% 524.22 Lake Forest 18.9% 1,491 0 0.0% 0.0% 524.26 Lake Forest/Unincorporated 8.9% 2,217 0 0.0% 0.0% 524.27 Lake Forest 12.4% 1,741 0 0.0% 0.0% 524.28 Lake Forest/Unincorporated 12.8% 2,181 0 0.0% 0.0% 525.06 Irvine 16.0% 828 0 0.0% 0.0% 525.22 Irvine 12.9% 1,446 59 4.1% 0.3% 525.23 Irvine 15.1% 1,544 0 0.0% 0.0% 525.26 Irvine 19.5% 1,366 0 0.0% 0.0% 525.27 Irvine 19.2% 2,713 124 4.6% 0.6% 626.20 Laguna Beach 18.3% 2,663 0 0.0% 0.0% 626.30 Irvine 16.7% 801 0 0.0% 0.0% 626.31 Irvine 7.9% 1,275 0 0.0% 0.0% 626.32 Laguna Beach 19.8% 2,191 70 3.2% 0.3% 626.33 Aliso Viejo 7.0% 1,742 0 0.0% 0.0% 626.34 Aliso Viejo 16.8% 2,066 0 0.0% 0.0% 626.35 Aliso Viejo/Laguna Woods 15.1% 1,713 0 0.0% 0.0% 626.38 Aliso Viejo 13.3% 2,432 0 0.0% 0.0% 626.39 Aliso Vie'o 17.6% 2,504 174 6.9% 0.9% 626.43 New ort Beach 10.0% 2,017 0 0.0% 0.0% 626.44 New ort Beach 17.6% 3,479 99 2.8% 0.5% 626.45 Newport Beach 9.3% 2,692 0 0.0% 0.0% 222 Table 7 -5 continued Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage (<20 %) of Low Income Populations -2010 Census Tract city Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Census Tract Percent of All Affordable Units 627.01 Newport Beach 16.1% 1,651 0 0.0% 0.0% 627.02 Newport Beach 17.3% 2,702 0 0.0% 0.0% 629.00 Newport Beach 19.6% 944 0 0.0% 0.0% 630.05 Newport Beach 15.0% 1,023 0 0.0% 0.0% 630.07 Newport Beach 18.6% 3,326 133 4.0% 0.7% 630.08 Newport Beach 12.5% 658 0 0.0% 0.0% 630.09 Newport Beach /Unincorporated 18.4% 752 0 0.0% 0.0% 630.10 Newport Beach 19.4% 3,372 0 0.0% 0.0% 636.01 Newport Beach 12.8% 1,393 0 0.0% 0.0% 756.04 Ora ng a /Unincorporated 12.6% 2,726 0 0.0% 0.0% 756.05 Ora ng a /Unincorporated 12.7% 2,198 0 0.0% 0.0% 756.06 Unincorporated 8.8% 2,270 0 0.0% 0.0% 757.03 Unincorporated 18.9% 1,384 0 0.0% 0.0% 758.09 Villa Park/Orange 13.7% 1,092 0 0.0% 0.0% 758.10 Villa Park/Orange 15.9% 1,033 0 0.0% 0.0% 758.14 Orange/Villa Park 14.0% 1,184 0 0.0% 0.0% 992.38 Huntington Beach 18.4% 1,396 0 0.0% 0.0% 992.39 Huntington Beach 19.3% 1,379 0 0.0% 0.0% 992.40 Huntington Beach 18.8% 2,166 0 0.0% 0.0% 992.43 Huntington Beach 19.8% 1,844 0 0.0% 0.0% 992.46 Huntington Beach 12.6% 1,241 0 0.0% 0.0% 993.08 Huntington Beach 10.3% 2,256 0 0.0% 0.0% 994.15 Huntington Beach 11.2% 2,095 0 0.0% 0.0% 995.04 Seal Beach 19.7% 999 0 0.0% 0.0% 995.13 Huntington Beach /Unincorporated 18.5% 1,337 0 0.0% 0.0% 995.14 Huntington Beach 9.8% 2,455 0 0.0% 0.0% 1100.07 Unincorporated/Seal Beach 15.7% 1,686 0 0.0% 0.0% 1100.11 Cypress 12.2% 1,112 13 1.2% 0.1% 1100.12 Seal Beach /Los Alamitos 14.6% 1,867 0 0.0% 0.0% 1101.18 Cypress 16.9% 767 0 0.0% 0.0% Total 186,329 1,205 0.6% 5.9% 2:�9 D. ANALYSIS OF THE LOCATION OF THE SECTION 8 HOUSING INVENTORY 1. Garden Grove Housing Authority (GGHA) The GGHA administers 2,504 Section 8 Housing Choice Vouchers. Of this total, 2,489 voucher holders reside in Garden Grove and other cities participating in the Regional Al. Table 7 -6 below lists the city residence of the Section 8 voucher holders. About 80.5% of the voucher holders live in Garden Grove (2,003 of 2,489). This table also lists the four census tracts having 5% or more of the Garden Grove's Section 8 voucher holders. Table 7 -6 Garden Grove Housing Authority Section 8 Assisted Families by City City Number of Families Anaheim 89 Buena Park 4 Cypress 0 Fountain Valley 13 Garden Grove Census Tract 881.07 137 Garden Grove Census Tract 887.01 156 Garden Grove Census Tract 889.01 135 Garden Grove Census Tract 891.04 265 Garden Grove - Balance of City 1,310 Huntington Beach 29 Irvine 19 La Habra 1 Laguna Woods 1 Newport Beach 3 Orange 14 Stanton 21 Westminster 160 Yorba Linda 2 Split Tracts* 130 Total 2,489 Source: Garden Grove Housing Authority *The data was provided by Census Tract and these tracts were split between two or more cities. Note: Census tracts listed have 5% (125) or more of the total (2,489) Section 8 assisted households. Tabulation by Castaneda & Associates 23O Table 7 -7 below identifies the number of Section 8 voucher holders residing in census tracts with a high percentage (80 % +) of minority populations. Only about one -fourth (660 of 2,489) of the GGHA voucher holders live in census tracts with a high percentage of minority populations. Within these census tracts Section 8 assisted housing — for the most part - comprises a small percentage of all the housing units. Only in census tract 891.04 does Section 8 housing comprise a "high" percentage (23.4 %) of all the housing units located in a census tract. Consequently, the vast majority (75 %) of Section 8 assisted housing is located in census tracts that do not have a high percentage of minority populations. Table 7 -7 Garden Grove Housing Authority Number of Section 8 Housing Units Located in Census Tracts With a High Percentage ( >80 %) of Minority Populations Census Tract City Total Population' Percent Minority # of Section 8 Assisted Units 891.04 Santa Ana /Garden Grove 6,074 92.61% 265 874.05 Anaheim 6,649 89.23% 1 890.03 Garden Grove 3,808 88.55% 63 875.04 Anaheim 8,248 87.42% 4 866.01 Anaheim 9,872 87.29% 1 874.03 Anaheim 3,735 85.78% 2 889.03 Garden Grove /Santa Ana 8,594 85.75% 84 873.00 Anaheim 10,041 85.04% 1 116.02 Anaheim 5,762 82.82% 1 891.06 Garden Grove 3,784 81.79% 96 891.02 Garden Grove 6,954 81.56% 20 12.01 La Habra/County 5,371 81.55% 1 888.01 Garden Grove 8,206 81.15% 121 Total 660 '2000 population Source: Garden Grove Housing Authority Tabulation by Castaneda & Associates 2S2 2. Santa Ana Housing Authority (SAHA) The SAHA administers Section 8 Housing Choice Vouchers predominately within the City of Santa Ana. Data on the census tract location of the voucher holders was provided by the SAHA. However, the census tract location is not available for all Section 8 voucher holders. (In some cases the census tract is unknown or an incorrect census tract was assigned to the voucher holder.) Table 7 -8 below and on the next page shows the census tract location of 653 Section 8 voucher holders. As noted by this table, the vast majority of Section 8 assisted families reside in Santa Ana. Table 7 -8 Santa Ana Housing Authority Section 8 Assisted Families by Census Tract Census Tract City Number of Section 8 Vouchers 740.03 Santa Ana 4 740.04 Santa Ana 10 740.05 Santa Ana 16 740.06 Santa Ana 9 741.02 Santa Ana 9 741.03 Santa Ana 1 741.06 Santa Ana/Unincorporated' 19 741.07 Santa Ana 8 741.08 Santa Ana/Unincorporated' 6 741.09 Santa Ana 5 741.10 Santa Ana 9 741.11 Santa Ana 1 742.00 Santa Ana 5 744.03 Santa Ana 9 744.05 Santa Ana 4 744.06 Santa Ana 5 744.07 Santa Ana 7 745.01 Santa Ana 1 745.02 Santa Ana 5 746.01 Santa Ana 5 746.02 Santa Ana 11 747.01 Santa Ana 6 747.02 Santa Ana 2 748.01 Santa Ana 10 748.02 Santa Ana 3 748.03 Santa Ana/Unincorporated' 11 748.05 Santa Ana 5 748.06 Santa Ana 3 749.01 Santa Ana 4 232 Table 7 -8 - continued Santa Ana Housing Authority Section 8 Assisted Families by Census Tract Census Tract city Number of Section 8 Vouchers 749.02 Santa Ana 5 750.02 Santa Ana 8 750.03 Santa Ana 1 750.04 Santa Ana 2 751.00 Santa Ana 5 752.01 Santa Ana 7 752.02 Santa Ana 10 753.01 Santa Ana /Orange 11 753.02 Santa Ana 31 753.03 Santa Ana 2 754.01 Santa Ana 3 754.03 Santa Ana 15 754.04 Santa Ana 9 754.05 Santa Ana 4 755.04 Santa Ana 5 757.01 Santa Ana 9 889.03 Santa Ana /Garden GroveMestminster 8 890.01 Santa Ana /Garden Grove 64 890.04 Santa Ana 27 891.02 Santa Ana /Garden Grove 9 891.04 Santa Ana /Garden Grove 13 891.05 Santa Ana 41 891.07 Santa Ana /Garden Grove 2 992.02 Santa Ana /Fountain Valley 38 992.03 Santa Ana /Fountain Valley/ Garden Grove/Westminster 22 992.47 Santa Ana 46 992.48 Santa Ana 40 992.49 Santa Ana 23 Total 653 Although this tract is split with Orange, all the population is located within the City of Santa Ana. 2There was no population within the City of Westminster. Source: Santa Ana Housing Authority Tabulation by Castaneda & Associates Table 7 -9 on the next page indicates the number of Section 8 voucher holders residing in census tracts with a high percentage (80 % +) of minority populations. Only about 28% (184 of 653) of the SAHA voucher holders live in census tracts with a high percentage of minority 233 populations. Within these census tracts Section 8 assisted housing — for the most part - comprises a small percentage of all the housing units. Consequently, the vast majority (72 %) of Section 8 assisted housing is located in census tracts that do not have a high percentage of minority populations. Table 7 -9 Santa Ana Housing Authority Number of Section 8 Housing Units Located in Census Tracts With a High Percentage ( >80 %) of Minority Populations Census Tract City Total Population' Minority Population Percent Minority Number of Section 8 Vouchers 749.02 Santa Ana 7,261 7,080 97.51% 5 744.07 Santa Ana 3,822 3,701 96.83% 7 746.02 Santa Ana 9,649 9,222 95.57% 11 747.02 Santa Ana 6,680 6,328 94.73% 2 747.01 Santa Ana 9,075 8,588 94.63% 6 750.03 Santa Ana 8,232 7,773 94.42% 1 748.06 Santa Ana 6,154 5,801 94.26% 3 750.04 Santa Ana 5,779 5,444 94.20% 2 749.01 Santa Ana 10,129 9,533 94.12% 4 748.05 Santa Ana 6,710 6,298 93.86% 5 744.05 Santa Ana 6,965 6,450 92.61% 4 742.00 Santa Ana 9,611 8,899 92.59% 5 744.03 Santa Ana 6,374 5,861 91.95% 9 748.01 Santa Ana 6,267 5,722 91.30% 10 752.01 Santa Ana 5,948 5,426 91.22% 7 740.03 Santa Ana 2,484 2,266 91.22% 4 746.01 Santa Ana 8,861 7,998 90.26% 5 752.02 Santa Ana 6,137 5,519 89.93% 10 750.02 Santa Ana 9,610 8,639 89.90% 8 745.02 Santa Ana 6,280 5,637 89.76% 5 741.03 Santa Ana 5,196 4,646 89.41% 1 744.06 Santa Ana 3,838 3,402 88.64% 5 891.05 Santa Ana 7,081 6,133 86.61% 41 741.09 Santa Ana 4,032 3,486 86.46% 5 745.01 Santa Ana 8,233 7,115 86.42% 1 748.02 Santa Ana 6,041 5,218 86.38% 3 741.08 Santa Ana/Unincorporated 2 5,287 4,515 85.40% 6 741.02 Santa Ana 7,428 5,996 80.72% 9 Total 184 12000 population 2Although this tract is split with an unincorporated area of the County, all the population is within the City of Santa Ana Source: Santa Ana Housing Authority Tabulation by Castaneda & Associates 234 3. Anaheim Housing Authority (AHA) Data are not available from the AHA. 4. Orange County Housing Authority (OCHA) OCHA administers 8,089 Section 8 Housing Choice Vouchers within the cities participating in the Regional Al. Data was available on the census tract location of 6,832 voucher holders. (The census tract location was not available for 989 recipients and another 268 had discrepancies with respect to a census tract number.) The geographic area covered by the OCHA spans from the City of La Habra in the north down to Dana Point in the south. Of the 6,832 voucher holders, 3,153 reside in census tracts entirely within an entitlement city as shown in Table 7 -10 on the next page. With respect to Urban County cities, 762 voucher holders reside in census tracts entirely within these jurisdictions as shown in Table 7 -11 on the next page. Almost 3,000 voucher holders reside in census tracts split between two or more jurisdictions. These shared jurisdictions include entitlement cities with entitlement cities and entitlement cities with urban county cities. Nearly 1,700 of these "shared" locations were with the City of Westminster. The geographic distribution of all Section 8 voucher holders is as follows: • Entitlement Cities 3,153 • Urban County Cities 762 • Split Tract Locations 2,917 Total 6,832 Table 7 -12 on page 7 -26 identifies the number of Section 8 voucher holders residing in census tracts with a high percentage (80 % +) of minority populations. Only about 5.3% (363 of 6,832) of the OCHA voucher holders live in census tracts with a high percentage of minority populations. Within these census tracts Section 8 assisted housing — for the most part - comprises a small percentage of all the housing units. Only in census tract 525.18 does Section 8 housing comprise a "high" percentage (67 %) of all housing in a census tract. However, the population in the tract is extremely low. Consequently, the vast majority (95 %) of Section 8 assisted housing is located in census tracts that do not have a high percentage of minority populations. An analysis also was completed to determine the number of Section 8 voucher holders residing in census tracts with a low ( <20 %) minority population. Some 258 (almost 4 %) OCHA Section 8 voucher holders reside in 34 low minority population neighborhoods /census tracts. Consequently, the number (258) of voucher holders residing in low minority population neighborhoods is about 100 less than the number (363) living in high minority population census tracts. Table 7 -13 on page 7 -27 presents the data analysis. 235 Table 7 -10 Orange County Housing Authority Section 8 Assisted Families by Entitlement City Entitlement Cities Number of Section 8 Vouchers Anaheim 92 Buena Park 117 Fountain Valley 193 Fullerton 251 Garden Grove 156 Huntington Beach 498 Irvine 538 La Habra 108 Lake Forest 169 Newport Beach 110 Orange 447 Rancho Santa Margarita 42 Santa Ana 2 Westminster 430 Total 3,153 Source: Orange County Housing Authority Table 7 -11 Orange County Housing Authority Section 8 Assisted Families by Urban County City Urban County Number of Section 8 Vouchers Aliso Viejo 13 Brea 129 Cypress 74 Dana Point 37 Laguna Beach 13 Laguna Hills 8 Laguna Woods 1 La Palma 46 Los Alamitos 11 Placentia 121 Seal Beach 3 Stanton 220 Villa Park 0 Yorba Linda 76 Unincorporated 10 Total 762 Source: Orange County Housing Authority 23 o Table 7 -12 Orange County Housing Authority Number of Section 8 Housing Units Located in Census Tracts With a High Percentage ( >80 %) of Minority Populations Census Tract City Total Population' Minority Population Percent Minority Number of Section 8 Vouchers 525.18 Irvine 3 3 100.00% 2 992.49 Orange 4,443 4,322 97.28 % 1 741.02 Santa Ana 7,428 6,904 92.95% 1 891.04 Garden Grove 6,074 5,625 92.61% 13 117.20 Placentia 7,535 6,973 92.54% 17 865.02 Anaheim 6,678 6,168 92.36% 1 874.05 Anaheim 6,649 5,933 89.23% 1 992.48 Santa Ana 5,365 4,757 88.67% 1 890.03 Garden Grove 3,808 3,372 88.55% 9 875.04 Anaheim 8,248 7,210 87.42% 1 878.03 Stanton 6,442 5,580 86.62% 87 874.03 Anaheim 3,735 3,204 85.78% 1 889.03 Garden Grove/Westminster 8,594 7,369 85.75% 21 873.00 Anaheim 10,041 8,539 85.04% 1 1106.06 Buena Park 4,841 4,043 83.52% 41 864.05 Anaheim 6,699 5,549 82.83% 1 116.02 Fullerton 5,762 4,772 82.82% 6 992.02 Fountain Valley 8,117 6,715 82.73% 2 744.08 Orange 5,239 4,323 82.52% 1 879.02 Anaheim /Stanton 5,983 4,911 82.08% 22 889.04 Garden Grove/Westminster 5,809 4,766 82.05% 72 891.06 Garden Grove 3,784 3,095 81.79% 2 891.02 Garden Grove/Orange 6,954 5,672 81.56% 3 12.01 La Habra 5,371 4,380 81.55% 13 889.02 Garden Grove/Westminster 5,136 4,177 81.33 % 16 888.01 Garden Grove 8,206 6,659 81.15% 27 Total 363 '2000 population Source: Orange County Housing Authority Tabulation by Castaneda & Associates 237 Table 7 -13 Orange County Housing Authority Number of Section 8 Housing Units Located in Census Tracts With a Low Percentage (<20 %) of Minority Populations Census Tract City Total Population' Minority Population Percent Minority Number of Section 8 Vouchers 994.07 Huntington Beach/Westminster 2,491 492 19.75% 44 992.20 Huntington Beach 5,421 1,067 19.68% 1 993.06 Huntington Beach 5,931 1,164 19.63% 11 632.01 Orange 3,611 701 19.41% 1 320.42 Trabuco Canyon 6,135 1,174 19.14% 1 993.07 Huntington Beach 2,377 437 18.38% 14 993.11 Huntington Beach 3,818 691 18.10% 2 995.12 Seal Beach 2,766 500 18.08% 3 218.09 Yorba Linda 2,616 472 18.04% 6 219.17 Orange 3,366 596 17.71% 4 218.16 Yorba Linda 4,943 853 17.26% 3 1100.08 Los Alamitos /Seal Beach 4,304 740 17.19% 2 626.05 La gun Beach 3,396 554 16.31% 10 320.13 Ladera Ranch 3,528 569 16.13% 1 993.09 Huntington Beach 3,565 522 14.64% 4 636.03 Newport Beach 6,263 901 14.39% 41 423.38 Dana Point 4,814 667 13.86% 2 630.10 Newport Beach 6,495 863 13.29% 4 995.06 Sunset Beach 1,267 161 12.71% 1 320.52 Ladera Ranch 3,330 422 12.67% 1 626.44 Corona del Mar /Newport Beach 6,558 821 12.52% 9 626.32 Laguna Beach 4,058 503 12.40% 1 992.44 Huntington Beach 3,846 469 12.19% 3 630.07 Newport Beach 5,928 714 12.04% 18 423.23 Dana Point 4,717 549 11.64% 2 635.00 Newport Beach 6,191 711 11.48% 4 630.08 Irvine 868 98 11.29% 2 626.22 Irvine/Laguna Hills/Laguna Woods 4,231 455 10.75% 26 630.04 Newport Beach 5,602 573 10.23% 18 628.00 Newport Beach 4,732 463 9.78% 3 423.05 Laguna Beach 3,782 325 8.59% 1 626.23 Laguna Hills/Laguna Woods 6,435 519 8.07% 11 634.00 Newport Beach 4,995 368 7.37% 3 626.46 Laguna Woods 3,643 249 6.84% 1 Total 258 12000 population Source: Orange County Housing Authority E. ACTIONS TO BE TAKEN As explained on page one, the location of affordable housing is central to fulfilling the commitment to AFFH because it determines whether such housing will reduce or perpetuate residential segregation. The data analysis shows that affordable housing is predominantly located outside areas of high minority and high low income population concentrations. Many of the developments were constructed before localities were required to develop policies to guide the location of affordable housing. During the 2010 -2015 period, the FHCOC will take the following actions: • Provide technical assistance to participating jurisdictions on how the location of affordable housing contributes to AFFH. • Aggregate - for each census tract - the number of voucher holders assisted by all four housing authorities. • Conduct an analysis of the location of affordable housing in census tracts with a low concentration of minority and low income populations for purposes of determining whether they offer sufficient affordable housing opportunities. • Extend the analysis to include census tracts with minority populations in the range of 60 to 80 %. • Suggest policies that the Housing Authorities and /or entitlement cities and the Urban County Program can implement to promote affordable housing opportunities outside of census tracts with high percentages of poverty and minority populations. 239 Attachment A Census Tracts With 80 %+ Minority Populations Census Tract city White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Pop. of two or more races 2000 Total Pop. Minority Percent Minority 2008 Total Pop. Pop. Change 2000 - 2008 745.01 Santa Ana 82 7,115 5 21 842 13 7 148 8,233 8,151 99.00% 8,547 314 748.06 Santa Ana 80 5,801 161 2 74 14 13 9 6,154 6,074 98.70% 6,395 241 749.02 Santa Ana 102 7,080 15 4 43 2 0 15 7,261 7,159 98.60% 7,539 278 748.01 Santa Ana 107 5,722 244 30 130 20 1 13 6,267 6,160 98.29% 6,448 181 749.01 Santa Ana 185 9,533 50 30 272 22 8 29 10,129 9,944 98.17% 10,520 391 747.01 Santa Ana 198 8,588 72 6 135 34 0 42 9,075 8,877 97.82% 9,419 344 748.05 Santa Ana 156 6,298 76 15 100 27 14 24 6,710 6,554 97.68% 6,966 256 992.49 Santa Ana 121 3,472 26 8 770 21 0 25 4,443 4,322 97.28% 4,612 169 752.01 Santa Ana 162 5,426 71 16 240 1 2 30 5,948 5,786 97.28% 6,206 258 745.02 Santa Ana 178 5,637 7 19 361 32 0 46 6,280 6,102 97.17% 6,527 247 746.02 Santa Ana 284 9,222 27 5 76 14 3 18 9,649 9,365 97.06% 10,008 359 891.05 Santa Ana 232 6,133 18 22 635 11 5 25 7,081 6,849 96.72% 7,144 63 743.00 Santa Ana 147 4,204 5 19 15 3 0 22 4,415 4,268 96.67% 4,584 169 750.03 Santa Ana 299 7,773 49 42 25 0 16 28 8,232 7,933 96.37% 8,531 299 747.02 Santa Ana 270 6,328 9 19 18 15 4 17 6,680 6,410 95.96% 6,953 273 750.04 Santa Ana 247 5,444 29 0 44 4 2 9 5,779 5,532 95.73% 6,018 239 750.02 Santa Ana 426 8,639 86 20 395 2 3 39 9,610 9,184 95.57% 10,145 535 744.03 Santa Ana 298 5,861 18 19 153 4 0 21 6,374 6,076 95.32% 6,617 243 741.09 Santa Ana 200 3,486 13 25 270 15 1 22 4,032 3,832 95.04% 4,198 166 740.03 Santa Ana 125 2,266 25 8 39 4 1 16 2,484 2,359 94.97% 3,462 978 742.00 Santa Ana 504 8,899 23 16 118 16 8 27 9,611 9,107 94.76% 9,976 365 752.02 Santa Ana 322 5,519 98 25 139 0 11 23 6,137 5,815 94.75% 6,366 229 744.05 Santa Ana 371 6,450 32 5 64 3 11 29 6,965 6,594 94.67% 7,429 464 741.08 Santa Ana 313 4,515 40 13 331 37 0 38 5,287 4,974 94.08% 5,496 209 748.02 Santa Ana 375 5,218 163 22 180 22 3 58 6,041 5,666 93.79% 6,278 237 741.02 Santa Ana 524 5,996 110 19 696 30 9 44 7,428 6,904 92.95% 1 7,709 281 ME Census Tract city White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Pop. of two or more races 2000 Total Pop. Minority Percent Minority 2008 Total Pop. Pop. Change 2000 - 2008 746.01 Santa Ana 626 7,998 29 29 110 23 4 42 8,861 8,235 92.94% 9,208 347 891.04 Santa Ana /Garden Grove 449 4,384 37 10 1,130 19 0 45 6,074 5,625 92.61% 6,293 219 741.03 Santa Ana 385 4,646 13 21 79 21 1 30 5,196 4,811 92.59% 5,394 198 744.07 Santa Ana/Tustin 573 6,765 100 6 161 8 6 68 7,687 7,114 92.55% 8,005 318 117.20 Anaheim /Placentia 562 6,612 93 24 158 11 10 65 7,535 6,973 92.54% 8,008 473 865.02 Anaheim 510 5,995 34 24 77 1 1 36 6,678 6,168 92.36% 6,916 238 748.03 Santa Ana 702 6,623 177 26 1,409 33 4 78 9,052 8,350 92.24% 9,416 364 744.06 Santa Ana 311 3,402 31 14 55 8 1 16 3,838 3,527 91.90% 3,994 156 874.04 Anaheim 323 3,338 34 14 53 9 0 14 3,785 3,462 91.47% 3,926 141 890.01 Santa Ana 794 3,704 54 30 2,835 46 1 110 7,574 6,780 89.52% 7,900 326 874.05 Anaheim 716 5,504 101 20 235 16 4 53 6,649 5,933 89.23% 6,977 328 890.04 Santa Ana 812 4,865 68 5 1,596 34 6 53 7,439 6,627 89.08% 7,823 384 992.47 Santa Ana 380 1,765 24 14 1,176 31 1 27 3,418 3,038 88.88% 3,558 140 992.48 Santa Ana 608 3,297 73 3 1,300 44 1 39 5,365 4,757 88.67% 5,595 230 890.03 Garden Grove 436 2,009 84 4 1,155 37 1 82 3,808 3,372 88.55% 3,973 165 875.04 Anaheim 1,038 6,342 106 35 587 22 0 118 8,248 7,210 87.42% 8,542 294 866.01 Anaheim 1,255 7,746 247 26 455 29 13 101 9,872 8,617 87.29% 10,343 471 878.03 Stanton /Anaheim 862 4,415 135 16 808 89 12 105 6,442 5,580 86.62% 6,671 229 740.05 Santa Ana 1,051 5,238 103 21 1,110 26 20 85 7,654 6,603 86.27% 7,947 293 874.03 Anaheim 531 3,059 21 9 92 2 0 21 3,735 3,204 85.78% 3,861 126 889.03 Garden Grove /Santa Ana 1,225 2,289 45 16 4,776 59 12 172 8,594 7,369 85.75% 9,001 407 873.00 Anaheim 1,502 7,428 216 23 716 16 3 137 10,041 8,539 85.04% 10,933 892 865.01 Anaheim 732 3,843 36 16 79 1 2 39 4,748 4,016 84.58% 4,929 181 1106.06 Buena Park 798 2,805 249 18 860 10 6 95 4,841 4,043 83.52% 5,215 374 864.05 Anaheim 1,150 5,067 100 8 288 10 17 59 6,699 5,549 82.83% 6,961 262 116.02 Fullerton /Anaheim 990 4,460 113 19 123 3 1 53 5,762 4,772 82.82% 5,990 228 2'4'1 242 Native American Hawaiian Pop. Indian and of Black or and Other Some two Pop. Hispanic African Alaska Pacific other or 2000 2008 Change Census White or American Native Asian Islander race more Total Percent Total 2000 - Tract city alone Latino alone alone alone alone alone races Pop. Minority Minority Pop. 2008 992.02 Santa Ana /Fountain Valley 1,402 4,206 88 54 2,194 49 10 114 8,117 6,715 82.73% 8,402 285 879.02 Stanton 1,072 3,586 81 11 1,019 86 1 127 5,983 4,911 82.08% 6,143 160 889.04 Westminster /Garden Grove 1,043 682 20 3 3,927 26 7 101 5,809 4,766 82.05% 6,072 263 864.04 Anaheim 1,121 4,347 57 24 585 5 6 72 6,217 5,096 81.97% 6,451 234 891.06 Garden Grove 689 2,317 32 7 680 12 3 44 3,784 3,095 81.79% 3,933 149 891.02 Garden Grove /Santa Ana 1,282 4,232 69 23 1,182 57 4 105 6,954 5,672 81.56% 7,234 280 12.01 La Habra/County 991 3,991 59 18 213 3 0 96 5,371 4,380 81.55% 5,586 215 753.02 Santa Ana 852 3,440 86 3 181 6 6 34 4,608 3,756 81.51% 4,782 174 889.02 Garden Grove 959 1,363 34 14 2,601 82 4 79 5,136 4,177 81.33% 5,387 251 888.01 Garden Grove 1,547 1,593 108 17 4,701 53 8 179 8,206 6,659 81.15% 8,633 427 741.11 Santa Ana 1,135 3,579 153 12 938 15 6 84 5,922 4,787 80.83% 6,148 226 117.14 Anaheim 58 227 1 0 3 9 0 0 5 302 244 80.79% 311 9 242 Attachment B Affordable Housing Inventory Arranged by Census Tract City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units La Habra Casa Nicolina 1510 W. La Habra Blvd. 90631 11.03 Family 562 22 La Habra La Habra Inn Senior Apartments 700 N. Beach Blvd. 90631 11.03 Senior SRO 55+ 70 70 La Habra Casa El Centro 101 N. Cypress St. 90631 12.02 Senior /Disabled 62+ 55 55 La Habra Las Lomas Gardens 900 S. Las Lomas Dr. 90631 13.03 Family 112 93 La Habra Cypress Villa Apartments 900 North Cypress Street 90631 14.01 Non Targeted 72 71 Brea Vintage Creek Sr. Apartments 855 North Brea Blvd. 92821 15.02 Senior 105 105 Brea Birch Street Loft Apartments 260 & 330 W. Birch St. 92821 15.03 1 Bedroom Lofts 30 25 Brea Imperial Terrace Apartments 430 W. Imperial Hwy. 92821 15.03 Family 36 18 Brea Loft Apartments 215 S. Brea Blvd. 92821 15.03 Artist's Lofts 32 8 Brea South Walnut Bungalows 302 -314 S. Walnut Ave. 92821 15.03 Family 9 9 Brea Walnut Village Apartments 620 Walnut Ave 92821 15.03 Large Family 46 46 Brea Birch Terrace Apartments 601 E. Birch St. 92821 15.04 Family 36 18 Brea BREAL Senior Apartments 111 N. Orange Ave. 92821 15.04 Senior 65+ 30 30 Brea Civic Center Apartments 651 E. Birch St. 92821 15.04 Family 30 16 Brea Orange Villa Senior Apartments 137 N. Orange Ave. 92821 15.04 Senior 62+ 36 9 Brea Williams Senior Apartments 212 S. Orange Ave. 92821 15.04 Senior 62+ 28 28 Brea Town and Country Apartments 800 S. Brea Blvd. 92821 15.05 Family 122 50 Brea Brea Woods Senior Apartments 195 W. Central Ave. 92821 15.06 Senior 55+ 151 36 Brea Tamarack Pointe Villas 330 W. Central Ave. 92821 15.07 Family 48 5 Fullerton North Hills Apartments 570 East Imperial Highway 92835 16.01 Non Targeted 204 203 24S City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Fullerton Harborview Terrace Apartments 2305 N. Harbor Blvd. 92835 17.06 Physical Disability 25 24 Fullerton Courtyard Apartments 4127 West Valencia 92633 18.01 Large Family 108 108 Fullerton Franklin Garden Apartment Homes 3828 Franklin Ave. 92833 18.01 Family 15 11 Fullerton Fullerton Residential Manor 2441 W. Orangethorpe Ave. 92632 18.02 Senior 62+ (Board & Care 97 97 Fullerton Ameri a Villa Apartments 343 W. Ameri e Ave. 92832 112.00 Senior 62+ or Disabled 101 100 Fullerton Fullerton City Lights 224 E. Commonwealth Ave. 92832 113.00 1 or 2 person 137 136 Fullerton Klim el Manor 229 E Amerig a Ave. 92832 113.00 Senior 59 59 Fullerton Casa Maria Del Rio 2130 E. Chapman Ave. 92831 115.02 Mobility Impaired 24 24 Fullerton East Fullerton Villas 2140 -2190 East Chapman Avenue 92821 115.02 Large Family 27 27 Fullerton Palm Garden Apartments 400 West Orangethorpe Avenue 92832 116.01 Non Targeted 223 223 Fullerton Richman Park 1 436 -442 W. Valencia Dr. 92832 116.01 Family 8 8 Fullerton Richman Park II 461 West Ave. 92832 116.01 Family 4 4 Fullerton Truslow Village 220 W. Truslow Ave. 92832 116.01 Family 12 1 Fullerton Allen Hotel Apartments 410 S. Harbor Blvd. 92832 116.02 Family 16 16 Fullerton Las Palmas Apartments 2598 N. Associated Rd. 92835 117.07 Family 259 52 Fullerton Garnet Housing 3012 -3024 Garnet Ln. 1512 & 1518 Placentia 92831 117.11 Family 20 20 Fullerton Garnet Lane Apartments 3125 -3149 Garnet Ln. 92631 117.11 Family 18 17 Placentia Imperial Villas 1050 E. Imperial Hwy. 92870 117.17 Family 58 58 Placentia Villa La Jolla 734 W. La Jolla Blvd. 92870 117.20 At -Risk 55 54 Placentia No Name Provided 219 Melrose St. 92870 117.21 Family 2 2 Placentia No Name Provided 307 Santa Fe Ave. 92870 117.21 Family 2 2 MEN City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Placentia No Name Provided 338 Santa Fe Ave. 92870 117.21 Family 4 4 Placentia Ramona Gardens 415 & 421 Ramona St. 92670 117.21 Family 6 6 Yorba Linda Evergreen Villas 5100 Avocado Circle 92886 218.02 Senior 55+ 52 25 Yorba Linda Yorba Linda Family Apartments 18542 Yorba Linda Blvd. 92886 218.02 Large Family 44 43 Yorba Linda Parkwood Apartments 4075 Prospect Avenue 92885 218.09 Senior 101 100 Placentia Arbor Lane East 1621 & 1931 Cherry St. 92870 218.21 Family 2 2 Placentia Highland Orchard Apartments 140 S. Highland Ave. 92870 218.21 Family 104 10 Yorba Linda Victoria Woods Yorba Linda 5303 Stonehaven Drive 92887 218.25 Senior 124 124 Yorba Linda Riverbend (Archstone Yorba Linda) 25550 River Bend Dr. 92887 218.26 Family 400 100 Anaheim Palacio Villas 435 S. Anaheim Hills Rd. 92807 219.05 Senior 62+ 117 27 Orange Villa Modena 4431 E. Marmon Ave. 92869 219.13 Family 5 5 Anaheim Fountain Glen 225 S. Festival Dr. 92808 219.22 Senior 55+ 259 130 Trabuco Canyon Trabuco Highlands 31872 Joshua Dr. 92679 320.04 Family 184 37 Rancho Santa Margarita Villa Aliento 114 Aliento St. 92688 320.51 Family 225 23 Ladera Ranch Laurel Glen 70 Sklar St. 92694 320.52 Family 220 44 Rancho Santa Margarita Fountain Glen Senior Apartments 30751 El Corazon 92688 320.54 Senior 55+ 166 34 Rancho Santa Margarita Villa La Paz 2 Via Amistosa 92688 320.55 Family 500 100 Dana Point OC Community Housing Corp. 25942 Domingo 92624 422.01 Family 24 24 Dana Point Monarch Coast 32400 Crown Valley Pkwy. 92629 423.24 Family 418 84 Irvine Northwood Affordable Apartments Jeffrey and Trabuco Road 92620 524.18 Large Family 96 94 245 city Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Irvine Northwood Place 1300 Hayes St. 92620 524.18 Family 604 186 Irvine Woodbury NE Apartments North of Talisman, South of Mission Park, East of Pink Sage, West of Hallmark in Planning Area 9A 92620 524.18 Large Family 150 148 Irvine Woodbury Apts. — Phase I Sand Can on /Trabuco 92620 524.18 Family 90 90 Lake Forest Alexan Bellecour 21041 Osterman Rd. 92630 524.23 Family 131 6 Lake Forest Arbors 26356 Vintage Woods Rd. 92630 524.23 Family 328 22 Lake Forest Emerald Court 21141 Canada Rd. 92630 524.23 Family 288 58 Lake Forest Westrid e 26571 Normadale Dr. 92630 524.23 Family & Senior 390 78 Lake Forest Trabuco Woods 22159 Rimhurst Dr. 92630 524.24 Family 72 15 Lake Forest Spring Lakes 21641 Canada Rd. 92630 524.25 Famii 180 36 Irvine Woodbridge Manor 27 Lake Road 92604 525.11 Senior 165 164 Irvine The Inn At Woodbridge 3 Osborne 92714 525.13 Senior 116 116 Irvine Cedar Creek 5051 Alton Pkwy. 92604 525.14 Family 176 36 Irvine Woodbridge Oaks 1 Knoll glen 92604 525.14 Family 120 120 Irvine Woodbridge Willows 344 Knoll glen 92614 525.14 Family 200 40 Irvine Santa Alicia Apartments 100 Santorini 92606 525.15 Family 84 82 Irvine Orchard Park 50 Tarocco 92618 525.17 Large Family 60 60 Irvine Woodbridge Villas 10 Thunder Run #30 92614 525.19 Family 258 60 Irvine Cross Creek 22 Creek Rd. 92604 525.20 Family 136 45 Irvine Woodbridge Cross Creek Apartments 22 Creek Rd., #1 92604 525.20 Family 136 45 Irvine San Leon Villa Apartments 1 San Leon 92606 525.21 Family 247 72 Irvine San Marco Apartments 101 Veneto 92614 525.21 Family 426 361 Irvine San Paulo Apartments 100 Duranzo Aisle 92606 525.21 Family 382 203 Irvine San Remo Villa 1011 San Remo 92606 525.21 Family 248 76 V2 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Irvine San Marino Villa Apartments 403 San Marino 92614 525.22 Family 199 59 Irvine Montecito Vista Apartment Homes 4000 El Camino Real 92602 525.25 Large Family 162 161 Irvine Northwood Park 146 Roosevelt St. 92620 525.25 Family 168 34 Irvine The Parklands 1 Monroe, #11 92620 525.25 Family 120 120 Irvine Windrow Apartments 5300 Trabuco Rd. 92620 525.25 Family 96 96 Irvine Abilityfirst Apartments 14501 Harvard Ave. 92606 525.27 Disabled 24 24 Irvine Windwood Glen 97 Hearthstone 92606 525.27 Family 196 40 Irvine Windwood Knoll 2 Flagstone 92606 525.27 Family 188 60 Irvine Deerfield Apartments 3 Bear Paw 92604 525.28 Family 288 20 Irvine Laguna Canyon Apartments 400 Limestone Way 92618 626.04 Large Family 120 118 Laguna Beach Glenne re Apartments 450 Glenne re Street 92651 626.05 Single Room 27 26 Laguna Beach Hagan Place 383 3rd St. 92651 626.05 1 Bedroom Disabled /HIV 24 24 Laguna Beach Harbor Cove Apartments 310 -312 Broadway St. 92651 626.05 Senior 62+ 15 15 Irvine Mariposa Co -Op 3773 University Dr. 92612 626.10 Disabled /Physically Challenged/Senior 40 39 Irvine Toscana Apartments 35 Via Lucca 92612 626.10 Family 563 84 Irvine Villa Sienna 25 Palatine #100 92612 626.10 Family 1442 216 Irvine Harvard Manor 21 California Ave. 92715 626.14 Senior 62+ 50 35 Laguna Hills Rancho Niguel Apartments 25952 Via Lomas 92653 626.25 Non Targeted 51 51 Irvine Berkeley Court 307 Berkeley 92612 626.26 Family 118 32 Irvine Columbia Court 307 Berkeley 92612 626.26 Family 58 12 Irvine Dartmouth Court 1100 Stanford 92612 626.26 Family 294 89 Irvine Stanford Court 400 Stanford 92612 626.26 Family 320 96 Irvine Harvard Court 146 Berkeley 92612 626.27 Family 112 34 Irvine Harvard Manor 50 Cornell Dr. 92712 626.27 Family 161 100 247 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Irvine Turtle Rock Canyon Apartments 100 Stone Cliff Aisle 92612 626.28 Family 217 66 Laguna Beach Vista Aliso Apartments 21544 Wesley Drive 92651 626.32 Senior 71 70 Aliso Viejo Wood Canyon Villas 28520 Wood Canyon Dr. 92656 626.39 Family 230 46 Aliso Viejo Wood ark Apartments 22702 Pacific Park Dr 92656 626.39 Large Family 128 128 Newport Beach Corona del Mar Seaview Lutheran Plaza 2800 Pacific View Dr. 92625 626.44 Senior 62+ & Mobility Impaired 100 99 Newport Beach Ba view Landing 1121 Back Bay Drive 92660 630.04 Senior 120 119 Newport Beach Newport North 2 Milano Dr. 92660 630.07 Family 570 133 Newport Beach SA Hei hts Lange Drive Family 1621 Mesa Drive 92707 631.01 Large Family 74 74 Newport Beach Newport Seacrest Apartments 843 W. 15th St. 92663 636.03 Family 65 65 Newport Beach Newport Seaside Apts. 1544 Placentia Avenue -0- 636.03 Large Family 26 26 Santa Ana La Gema Del Barrio 638 -642 East Adams 92707 740.03 Large Family 6 6 Santa Ana Warwick Square Apartments 780 South Lyon Street 92705 744.03 Large Family 500 500 Santa Ana 901 E. 6th St. 901 E. 6th St. 744.05 Family 24 24 Santa Ana Wakeham Grant Apartments 816 Minnie Street 92701 745.01 Non Targeted 127 126 Santa Ana Cornerstone Village 923 -1117 S. Minnie 745.01 Family 200 200 Santa Ana 415 -417 Birch 415 -417 Birch St. 92701 746.01 Family 3 3 Santa Ana Raitt Street Apartments 201, 271 North Raitt Street 92703 748.01 Large Family 6 2 Santa Ana Santa Ana Civic Center 405 & 411 S. Raitt St. 92703 748.01 Family 12 6 Santa Ana Santa Ana Civic Center 2009 W. Myrtle St. 92703 748.02 Family 6 6 Santa Ana Sullivan Manor 2516 W. 1st St. 92703 748.02 Family 54 54 Santa Ana Villa Del Sol Apartments 811 S. Fairview St. 92704 748.05 Family 562 112 Santa Ana 1060 W. Third 1060 W. Third St. 92701 749.01 Family/Senior 6 6 Santa Ana Flower Park Plaza 901 West First Street 92703 749.01 Senior 199 198 Santa Ana Highland Manor Apartments 1128 W. Highland St. 92703 749.02 Family 12 12 Santa Ana Henin er Village Apartments 200 S. Sycamore Street 92701 750.02 Senior 58 58 242 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Santa Ana Santa Ana Towers 401 W. First Street 92701 750.02 Senior 199 198 Santa Ana Rosswood Villas 100 N. Ross 750.02 Senior 199 198 Santa Ana Garden Court 300 E. Santa Ana BI. 750.02 Family 84 42 Santa Ana Ross & Durant Apartments 1411 N. Durant Street & 1501 N. Ross Street 92706 750.03 Large Family 49 48 Santa Ana 1025 N. Spurgeon 1025 N. Spurgeon St. 92701 750.04 Family 4 4 Santa Ana Wycliffe Plaza 1401 N. Flower St. 92706 751.00 Senior 62+ /Disabled 199 140 Santa Ana City Gardens Apartments 2901 N Bristol St 92706 753.01 Non Targeted 274 55 Santa Ana Santiago Villas 939 E. 17th St. 754.01 Senior 89 89 Irvine Alta Court Apartments 2552 Kelvin Ave. 92614 755.15 Family 132 27 Irvine Granite Court 17421 Murphy Ave. 92612 755.15 Family 71 71 Irvine Irvine Inn 2810 Warner Avenue 92606 755.15 Single Room 192 192 Irvine The Camden Apts. 2801 Main St. 92614 755.15 Family 290 58 Orange Stonegate Senior Apartments 170 N. Prospect Street 92869 758.04 Senior 20 19 Orange Rose Avenue Apartments 1743 E. Rose Ave. 92867 758.05 Family 6 6 Orange Casas Del Rio 1740 E. La Veta Ave. 92866 758.06 Disabled Only 40 40 Orange Chestnut Place 1745 E. Fairway Dr. 92866 758.06 Senior 62+ 50 49 Orange Harmony Creek Sr. Apartments 1616 E. Rock Creek Dr. 92866 758.06 Senior 62+ 83 82 Orange Esplanade St. Apartments 280 S. Esplanade St. 92869 758.07 Family 27 27 Orange Adams Triplexes 1741 -1745, 1837 -1841, & 1915 -1919 E. Adams Ave. 92867 758.12 Family 9 9 Orange Orange Garden Apartments (see Plaza Garden) 928 N. Highland St., #2 92867 758.12 Family 24 24 2 —" City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Orange Plaza Garden Apartments 928 N. Highland St., #2 92867 758.12 Family 56 56 Orange Wilson Avenue Apartment 1 1924 & 1934 E. Wilson Ave. 92867 758.12 Family 20 20 Orange Wilson Avenue Apartments 11 1844 E. Wilson Ave. 92867 758.12 Family 10 10 Orange Wilson Avenue Apartments III 1944 E. Wilson Ave. 92867 758.12 Family 10 10 Orange The Knolls Apartments 206 Prospect Avenue 92669 758.16 Non Targeted 260 260 Orange Casa Ramon Apartments 840 West Walnut Avenue 92868 759.01 Large Family 75 74 Orange Friendly Center 451 -453 N. Lemon St. 92866 759.01 Family 8 8 Orange Parker Street Apartments 161 N. Parker St. 92868 759.01 Family 3 3 Orange OHDC /Orange Rotary Senior Plaza 235 W. La Veta Avenue 92866 759.02 Senior 6 6 Orange Triangle Terrace 555 S. Shaffer St. 92866 759.02 Senior 62+ 75 75 Orange Pixley Arms 537 W. Almond Ave. 92868 760.00 Senior 62+ 15 15 Orange Citrus Village 501 N. Citrus St. 92868 761.01 Family 47 22 Orange Community Garden Tower East 3919 W. Garden Grove Blvd. 92868 761.02 Senior 62+ 333 332 Garden Grove Arroyo Vista 12242 Haster St. 92840 761.03 Family 148 10 Garden Grove Crystal View Apartments 12091 Bayport St. 92840 761.03 Family 402 80 Orange Hoover Avenue 108 -118, 218 -228 W. Hoover Ave. 92867 762.04 Family 40 40 Orange Orangevale Apartments 1300 North Shaffer Avenue 92867 762.05 Non Targeted 64 64 Orange Orchid Gardens 1051 N. Glassell St. 92867 762.05 Senior 62+ 33 17 Orange Walnut - Pixley 1519 E Walnut and 537 W Almond Ave 92867 762.06 Large Family 22 22 Anaheim Broadway Village 1245 E. Broadway 92805 863.01 Large Family 46 45 2150 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Anaheim Tyrol Plaza Senior Apartments 891 S. State College Blvd. 92806 863.01 Senior 60 59 Anaheim Carbon Creek Shores 3060 E. Frontera St. 92806 864.07 Families, Mobility & Sensory Impaired 40 40 Anaheim Park Vista Apartments 1200 N. Robin Street 92801 866.01 Family 392 390 Anaheim Paseo Village 1115 N. Citron Ln. 92801 866.01 Family 176 174 Anaheim Casa Delia 1105 N. Citron St. 92801 866.01 Family 12 12 Anaheim Sae Park Apts. 810 N. Loara 92801 866.02 Senior 62+ 100 25 Anaheim Villa Catalpa Apts. 1680 Catalpa 92801 866.02 Senior 62+ 18 6 Anaheim Fairhaven Apts. 535 Fairhaven 92801 867.02 Senior 62+ 17 6 Anaheim Monarch Pointe Apartment Homes 1830 W. Crescent Avenue (Crescent and Chippewa Avenue at the I -5 Freeway) 92801 867.02 Large Family 63 62 Anaheim Sea Wind Apartments 1924 Glenoaks & 1925 Greenleaf Avenue 92801 867.02 Non Targeted 91 18 Anaheim Greenleaf Family Apartments 2048 Greenleaf 867.02 Family 53 53 Buena Park Dorado Senior Apartments 8622 Stanton Ave. 90620 868.03 Senior 55+ 150 150 Anaheim Miracle Terrace 225 S. Western Ave. 92804 869.01 Senior 62+ 179 177 Anaheim Palm West Apartments 644 South Knott Avenue 92804 869.01 Non Targeted 58 23 Anaheim Renaissance Park Apartments 3433 West Del Monte 92804 869.01 Non Targeted 127 51 Anaheim Westchester Apartments 125 S. Westchester Dr. 92804 869.01 Family 65 64 Anaheim New porter Apts. 3424 W. Orange 869.01 Family 22 4 Anaheim Cobblestone Apartments 870 South Beach Blvd. 92804 869.03 Non Targeted 64 13 Anaheim Casa Alegre 2761 West Ball Road 92804 870.01 Disabled Persons — AIDS /HIV 23 22 Anaheim Magnolia Acres 640 S. Magnolia Avenue 92807 870.01 1 Senior 40 10 251 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Anaheim Harbor Village 2736 W. Lincoln 870.01 Family 111 9 Anaheim Sunset Plaza Apartments 2771 W. Ball Rd. 870.01 Family 106 9 Anaheim Gilbert Park Apts. 925 S. Gilbert 92804 870.02 Senior 62+ 24 8 Anaheim California Villas 935 S. Gilbert Street 92804 870.02 Senior 34 33 Anaheim Linbrook Court 2240 W. Lincoln Avenue 92801 871.01 Senior 81 80 Anaheim Bel-Age Manor 1660 W. Broadway 92802 871.05 Senior 55+ 180 179 Anaheim Acaciawood Village 1415 W. Ball Rd. 92802 871.06 Seniors 62+ 123 31 Anaheim Heritage Village Apts. 707 W. Santa Ana St. 92805 872.00 Senior 62+ 196 49 Anaheim Vintage Apartments 200 S. Citron 872.00 Senior 55+ 82 21 Anaheim Diamond Asile 1232 Diamond St. 872.00 Special Needs 26 25 Anaheim Anaheim Family Housing 415 South Vine Street 92805 873.00 Large Family 60 59 Anaheim Anaheim Memorial Manor 275 E. Center St. 92805 873.00 Senior 62+ 75 75 Anaheim Elm Street Commons 111 -125 West Elm Street 92805 873.00 Large Family 52 51 Anaheim Village Center Apartments 200 E. Lincoln Ave. 92805 873.00 Senior 62+ 100 100 Anaheim Hermosa Village Apartments 1515 S. Calle Del Mar Dr. 92802 875.01 Large Families 517 517 Anaheim Nutwood Park Apartments 1668 S. Nutwood St. 92802 876.02 Family 30 2 Anaheim Cornerstone Apartments 9541 W. Ball Road 92804 877.01 Family 49 48 Anaheim New Horizons Apts. 835 S. Brookhurst 92804 877.01 Senior 62+ 80 32 Anaheim Heritage Park Apartments 950 S. Gilbert 877.01 Senior 60+ 94 29 Stanton Casa de Esperanza 10572 Knott Ave. 90680 878.01 Special Needs 10 9 Stanton Continental Gardens Apartments 8101 Cerritos Avenue 90680 878.03 Non Targeted 298 298 Anaheim Pebble Cove Apartments 2555 W. Winston Rd. 95242 878.06 Family 112 45 Garden Grove Malabar Apartments 9777 Bixby Avenue 92841 882.03 Large Family 126 126 Garden Grove Aslam 11211 Steele St. 92840 883.01 Family 10 10 Garden Grove Pat Stein -Palma Vista 10772 -10862 Palma Vista 883.01 24 24 2152 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Garden Grove Tamerlane 12131,12141,12161,12171 Tamerlane; 12112,12222,12132,12182 Tamerlane 884.02 43 28 Anaheim Harborcliffe 2170 S. Harbor BI. 884.03 Family 130 26 Garden Grove Briar Crest and Rose Crest Briar: 11701 Stewart St. Rose: 11762 Stewart St. 92843 885.01 Briar - 32 Rose —10 42 Garden Grove Stuart Drive Apartments 11632 Stuart Dr. #3 92843 885.01 Family 95 95 Garden Grove Arbor Glen Apartments 12680 Buaro St. 92840 885.02 Family 136 68 Garden Grove Garden Grove Senior Apartments 12739 Garden Grove Blvd. 92843 885.02 Senior 85 85 Garden Grove Sun rove Senior Apartments 12811 Garden Grove Blvd. 92843 885.02 Senior 82 82 Garden Grove Acacia Villa Apartments 10931 Acacia Pkwy. 92840 886.01 Senior 62+ 161 161 Garden Grove Jordan Manor 11441 Acacia Pkwy. 92840 886.02 Senior 62+ 64 64 Garden Grove Rose Garden Apartment 8551 Westminster Ave. 92844 889.01 Family 144 144 Garden Grove Orange Tree Apartments 13902 Taft 889.02 80 80 Santa Ana Harbor Pointe Apartments 1500 N. Harbor Blvd. 92703 890.04 Family 130 26 Santa Ana Vintage Wood Apartments 3900 W. 5th St. 92703 890.04 Family 170 34 Garden Grove Tudor Grove 12631 Sunswept Avenue #1 92843 891.04 144 144 Garden Grove Thomas House 12591 -12601 Mornin side 891.04 16 14 Garden Grove La Esperanza I and II 14024,14021,14041,14061 Buena St. 891.04 28 28 Garden Grove OCCHC /Emergency Shelter for the Homeless 12602 Keel St. 891.04 8 8 Santa Ana Jackson Park 300 -304 N. Jackson St. 92701 891.05 Family 7 4 Santa Ana Santa Ana Civic Center 3524 W. Washington Ave. 92703 891.05 Family 8 8 253 254 Low Zip Census Total Income City Name Address Code Tract Housing Type Units Units Anaheim CHOC Site Lincoln Ave. /East St. 894.05 Family 150 150 Stanton Park Stanton Senior 7622 Katella Ave. 90680 897.01 Senior 55+ 335 334 Apartments (Formerly Park Place Apartments) Stanton Plaza Court 11380 -11480 Court Street 90680 897.01 Large Family 103 103 Orange Alice Clark Orange Blossom 141 E. Walnut Ave. 92866 962.05 Senior 62+ 4 4 Sr. Apartments Garden Grove Garden Grove Manor 10642 Bolsa Ave. 92843 992.03 Family 78 31 Westminster Summerville at Brookhurst 15302 Brookhurst St. 92683 992.04 Senior 62+ 117 24 Huntington Beach Huntington Breakers 21270 Beach Blvd. 92648 992.20 Family/Senior/Disabled 342 68 Fountain Valley Club 42 17230 Newho a 92708 992.29 Family 7 7 Fountain Valley Guadalupe Manor 17103 Magnolia St. 92708 992.33 Senior 62+ & Mobility 71 69 Impaired Fountain Valley Fountain Valley Senior (The 17911 Bushard Street 92708 992.34 Senior 156 154 Jasmine Huntington Beach Beachview Villa 8102 Ellis Avenue 92648 992.35 Single Room 107 86 Huntington Beach Huntington Villa Yorba 16000 Villa Yorba 92647 992.41 Family 198 192 Huntington Beach Sea Air Apartments 725, 729 & 733 Utica Ave. 92648 993.05 Family 36 36 Huntington Beach Bowen Court 1970, 1974, 1978, 1982 & 92648 993.05 Senior 20 20 1990 Lake Street Huntington Beach Fountain Glen @ Seacliff 7200 Garden Glen Dr 92648 993.09 Senior 55+ 271 80 (North of Main & Yorktown Huntington Beach Main Place Apartments 7311 Luna (N/W corner 92648 993.09 Family 26 26 Cla /Gothard /Main Huntington Beach Oceanaire Garden 7811 Talbert Ave. 92648 994.02 Family 65 65 Apartments Huntington Beach Shelter For the Homeless 7802 Barton Dr. 7812 92647 994.02 Family 8 8 Barton Dr. 254 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Huntington Beach Shelter for the Homeless Keelson 17382 Keelson Ln. 92647 994.02 Family 4 4 Huntington Beach Huntington Village Senior Apartments 16171 Springdale St. 92649 994.07 Senior 62+ 114 11 Huntington Beach Sher Lane Apartments 16112 Sher Ln. 92647 994.10 Family/Senior 66 66 Huntington Beach Bridges Apartments 16851 Nichols St. 92647 994.11 Family 80 80 Huntington Beach 5 Points Senior Apartments 18561 Florida St. 92648 994.13 Senior 55+ 166 50 Huntington Beach Emerald Cove 18191 Parktree Cir. 92648 994.13 Senior 60+ 164 164 Huntington Beach Wycliffe Gardens 18765 Florida St. 92648 994.13 Senior 62+ & disabled 185 185 Huntington Beach Huntington Pointe (Quo Vadis Apartments) 18992 Florida Street 92648 994.13 Non Targeted 104 102 Huntington Beach Hermosa Vista Apartments 15353 & 15425 Goldenwest Street 92647 996.05 Non Targeted 88 87 Midway City Jackson Aisle Apartments 15432 Jackson Street 92655 997.02 Special Needs 30 29 Midway City Pacific Terrace Apartments 15000 Pacific St. 92655 997.02 Seniors 62+ 97 97 Westminster Cambridge Heights Senior Apartments 7541 Wyoming Street 92683- 3922 998.02 Senior 22 21 Westminster Coventry Heights 7521 Wyoming Street 92683 998.02 Senior 76 75 Westminster Westminster Senior Apartments 7632 21st Street 92683 998.02 Senior 92 91 Westminster The Rose Gardens" 8190 13th Street 92683 998.03 Large Family or Senior? 132 132 Westminster Windsor Court & Stratford Place 8140 - 8156 13th Street 92683 998.03 Large Family 86 85 Garden Grove Valley View Senior Villas 12200 Valley View St. 92845 1100.03 Senior 55+ 36 36 Cypress Cypress Park Senior Community 9021 Grindlay St. 90630 1101.04 Active Senior 55+ 124 31 Cypress Cypress Pointe Senior Community 5120 Lincoln Ave. 90630 1101.04 Senior 55+ 110 11 2155 city Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Cypress Cypress Sunrise Apartments 9151 Grindlay Street 90630 1101.04 Senior 75 74 Cypress Tara Village Apartments 5201 Lincoln Avenue 90630 1101.04 Large Family 170 168 Cypress OC Community Housing Corp. 8702 & 8692 LaSalle 90630 1101.11 Family 8 8 Cypress Sumner Place 8542 -8552 Sumner PI. 90630 1101.11 Family 5 5 Los Alamitos Laurel Park Manor 4121 Katella Ave. 90720 1101.13 Senior 62+ and Mobility Impaired 71 70 La Palma Seasons La Palma 7051 -7061 Walker St. 90623 1101.15 Senior 62+ 60 60 La Palma Camden Place Apartments 4500 Montecito Drive 90623 1101.16 Senior 35 35 La Palma Casa La Palma Apartments 7799 Valley View Street 90623 1101.16 Non Targeted 269 269 Anaheim Solara Court 3335 West Lincoln Avenue 92801 1102.01 Senior 132 132 Anaheim Villa Anaheim 3305 W. Lincoln Avenue 92626 1102.01 Senior 135 47 Buena Park Emerald Garden Apartments 8720 Valley View St. 90620 1102.01 Family 110 109 Buena Park Casa Santa Maria 7551 Oran ethorpe Ave. 90621 1105.00 Senior 62+ 100 98 Buena Park Harmony Park Apartments 7252 Melrose St. 90622 1105.00 Senior 62+ 59 58 Buena Park OC Community Housing Corp. Palm Village) 7602 -7638 W. 9th St. 90621 1105.00 Family 38 38 Buena Park Walden Glen Apartments 6570 -6680 Knott Avenue 90621 1105.00 Non Targeted 186 185 Anaheim OC Community Housing Corp. Various Locations 92801 92802, 92804 Family 17 17 Garden Grove OC Community Housing Corp. Various Locations 92843 Family 44 44 Huntington Beach OC Community Housing Corp. Various Location 92647, 92648 Family 64 64 Irvine OC Community Housing Corp. Various locations 92604, 92618, 92620 Family 6 6 2150 257 Low Zip Census Total Income City Name Address Code Tract Housing Type Units Units Orange Lemon Street Apartments 481 -491 Lemon Street 92866 Family 6 6 Placentia OC Community Housing Various Locations 92870 Family 14 14 Corp. Santa Ana OC Community Housing Various Locations 92703, Family 10 10 Corp. 92704 92707 Santa Ana Orange Housing Various Locations 92701 Family 352 313 Development Corp. TOTAL 34,834 20,379 257 This Page Intentionally Left Blank 252 TECHNICAL APPENDICES 259 This Page Intentionally Left Blank 200 Technical Appendix A Orange County Fair Housing Community Profile 201 Table A -1 Regional Analysis of Fair Housing Impediments Entitlement Cities: Year 2010 Population Estimates by City city Total Population Household Population Group Quarters Persons Per Household Anaheim 353,643 349,847 3,796 3.485 Buena Park 84,141 83,207 934 3.465 Fountain Valley 58,741 58,229 512 3.130 Fullerton 138,610 135,395 3,215 2.945 Garden Grove 175,618 173,384 2,234 3.714 Huntington Beach 203,484 202,692 792 2.667 Irvine 217,686 209,482 8,204 2.708 La Habra 63,184 62,589 595 3.215 Lake Forest 78,720 77,876 844 3.029 Newport Beach 86,738 85,798 940 2.212 Orange 142,708 137,240 5,468 3.148 Rancho Santa Margarita 49,945 49,931 14 3.022 Santa Ana 357,754 352,107 5,647 4.737 Westminster 94,294 93,742 552 3.462 Total 2,105,266 2,071,519 33,747 3.265 Source: State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 202 Table A -2 Regional Analysis of Fair Housing Impediments Urban County: Year 2010 Population Estimates by City city Total Population Household Population Group Quarters Persons Per Household Aliso Viejo 46,123 45,963 160 2.596 Brea 40,377 40,249 128 2.813 Cypress 49,981 49,660 321 3.054 Dana Point 37,326 37,084 242 2.517 Laguna Beach 25,354 25,232 122 2.140 Laguna Hills 33,593 33,169 424 3.069 Laguna Woods 18,747 18,673 74 1.469 La Palma 16,304 16,273 31 3.223 Los Alamitos 12,270 11,864 406 2.735 Placentia 52,305 52,002 303 3.199 Seal Beach 26,010 25,752 258 1.928 Stanton 39,799 39,281 518 3.575 Villa Park 6,307 6,286 21 3.199 Yorba Linda 69,273 69,138 135 3.179 Unincorporated 120,088 118,621 1,467 3.178 Total 593,857 589,247 4,610 2.815 Source: State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2009 Table construction by Castaneda & Associates 203 Table A -3 Regional Analysis of Fair Housing Impediments Entitlement Cities: Population Growth April 1, 1990, April 1, 2000 and January 1, 2010 City 1990 2000 2010 Numerical Change 1990 -2000 Percentage Change 1990 -2000 Numerical Change 2000 -2010 Percentage Change 2000 -2010 Anaheim 266,406 328,014 353,643 61,608 23.1% 25,629 7.8% Buena Park 68,784 77,962 84,141 9,178 13.3% 6,179 7.9% Fountain Valley 53,691 54,978 58,741 1,287 2.4% 3,763 6.8% Fullerton 114,144 126,003 138,610 11,859 10.4% 12,607 10.0% Garden Grove 142,965 165,196 175,618 22,231 15.5% 10,422 6.3% Huntington Beach 181,519 189,627 203,484 8,108 4.5% 13,857 7.3% Irvine 110,330 143,072 217,686 32,742 29.7% 74,614 52.2% La Habra 51,266 58,974 63,184 7,708 15.0% 4,210 7.1% Lake Forest NA 58,707 78,720 NA NA 20,013 34.1% Newport Beach 66,643 70,032 86,738 3,389 5.1% 16,706 23.9% Orange 110,658 128,868 142,708 18,210 16.5% 13,840 10.7% Rancho Santa Margarita* 11,390 47,214 49,945 35,824 314.5% 2,731 5.8% Santa Ana 293,827 337,977 357,754 44,150 15.0% 19,777 5.9% Westminster 78,293 88,207 94,294 9,914 12.7% 6,087 6.9% Total NA 1,874,831 2,105,266 NA NA 230,435 12.3% 'Lake Forest was unincorporated in 1990 2Rancho Santa Margarita was a Census Division Place (CDP) and not an incorporated city in 1990 Source: 1990 Census Summary Tape File 1 (STF1) Table P001 Persons State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2000 State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates WON Table A -4 Regional Analysis of Fair Housing Impediments Urban County: Population Growth April 1, 1990, April 1, 2000 and January 1, 2010 Cities 1990 2000 2010 Numerical Change 1990 -2000 Percentage Change 1990 -2000 Numerical Change 2000 -2010 Percentage Change 2000 -2010 Aliso Viejo* NA NA 46,123 NA NA NA NA Brea 32,873 35,410 40,377 2,537 7.7% 4,967 14.0% Cypress 42,655 46,549 49,981 3,894 9.1% 3,432 7.4% Dana Point 31,896 35,110 37,326 3,214 10.1% 2,216 6.3% Laguna Beach 23,170 23,727 25,354 557 2.4% 1,627 6.9% Laguna Hills* NA 29,891 33,593 NA NA 3,702 12.4% Laguna Woods* NA 17,794 18,747 NA NA 953 5.4% La Palma 15,392 15,408 16,304 16 0.1% 896 5.8% Los Alamitos 11,788 11,536 12,270 -252 -2.1% 734 6.4% Placentia 41,259 46,488 52,305 5,229 12.7% 5,817 12.5% Seal Beach 25,098 24,157 26,010 -941 -3.7% 1,853 7.7% Stanton 30,491 37,403 39,799 6,912 22.7% 2,396 6.4% Villa Park 6,299 5,952 6,307 -347 -5.5% 355 6.0% Yorba Linda 52,422 58,918 69,273 6,496 12.4% 10,355 17.6% Unincorporated 226,927 168,132 120,088 - 58,795 -25.9% - 48,044 -28.6% Total NA 556,475 593,857 NA NA NA NA *Denotes that the city was not incorporated in 1990 Source: 1990 Census Summary Tape File 1 (STF1) Table P001 Persons State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2000 State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 205 Table A -5 Regional Analysis of Fair Housing Impediments Entitlement Cities: Year 2010 Housing Supply Estimate by City City_ Single Detached Single Attached 2 to 4 Units 5 Plus Units Mobile Homes Total Percent Vacant Anaheim 43,733 9,064 10,436 35,624 4,385 103,242 2.76 Buena Park 14,351 2,024 1,462 6,395 291 24,523 2.07 Fountain Valley 12,486 2,247 672 3,122 398 18,925 1.69 Fullerton 23,958 4,101 3,711 14,518 921 47,209 2.60 Garden Grove 26,811 4,538 3,426 11,014 1,828 47,617 1.95 Huntington Beach 38,619 9,467 9,909 16,924 3,141 78,060 2.65 Irvine 28,138 14,605 5,091 32,155 1,022 81,011 4.52 La Habra 10,619 1,750 1,362 5,508 734 19,973 2.54 Lake Forest 14,165 3,923 1,276 5,734 1,286 26,384 2.55 Newport Beach 19,467 7,166 5,599 10,420 863 43,515 10.87 Orange 25,254 5,374 4,726 7,934 1,339 44,627 2.32 Rancho Santa Margarita 9,117 3,883 598 3,194 0 16,792 1.59 Santa Ana 33,746 7,223 7,473 23,592 3,909 75,943 2.13 Westminster 14,932 2,550 2,106 4,972 3,068 27,628 1.98 Total 315,396 77,915 57,847 181,106 23,185 655,449 3.19 Source: State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 200 Table A -6 Regional Analysis of Fair Housing Impediments Urban County: Year 2010 Housing Supply Estimate by City City Single Detached Single Attached 2 to 4 Units 5 Plus Units Mobile Homes Total Percent Vacant Aliso Viejo 6,549 4,991 753 5,899 15 18,207 2.76 Brea 8,510 1,095 569 3,548 869 14,591 1.93 Cypress 10,195 2,717 529 2,842 364 16,647 2.34 Dana Point 7,958 2,273 2,831 2,622 299 15,983 7.80 Laguna Beach 8,336 762 1,760 2,100 324 13,282 11.23 Laguna Hills 5,873 2,183 608 2,272 217 11,153 3.10 Laguna Woods 727 4,146 2,474 6,390 26 13,763 7.61 La Palma 3,643 376 102 989 27 5,137 1.71 Los Alamitos 1,940 269 1,061 1,023 129 4,422 1.90 Placentia 9,798 2,113 1,117 2,954 587 16,569 1.89 Seal Beach 4,711 2,121 1,160 6,390 164 14,546 8.17 Stanton 3,062 1,915 988 4,009 1,262 11,236 2.22 Villa Park 1,994 18 0 6 5 2,023 2.87 Yorba Linda 17,399 2,395 662 1,336 311 22,103 1.62 Unincorporated 30,529 2,188 2,213 3,260 306 38,496 3.04 Total 121,224 29,562 16,827 45,640 4,905 218,158 3.97 Source: State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 20 Table A -7 Regional Analysis of Fair Housing Impediments Entitlement Cities: Housing Supply Growth April 1, 1990, April 1, 2000 and January 1, 2010 city 1990 2000 2010 Numerical Change 1990 -2000 Percentage Change 1990 -2000 Numerical Change 2000 -2010 Percentage Change 2000 -2010 Anaheim 93,177 99,719 103,242 6,542 7.0% 3,523 3.4% Buena Park 23,200 23,690 24,523 490 2.1% 833 3.4% Fountain Valley 18,019 18,473 18,925 454 2.5% 452 2.4% Fullerton 42,956 44,771 47,209 1,815 4.2% 2,438 5.2% Garden Grove 45,957 46,703 47,617 746 1.6% 914 1.9% Huntington Beach 72,736 75,679 78,060 2,943 4.0% 2,381 3.1% Irvine 42,221 53,711 81,011 11,490 27.2% 27,300 33.7% Lake Forest' NA 20,486 26,384 NA NA 5,898 22.4% La Habra 18,670 19,441 19,973 771 4.1% 532 2.7% Newport Beach 34,861 37,288 43,515 2,427 7.0% 6,227 14.3% Orange 38,018 41,920 44,627 3,902 10.3% 2,707 6.1% Rancho Santa Margarita 2 4,951 16,515 16,792 11,564 233.6% 277 1.6% Santa Ana 75,000 74,588 75,943 -412 -0.5% 1,355 1.8% Westminster 25,892 26,940 27,628 1,048 4.0% 688 2.5% Total NA 599,924 655,449 NA NA 55,525 8.5% 'Lake Forest was unincorporated in 1990 2Rancho Santa Margarita was a Census Division Place (CDP) and not an incorporated city in 1990 Source: 1990 Census Summary Tape File 1 (STF1) Table H001 Housing Units State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing - Report E -5, January 1, 2000 State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates is Table A -8 Regional Analysis of Fair Housing Impediments Urban County: Housing Supply Growth April 1, 1990, April 1, 2000 and January 1, 2010 city 1990 2000 2010 Numerical Change 1990 -2000 Percentage Change 1990 -2000 Numerical Change 2000 -2010 Percentage Change 2000 -2010 Aliso Viejo* NA NA 18,207 NA NA NA NA Brea 12,648 13,327 14,591 679 5.4% 1,264 8.7% Cypress 14,715 16,164 16,647 1,449 9.8% 483 2.9% Dana Point 14,666 15,682 15,983 1,016 6.9% 301 1.9% Laguna Beach 12,846 12,965 13,282 119 0.9% 317 2.4% Laguna Hills' NA 10,324 11,153 NA NA 829 7.4% Laguna Woods" NA 13,629 13,763 NA NA 134 1.0% La Palma 4,935 5,066 5,137 131 2.7% 71 1.4% Los Alamitos 4,312 4,329 4,422 17 0.4% 93 2.1% Placentia 13,733 15,326 16,569 1,593 11.6% 1,243 7.5% Seal Beach 14,407 14,267 14,546 -140 -1.0% 279 1.9% Stanton 10,755 11,011 11,236 256 2.4% 225 2.0% Villa Park 1,966 1,992 2,023 26 1.3% 31 1.5% Yorba Linda 17,341 19,567 22,103 2,226 12.8% 2,536 11.5% Unincorporated 89,440 61,161 38,496 - 28,279 -31.6% - 22,665 - 58.9% Total NA NA 218,158 NA NA NA NA 'Denotes that the city was not incorporated in 1990 Source: 1990 Census Summary Tape File 1 (STF1) Table H001 Housing Units State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2000 State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 2o9 Table A -9 Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities city, Year/Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Anaheim Number 2000 117,607 153,374 7,939 1,049 38,919 1,263 457 7,406 328,014 Percent 2000 35.9% 46.8% 2.4% 0.3% 11.9% 0.4% 0.1% 2.3% 100.0% Number 2008 97,373 187,122 10,049 693 46,087 1,040 347 3,812 346,522 Percent 2008 28.1% 54.0% 2.9% 0.2% 13.3% 0.3% 0.1% 1.1% 100.0% # Change - 20,234 33,748 2,110 -356 7,168 -223 -110 -3,594 18,508 % Change - 17.2% 22.0% 26.6% -33.9% 18.4% -17.7% - 24.2% -48.5% 5.6% Buena Park Number 2000 29,885 26,221 2,826 315 16,338 358 154 2,185 78,282 Percent 2000 38.2% 33.5% 3.6% 0.4% 20.9% 0.5% 0.2% 2.8% 100.0% Number 2008 29,396 31,632 1,573 662 17,969 248 331 994 82,807 Percent 2008 35.5% 38.2% 1.9% 0.8% 21.7% 0.3% 0.4% 1.2% 100.0% # Change -489 5,411 -1,253 347 1,631 -110 177 -1,191 4,525 % Change -1.6% 20.6% 44.3% 110.3% 10.0% - 30.6% 115.1% -54.5% 5.8% Fountain Valley` Number 2000 32,144 5,870 584 171 14,100 202 129 1,778 54,978 Percent 2000 58.5% 10.7% 1.1% 0.3% 25.6% 0.4% 0.2% 3.2% 100.0% Number 2008 31,166 6,720 521 463 17,437 116 116 1,390 57,929 Percent 2008 53.8% 11.6% 0.9% 0.8% 30.1% 0.2% 0.2% 2.4 % 100.0% # Change -978 1 850 1 -63 1 2921 3,337 1 -86 1 -13 1 -388 1 2,951 % Change -3.0% 1 14.5% 1 - 10.7% 1 171.0% 1 23.7% 1 - 42.6% 1 - 10.2% 1 - 21.8% 1 5.4% 270 Table A -9 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Fullerton Number 2000 61,420 38,014 2,675 404 20,130 251 237 2,872 126,003 Percent 2000 48.7% 30.2% 2.1% 0.3% 16.0% 0.2% 0.2% 2.3% 100.0% Number 2008 52,943 44,988 5,486 686 29,489 137 137 3,292 137,158 Percent 2008 38.6% 32.8% 4.0% 0.5% 21.5% 0.1% 0.1% 2.4% 100.0% # Change -8,477 6,974 2,811 282 9,359 -114 -100 420 11,155 %Change - 13.8% 18.3% 105.1% 69.8% 46.5% - 45.4% -42.1% 14.6% 8.9% Garden Grove Number 2000 53,735 53,608 1,873 523 50,803 995 210 3,449 165,196 Percent 2000 32.5% 32.5% 1.1% 0.3% 30.8% 0.6% 0.1% 2.1% 100.0% Number 2008 41,582 69,476 2,080 173 58,215 69 347 1,387 173,329 Percent 2008 24.0% 40.1 % 1.2% 0.1 % 33.6% 0.0% 0.2% 0.8% 100.0% # Change - 12,153 15,868 207 -350 7,412 -926 137 -2,062 8,133 % Change - 22.6% 29.6% 11.0% - 66.9% 14.6% - 93.0% 65.1% - 59.8% 4.906 Huntington Beach Number 2000 136,237 27,798 1,383 777 17,544 432 314 5,109 189,594 Percent 2000 71.9% 14.7% 0.7% 0.4% 9.3% 0.2% 0.2% 2.7% 100.0% Number 2008 140,297 31,244 1,008 403 22,375 1,613 403 4,233 201,576 Percent 2008 69.6% 15.5% 0.5% 0.2% 11.1% 0.8% 0.2% 2.1% 100.0% # Change 4,060 3,446 -375 -374 4,831 1,181 89 -876 11,982 %Change 3.0% 12.4% -27.1% -48.1% 27.5% 273.3% 28.4% -17.1% 6.3% Irvine Number 2000 81,613 10,539 1,977 162 42,506 180 359 5,736 143,072 Percent 2000 57.0% 7.4% 1.4% 0.1% 29.7% 0.1% 0.3% 4.0% 100.0% Number 2008 105,467 18,698 2,311 420 75,844 420 840 6,093 210,094 Percent 2008 50.2% 8.9% 1.1% 0.2% 36.1 % 0.2% 0.4% 2.9% 100.0% # Change 23,854 8,159 334 258 33,338 240 481 357 67,022 % Change 29.2% 77.4% 16.9% 159.4% 78.4% 133.4% 134.1% 6.2% 46.8% 271 Table A -9 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total La Habra" Number 2000 24,399 28,922 808 188 3,432 89 95 1041 58,974 Percent 2000 41.4% 49.0% 1.4% 0.3% 5.8% 0.2% 0.2% 1.8% 100.0% Number 2008 19,634 35,641 1,188 125 4,940 125 125 750 62,528 Percent 2008 31.4% 57.0% 1.9% 0.2% 7.9% 0.2% 0.2% 1.2% 100.0% # Change -4,765 6,719 380 -63 1,508 36 30 -291 3,554 % Change - 19.5% 23.2% 47.0% - 33.5% 43.9% 40.5% 31.6% - 27.9% 6.0% Lake Forest Number 2000 39,161 10,913 998 143 5,647 113 102 1,630 58,707 Percent 2000 66.7% 18.6% 1.7% 0.2% 9.6% 0.2% 0.2% 2.8% 100.0% Number 2008 44,895 18,817 1,327 78 11,087 156 156 1,562 78,078 Percent 2008 57.5% 24.1 % 1.7% 0.1 % 14.2% 0.2% 0.2% 2.0% 100.0% # Change 5,734 1 7,904 329 -651 5,440 43 1 54 -68 1 19,371 % Change 14.6% 72.4% 33.0% - 45.4% 96.3% 38.2% 53.1% -4.2% 33.006 Newport Beach Number 2000 62,342 3,301 354 137 2,763 81 93 961 70,032 Percent 2000 89.0% 4.7% 0.5% 0.2% 3.9% 0.1% 0.1% 1.4% 100.0% Number 2008 NA NA NA NA NA NA NA NA 85,145 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 15,113 % Change NA NA NA NA NA NA NA NA 21.6% Orange Number 2000 70,292 41,434 1,798 393 11,898 268 162 2,576 128,821 Percent 2000 54.6% 32.2% 1.4% 0.3% 9.2% 0.2% 0.1% 2.0% 100.0% Number 2008 64,344 56,037 1,549 282 15,347 282 141 2,816 140,796 Percent 2008 45.7% 39.8% 1.1% 0.2% 10.9% 0.2% 0.1% 2.0% 100.0% # Change -5,948 14,603 -249 -111 3,449 14 -21 240 11,975 %Change -8.5% 35.2% - 13.9% - 28.3% 29.0% 5.1% -13.1% 9.3% 9.3% 272 Table A -9 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Rancho Santa Margarita* Number 2000 35,132 6,139 787 131 3,440 90 91 1,404 47,214 Percent 2000 74.4% 13.0% 1.7% 0.3% 7.3% 02% 0.2% 3.0% 100.0% Number 2008 35,989 7,386 744 149 4,263 0 0 1,041 49,572 Percent 2008 72.6% 14.9% 1.5% 0.3% 8.6% 0.0% 0.0% 2.1% 100.0% # Change 857 1,247 -43 18 823 -90 -91 -363 2,358 % Change 2.4% 20.3% -5.5% 13.5% 23.9% - 100.0% - 100.0% - 25.9% 5.0% Santa Ana Number 2000 41,984 257,097 4,309 886 29,412 993 273 3,023 337,977 Percent 2000 12.4% 76.1% 1.3% 0.3% 8.7% 0.3% 0.1% 0.9% 100.0% Number 2008 33,543 284,234 3,885 353 29,306 106 353 1,413 353,193 Percent 2008 9.5% 80.5% 1.1 % 0.1 % 8.3% 0.0% 0.1% 0.4% 100.0% # Change -8,441 27,137 -424 -533 -106 -887 80 -1,610 15,216 %Change -20.1% 10.6% -9.8% -60.1% -0.4% -89.3% 29.4% - 53.3% 4.5% Westminster Number 2000 31,962 19,138 764 293 33,511 393 101 2,045 88,207 Percent 2000 36.2% 21.7% 0.9% 0.3% 38.0% 0.4% 0.1% 2.3% 100.0% Number 2008 NA NA NA NA NA NA NA NA 92,854 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 4,647 % Change NA NA NA NA NA NA NA NA 5.3% * Denotes 2006 -2008 ACS 3 -Year Estimate Data Source: Census 2000, Summary File 1, Table P4 Hispanic or Latino by Race, Not Hispanic or Latino. 2008 American Community Survey (ACS) 1 Year Estimates, Select Demographic Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates Note: The ACS data was used for determining the percent breakdown for the population, which was then applied to a mid year -2008 estimate of DOF population estimates. 273 Table A -10 Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban County Cities city Year/Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Aliso Viejo Number 2000 28,599 4,680 790 107 4,367 78 102 1,443 40,166 Percent 2000 71.2% 11.7% 2.0% 0.3% 10.9% 0.2% 0.3% 3.6% 100.0% Number 2008 27,833 8,718 1,544 91 6,039 0 136 1,044 45,404 Percent 2008 61.3% 19.2% 3.4% 0.2% 13.3% 0.0% 0.3% 2.3% 100.0% # Change -766 4,038 754 -16 1,672 -78 34 -399 5,238 % Change -2.7% 86.3% 95.4% -15.1% 38.3% - 100.0% 33.5% -27.6% 13.0% Brea Number 2000 23,541 7,205 409 111 3,184 71 57 832 35,410 Percent 2000 66.5% 20.3% 1.2% 0.3% 9.0% 0.2% 0.2% 2.3% 100.0% Number 2008 23,319 8,320 640 80 6,440 40 160 1,000 39,998 Percent 2008 58.3% 20.8% 1.6% 0.2% 16.1% 0.1% 0.4% 2.5% 100.0% # Change -222 1,115 231 -31 3,256 -31 103 168 4,588 % Change -0.9% 15.5% 56.5% -27.9% 102.3% - 43.7% 180.7% 20.2% 13.0% Cypress Number 2000 26,400 7,235 1,251 176 9,564 164 112 1,327 46,229 Percent 2000 57.1% 15.7% 2.7% 0.4% 20.7% 0.4% 0.2% 2.9% 100.0% Number 2008 1 24,2721 8,305 1 1,137 1 198 1 13,842 1 346 1 99 1 1,236 1 49,434 Percent 2008 1 49.1% 1 16.8% 1 2.3% 1 0.4% 1 28.0% 1 0.7% 1 0.2% 1 2.5% 1 100.0% # Change 1 -2,1281 1,070 1 -114 1 22 1 4,278 1 182 1 -13 1 -91 1 3,205 % Change 1 -8.1% 1 14.8% 1 -9.1% 1 12.4% 1 44.7% 1 111.0% 1 -11.7% 1 -6.9% 1 6.9% 27.4. Table A -10 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban Count I Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Dana Point Number 2000 27,658 5,440 252 123 874 31 76 656 35,110 Percent 2000 78.8% 15.5% 0.7% 0.4% 2.5% 0.1% 0.2% 1.9% 100.0% Number 2008 28,940 5,131 406 111 923 37 664 701 36,913 Percent 2008 78.4% 13.9% 1.1% 0.3% 2.5% 0.1% 1.8% 1.9% 100.0% # Change 1,282 -309 154 -12 49 6 588 45 1,803 % Change 4.6% -5.7% 61.1% - 10.0% 5.6% 19.1% 774.3% 6.9% 5.1% Laguna Beach Number 2000 20,921 1,570 183 59 486 19 36 453 23,727 Percent 2000 88.2% 6.6% 0.8% 0.2% 2.0% 0.1% 0.2% 1.9% 100.0% Number 2008 NA NA NA NA NA NA NA NA 25,087 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 1,360 % Change NA NA NA NA NA NA NA NA 5.7% Laguna Hills Number 2000 21,471 5,113 404 77 3,153 45 73 842 31,178 Percent 2000 68.9% 16.4% 1.3% 0.2% 10.1% 0.1% 0.2% 2.7% 100.0% Number 2008 21,391 7,230 700 33 2,899 100 133 833 33,319 Percent 2008 64.2% 21.7% 2.1% 0.1% 8.7% 0.3% 0.4% 2.5% 100.0% # Change -80 2,117 296 -44 -254 55 60 -9 2,141 % Change -0.4% 41.4% 73.2% - 56.7% -8.1% 122.1% 82.6% -1.1% 6.9% Los Alamitos Number 2000 7,836 1,848 358 31 1,090 35 18 320 11,536 Percent 2000 67.9% 16.0% 3.1% 0.3% 9.4% 0.3% 0.2% 2.8% 100.0% Number 2008 NA NA NA NA NA NA NA NA 12,165 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 629 % Change NA NA NA NA NA NA NA NA 5.5% 275 Table A -10 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban Count I Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total La Palma Number 2000 5,592 1,736 696 37 6,874 43 35 395 15,408 Percent 2000 36.3% 11.3% 4.5% 0.2% 44.6% 0.3% 0.2% 2.6% 100.0% Number 2008 NA NA NA NA NA NA NA NA 16,139 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 731 % Change NA NA NA NA NA NA NA NA 4.7% Laguna Woods Number 2000 15,580 340 41 18 412 4 7 105 16,507 Percent 2000 94.4% 2.1% 0.2% 0.1% 2.5% 0.0% 0.0% 0.6% 100.0% Number 2008 NA NA NA NA NA NA NA NA 18,399 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 1,892 % Change NA NA NA NA NA NA NA NA 11.5% Placentia Number 2000 24,967 14,460 746 177 5,121 65 61 891 46,488 Percent 2000 53.7% 31.1% 1.6% 0.4% 11.0% 0.1% 0.1% 1.9% 100.0% Number 2008 23,225 19,664 671 103 6,813 361 103 671 51,612 Percent 2008 45.0% 38.1% 1.3% 0.2% 13.2% 0.7% 0.2% 1.3% 100.0% # Change -1,742 5,204 -75 -74 1,692 296 42 -220 5,124 % Change -7.0% 36.0% -10.1% 41.7% 33.0% 455.8% 69.2% -24.7% 11.0% Seal Beach Number 2000 20,372 1,554 329 54 1,363 37 21 427 24,157 Percent 2000 84.3% 6.4% 1.4% 0.2% 5.6% 0.2% 0.1% 1.8% 100.0% Number 2008 21,210 1,811 259 207 1,733 0 129 517 25,866 Percent 2008 82.0% 7.0% 1.0% 0.8% 6.7% 0.0% 0.5% 2.0% 100.0% # Change 838 257 -70 153 370 -37 108 90 1,709 % Change 4.1% 16.5% -21.4% 283.2% 27.1% - 100.0% 515.9% 21.2% 7.1% 270 Table A -10 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban County Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Stanton Number 2000 11,295 18,285 721 155 5,721 322 57 847 37,403 Percent 2000 30.2% 48.9% 1.9% 0.4% 15.3% 0.9% 0.2% 2.3% 100.0% Number 2008 9,459 19,743 1,021 157 8,007 236 196 432 39,251 Percent 2008 24.1% 50.3% 2.6% 0.4% 20.4% 0.6% 0.5% 1.1% 100.0% # Change -1,836 1,458 300 2 2,286 -86 139 -415 1,848 % Change -16.3% 8.0% 41.5% 1.3% 40.0% -26.9% 244.3% -49.0% 4.9% Villa Park Number 2000 4,691 354 41 22 769 2 4 116 5,999 Percent 2000 78.2% 5.9% 0.7% 0.4% 12.8% 0.0% 0.1% 1.9% 100.0% Number 2008 NA NA NA NA NA NA NA NA 6,248 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 249 % Change NA NA NA NA NA NA NA NA 4.2% Yorba Linda Number 2000 44,071 6,044 638 139 6,502 50 138 1,336 58,918 Percent 2000 74.8% 10.3% 1.1% 0.2% 11.0% 0.1% 0.2% 2.3% 100.0% Number 2008 46,676 8,301 1,361 613 9,390 14 476 1,225 68,056 Percent 2008 68.6% 12.2% 2.0% 0.9% 13.8% 0.0% 0.7% 1.8% 100.0% # Change 2,605 2,257 723 474 2,888 -36 338 -111 9,138 % Change 5.9% 37.3% 113.3% 340.7% 44.4% -72.8% 245.2% -8.3% 15.5% Source: Census 2000, Summary File 1, Table P4 Hispanic or Latino by Race, Not Hispanic or Latino. 2008 American Community Survey (ACS) 3 -Year Estimates, Select Demographic Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates Note: The ACS data was used for determining the percent breakdown for the population, which was then applied to a mid year -2008 estimate of DOF population estimates. 277 Table A -11 Regional Analysis of Fair Housing Impediments Household Type for Entitlement Cities - 2008 City Married Couple Families Percent Male Householder, No Wife Present Percent Female Householder, No Husband Present Percent Non - Family Households Percent Total Households Anaheim 54,620 55.1% 4,758 4.8% 16,059 16.2% 23,692 23.9% 99,129 Buena Park 13,353 56.0% 1,478 6.2% 4,220 17.7% 4,793 20.1% 23,844 Fountain Valley* 11,571 62.5% 926 5.0% 1,463 7.9% 4,554 24.6% 18,514 Fullerton 23,485 51.2% 1,743 3.8% 5,045 11.0% 15,595 34.0% 45,868 Garden Grove 25,337 54.5% 4,463 9.6% 6,787 14.6% 9,902 21.3% 46,489 Huntington Beach 39,044 51.4% 3,950 5.2% 7,900 10.4% 25,067 33.0% 75,961 Irvine 38,977 52.1% 3,666 4.9% 6,509 8.7% 25,661 34.3% 74,813 Lake Forest 14,604 56.8% 1,800 7.0% 1,491 5.8% 7,816 30.4% 25,711 La Habra* 10,009 51.5% 1,458 7.5% 2,974 15.3% 4,995 25.7% 19,436 Newport Beach 18,244 47.5% 922 2.4% 2,612 6.8% 16,631 43.3% 38,409 Orange 24,767 57.1% 2,429 5.6% 4,337 10.0% 11,841 27.3% 43,374 Rancho Santa Margarita 10,279 62.2% 793 4.8% 1,405 8.5% 4,049 24.5% 16,526 Santa Ana 39,089 52.8% 8,292 11.2% 12,659 17.1% 13,992 18.9% 74,032 Westminster 15,542 57.8% 1,775 6.6% 3,092 11.5% 6,480 24.1% 26,889 Total 338,921 53.9% 38,453 6.1% 76,553 12.2% 175,068 27.8% 628,995 *Denotes data from the 2006 -2008 ACS estimate Source: 2008 American Community Survey (ACS) 1 -Year Estimates, Select Demographic Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates 272 Table A -12 Regional Analysis of Fair Housing Impediments Household Type for Urban County Cites - 2008 City Married Couple Families Percent Male Householder, No Wife Present Percent Female Householder, No Husband Present Percent Non - Family Households Percent Total Households Aliso Viejo 8,810 50.1% 545 3.1% 1,460 8.3% 6,770 38.5% 17,585 Brea 7,867 55.0% 544 3.8% 1,545 10.8% 4,348 30.4% 14,303 Cypress 9,849 60.7% 681 4.2% 2,369 14.6% 3,326 20.5% 16,225 Dana Point 7,690 52.3% 573 3.9% 1,338 9.1% 5,102 34.7% 14,704 Laguna Beach 5,038 42.8% 530 4.5% 612 5.2% 5,592 47.5% 11,772 Laguna Hills 6,873 63.6% 378 3.5% 1,092 10.1% 2,464 22.8% 10,807 Laguna Woods NA NA NA NA NA NA NA NA 12,591 La Palma NA NA NA NA NA NA NA NA 5,043 Los Alamitos NA NA NA NA NA NA NA NA 4,339 Placentia 9,274 57.3% 906 5.6% 2,023 12.5% 3,982 24.6% 16,185 Seal Beach 4,930 36.8% 121 0.9% 710 5.3% 7,636 57.0% 13,397 Stanton 5,543 50.7% 492 4.5% 1,727 15.8% 3,171 29.0% 10,933 Villa Park NA NA NA NA NA NA NA NA 1,964 Yorba Linda 15,349 71.2% 884 4.1% 1,660 7.7% 3,665 17.0% 21,558 Total' 81,224 55.1% 5,654 3.8% 14,535 9.9% 46,056 31.2% 147,469 'Totals are only for the cities that have ACS data and exclude the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park all of which have populations of less than 20,000. The ACS 3 -Year estimates are available for cities having populations between 20,000 and 65,000 persons. The percentages are based on the total for the known cities (147,469). Source: 2006 -2008 American Community Survey (ACS) 3 -Year Estimates, Select Social Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda 8 Associates Table A -13 Regional Analysis of Fair Housing Impediments Households with Children under 18 Years of Age by Type of Household Entitlement Cities - 2008 City Married Couple Families Percent of All Households Male Householder, No Wife Present Percent of All Households Female Householder, No Husband Present Percent of All Households Total Percent of All Households Total Households Anaheim 31,226 31.5% 1,883 1.9% 8,723 8.8% 41,832 42.2% 99,129 Buena Park 9,347 39.2% 501 2.1% 1,836 7.7% 11,684 49.0% 23,844 Fountain Vale y* 4,684 25.3% 296 1.6% 574 3.1% 5,554 30.0% 18,514 Fullerton 10,962 23.9% 871 1.9% 2,477 5.4% 14,311 31.2% 45,868 Garden Grove 14,179 30.5% 1,162 2.5% 3,115 6.7% 18,456 39.7% 46,489 Huntington Beach 16,256 21.4% 1,367 1.8% 3,874 5.1% 21,497 28.3% 75,961 Irvine 19,751 26.4% 2,020 2.7% 2,693 3.6% 24,464 32.7% 74,813 Lake Forest 7,251 28.2% 823 3.2% 694 2.7% 8,767 34.1% 25,711 La Habra* 5,073 26.1% 603 3.1% 1,769 9.1% 7,444 38.3% 19,436 Newport Beach 8,143 21.2% 346 0.9% 1,383 3.6% 9,871 25.7% 38,409 Orange 11,537 26.6% 954 2.2% 2,472 5.7% 14,964 34.5% 43,374 Rancho Santa Margarita* 6,363 38.5% 331 2.0% 826 5.0% 7,520 45.5% 16,526 Santa Ana 25,467 34.4% 5,108 6.9% 7,403 10.0% 37,978 51.3% 74,032 Westminster 7,529 28.0% 323 1.2% 1,533 5.7% 9,384 34.9% 26,889 Total 177,768 28.0% 16,588 2.7% 39,372 6.3% 233,726 36.9% 628,995 *Denotes data from 3 -Year 2006 -2008 estimate Source: 2008 American Community Survey (ACS) 1 -Year Estimates, Select Demographic Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1. 2009 Table construction by Castaneda & Associates v� Table A -14 Regional Analysis of Fair Housing Impediments Households with Children under 18 Years of Age by Type of Household Urban County Cities - 2008 city Married Couple Families Percent of All Households Male Householder, No Wife Present Percent of All Households Female Householder, No Husband Present Percent of All Households Total Percent of All Households Total Households Aliso Viejo 4,977 28.3% 264 1.5% 844 4.8% 6,084 34.6% 17,585 Brea 3,561 24.9% 200 1.4% 744 5.2% 4,505 31.5% 14,303 Cypress 4,738 29.2% 373 2.3% 925 5.7% 6,036 37.2% 16,225 Dana Point 2,603 17.7% 221 1.5% 779 5.3% 3,602 24.5% 14,704 Laguna Beach 1,460 12.4% 224 1.9% 341 2.9% 2,025 17.2% 11,772 Laguna Hills 2,885 26.7% 195 1.8% 659 6.1% 3,739 34.6% 10,807 Laguna Woods NA NA NA NA NA NA NA NA 12,591 La Palma NA NA NA NA NA NA NA NA 5,043 Los Alamitos NA NA NA NA NA NA NA NA 4,339 Placentia 4,645 28.7% 469 2.9% 939 5.8% 6,053 37.4% 16,185 Seal Beach 1,233 9.2% 67 0.5% 281 2.1% 1,581 11.8% 13,397 Stanton 3,160 28.9% 219 2.0% 951 8.7% 4,329 39.6% 10,933 Villa Park NA NA NA NA NA NA NA NA 1,964 Yorba Linda 7,114 33.0% 366 1.7% 755 3.5% 8,235 38.2% 21,558 Total 36,375 24.7% 2,597 1.8% 7,218 4.9% 46,191 31.3% 147,469 'Totals are only for the cities that have ACS data and exclude the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park all of which have populations of less than 20,000. The ACS 3 -Year estimates are available for cities having populations between 20,000 and 65,000 persons. The percentages are based on the total for the known cities (147,469). Source: 2006 -2008 American Community Survey (ACS) 3 -Year Estimates, Select Social Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates 2g2 Table A -15 Regional Analysis of Fair Housing Impediments Poverty Rates for Female Householders And Presence of Children for Entitlement Cities - 2008 City With Related Children <5 Years With Related Children <18 Years All Female Householder Families Anaheim 20.6% 27.0% 19.8% Buena Park 0.0% 15.1% 10.2% Fountain Valley* 0.0% 13.3% 8.0% Fullerton 16.1% 317% 23.1% Garden Grove 36.2% 28.7% 22.5% Huntington Beach 15.1% 8.5% 10.2% Irvine 11.6% 9.9% 6.8% La Habra* 52.0% 27.9% 21.3% Lake Forest N/A N/A N/A Newport Beach N/A 5.3% 13.7% Orange 14.4% 14.5% 11.4% Rancho Santa Margarita* 44.1% 7.0% 4.6% Santa Ana 25.7% 31.4% 23.8% Westminster 0.0% 17.8% 10.6% *Denotes data from 3 -Year 2006 -2008 ACS estimate Source: 2008 American Community Survey (ACS) 1 -Year Estimates, Select Income Characteristics Table construction by Castaneda & Associates 222 Table A -16 Regional Analysis of Fair Housing Impediments Poverty Rates for Female Householders And Presence of Children for Urban County Cities — 2008 City With Related Children <5 Years With Related Children <18 Years All Female Householder Families Aliso Viejo 12.3% 18.6% 12.8% Brea 100.0% 18.7% 9.6% Cypress 0.0% 9.2% 6.1% Dana Point 23.6% 10.2% 6.8% Laguna Beach N/A 15.3% 12.2% Laguna Hills 0.0% 30.6% 20.4% Laguna Woods N/A N/A N/A La Palma N/A N/A N/A Los Alamitos N/A N/A N/A Placentia 59.3% 32.4% 21.0% Seal Beach N/A N/A N/A Stanton 28.7% 51.7% 33.3% Villa Park N/A N/A N/A Yorba Linda 20.7% 22.2% 12.5% Source: 2008 American Community Survey (ACS) 3 -Year Estimates, Select Income Characteristics Table construction by Castaneda & Associates 22S Table A -17 Regional Analysis of Fair Housing Impediments Marital Status for Entitlement Cities - 2008 City Married Households Percent Not Married Households Percent Total Households Anaheim 54,620 55.1% 44,509 44.9% 99,129 Buena Park 13,353 56.0% 10,491 44.0% 23,844 Fountain Valley* 11,553 62.4% 6,961 37.6% 18,514 Fullerton 23,439 51.1% 22,429 48.9% 45,868 Garden Grove 25,337 54.5% 21,152 45.5% 46,489 Huntington Beach 39,044 51.4% 36,917 48.6% 75,961 Irvine 39,052 52.2% 35,761 47.8% 74,813 La Habra* 10,010 51.5% 9,426 48.5% 19,436 Lake Forest 14,578 56.7% 11,133 43.3% 25,711 Newport Beach 18,244 47.5% 20,165 52.5% 38,409 Orange 24,810 57.2% 18,564 42.8% 43,374 Rancho Santa Margarita* 10,296 62.3% 6,230 37.7% 16,526 Santa Ana 39,089 52.8% 34,943 47.2% 74,032 Westminster 15,542 57.8% 11,347 42.2% 26,889 Total 338,965 53.9% 290,030 46.1% 628,995 *Denotes data from 3 -Year 2006 -2008 ACS estimate Source: 2008 American Community Survey (ACS) 1 -Year Estimates, Select Social Characteristics. California Department of Finance (DOF) Mid -Point Estimate for 2008 Occupied Housing Units (Households) for January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates r Table A -18 Regional Analysis of Fair Housing Impediments Marital Status for Urban County - 2008 city Married Households Percent Not Married Households Percent Total Households Aliso Viejo 8,810 50.1% 8,775 49.9% 17,585 Brea 7,852 54.9% 6,451 45.1% 14,303 Cypress 9,865 60.8% 6,360 39.2% 16,225 Dana Point 7,675 52.2% 7,029 47.8% 14,704 Laguna Beach 5,038 42.8% 6,734 57.2% 11,772 Laguna Hills 6,862 63.5% 3,945 36.5% 10,807 Laguna Woods N/A N/A N/A N/A 12,591 La Palma N/A N/A N/A N/A 5,043 Los Alamitos N/A N/A N/A N/A 4,339 Placentia 9,290 57.4% 6,895 42.6% 16,185 Seal Beach 4,930 36.8% 8,467 63.2% 13,397 Stanton 5,543 50.7% 5,390 49.3% 10,933 Villa Park N/A N/A N/A N/A 1,964 Yorba Linda 15,371 71.3% 6,187 28.7% 21,558 Total 1 81,238 55.1% 66,231 44.9% 147,469 'Totals are only for the cities that have ACS data and exclude the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park all of which have populations of less than 20,000. The ACS 3 -Year estimates are available for cities having populations between 20,000 and 65,000 persons. The percentages are based on the total for the known cities (147,469). Source: 2008 American Community Survey (ACS) 3 -Year Estimates, Select Social Characteristics. California Department of Finance (DOF) Mid -Point Estimate for 2008 Occupied Housing Units (Households) for January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates 225 This Page Intentionally Left Blank Technical Appendix 6 Minority Population by Census Tract 22 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 525.18 0 0 0 0 0 0 0 3 3 3 100.00% 745.01 82 7,115 5 21 842 13 7 148 8,233 8,151 99.00% 748.06 80 5,801 161 2 74 14 13 9 6,154 6,074 98.70% 749.02 102 7,080 15 4 43 2 0 15 7,261 7,159 98.60% 748.01 107 5,722 244 30 130 20 1 13 6,267 6,160 98.29% 749.01 185 9,533 50 30 272 22 8 29 10,129 9,944 98.17 %° 747.01 198 8,588 72 6 135 34 0 42 9,075 8,877 97.82% 748.05 156 6,298 76 15 100 27 14 24 6,710 6,554 97.68% 992.49 121 3,472 26 8 770 21 0 25 4,443 4,322 97.28% 752.01 162 5,426 71 16 240 1 2 30 5,948 5,786 97.28% 745.02 178 5,637 7 19 361 32 0 46 6,280 6,102 97.17% 746.02 284 9,222 27 5 76 14 3 18 9,649 9,365 97.06% 891.05 232 6,133 18 22 635 11 5 25 7,081 6,849 96.72% 743.00 147 4,204 5 19 15 3 0 22 4,415 4,268 96.67% 750.03 299 7,773 49 42 25 0 16 28 8,232 7,933 96.37% 747.02 270 6,328 9 19 18 15 4 17 6,680 6,410 95.96% 750.04 247 5,444 29 0 44 4 2 9 5,779 5,532 95.73% 750.02 426 8,639 86 20 395 2 3 39 9,610 9,184 95.57% 744.03 298 5,861 18 19 153 4 0 21 6,374 6,076 95.32% 741.09 200 3,486 13 25 270 15 1 22 4,032 3,832 95.04% 740.03 125 2,266 25 8 39 4 1 16 2,484 2,359 94.97% 742.00 504 8,899 23 16 118 16 8 27 9,611 9,107 94.76% 752.02 322 5,519 98 25 139 0 11 23 6,137 5,815 94.75% 744.05 371 6,450 32 5 64 3 11 29 6,965 6,594 94.67% 741.08 313 4,515 40 13 331 37 0 38 5,287 4,974 94.08% 748.02 375 5,218 163 22 180 22 3 58 6,041 5,666 93.79% 741.02 524 5,996 110 19 696 30 9 44 7,428 6,904 92.95% 746.01 626 7,998 29 29 110 23 4 42 8,861 8,235 92.94% 891.04 449 4,384 37 10 1,130 19 0 45 6,074 5,625 92.61% 741.03 385 4,646 13 21 79 21 1 30 5,196 4,811 92.59% 744.07 573 6,765 100 6 161 8 6 68 7,687 7,114 92.55% v� Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 117.20 562 6,612 93 24 158 11 10 65 7,535 6,973 92.54% 865.02 510 5,995 34 24 77 1 1 36 6,678 6,168 92.36% 748.03 702 6,623 177 26 1,409 33 4 78 9,052 8,350 92.24% 744.06 311 3,402 31 14 55 8 1 16 3,838 3,527 91.90% 874.04 323 3,338 34 14 53 9 0 14 3,785 3,462 91.47% 890.01 794 3,704 54 30 2,835 46 1 110 7,574 6,780 89.52% 874.05 716 5,504 101 20 235 16 4 53 6,649 5,933 89.23% 890.04 812 4,865 68 5 1,596 34 6 53 7,439 6,627 89.08% 992.47 380 1,765 24 14 1,176 31 1 27 3,418 3,038 88.88% 992.48 608 3,297 73 3 1,300 44 1 39 5,365 4,757 88.67% 890.03 436 2,009 84 4 1,155 37 1 82 3,808 3,372 88.55% 875.04 1,038 6,342 106 35 587 22 0 118 8,248 7,210 87.42% 866.01 1,255 7,746 247 26 455 29 13 101 9,872 8,617 87.29% 878.03 862 4,415 135 16 808 89 12 105 6,442 5,580 86.62% 740.05 1,051 5,238 103 21 1,110 26 20 85 7,654 6,603 86.27% 874.03 531 3,059 21 9 92 2 0 21 3,735 3,204 85.78% 889.03 1,225 2,289 45 16 4,776 59 12 172 8,594 7,369 85.75% 873.00 1,502 7,428 216 23 716 16 3 137 10,041 8,539 85.04% 865.01 732 3,843 36 16 79 1 2 39 4,748 4,016 84.58% 1106.06 798 2,805 249 18 860 10 6 95 4,841 4,043 83.52% 864.05 1,150 5,067 100 8 288 10 17 59 6,699 5,549 82.83% 116.02 990 4,460 113 19 123 3 1 53 5,762 4,772 82.82 % 992.02 1,402 4,206 88 54 2,194 49 10 114 8,117 6,715 82.73 % 744.08 916 3,664 213 24 322 17 7 76 5,239 4,323 82.52% 879.02 1,072 3,586 81 11 1,019 86 1 127 5,983 4,911 82.08% 889.04 1,043 682 20 3 3,927 26 7 101 5,809 4,766 82.05% 864.04 1,121 4,347 57 24 585 5 6 72 6,217 5,096 81.97% 891.06 689 2,317 32 7 680 12 3 44 3,784 3,095 81.79% 891.02 1,282 4,232 69 23 1,182 57 4 105 6,954 5,672 81.56% 12.01 991 3,991 59 18 213 3 0 96 5,371 4,380 81.55% 753.02 852 3,440 86 3 181 6 6 34 4,608 3,756 81.51% Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 889.02 959 1,363 34 14 2,601 82 4 79 5,136 4,177 81.33% 88.01 1,547 1,593 108 17 4,701 53 8 179 8,206 6,659 81.15% 741.11 1,135 3,579 153 12 938 15 6 84 5,922 4,787 80.83% 117.14 58 227 0 3 9 0 0 5 302 244 80.79% 637.01 1,296 5,028 60 11 189 20 12 76 6,692 5,396 80.63% 875.01 1,214 4,135 79 8 442 3 4 65 5,950 4,736 79.60% 889.05 1,028 835 30 13 2,991 10 1 72 4,980 3,952 79.36% 755.14 824 2,430 127 15 424 24 5 74 3,923 3,099 79.00% 755.15 1,588 4,325 227 24 1,129 16 19 154 7,482 5,894 78.78% 1105.00 1,843 4,663 417 40 1,382 61 16 177 8,599 6,756 78.57% 762.04 1,150 3,716 28 15 393 4 1 53 5,360 4,210 78.54% 751.00 2,250 7,416 258 13 336 12 11 126 10,422 8,172 78.41% 998.03 1,165 1,397 33 13 2,671 9 6 87 5,381 4,216 7835% 871.02 1,279 2,816 311 11 1,237 44 5 159 5,862 4,583 78.18% 891.07 1,251 2,753 48 13 1,522 34 11 78 5,710 4,459 78.09% 1106.03 1,889 4,535 434 41 1,441 28 16 189 8,573 6,684 77.97% 636.05 1,246 4,149 50 11 93 1 3 68 5,621 4,375 77.83% 116.01 1,840 5,322 249 37 625 11 6 202 8,292 6,452 77.81% 741.10 849 1,255 89 4 1,549 9 1 70 3,826 2,977 77.81% 761.03 1,918 4,276 179 51 1,991 66 8 150 8,639 6,721 77.80% 878.06 1,203 3,153 92 20 733 53 8 145 5,407 4,204 77.75% 889.01 1,530 1,422 94 15 3,510 24 6 162 6,763 5,233 77.38% 887.01 1,433 1,987 61 22 2,635 41 2 133 6,314 4,881 77.30% 13.04 912 2,798 59 16 105 10 0 45 3,945 3,033 76.88% 994.02 2,055 5,973 60 39 468 3 2 126 8,726 6,671 76.45% 638.08 1,598 4,682 67 13 221 74 13 85 6,753 5,155 76.34% 888.02 1,309 1,656 72 5 2,312 28 2 110 5,494 4,185 76.17% 887.02 1,305 1,409 16 8 2,549 21 9 142 5,459 4,154 76.09% 740.06 1,354 3,142 171 22 657 20 9 147 5,522 4,168 75.48% 866.02 1,521 3,720 226 23 538 22 8 119 6,177 4,656 75.38% 867.02 1,645 3,741 289 7 663 51 13 237 6,646 5,001 75.25% 29 D Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 885.02 1,252 2,563 54 14 1,003 42 6 89 5,023 3,771 75.07% 14.04 939 2,557 40 25 122 5 4 75 3,767 2,828 75.07% 12.02 843 2,360 25 13 72 8 4 42 3,367 2,524 74.96% 998.02 1,020 1,292 30 30 1,556 5 1 123 4,057 3,037 74.86% 875.03 1,805 4,467 143 20 520 32 4 119 7,110 5,305 74.61% 992.03 1,572 1,191 47 12 3,195 37 4 112 6,170 4,598 74.52% 884.02 1,248 2,597 80 29 815 58 4 65 4,896 3,648 74.51% 884.03 1,664 3,473 178 25 992 30 5 147 6,514 4,850 74.46% 218.13 11 28 0 0 0 0 0 4 43 32 74.42% 886.01 1,468 1,889 63 14 2,163 32 4 99 5,732 4,264 74.39% 86101 1,801 4,482 68 25 458 6 8 82 6,930 5,129 74.01% 885.01 1,712 3,235 71 23 1,368 43 16 116 6,584 4,872 74.00% 881.07 1,557 1,316 39 35 2,699 9 13 198 5,866 4,309 73.46% 996.01 1,955 2,724 55 9 2,415 37 4 137 7,336 5,381 73.35% 423.12 2,256 5,919 20 68 73 2 1 76 8,415 6,159 73.19% 740.04 1,986 3,535 259 7 1,272 34 17 129 7,239 5,253 72.57% 999.04 1,871 2,069 56 28 2,604 35 10 128 6,801 4,930 72.49% 117.21 1,283 2,854 100 32 276 13 2 94 4,654 3,371 72.43% 879.01 909 1,579 54 16 632 21 3 58 3,272 2,363 72.22% 997.01 1,622 1,149 39 20 2,840 19 3 144 5,836 4,214 72.21% 874.01 859 1,999 40 11 84 12 2 51 3,058 2,199 71.91% 1101.16 1,369 468 200 2 2,677 21 12 99 4,848 3,479 71.76% 877.03 1,751 2,855 110 34 1,225 62 7 150 6,194 4,443 71.73% 871.06 1,422 2,865 83 42 515 12 2 49 4,990 3,568 71.50% 1106.05 1,952 520 62 7 4,122 2 12 110 6,787 4,835 71.24% 18.01 1,492 2,394 292 27 774 6 14 122 5,121 3,629 70.87% 219.13 2,506 4,907 61 28 834 24 12 110 8,482 5,976 70.46% 999.03 1,659 2,036 32 24 1,701 52 12 92 5,608 3,949 70.42% 753.01 1,576 3,041 145 21 405 13 4 77 5,282 3,706 70.16% 876.01 1,543 2,736 101 18 629 5 12 113 5,157 3,614 70.08% 755.12 1,070 1,477 95 4 730 14 3 117 3,510 2,440 69.52% : 92 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 17.07 1,906 604 96 6 3,437 9 3 131 6,192 4,286 69.22% 992.23 1,623 903 68 18 2,432 37 6 135 5,222 3,599 68.92% 1104.02 1,649 2,636 141 11 660 43 10 149 5,299 3,650 68.88% 878.05 2,165 3,417 131 25 819 61 10 169 6,797 4,632 68.15% 13.03 1,861 3,460 66 14 248 3 11 87 5,750 3,889 67.63% 18.02 2,398 3,825 246 27 658 34 18 194 7,400 5,002 67.59% 864.02 1,731 2,991 67 23 402 25 8 89 5,336 3,605 67.56% 117.22 1,021 1,662 67 13 334 1 0 38 3,136 2,115 67.44% 871.01 1,337 1,267 181 13 1,094 15 15 165 4,087 2,750 67.29% 998.01 1,825 1,613 65 26 1,826 66 3 140 5,564 3,739 67.20% 868.02 1,789 2,326 173 16 918 15 5 117 5,359 3,570 66.62% 870.01 1,819 2,478 207 35 715 35 3 111 5,403 3,584 66.33% 1101.18 944 203 115 1 1,441 1 8 78 2,791 1,847 66.18% 869.01 3,053 3,859 366 27 1,219 183 22 249 8,978 5,925 65.99% 111.02 1,560 2,213 109 16 512 11 7 100 4,528 2,968 65.55% 878.02 2,330 2,945 209 28 1,008 43 8 154 6,725 4,395 65.35% 992.04 1,506 405 37 4 2,280 28 8 74 4,342 2,836 65.32% 626.26 928 200 35 2 1,356 3 12 136 2,672 1,744 65.27% 867.01 2,991 3,965 183 26 1,220 14 16 183 8,598 5,607 65.21% 886.02 1,569 1,402 66 30 1,307 28 4 73 4,479 2,910 64.97% 872.00 2,605 3,874 205 33 485 8 10 151 7,371 4,766 64.66% 997.02 2,922 1,904 82 16 3,074 12 5 191 8,206 5,284 64.39 % 761.02 2,484 2,750 290 21 1,211 28 7 133 6,924 4,440 64.12 % 864.06 1,460 1,923 88 24 412 11 10 91 4,019 2,559 63.67% 1103.02 2,193 2,255 87 20 1,188 31 11 159 5,944 3,751 63.11% 1101.15 1,311 417 171 17 1,537 2 3 85 3,543 2,232 63.00% 524.04 358 500 32 12 37 7 2 19 967 609 62.98% 761.01 1,963 2,658 46 10 452 15 7 113 5,264 3,301 62.71% 869.03 2,254 2,348 185 21 930 93 5 178 6,014 3,760 62.52% 117.11 2,713 3,427 182 19 684 12 20 169 7,226 4,513 62.46% 995.02 1 2481 1391 1651 61 691 91 21 181 6561 4081 62.20% �9 � Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 871.05 1,712 1,729 117 13 776 37 5 118 4,507 2,795 62.01% 876.02 2,802 3,093 118 17 1,107 17 12 188 7,354 4,552 61.90% 754.03 2,403 3,199 163 23 364 28 6 112 6,298 3,895 61.85% 1106.07 1,315 1,074 91 21 789 15 15 114 3,434 2,119 61.71% 741.06 2,088 2,341 156 11 672 32 6 132 5,438 3,350 61.60% 755.13 1,809 1,731 205 23 744 30 9 118 4,669 2,860 61.26 % 992.27 2,362 1,265 128 10 2,082 25 15 175 6,062 3,700 61.04% 880.01 1,835 1,409 58 15 1,213 42 6 126 4,704 2,869 60.99% 754.04 2,406 3,074 164 25 313 28 10 123 6,143 3,737 60.83% 881.06 1,748 1,238 73 13 1,207 52 1 118 4,450 2,702 60.72% 881.05 1,540 1,035 38 10 1,193 13 5 82 3,916 2,376 60.67% 1102.02 3,055 2,169 353 29 1,810 54 21 266 7,757 4,702 60.62% 636.04 1,575 2,187 38 5 107 4 5 62 3,983 2,408 60.46% 117.12 1,875 2,003 95 19 580 5 11 99 4,687 2,812 60.00% 11.03 1,788 2,348 69 12 148 7 8 80 4,460 2,672 59.91% 626.14 4,648 1,199 253 10 4,929 12 69 419 11,539 6,891 59.72% 525.15 2,785 432 99 3 3,151 12 26 381 6,889 4,104 59.57% 992.22 1,908 655 25 4 1,934 16 12 117 4,671 2,763 59.15% 870.02 2,774 2,185 259 22 1,113 38 7 316 6,714 3,940 58.68% 758.11 1,383 1,674 20 6 176 4 3 45 3,311 1,928 58.23% 871.03 3,188 2,472 144 30 1,541 33 25 198 7,631 4,443 58.22% 877.04 1,983 1,580 82 16 933 15 9 116 4,734 2,751 58.11 % 884.01 2,061 1,660 37 10 1,011 31 3 90 4,903 2,842 57.96 % 882.03 1,962 1,245 125 14 1,160 16 6 120 4,648 2,686 57.79% 868.03 3,078 1,869 480 28 1,515 24 12 278 7,284 4,206 57.74% 639.04 2,125 1,840 30 21 704 186 7 96 5,009 2,884 57.58% 883.01 2,544 2,012 61 30 1,154 43 2 145 5,991 3,447 57.54% 864.07 2,530 2,445 229 8 589 18 7 131 5,957 3,427 57.53% 115.02 1,725 1,557 102 24 480 14 6 99 4,007 2,282 56.95% 755.07 2,328 1,789 252 26 733 22 21 201 5,372 3,044 56.660% 421.07 1 1,9691 2,3281 461 221 751 41 51 871 4,5361 2,5671 56.59% 293 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 637.02 2,435 2,668 59 20 263 21 6 120 5,592 3,157 56.46% 19.03 1,307 1,056 78 15 458 8 6 70 2,998 1,691 56.40% 992.26 1,716 350 32 5 1,664 22 13 123 3,925 2,209 56.28% 1103.01 2,951 1,328 306 42 1,810 28 22 238 6,725 3,774 56.12% 878.01 2,146 1,773 126 28 556 28 13 220 4,890 2,744 56.11% 1101.02 2,468 767 171 13 1,985 13 18 171 5,606 3,138 55.98% 758.16 1,581 1,322 127 9 402 9 3 124 3,577 1,996 55.80% 1106.04 3,237 983 225 16 2,493 8 9 263 7,234 3,997 55.25% 999.02 2,077 1,329 52 19 987 23 8 143 4,638 2,561 55.22% 881.04 2,072 1,286 80 30 987 24 15 119 4,613 2,541 55.08% 880.02 1,594 780 48 12 970 21 9 110 3,544 1,950 55.02% 111.01 1,796 1,700 83 11 308 4 5 65 3,972 2,176 54.78% 1103.04 2,213 880 92 18 1,465 22 4 170 4,864 2,651 54.50% 877.01 2,235 1,382 113 13 997 16 3 123 4,882 2,647 54.22% 114.03 2,589 2,530 83 27 297 12 7 110 5,655 3,066 54.22% 882.01 1,687 1,240 40 18 605 3 3 65 3,661 1,974 53.92% 117.16 1,916 885 67 11 1,172 4 4 72 4,131 2,215 53.62% 14.01 2,607 2,659 92 9 137 7 12 81 5,604 2,997 53.48% 14.02 2,426 2,342 72 13 189 13 28 112 5,195 2,769 53.30% 863.03 2,125 1,518 126 23 615 15 7 117 4,546 2,421 53.26% 1102.01 3,277 1,801 325 29 1,332 28 19 195 7,006 3,729 53.23% 863.04 2,135 1,716 96 20 448 6 1 110 4,532 2,397 52.89% 863.06 1,690 1,158 96 15 472 15 4 120 3,570 1,880 52.66% 525.27 3,646 595 123 11 2,962 3 14 327 7,681 4,035 52.53% 525.22 1,928 222 44 3 1,633 8 13 204 4,055 2,127 52.45% 758.07 2,219 1,905 44 17 364 4 5 82 4,640 2,421 52.18% 882.02 1,377 679 45 15 665 16 1 71 2,869 1,492 52.00% 19.01 1,298 1,011 43 3 272 12 8 56 2,703 1,405 51.98% 1103.03 2,339 1,020 186 14 1,125 22 5 151 4,862 2,523 51.89% 992.51 2,496 981 105 24 1,357 23 17 184 5,187 2,691 51.88% 626.11 1,810 335 76 4 1,296 11 10 197 3,739 1,929 51.59% :94 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 758.12 3,225 2,815 94 21 359 13 6 118 6,651 3,426 51.51% 525.21 2,214 491 185 8 1,373 7 7 254 4,539 2,325 51.22% 760.00 4,269 3,250 217 37 774 25 17 163 8,752 4,483 51.22% 869.02 2,409 1,197 202 18 866 63 7 159 4,921 2,512 51.05% 1101.10 2,804 1,602 194 22 857 50 15 160 5,704 2,900 50.84% 1104.01 2,294 1,434 115 20 644 22 6 99 4,634 2,340 50.50% 759.01 2,213 1,979 61 14 101 13 7 73 4,461 2,248 50.39% 868.01 1,545 847 70 5 552 19 4 72 3,114 1,569 50.39% 17.05 2,168 1,497 71 6 496 8 1 112 4,359 2,191 50.26% 19.02 1,463 944 72 13 344 12 16 63 2,927 1,464 50.02% 524.20 3,723 438 49 3 2,889 5 5 326 7,438 3,715 49.95% 525.23 2,061 273 48 4 1,510 4 18 172 4,090 2,029 49.61% 639.06 3,429 2,646 109 18 339 42 18 176 6,777 3,348 49.40% 626.27 1,599 234 23 4 1,158 7 4 124 3,153 1,554 49.29% 15.04 2,262 1,766 36 16 251 6 1 121 4,459 2,197 49.27% 115.04 2,710 943 291 25 1,114 21 14 217 5,335 2,625 49.20% 639.03 2,072 1,123 45 7 678 30 7 116 4,078 2,006 49.19% 754.01 1,803 1,549 46 15 73 3 3 46 3,538 1,735 49.04% 524.11 2,621 1,773 68 7 499 13 1 150 5,132 2,511 48.93% 17.04 1,493 252 43 7 1,018 5 6 66 2,890 1,397 48.34% 524.18 1,559 339 108 6 812 3 2 162 2,991 1,432 47.88% 758.06 3,044 2,127 81 29 398 17 3 140 5,839 2,795 47.87% 17.08 1,995 521 20 4 1,190 3 15 73 3,821 1,826 47.79% 997.03 2,421 561 54 15 1,419 9 2 133 4,614 2,193 47.53% 320.14 3,227 2,191 56 20 489 19 13 123 6,138 2,911 47.43% 883.02 2,750 1,101 72 14 1,188 18 16 71 5,230 2,480 47.42% 992.42 1,984 979 35 18 628 6 1 106 3,757 1,773 47.19% 755.05 1,856 1,161 95 21 257 20 15 88 3,513 1,657 47.17% 994.11 3,006 1,656 93 19 643 23 10 165 5,615 2,609 46.46% 1103.13 1,314 410 37 6 571 6 5 88 2,437 1,123 46.08% 762.05 3,377 2,203 77 29 347 15 5 175 6,228 2,851 45.78% 29 5 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 525.05 2,769 617 73 10 1,439 12 9 171 5,100 2,331 45.71% 218.21 2,857 1,302 138 32 775 10 12 132 5,258 2,401 45.66% 11.02 1,683 1,098 50 17 170 3 4 62 3,087 1,404 45.48% 881.01 1,190 584 48 8 261 13 12 51 2,167 977 45.09% 1101.04 3,197 900 231 26 1,236 20 10 145 5,765 2,568 44.54% 639.08 3,156 1,053 158 24 1,035 16 12 235 5,689 2,533 44.52% 753.03 1,913 1,299 55 6 108 5 3 41 3,430 1,517 44.23% 863.05 2,085 978 40 10 520 8 1 88 3,730 1,645 44.10% 525.26 2,458 478 46 3 1,259 6 3 141 4,394 1,936 44.06% 320.27 3,546 1,839 73 19 643 15 9 180 6,324 2,778 43.93% 219.14 2,376 1,456 62 9 240 3 2 78 4,226 1,850 43.78% 639.02 3,776 1,666 116 9 892 44 19 166 6,688 2,912 43.54% 759.02 3,865 2,339 147 22 287 23 13 129 6,825 2,960 4337% 13.01 3,518 2,123 105 20 300 12 11 94 6,183 2,665 43.10% 320.22 3,580 2,016 132 23 356 11 3 170 6,291 2,711 43.09% 757.01 3,671 2,088 150 18 373 3 6 133 6,442 2,771 43.01% 1101.09 2,669 668 122 21 1,032 10 27 131 4,680 2,011 42.97% 117.08 2,519 895 140 15 649 16 8 164 4,406 1,887 42.83% 219.24 2,511 491 97 4 1,123 0 6 158 4,390 1,879 42.80% 992.41 2,455 641 55 17 976 3 11 120 4,278 1,823 42.61% 741.07 2,598 1,128 122 14 498 24 7 135 4,526 1,928 42.60% 219.13 2,281 900 79 6 546 19 4 130 3,965 1,684 42.47 %° 525.25 4,383 529 70 12 2,334 5 12 272 7,617 3,234 42.46 %° 992.24 1,965 291 27 11 1,006 29 2 83 3,414 1,449 42.44% 994.10 2,438 829 80 28 646 32 7 174 4,234 1,796 42.42% 758.05 2,336 1,347 45 28 198 19 7 59 4,039 1,703 42.16% 1101.11 3,058 957 157 29 914 20 4 126 5,265 2,207 41.92% 992.12 2,952 1,122 64 26 721 19 9 148 5,061 2,109 41.67% 992.25 1,973 240 27 4 1,005 14 5 107 3,375 1,402 41.54% 1102.23 3,200 1,087 138 28 797 23 5 175 5,453 2,253 41.32% 525.17 2,838 369 100 5 1,249 7 25 224 4,817 1,979 41.08% 29 0 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 626.10 885 141 38 5 245 1 9 171 1,495 610 40.80% 992.29 3,396 721 76 24 1,260 15 9 218 5,719 2,323 40.62% 525.24 4,232 723 177 7 1,550 8 10 312 7,019 2,787 39.71% 110.00 3,926 1,596 129 23 680 14 4 130 6,502 2,576 39.62% 1101.07 3,479 785 247 11 1,019 14 14 152 5,721 2,242 39.19% 626.28 2,056 166 75 7 951 3 10 106 3,374 1,318 39.06% 626.25 2,912 1,470 56 7 248 1 2 67 4,763 1,851 38.86% 762.05 3,487 1,526 100 23 350 41 9 153 5,689 2,202 38.71% 525.28 2,087 236 46 2 887 1 1 140 3,400 1,313 38.62% 525.19 2,585 403 73 7 869 10 8 235 4,190 1,605 38.31% 992.50 1,821 312 49 19 619 4 11 115 2,950 1,129 38.27% 11.01 2,654 1,349 64 16 119 1 4 89 4,296 1,642 38.22% 626.41 2,167 935 63 11 239 2 11 75 3,503 1,336 38.14% 1100.14 2,904 816 222 15 533 25 11 147 4,673 1,769 37.86% 15.03 3,169 1,552 51 6 209 11 4 86 5,088 1,919 37.72% 423.13 4,501 2,363 52 24 138 11 7 127 7,223 2,722 37.69% 219.18 3,128 1,127 57 8 591 4 2 92 5,009 1,881 37.55% 758.14 2,188 218 27 5 957 4 7 94 3,500 1,312 37.49 % 755.04 2,553 1,027 66 17 262 7 17 122 4,071 1,518 37.29% 112.00 2,504 1,084 40 21 247 4 12 79 3,991 1,487 37.26% 524.19 1,759 161 23 6 769 7 3 74 2,802 1,043 37.22% 1100.10 2,887 512 54 12 953 18 10 148 4,594 1,707 37.16% 754.05 1,691 748 55 11 117 6 4 54 2,686 995 37.04% 219.23 3,705 635 137 5 1,174 10 12 186 5,864 2,159 36.82% 423.10 5,497 2,758 40 59 127 14 11 174 8,680 3,183 36.67% 320.55 2,680 966 64 15 343 9 13 133 4,223 1,543 36.54% 525.14 3,358 373 60 8 1,229 9 7 246 5,290 1,932 36.52% 758.13 3,269 933 31 20 762 3 1 120 5,139 1,870 36.39% 219.22 2,916 538 75 14 872 5 11 150 4,581 1,665 36.35% 992.33 2,131 259 7 8 794 9 6 133 3,347 1,216 36.33% 524.17 1 3,6861 3831 501 51 1,4691 101 161 1491 5,7681 2,0821 36.10% �9� Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 423.07 4,821 1,564 101 25 766 8 16 209 7,510 2,689 35.81% 525.02 3,738 895 92 13 907 6 11 157 5,819 2,081 35.76% 992.34 1,962 269 21 11 657 2 8 104 3,034 1,072 35.33% 320.28 2,054 646 42 7 275 7 7 128 3,166 1,112 35.12% 219.21 2,942 411 70 5 952 8 13 119 4,520 1,578 34.91% 638.07 3,439 903 177 1 570 7 7 133 5,237 1,798 34.33% 1101.14 3,179 782 74 19 582 11 9 181 4,837 1,658 34.28% 638.03 3,057 1,288 29 24 124 15 7 106 4,650 1,593 34.26% 758.15 3,228 1,168 50 9 322 4 4 125 4,910 1,682 34.26% 218.20 2,772 490 60 13 775 3 12 84 4,209 1,437 34.14% 756.07 3,747 509 75 9 1,152 10 9 172 5,683 1,936 34.07% 524.10 3,365 1,018 73 16 460 13 7 146 5,098 1,733 33.99% 1101.08 1,828 509 70 7 286 5 1 60 2,766 938 33.91% 524.23 3,337 812 140 14 555 10 11 168 5,047 1,710 33.88% 639.07 3,352 571 96 2 779 26 13 229 5,068 1,716 33.86% 993.05 4,926 1,887 42 44 350 23 10 158 7,440 2,514 33.79% 762.01 3,608 1,124 96 13 424 26 12 145 5,448 1,840 33.77% 524.16 2,701 848 56 23 327 1 2 116 4,074 1,373 33.70% 15.07 2,846 752 86 16 431 4 23 132 4,290 1,444 33.66% 996.02 2,140 495 35 13 394 11 13 110 3,211 1,071 33.35% 218.28 3,136 365 98 13 929 1 6 157 4,705 1,569 33.35% 423.20 3,703 1,008 94 15 524 13 18 170 5,545 1,842 33.22% 218.12 4,353 1,121 150 18 669 10 25 159 6,505 2,152 33.08 % 524.24 3,234 780 125 6 476 13 11 180 4,825 1,591 32.97% 219.15 2,732 383 53 10 758 3 5 130 4,074 1,342 32.94% 994.13 5,091 1,046 68 41 1,091 22 9 215 7,583 2,492 32.86% 525.13 3,922 433 55 14 1,219 10 2 174 5,829 1,907 32.72% 626.36 2,489 563 112 16 394 6 15 103 3,698 1,209 32.69% 999.05 2,208 559 40 19 344 9 2 91 3,272 1,064 32.52% 1101.06 2,440 542 58 13 414 31 13 100 3,611 1,171 32.43% 524.27 1 3,4591 5451 741 131 7801 111 71 2151 5,1041 1,645 32.23% Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 320.51 3,112 910 123 20 282 9 15 120 4,591 1,479 32.22% 113.00 2,556 787 57 19 236 4 2 98 3,759 1,203 32.00% 423.30 4,347 1,174 121 8 490 2 5 241 6,388 2,041 31.95% 524.25 3,926 743 134 15 773 4 11 149 5,755 1,829 31.78% 762.06 3,039 1,111 33 18 175 4 9 59 4,448 1,409 31.68% 636.01 2,510 875 20 24 104 21 2 106 3,662 1,152 31.46 % 626.12 4,963 427 58 1 1,473 11 17 251 7,201 2,238 31.08% 15.05 4,440 1,034 78 20 694 14 3 149 6,432 1,992 30.97% 218.14 4,833 857 123 27 973 2 12 170 6,997 2,164 30.93% 15.06 2,987 589 38 12 551 14 3 125 4,319 1,332 30.84% 1100.11 1,905 234 31 12 476 12 2 76 2,748 843 30.68% 218.27 2,431 322 74 6 571 1 7 92 3,504 1,073 30.62% 755.06 2,254 513 61 11 338 4 8 58 3,247 993 30.58% 524.26 3,247 533 73 8 630 17 8 153 4,669 1,422 30.46% 996.05 2,590 396 30 3 582 8 1 113 3,723 1,133 30.43% 218.26 1,789 323 50 5 291 4 9 98 2,569 780 30.36% 421.08 4,133 1,450 45 37 93 14 11 151 5,934 1,801 30.35% 992.15 3,805 892 39 25 500 19 12 167 5,459 1,654 30.30% 999.06 3,338 524 41 26 640 12 9 198 4,788 1,450 30.28% 525.20 2,452 190 18 3 739 3 8 104 3,517 1,065 30.28% 996.03 4,362 744 55 28 895 15 7 147 6,253 1,891 30.24% 626.39 4,369 736 142 16 701 10 7 260 6,241 1,872 30.00 % 762.08 3,347 896 62 15 333 9 6 105 4,773 1,426 29.88 % 320.29 3,267 668 91 5 439 13 20 143 4,646 1,379 29.68% 423.34 3,687 723 56 13 547 2 17 191 5,236 1,549 29.58% 992.31 4,010 392 33 10 1,080 7 2 159 5,693 1,683 29.56% 626.21 3,481 689 90 8 495 13 17 147 4,940 1,459 29.53% 320.15 4,746 967 115 12 691 10 17 172 6,730 1,984 29.48% 992.46 2,676 253 28 11 689 10 5 111 3,783 1,107 29.26% 218.29 3,820 332 64 9 1,067 2 5 93 5,392 1,572 29.15% 219.05 1 3,6961 6971 971 141 5971 41 31 1081 5,2161 1,5201 29.14% Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 626.38 3,114 447 97 15 540 11 4 161 4,389 1,275 29.05% 117.07 3,119 551 66 14 492 7 16 114 4,379 1,260 28.77% 320.39 4,944 1,038 55 9 644 15 5 226 6,936 1,992 28.72% 114.01 1,519 387 37 12 117 6 5 45 2,128 609 28.62% 992.32 3,888 390 26 11 915 17 14 181 5,442 1,554 28.56% 320.33 2,522 461 66 5 308 19 6 142 3,529 1,007 28.53% 423.35 2,698 448 65 11 356 17 11 169 3,775 1,077 28.53% 1101.01 3,250 583 64 13 496 15 5 120 4,546 1,296 28.51% 320.54 3,313 746 113 22 272 10 6 146 4,628 1,315 28.41% 218.07 2,737 682 57 16 235 3 5 87 3,822 1,085 28.39% 994.05 3,173 606 37 13 432 10 18 138 4,427 1,254 28.33% 525.11 4,218 298 44 7 1,110 1 22 178 5,878 1,660 28.24% 524.21 3,853 327 57 4 968 3 11 139 5,362 1,509 28.14% 14.03 2,354 675 10 12 124 18 4 75 3,272 918 28.06% 626.35 2,976 461 57 14 465 7 16 135 4,131 1,155 27.96% 320.56 3,892 654 88 15 545 3 7 195 5,399 1,507 27.91% 626.29 1,949 82 4 6 574 0 2 78 2,695 746 27.68% 320.38 5,048 536 98 10 1,045 19 16 204 6,976 1,928 27.64% 626.37 2,029 310 67 2 216 9 9 151 2,793 764 27.35% 117.15 4,157 620 60 17 721 9 8 119 5,711 1,554 27.21% 756.05 4,323 480 28 15 965 7 5 100 5,923 1,600 27.01% 320.50 3,758 720 74 18 361 26 16 170 5,143 1,385 26.93% 994.06 3,248 517 53 6 500 9 9 93 4,435 1,187 26.76 %° 626.40 2,606 376 54 14 353 17 7 121 3,548 942 26.55% 15.01 4,224 786 51 16 545 22 3 100 5,747 1,523 26.50% 626.34 4,104 455 76 9 723 4 9 198 5,578 1,474 26.43% 423.31 4,016 795 52 8 397 10 8 172 5,458 1,442 26.42% 219.20 3,929 422 64 14 769 6 9 125 5,338 1,409 26.40% 219.19 2,037 306 27 6 289 3 11 88 2,767 730 26.38% 320.47 2,295 435 64 16 196 4 0 106 3,116 821 26.35% 992.30 3,246 355 34 27 569 16 18 139 4,404 1,158 26.29% 300 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 218.23 2,363 351 39 5 323 4 11 109 3,205 842 26.27% 16.01 5,037 850 70 17 698 9 13 130 6,824 1,787 26.19% 524.22 3,008 406 109 3 441 8 10 88 4,073 1,065 26.15% 992.38 3,032 243 23 17 603 13 5 167 4,103 1,071 26.10% 992.35 3,465 621 34 25 398 5 4 134 4,686 1,221 26.06% 996.04 2,762 351 28 31 432 7 1 123 3,735 973 26.05% 631.01 2,094 432 49 22 171 7 1 55 2,831 737 26.03% 995.08 3,450 847 26 20 168 16 14 120 4,661 1,211 25.98% 218.25 2,495 304 38 8 436 0 13 76 3,370 875 25.96% 115.03 1,317 236 17 4 156 5 2 40 1,777 460 25.89% 1100.03 2,361 353 19 11 324 7 2 98 3,175 814 25.64% 626.33 2,715 309 63 4 420 8 12 117 3,648 933 25.58% 16.02 3,200 356 40 3 581 1 13 98 4,292 1,092 25.44% 218.02 4,878 1,119 52 19 301 5 30 134 6,538 1,660 25.39% 117.18 2,516 397 48 18 277 9 1 95 3,361 845 25.14% 525.06 1,901 136 26 4 383 7 8 73 2,538 637 25.10% 423.39 2,612 643 38 11 100 12 4 57 3,477 865 24.88% 117.10 2,654 401 43 3 358 3 4 60 3,526 872 24.73% 639.05 3,200 544 56 22 290 8 4 118 4,242 1,042 24.56% 992.16 3,076 460 28 21 360 8 2 121 4,076 1,000 24.53% 320.31 2,852 478 31 12 283 0 6 107 3,769 917 24.33% 218.24 2,199 259 14 5 385 7 11 25 2,905 706 24.30% 17.06 2,814 211 33 3 586 4 1 64 3,716 902 24.27% 756.06 4,734 404 45 16 906 4 9 125 6,243 1,509 24.17% 219.16 2,878 186 51 4 555 2 7 101 3,784 906 23.94% 423.33 3,398 240 33 9 606 4 25 151 4,466 1,068 23.91% 320.48 4,489 641 94 7 499 3 8 146 5,887 1,398 23.75% 994.16 3,502 580 44 19 296 7 2 142 4,592 1,090 23.74% 1100.12 3,726 316 65 5 648 11 9 96 4,876 1,150 23.58% 992.45 2,345 290 29 11 291 7 11 83 3,067 722 23.54% 320.49 6,175 733 167 16 737 16 21 211 8,076 1,901 23.54% 301 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 626.31 2,712 85 8 0 613 2 4 117 3,541 829 23.41% 320.53 6,004 900 135 29 518 12 6 235 7,839 1,835 23.41% 320.34 4,919 473 86 14 696 1 8 224 6,421 1,502 23.39% 423.29 3,492 602 38 17 287 6 8 108 4,558 1,066 23.39% 218.10 2,822 493 40 17 228 5 6 70 3,681 859 2134% 423.27 3,912 387 67 18 528 8 12 158 5,090 1,178 23.14% 423.36 3,507 366 33 7 476 6 22 144 4,561 1,054 23.11% 422.05 5,104 1,153 31 13 200 1 5 130 6,637 1,533 23.10% 626.30 1,272 58 8 1 278 1 5 30 1,653 381 23.05% 994.12 3,596 503 53 10 362 16 1$ 112 4,670 1,074 23.00% 320.20 4,631 745 52 11 374 8 21 167 6,009 1,378 22.93% 423.26 3,232 465 113 7 228 4 5 138 4,192 960 22.90% 992.39 3,099 243 20 16 517 11 8 99 4,013 914 22.78% 320.30 2,957 456 26 9 260 5 4 110 3,827 870 22.73% 758.10 2,379 197 26 9 419 1 8 39 3,078 699 22.71% 1100.05 2,443 313 26 10 257 5 5 100 3,159 716 22.67% 992.37 2,727 316 15 10 358 4 5 89 3,524 797 22.62% 218.17 2,845 428 53 2 235 10 13 87 3,673 828 22.54% 992.14 2,654 359 29 11 277 6 8 82 3,426 772 22.53% 1100.04 3,611 450 30 23 424 7 21 95 4,661 1,050 22.53% 632.02 2,722 595 11 16 72 7 10 77 3,510 788 22.45% 218.30 4,563 460 36 13 676 0 14 114 5,876 1,313 22.35% 626.43 2,622 134 6 4 508 0 2 93 3,369 747 22.17% 756.04 5,902 501 38 9 937 7 24 163 7,581 1,679 22.15% 626.47 3,281 510 39 7 297 1 0 71 4,206 925 21.99% 320.02 4,806 717 62 23 370 9 7 163 6,157 1,351 21.94% 423.15 4,635 657 87 18 358 7 18 153 5,933 1,298 21.88% 993.08 3,764 254 27 10 697 0 7 59 4,818 1,054 21.88% 638.02 2,261 354 16 11 147 11 10 84 2,894 633 21.87% 320.45 2,278 333 21 5 169 4 9 96 2,915 637 21.85% 524.28 4,998 641 101 14 425 8 13 191 6,391 1,393 21.80% 302 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 1100.15 2,766 409 45 9 191 5 4 107 3,536 770 21.78% 756.03 3,011 429 43 7 194 7 20 137 3,848 837 21.75% 994.08 2,494 350 18 15 211 8 5 83 3,184 690 21.67% 117.09 3,450 451 34 14 357 5 4 84 4,399 949 21.57% 524.08 5,003 537 62 10 568 5 9 180 6,374 1,371 21.51% 758.09 2,468 194 8 12 376 1 4 67 3,130 662 21.15% 638.06 2,889 411 26 17 185 18 12 98 3,656 767 20.98% 117.17 2,129 304 48 5 146 0 0 61 2,693 564 20.94% 421.14 2,953 558 31 14 121 6 1 50 3,734 781 20.92% 218.22 2,958 343 45 14 250 6 9 110 3,735 777 20.80% 320.41 855 152 11 7 34 1 3 16 1,079 224 20.76% 423.11 4,559 837 29 23 174 3 11 117 5,753 1,194 20.75% 757.02 2,576 391 15 4 191 7 2 61 3,247 671 20.67% 758.08 2,564 455 19 4 115 3 3 63 3,226 662 20.52% 423.19 2,769 190 20 6 424 0 2 71 3,482 713 20.48% 320.36 2,897 424 22 9 206 1 3 80 3,642 745 20.46% 994.17 3,155 316 34 9 338 5 3 99 3,959 804 20.31% 422.01 4,664 908 29 27 115 2 12 95 5,852 1,188 20.30% 994.15 4,380 300 9 10 619 4 2 170 5,494 1,114 20.28% 218.15 2,478 328 24 7 208 2 4 55 3,106 628 20.22% 992.40 4,127 415 26 18 395 19 12 150 5,162 1,035 20.05% 994.04 3,777 432 28 19 322 6 12 127 4,723 946 20.03 % 993.10 3,603 420 20 36 228 11 4 170 4,492 889 19.79 % 994.07 1,999 197 17 18 174 5 1 80 2,491 492 19.75% 423.25 2,901 263 31 1 320 3 6 90 3,615 714 19.75% 992.20 4,354 559 31 19 232 14 9 203 5,421 1,067 19.68% 993.06 4,767 641 24 37 255 12 24 171 5,931 1,164 19.63% 320.32 2,653 342 11 12 204 9 4 65 3,300 647 19.61% 219.12 2,706 176 15 4 379 2 0 78 3,360 654 19.46% 636.02 2,910 401 32 16 148 10 12 82 3,611 701 19.410% 524.15 1 3,3151 3241 651 71 2961 71 71 881 4,1091 7941 19.32% 303 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 114.02 1,839 239 15 2 121 2 11 48 2,277 438 19.24% 992.43 3,319 359 19 14 296 2 2 95 4,106 787 19.17% 320.42 4,961 582 57 16 327 16 9 167 6,135 1,174 19.14% 631.02 5,087 752 51 27 215 18 8 131 6,289 1,202 19.11% 423.37 3,121 241 39 4 331 4 7 88 3,835 714 18.62% 638.05 1,896 212 27 8 121 9 4 52 2,329 433 18.59% 993.07 1,940 221 27 15 116 10 3 45 2,377 437 18.38% 993.11 3,127 376 12 18 144 15 8 118 3,818 691 18,10% 995.12 2,266 260 25 6 128 7 7 67 2,766 500 18.08% 218.09 2,144 257 15 10 139 0 4 47 2,616 472 18.04% 320.12 3,032 350 43 9 184 3 11 63 3,695 663 17.94% 757.03 3,271 285 16 8 327 1 0 78 3,986 715 17.94% 421.09 4,128 462 55 17 232 12 2 118 5,026 898 17.87% 633.01 2,506 316 33 11 88 11 19 65 3,049 543 17.81% 219.17 2,770 261 18 8 252 0 5 52 3,366 596 17.71% 320.03 4,103 531 22 2 209 13 2 97 4,979 876 17.59% 1100.06 2,389 197 27 10 196 2 10 67 2,898 509 17.56% 626.45 3,987 166 19 11 546 4 8 83 4,824 837 17.35% 218.16 4,090 488 34 11 228 4 8 80 4,943 853 17.26% 1100.08 3,564 310 57 8 237 6 11 111 4,304 740 17.19% 995.14 4,826 290 23 5 538 5 22 112 5,821 995 17.09% 992.17 2,034 172 14 8 161 1 1 50 2,441 407 16.67% 320.40 2,409 205 9 5 213 1 1 47 2,890 481 16.64% 421.12 3,139 343 26 8 152 9 10 75 3,762 623 16.56% 320.23 2,285 318 7 15 58 2 7 43 2,735 450 16.45% 626.05 2,842 356 23 17 64 3 6 85 3,396 554 16.31% 320.13 2,959 293 39 9 137 14 4 73 3,528 569 16.13% 421.03 6,345 878 32 16 91 3 13 152 7,530 1,185 15.74% 320.35 2,057 138 28 10 116 3 7 68 2,427 370 15.25% 423.28 2,036 88 19 5 207 3 0 42 2,400 364 15.17% 1100.07 4,031 314 18 11 256 3 3 91 4,727 696 14.72% U001 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 320.43 3,659 174 28 2 274 0 7 143 4,287 628 14.65% 993.09 3,043 259 14 12 156 6 3 72 3,565 522 14.64% 636.03 5,362 511 69 20 191 12 5 93 6,263 901 14.39% 995.13 2,005 148 7 10 124 3 5 39 2,341 336 14.35% 423.32 4,784 302 43 5 333 5 8 102 5,582 798 14.30% 995.11 2,929 259 12 18 126 3 1 68 3,416 487 14.26% 422.03 6,374 633 45 14 207 10 4 126 7,413 1,039 14.02% 423.38 4,147 365 26 10 158 1 6 101 4,814 667 13.86% 423.17 3,125 204 23 6 191 1 16 57 3,623 498 13.75% 320.46 3,527 228 34 2 215 12 0 68 4,086 559 13.68% 421.13 3,875 340 6 20 146 7 7 82 4,483 608 13.56% 633.02 3,452 341 13 10 77 9 9 75 3,986 534 13.40% 630.10 5,632 391 32 15 309 2 24 90 6,495 863 13.29% 995.06 1,106 82 1 3 25 0 16 34 1,267 161 12.71% 320.52 2,908 231 11 6 120 5 3 46 3,330 422 12.67% 320.44 5,293 307 37 10 279 2 16 112 6,056 763 12.60% 626.44 5,737 278 39 11 398 6 6 83 6,558 821 12.52% 995.04 2,198 144 5 5 88 4 0 67 2,511 313 12.47% 626.32 3,555 262 31 10 104 3 9 84 4,058 503 12.40% 630.09 1,466 62 6 1 96 2 1 37 1,671 205 12.27% 992.44 3,377 187 12 19 178 2 3 68 3,846 469 12.19% 421.11 5,190 412 39 12 151 4 0 96 5,904 714 12.09% 630.07 5,214 234 31 4 352 4 2 87 5,928 714 12.04% 631.03 2,262 166 17 8 48 7 7 45 2,560 298 11.64% 423.23 4,168 305 40 20 74 2 25 83 4,717 549 11.64% 423.24 3,767 182 34 3 176 0 8 87 4,257 490 11.51% 635.00 5,480 373 35 10 169 11 8 105 6,191 711 11.48% 626.42 2,876 106 5 2 205 5 10 34 3,243 367 11.32% 630.08 770 25 7 1 45 1 1 18 868 98 11.29% 626.20 4,506 325 30 14 98 3 5 97 5,078 572 11.26% 626.22 3,776 249 28 7 128 1 4 38 4,231 455 10.75% 305 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 422.06 2,702 189 24 8 55 1 5 40 3,024 322 10.65% 626.04 3,714 254 17 15 73 1 3 74 4,151 437 10.53% 320.11 1,580 92 9 12 16 4 6 43 1,762 182 10.33% 630.04 5,029 211 20 6 231 9 11 85 5,602 573 10.23% 628.00 4,269 266 28 13 66 12 10 68 4,732 463 9.78% 320.37 3,987 149 22 8 189 0 3 38 4,396 409 9.30% 423.05 3,457 170 23 5 60 2 4 61 3,782 325 8.59% 626.19 3,664 193 19 5 50 7 9 60 4,007 343 8.56% 627.02 4,293 203 18 8 92 3 8 59 4,684 391 8.35% 995.10 3,874 160 16 9 111 0 0 47 4,217 343 8.13% 630.05 1,356 24 15 0 63 0 0 18 1,476 120 8.13% 626.23 5,916 247 53 8 161 1 2 47 6,435 519 8.07% 627.10 2,684 104 7 7 70 7 3 31 2,913 229 7.86% 421.06 1,395 68 5 2 20 1 3 14 1,508 113 7.49% 634.00 4,627 202 13 17 77 3 1 55 4,995 368 7.37% 626.46 3,394 98 8 2 110 2 2 27 3,643 249 6.84% 630.06 2,907 99 13 6 66 2 0 27 3,120 213 6.83% 995.09 3,450 112 17 5 86 2 0 17 3,689 239 6.48% 629.00 1 1,7041 581 21 51 131 11 31 141 1,8001 96 5.33% 30% Technical Appendix C Low Income Population by Census Tract and Block Group Sol Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Brea city 021815 1 7 7 100.0 Fullerton city 011708 3 17 17 100.0 Fullerton city 086701 3 125 125 100.0 Garden Grove city 089001 1 21 21 100.0 Los Alamitos city 110113 1 141 141 100.0 Newport Beach city 063101 1 8 8 100.0 Placentia city 021813 9 20 20 100.0 Westminster city 088901 1 15 15 100.0 Westminster city 099701 3 25 25 100.0 001903 2 61 61 100.0 021924 1 33 33 100.0 Buena Park city 001801 1 295 296 99.7 Santa Ana city 074601 2 1668 1708 97.7 Santa Ana city 074501 3 996 1022 97.5 Anaheim city 088402 1 768 790 97.2 001201 3 257 269 95.5 Garden Grove city 087806 2 96 101 95.0 Anaheim city 087501 3 1294 1363 94.9 Garden Grove city 089104 2 3469 3656 94.9 Anaheim city 011720 1 1463 1556 94.0 Santa Ana city 074405 1 1517 1614 94.0 Santa Ana city 074901 1 2075 2225 93.3 Santa Ana city 074901 3 1960 2107 93.0 Santa Ana city 074902 3 2765 2983 92.7 Garden Grove city 089106 2 1435 1549 92.6 Santa Ana city 074406 3 1540 1669 92.3 Santa Ana city 075003 2 3282 3569 92.0 Irvine city 062626 2 1191 1306 91.2 Stanton city 087803 3 3319 3638 91.2 Orange city 075811 2 1354 1490 90.9 Santa Ana city 074501 2 2435 2679 90.9 Santa Ana city 075100 4 1896 2086 90.9 Irvine city 062627 2 687 758 90.6 Santa Ana city 074601 3 1347 1492 90.3 Santa Ana city 074407 1 3442 3822 90.1 Santa Ana city 074403 2 2699 3002 89.9 Fullerton city 011504 2 447 498 89.8 Santa Ana city 074805 1 4183 4670 89.6 Stanton city 087806 1 1653 1846 89.5 Santa Ana city 074405 2 1761 1973 89.3 Anaheim city 086405 2 1706 1923 88.7 Fullerton city 011601 5 814 919 88.6 Stanton city 087902 2 1126 1271 88.6 Anaheim city 087501 2 1868 2116 88.3 Westminster city 099601 3 1668 1889 88.3 Westminster city 099803 1 1743 1977 88.2 Buena Park city 001801 4 119 135 88.1 Santa Ana city 075004 2 2292 2603 88.1 Anaheim city 086601 1 2126 2424 87.7 Garden Grove city 088701 1 1201 1369 87.7 Santa Ana city 075003 3 2116 2412 87.7 308 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Santa Ana city 075002 3 4171 4777 87.3 Anaheim city 086502 4 1881 2158 87.2 Santa Ana city 074405 3 1636 1884 86.8 Garden Grove city 088501 2 1917 2213 86.6 Santa Ana city 074806 1 2843 3288 86.5 Anaheim city 087102 3 1240 1440 86.1 Fullerton city 001802 5 1159 1346 86.1 Anaheim city 087403 2 1176 1367 86.0 Anaheim city 087404 1 2349 2739 85.8 Laguna Woods city 062641 2 204 238 85.7 Santa Ana city 074405 4 1110 1295 85.7 Huntington Beach city 099402 4 2047 2395 85.5 Buena Park city 110402 3 1573 1841 85.4 Santa Ana city 089105 2 2122 2488 85.3 Huntington Beach city 099402 3 3038 3571 85.1 Anaheim city 087405 3 2895 3407 85.0 Santa Ana city 074901 4 1430 1682 85.0 Santa Ana city 089105 3 2499 2948 84.8 Santa Ana city 074403 1 2857 3372 84.7 Santa Ana city 074602 3 1948 2302 84.6 Anaheim city 087405 1 1496 1770 84.5 Fullerton city 011711 5 1934 2290 84.5 Santa Ana city 089105 1 1314 1555 84.5 Santa Ana city 099249 1 2143 2539 84.4 Anaheim city 087200 3 1117 1327 84.2 Placentia city 011720 1 1836 2184 84.1 Santa Ana city 074501 1 2257 2685 84.1 Santa Ana city 074602 1 1055 1255 84.1 Santa Ana city 076000 2 121 144 84.0 Anaheim city 087504 3 1743 2081 83.8 Orange city 075812 1 2640 3157 83.6 Santa Ana city 074802 3 2259 2703 83.6 Fullerton city 011101 3 567 682 83.1 Anaheim city 011720 3 492 593 83.0 Anaheim city 110402 2 581 700 83.0 Laguna Woods city 062622 5 44 53 83.0 Anaheim city 087503 5 1984 2397 82.8 Santa Ana city 074801 2 1625 1962 82.8 Anaheim city 086502 3 1116 1349 82.7 Anaheim city 087601 1 1604 1939 82.7 Santa Ana city 075004 1 2573 3110 82.7 Santa Ana city 074801 1 1413 1711 82.6 Westminster city 099903 2 2173 2634 82.5 Anaheim city 087102 4 488 592 82.4 Fullerton city 011601 6 1579 1916 82.4 Garden Grove city 088502 3 1480 1797 82.4 Santa Ana city 075002 2 1749 2122 82.4 Santa Ana city 074602 2 1906 2320 82.2 Santa Ana city 075100 1 2313 2825 81.9 Anaheim city 086502 1 1082 1325 81.7 Anaheim city 087300 3 926 1133 81.7 309 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 087504 2 2398 2941 81.5 Orange city 075807 3 1069 1313 81.4 Anaheim city 011602 2 385 474 81.2 Anaheim city 086601 5 1262 1556 81.1 Santa Ana city 075003 1 1800 2219 81.1 Santa Ana city 075002 1 2080 2567 81.0 Santa Ana city 099248 1 2067 2557 80.8 Garden Grove city 088203 2 1320 1643 80.3 Anaheim city 086602 2 1685 2100 80.2 Fullerton city 011200 2 631 787 80.2 Fullerton city 011403 4 687 860 79.9 Santa Ana city 074601 1 1390 1740 79.9 Santa Ana city 074902 2 1695 2122 79.9 Anaheim city 087300 1 1591 1993 79.8 Westminster city 099904 4 995 1252 79.5 Anaheim city 087504 1 1245 1568 79.4 Fullerton city 011504 5 1116 1405 79.4 Laguna Woods city 062646 2 532 670 79.4 Santa Ana city 074701 1 1989 2504 79.4 Anaheim city 087300 5 1060 1337 79.3 Santa Ana city 074406 2 879 1108 79.3 Irvine city 062614 2 2342 2966 79.0 La Habra city 001202 3 795 1008 78.9 Santa Ana city 074502 2 2546 3225 78.9 Anaheim city 086901 3 3110 3945 78.8 Buena Park city 110500 1 2120 2692 78.8 Seal Beach city 099509 1 375 476 78.8 Buena Park city 110603 3 1742 2218 78.5 Santa Ana city 074806 2 2237 2848 78.5 Buena Park city 110606 1 2289 2918 78.4 Anaheim city 087405 2 1098 1403 78.3 Fullerton city 011101 1 372 475 78.3 Santa Ana city 074003 1 1758 2253 78.0 Fullerton city 011601 1 921 1183 77.9 Santa Ana city 074901 5 1763 2265 77.8 Santa Ana city 074802 2 987 1270 77.7 Santa Ana city 074902 1 1662 2138 77.7 Anaheim city 087701 2 430 554 77.6 Anaheim city 011602 1 1454 1879 77.4 Placentia city 011720 2 1958 2531 77.4 Anaheim city 087503 1 741 959 77.3 La Habra city 001201 2 1403 1814 77.3 Placentia city 011721 4 1669 2158 77.3 Cypress city 110104 3 799 1035 77.2 Westminster city 099904 5 1357 1758 77.2 Santa Ana city 074108 1 1462 1896 77.1 Orange city 075813 2 892 1161 76.8 Stanton city 088105 1 43 56 76.8 Anaheim city 086502 2 1409 1837 76.7 Santa Ana city 074406 1 713 929 76.7 Anaheim city 086903 1 1700 2220 76.6 310 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% La Habra city 001201 3 1310 1712 76.5 Santa Ana city 074602 4 1749 2287 76.5 Laguna Woods city 062646 1 427 559 76.4 Orange city 075806 4 1799 2359 76.3 Santa Ana city 089004 2 2767 3633 76.2 Anaheim city 087403 1 524 689 76.1 Fullerton city 011601 2 890 1170 76.1 Anaheim city 087001 1 2204 2900 76.0 Laguna Woods city 062622 3 662 872 75.9 Fullerton city 001802 4 929 1226 75.8 Santa Ana city 074803 1 3064 4041 75.8 Santa Ana city 074004 2 529 700 75.6 Anaheim city 086901 4 986 1308 75.4 La Habra city 001304 3 402 533 75.4 La Habra city 001404 2 783 1039 75.4 Santa Ana city 074801 3 1865 2474 75.4 Fullerton city 011401 1 477 634 75.2 021913 4 2144 2850 75.2 Santa Ana city 074103 3 1582 2107 75.1 La Habra city 001401 4 1196 1595 75.0 Santa Ana city 074005 3 1075 1433 75.0 La Habra city 001304 2 1510 2015 74.9 Santa Ana city 089104 1 739 987 74.9 Anaheim city 086501 1 1705 2280 74.8 Garden Grove city 088601 4 846 1131 74.8 Santa Ana city 074300 1 1696 2266 74.8 Anaheim city 087401 1 339 454 74.7 Huntington Beach city 099214 4 566 758 74.7 Orange city 076204 2 1678 2253 74.5 Placentia city 011721 1 830 1116 74.4 Westminster city 099802 2 2104 2829 74.4 Anaheim city 087806 1 1050 1413 74.3 Anaheim city 110202 3 1488 2006 74.2 Lake Forest city 032014 1 1462 1970 74.2 Seal Beach city 099509 4 703 950 74.0 Anaheim city 087803 1 1094 1481 73.9 Santa Ana city 089004 3 1433 1938 73.9 Stanton city 087806 2 181 245 73.9 Anaheim city 087106 3 1174 1591 73.8 Santa Ana city 074702 1 2655 3600 73.8 Anaheim city 087601 3 989 1343 73.6 Dana Point city 042201 1 572 777 73.6 Anaheim city 011722 1 706 961 73.5 Rancho Santa Margarita city 032055 2 863 1174 73.5 Santa Ana city 075100 2 1107 1507 73.5 Fullerton city 110605 2 798 1089 73.3 Westminster city 099904 2 1435 1959 73.3 La Habra city 001404 3 854 1166 73.2 Tustin Foothills CDP 075701 4 115 157 73.2 Santa Ana city 074802 1 1396 1910 73.1 Anaheim city 086903 2 10151 1390 73.0 311 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 087200 2 1621 2225 72.9 Fullerton city 011712 2 363 498 72.9 Anaheim city 087504 4 1202 1652 72.8 Santa Ana city 075201 2 1719 2364 72.7 Anaheim city 086702 2 595 819 72.6 Irvine city 062611 1 530 730 72.6 099227 2 283 390 72.6 Garden Grove city 088601 2 1000 1382 72.4 Garden Grove city 088702 1 1023 1413 72.4 Seal Beach city 099510 3 594 821 72.4 Santa Ana city 074109 2 1445 1998 72.3 Stanton city 087803 2 793 1097 72.3 Fullerton city 011502 1 635 879 72.2 Westminster city 099203 1 281 390 72.1 Anaheim city 086601 4 1214 1687 72.0 Westminster city 099802 1 836 1161 72.0 Seal Beach city 099510 5 501 697 71.9 Orange city 075902 3 1363 1898 71.8 Seal Beach city 099502 1 483 673 71.8 Seal Beach city 099510 2 1168 1627 71.8 Cypress city 110110 1 602 840 71.7 Orange city 076102 3 1556 2171 71.7 Santa Ana city 075202 2 2359 3291 71.7 Laguna Hills city 062623 2 141 197 71.6 La Habra city 001201 1 1123 1573 71.4 Santa Ana city 074701 2 2115 2966 71.3 Anaheim city 086601 3 1576 2214 71.2 Buena Park city 110603 5 1358 1907 71.2 Santa Ana city 074200 1 849 1192 71.2 Santa Ana city 075701 2 1246 1749 71.2 032056 4 47 66 71.2 Garden Grove city 088801 2 624 878 71.1 Westminster city 088901 4 248 349 71.1 Anaheim city 087503 4 373 525 71.0 Garden Grove city 088701 2 1400 1972 71.0 Santa Ana city 089004 1 1313 1852 70.9 Fullerton city 011300 1 776 1096 70.8 Anaheim city 086405 3 1343 1899 70.7 Santa Ana city 074701 3 2539 3596 70.6 Anaheim city 086802 2 1355 1924 70.4 Santa Ana city 074901 2 1284 1823 70.4 021918 3 528 750 70.4 Buena Park city 110603 4 717 1020 70.3 Anaheim city 086702 4 302 430 70.2 Anaheim city 087103 3 970 1383 70.1 Garden Grove city 088702 2 614 876 70.1 Laguna Woods city 062646 4 568 810 70.1 Laguna Hills city 062625 4 1224 1750 69.9 Garden Grove city 089102 1 1826 2617 69.8 Stanton city 087805 3 1837 2637 69.7 0997021 21 9011 12931 69.7 312 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Fullerton city 001801 2 1052 1512 69.6 Westminster city 099601 1 1381 1985 69.6 Fullerton city 011000 4 984 1416 69.5 Santa Ana city 074006 1 867 1248 69.5 Anaheim city 086702 5 2027 2921 69.4 La Habra city 001501 1 177 255 69.4 Garden Grove city 088902 1 1105 1594 69.3 Santa Ana city 075202 1 1893 2734 69.2 Santa Ana city 075302 1 1392 2013 69.2 Stanton city 088106 3 2098 3033 69.2 La Habra city 001303 2 687 994 69.1 Laguna Woods city 062647 2 405 586 69.1 Santa Ana city 099248 2 2091 3025 69.1 086701 3 288 417 69.1 Anaheim city 086902 1 871 1262 69.0 Garden Grove city 076103 2 2598 3771 68.9 Santa Ana city 074803 2 2070 3003 68.9 Santa Ana city 075403 2 855 1241 68.9 Santa Ana city 074005 2 1679 2442 68.8 Westminster city 088904 2 953 1388 68.7 Fullerton city 001802 1 1088 1586 68.6 Anaheim city 086407 3 1417 2068 68.5 La Habra city 001202 1 912 1331 68.5 Laguna Woods city 062646 3 554 809 68.5 Laguna Woods city 062647 3 214 313 68.4 Santa Ana city 074102 1 1317 1926 68.4 Santa Ana city 074805 2 1394 2040 68.3 Santa Ana city 074102 3 649 951 68.2 Santa Ana city 088903 3 1156 1695 68.2 087701 3 135 198 68.2 Garden Grove city 088201 1 898 1318 68.1 La Habra city 001202 2 623 915 68.1 Anaheim city 087805 1 1086 1598 68.0 Orange city 076101 3 1217 1793 67.9 Placentia city 011722 2 359 529 67.9 Anaheim city 086901 1 1136 1676 67.8 Santa Ana city 099249 2 1289 1904 67.7 Santa Ana city 075302 3 635 942 67.4 Santa Ana city 089001 2 953 1413 67.4 Stanton city 087803 1 152 226 67.3 Santa Ana city 099247 2 1442 2147 67.2 Huntington Beach city 099413 4 982 1464 67.1 Santa Ana city 099202 2 2540 3783 67.1 Santa Ana city 074803 3 1341 2002 67.0 Garden Grove city 089003 1 1202 1796 66.9 Stanton city 087902 3 1583 2366 66.9 Orange city 076000 5 937 1402 66.8 Orange city 076103 1 813 1217 66.8 Los Alamitos city 110117 4 46 69 66.7 001501 3 16 24 66.7 Anaheim city 086404 2 10171 1527 66.6 313 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 087103 4 1113 1672 66.6 Buena Park city 110607 2 711 1067 66.6 Garden Grove city 088301 1 1530 2299 66.6 Santa Ana city 074005 1 1247 1872 66.6 Santa Ana city 074601 4 1281 1924 66.6 Garden Grove city 088107 2 2400 3608 66.5 Seal Beach city 099509 5 461 693 66.5 Westminster city 099223 2 902 1357 66.5 Fullerton city 011602 2 675 1016 66.4 Buena Park city 110500 2 2105 3173 66.3 Anaheim city 086803 1 1209 1827 66.2 Anaheim city 110202 2 730 1103 66.2 Fullerton city 001801 1 1090 1647 66.2 Garden Grove city 088901 3 1516 2293 66.1 Garden Grove city 089106 1 1359 2056 66.1 Laguna Woods city 062622 2 479 725 66.1 Villa Park city 075812 2 39 59 66.1 Garden Grove city 088402 2 1441 2182 66.0 La Habra city 001304 1 922 1397 66.0 Santa Ana city 089001 3 1524 2309 66.0 Irvine city 062626 1 960 1456 65.9 Laguna Woods city 062625 1 496 754 65.8 Garden Grove city 088702 3 2068 3148 65.7 Santa Ana city 074300 2 1408 2143 65.7 Anaheim city 086501 2 999 1522 65.6 Garden Grove city 088801 5 1053 1605 65.6 La Habra city 001303 1 1179 1798 65.6 Westminster city 099222 1 512 782 65.5 Fullerton city 011502 4 697 1067 65.3 Anaheim city 087300 2 2546 3908 65.1 Laguna Beach city 062605 2 385 591 65.1 Santa Ana city 075201 1 2328 3584 65.0 Orange city 021913 4 731 1126 64.9 Westminster city 099905 1 1293 1996 64.8 Anaheim city 087101 1 1356 2096 64.7 Fullerton city 011708 1 1438 2224 64.7 Garden Grove city 088801 4 1415 2190 64.6 Fullerton city 011504 3 424 658 64.4 Anaheim city 087102 1 978 1520 64.3 Garden Grove city 088801 3 1201 1869 64.3 Laguna Woods city 062647 4 615 956 64.3 Dana Point city 042313 5 1210 1886 64.2 Anaheim city 087105 1 1100 1715 64.1 Orange city 076204 1 1882 2934 64.1 Santa Ana city 074200 4 1859 2898 64.1 Anaheim city 086405 1 790 1234 64.0 Anaheim city 087002 2 1054 1646 64.0 Buena Park city 110603 2 992 1549 64.0 Rancho Santa Margarita city 032051 4 579 905 64.0 Santa Ana city 074006 3 1774 2773 64.0 Westminster city 099601 2 1622 2533 64.0 mail Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Fullerton city 011602 3 1528 2393 63.9 Anaheim city 076202 4 1072 1680 63.8 Brea city 001504 1 750 1175 63.8 Fullerton city 011504 4 572 896 63.8 Irvine city 062612 3 461 723 63.8 La Palma city 110116 3 918 1442 63.7 Los Alamitos city 110106 2 35 55 63.6 Santa Ana city 075404 3 1532 2409 63.6 Stanton city 087802 4 954 1499 63.6 075701 3 279 439 63.6 Anaheim city 087704 1 658 1036 63.5 Lake Forest city 052410 5 498 784 63.5 Santa Ana city 074103 2 934 1471 63.5 099702 3 1342 2112 63.5 Santa Ana city 074004 1 1550 2444 63.4 Anaheim city 087101 2 809 1278 63.3 Buena Park city 110500 3 1053 1664 63.3 Fullerton city 011403 2 1092 1725 63.3 Garden Grove city 088601 3 1361 2151 63.3 Garden Grove city 088104 1 84 133 63.2 Irvine city 052505 4 321 508 63.2 Anaheim city 086301 1 1635 2593 63.1 Anaheim city 086306 1 937 1486 63.1 Fullerton city 011711 2 952 1508 63.1 Anaheim city 086303 4 1228 1953 62.9 Huntington Beach city 099410 3 1466 2329 62.9 Huntington Beach city 099411 4 930 1479 62.9 Orange city 076102 1 127 202 62.9 Anaheim city 086405 4 993 1582 62.8 Anaheim city 086404 1 1873 2987 62.7 Anaheim city 086803 3 1719 2742 62.7 Orange city 076201 2 723 1155 62.6 Huntington Beach city 099402 2 1362 2180 62.5 Seal Beach city 099509 3 412 659 62.5 Santa Ana city 074109 1 1262 2022 62.4 087703 1 1190 1908 62.4 Huntington Beach city 099305 4 1418 2276 62.3 Lake Forest city 032027 1 316 507 62.3 Anaheim city 087403 3 1000 1607 62.2 Anaheim city 110202 1 804 1293 62.2 Stanton city 087805 1 834 1342 62.1 Santa Ana city 075301 1 927 1496 62.0 Stanton city 087901 1 2024 3266 62.0 Orange city 076208 4 589 952 61.9 Anaheim city 086602 3 1526 2470 61.8 Orange city 075901 3 1723 2790 61.8 Fullerton city 011711 4 836 1354 61.7 Anaheim city 086802 1 1403 2283 61.5 Garden Grove city 088602 1 1367 2230 61.3 Garden Grove city 088001 3 931 1522 61.2 Irvine city 052514 1 729 1192 61.2 SZJ5 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Seal Beach city 099510 1 312 511 61.1 Orange city 075816 1 1335 2187 61.0 Anaheim city 086402 1 1738 2856 60.9 Orange city 076101 1 1179 1938 60.8 Anaheim city 021812 4 1044 1722 60.6 Anaheim city 087002 3 1715 2831 60.6 Garden Grove city 088104 2 361 596 60.6 Santa Ana city 074200 2 1227 2026 60.6 Santa Ana city 074702 2 1865 3077 60.6 Laguna Woods city 062623 1 403 666 60.5 Seal Beach city 099509 2 437 722 60.5 Cypress city 110111 3 1079 1786 60.4 Anaheim city 110201 1 359 595 60.3 Anaheim city 086406 1 562 934 60.2 Laguna Hills city 042307 4 701 1165 60.2 087902 1 950 1582 60.1 Anaheim city 086406 2 767 1279 60.0 Garden Grove city 089003 2 1208 2012 60.0 076204 1 42 70 60.0 Anaheim city 087602 3 2067 3456 59.8 Anaheim city 087701 3 921 1540 59.8 Fullerton city 011708 2 781 1306 59.8 La Habra city 001301 5 1060 1774 59.8 Westminster city 099204 1 834 1394 59.8 Orange city 075902 2 1261 2112 59.7 099701 3 818 1370 59.7 Santa Ana city 074106 1 1310 2197 59.6 Buena Park city 110201 3 1567 2637 59.4 Garden Grove city 088903 3 885 1490 59.4 Garden Grove city 088802 1 1005 1696 59.3 Westminster city 099902 3 1129 1907 59.2 Stanton city 087802 1 251 425 59.1 Irvine city 052418 2 847 1435 59.0 Laguna Hills city 062622 5 715 1211 59.0 Stanton city 087801 2 1238 2100 59.0 Westminster city 099801 2 1454 2465 59.0 Anaheim city 086404 3 997 1693 58.9 Anaheim city 086601 2 1030 1749 58.9 Fullerton city 011711 3 531 902 58.9 Garden Grove city 089107 1 538 913 58.9 Garden Grove city 088501 3 956 1626 58.8 Rancho Santa Margarita city 032054 3 354 603 58.7 Santa Ana city 089001 4 1355 2307 58.7 Anaheim city 086602 1 896 1529 58.6 Brea city 001503 3 1018 1741 58.5 Laguna Woods city 062646 5 447 764 58.5 Santa Ana city 075302 2 941 1609 58.5 Santa Ana city 089104 3 834 1429 58.4 Buena Park city 110500 4 519 890 58.3 Buena Park city 110603 1 1060 1817 58.3 Laguna Woods city 062622 1 396 679 58.3 31O Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Lake Forest city 032047 1 589 1010 58.3 Anaheim city 086702 1 824 1415 58.2 Anaheim city 087802 1 813 1396 58.2 Garden Grove city 088403 1 331 570 58.1 Garden Grove city 076103 3 1959 3382 57.9 Santa Ana city 099202 3 774 1337 57.9 Santa Ana city 074501 4 1067 1847 57.8 Garden Grove city 099203 1 697 1207 57.7 Santa Ana city 099247 1 608 1054 57.7 Cypress city 110110 2 749 1300 57.6 Garden Grove city 088106 3 811 1409 57.6 Santa Ana city 075403 3 1262 2192 57.6 La Habra city 001103 3 991 1722 57.5 Santa Ana city 074502 1 1756 3055 57.5 Seal Beach city 099510 4 203 353 57.5 Stanton city 087801 1 451 785 57.5 Anaheim city 087401 4 540 940 57.4 Irvine city 052421 5 304 530 57.4 Anaheim city 011714 1 126 220 57.3 Anaheim city 076102 1 591 1031 57.3 Santa Ana city 075701 3 566 988 57.3 Fullerton city 001802 3 770 1346 57.2 Irvine city 052417 2 450 787 57.2 Anaheim city 087106 1 641 1122 57.1 Garden Grove city 088802 2 1403 2459 57.1 Rancho Santa Margarita city 032051 3 322 564 57.1 Santa Ana city 075301 4 385 674 57.1 Irvine city 075515 3 312 547 57.0 Santa Ana city 074200 3 1980 3476 57.0 Orange city 021914 2 694 1220 56.9 Garden Grove city 088107 1 1161 2044 56.8 Cypress city 110202 1 165 291 56.7 Fullerton city 011200 3 802 1418 56.6 Garden Grove city 088401 3 668 1183 56.5 Huntington Beach city 099241 2 922 1636 56.4 Garden Grove city 089102 3 1041 1848 56.3 Huntington Beach city 099508 3 744 1322 56.3 Santa Ana city 075504 1 583 1035 56.3 Stanton city 088104 2 846 1503 56.3 Anaheim city 086803 2 623 1109 56.2 Anaheim city 087300 4 899 1601 56.2 Placentia city 011711 1 453 806 56.2 Anaheim city 087401 3 402 717 56.1 Santa Ana city 074111 3 1827 3260 56.0 Fullerton city 001903 1 810 1450 55.9 Garden Grove city 088901 4 744 1331 55.9 Garden Grove city 088903 2 1680 3004 55.9 Anaheim city 086501 3 525 941 55.8 Fullerton city 001601 1 608 1093 55.6 La Habra city 001103 2 800 1439 55.6 Anaheim city 087801 1 6221 1121 55.5 317 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Buena Park city 110110 1 269 485 55.5 Fountain Valley city 099229 3 909 1637 55.5 Santa Ana city 074602 5 824 1485 55.5 Huntington Beach city 099212 4 625 1130 55.3 Buena Park city 110302 1 766 1387 55.2 Garden Grove city 088701 3 1194 2162 55.2 Garden Grove city 088801 1 892 1616 55.2 La Habra city 001301 4 575 1041 55.2 La Palma city 110301 4 858 1553 55.2 Brea city 001504 3 362 657 55.1 Fullerton city 011601 4 663 1203 55.1 Santa Ana city 074006 2 825 1501 55.0 Santa Ana city 074601 5 1054 1917 55.0 Anaheim city 087106 2 1114 2028 54.9 Anaheim city 087704 3 636 1158 54.9 Anaheim city 011722 2 449 819 54.8 Anaheim city 087102 2 1263 2306 54.8 Cypress city 110102 3 707 1290 54.8 Westminster city 099222 2 867 1581 54.8 Anaheim city 087001 3 709 1296 54.7 Huntington Beach city 099220 5 736 1348 54.6 Fullerton city 001801 4 441 809 54.5 Anaheim city 086902 2 864 1588 54.4 Fullerton city 011102 2 558 1028 54.3 Buena Park city 110606 2 1043 1923 54.2 Laguna Woods city 062625 2 509 940 54.1 Westminster city 088905 2 1350 2495 54.1 087806 1 33 61 54.1 Fountain Valley city 099251 1 1212 2246 54.0 Huntington Beach city 099212 1 758 1403 54.0 La Habra city 001103 1 569 1054 54.0 Westminster city 099803 2 806 1492 54.0 099701 1 1180 2188 53.9 Garden Grove city 088902 3 701 1302 53.8 Stanton city 110203 1 29 54 53.7 Anaheim city 086701 1 2159 4028 53.6 Buena Park city 110607 3 739 1379 53.6 Garden Grove city 088301 4 366 683 53.6 Irvine city 052505 2 446 832 53.6 Westminster city 099223 1 1158 2160 53.6 Fullerton city 001903 2 793 1483 53.5 Anaheim city 087200 5 1026 1923 53.4 Garden Grove city 088602 2 1202 2249 53.4 La Habra city 001401 3 627 1174 53.4 Fountain Valley city 099251 2 937 1759 53.3 Garden Grove city 088403 2 1488 2793 53.3 Stanton city 087802 2 1017 1907 53.3 Westminster city 099801 3 897 1682 53.3 Fullerton city 011601 3 997 1873 53.2 Irvine city 062611 2 885 1662 53.2 Santa Ana city 074102 2 10441 1965 53.1 318 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 110402 3 551 1039 53.0 Irvine city 052521 2 651 1229 53.0 Placentia city 011712 1 1141 2152 53.0 Placentia city 011721 3 507 957 53.0 Anaheim city 086301 3 1333 2525 52.8 Placentia city 011712 2 644 1220 52.8 Westminster city 099904 1 422 801 52.7 Brea city 001507 1 830 1579 52.6 Anaheim city 086701 4 754 1436 52.5 Huntington Beach city 099244 2 917 1747 52.5 Stanton city 088104 1 1094 2085 52.5 Westminster city 099902 1 560 1073 52.2 Fullerton city 001902 1 601 1156 52.0 Laguna Hills city 042307 5 638 1226 52.0 Santa Ana city 075404 1 1045 2008 52.0 Garden Grove city 088901 2 645 1242 51.9 Placentia city 011720 3 348 671 51.9 Garden Grove city 088302 1 624 1204 51.8 Laguna Woods city 062641 1 331 639 51.8 Los Alamitos city 110014 2 736 1420 51.8 Westminster city 099204 2 495 955 51.8 Garden Grove city 088903 1 1200 2322 51.7 Westminster city 099903 3 596 1156 51.6 Fullerton city 001802 2 934 1813 51.5 Huntington Beach city 099411 2 953 1851 51.5 Santa Ana city 074106 3 631 1225 51.5 Garden Grove city 088902 2 1106 2158 51.3 Fullerton city 011403 5 631 1232 51.2 Orange city 076205 1 1485 2901 51.2 Garden Grove city 088501 1 1395 2737 51.0 Buena Park city 110302 4 692 1361 50.8 Santa Ana city 074108 2 1711 3369 50.8 Fullerton city 001902 2 756 1491 50.7 Fullerton city 011502 2 381 752 50.7 099703 1 232 458 50.7 La Habra city 001404 1 606 1198 50.6 Laguna Woods city 062623 4 419 828 50.6 Anaheim city 087002 1 1128 2232 50.5 Garden Grove city 088402 1 923 1829 50.5 Anaheim city 087704 2 497 987 50.4 Lake Forest city 052423 2 1088 2158 50.4 Garden Grove city 088901 1 636 1265 50.3 099701 2 516 1025 50.3 Buena Park city 110401 3 678 1356 50.0 Irvine city 052410 5 19 38 50.0 La Habra city 001401 1 715 1429 50.0 Lake Forest city 032014 2 1817 3631 50.0 Santa Ana city 075301 3 887 1775 50.0 Seal Beach city 099511 2 2531 506 50.0 Anaheim city 087404 2 518 1039 49.9 Huntington Beach city 099306 3 5631 1129 49.9 sz9 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Irvine city 052528 4 380 762 49.9 Huntington Beach city 099307 1 444 892 49.8 Los Alamitos city 110014 4 539 1083 49.8 Stanton city 087802 3 746 1498 49.8 Anaheim city 086304 3 1000 2014 49.7 Anaheim city 087503 2 1043 2098 49.7 Newport Beach city 063103 2 74 149 49.7 Santa Ana city 075405 1 801 1612 49.7 Huntington Beach city 099305 2 516 1042 49.5 Lake Forest city 052425 3 766 1550 49.4 Santa Ana city 074103 1 791 1600 49.4 Anaheim city 086801 3 460 933 49.3 Garden Grove city 089107 2 1090 2209 49.3 Buena Park city 110202 3 383 779 49.2 Fountain Valley city 099203 2 420 858 49.0 Garden Grove city 088001 2 865 1765 49.0 Orange city 076000 1 625 1276 49.0 062641 2 892 1821 49.0 Anaheim city 086406 4 418 854 48.9 La Habra city 001402 2 986 2016 48.9 Anaheim city 087401 2 461 945 48.8 Orange city 075805 1 605 1241 48.8 Anaheim city 086901 2 566 1162 48.7 Anaheim city 087602 2 680 1395 48.7 Garden Grove city 088502 2 530 1088 48.7 Orange city 076208 1 812 1670 48.6 Los Alamitos city 110015 9 100 206 48.5 Fullerton city 001704 3 333 689 48.3 Huntington Beach city 099220 1 255 528 48.3 Santa Ana city 089102 2 1079 2236 48.3 Buena Park city 110302 2 1203 2497 48.2 La Habra city 001101 2 281 583 48.2 La Habra city 001402 3 980 2033 48.2 087806 2 833 1728 48.2 Dana Point city 042339 3 597 1240 48.1 063103 2 174 362 48.1 Brea city 001506 1 1000 2087 47.9 Fullerton city 011403 3 474 990 47.9 Fullerton city 011101 4 579 1211 47.8 Santa Ana city 074102 4 1198 2508 47.8 Cypress city 110117 1 947 1985 47.7 Orange city 076202 3 862 1809 47.7 Santa Ana city 075404 2 812 1707 47.6 Anaheim city 086407 2 751 1581 47.5 Los Alamitos city 110108 3 308 649 47.5 Anaheim city 086702 3 493 1039 47.4 Huntington Beach city 099412 1 882 1860 47.4 Westminster city 099204 3 712 1503 47.4 Anaheim city 021807 1 934 1973 47.3 Fullerton city 110605 3 613 1298 47.2 Garden Grove city 088301 2 886 1884 47.0 320 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Westminster city 099702 1 1189 2535 46.9 Fullerton city 011000 2 470 1004 46.8 Huntington Beach city 099405 3 939 2005 46.8 La Habra city 001102 1 415 887 46.8 Westminster city 088905 3 598 1277 46.8 087703 2 759 1625 46.7 Anaheim city 087103 1 750 1608 46.6 Huntington Beach city 099212 3 606 1301 46.6 Anaheim city 086303 2 351 757 46.4 Buena Park city 001801 3 333 717 46.4 Buena Park city 110604 3 1278 2762 46.3 Garden Grove city 088601 1 421 912 46.2 Los Alamitos city 110108 2 340 737 46.1 Buena Park city 110303 1 1109 2412 46.0 Irvine city 052525 7 658 1430 46.0 Irvine city 062627 3 433 942 46.0 Santa Ana city 074111 2 672 1461 46.0 Huntington Beach city 099411 3 693 1509 45.9 Cypress city 110109 2 488 1065 45.8 Garden Grove city 088502 1 917 2010 45.6 Rancho Santa Margarita city 032055 1 313 686 45.6 Anaheim city 088403 1 1420 3118 45.5 Orange city 075815 2 711 1563 45.5 Anaheim city 087103 6 322 711 45.3 Fountain Valley city 099227 2 1449 3201 45.3 Anaheim city 086304 2 401 889 45.1 Laguna Woods city 062623 3 587 1304 45.0 Santa Ana city 089001 1 682 1514 45.0 Brea city 001504 4 525 1169 44.9 Fullerton city 011707 1 618 1375 44.9 Garden Grove city 088002 2 886 1972 44.9 Garden Grove city 088201 2 556 1238 44.9 Huntington Beach city 099215 1 1666 3708 44.9 Santa Ana city 099203 1 691 1539 44.9 Huntington Beach city 099508 4 402 897 44.8 Huntington Beach city 099305 3 733 1640 44.7 Orange city 076000 3 699 1569 44.6 Anaheim city 110203 1 1067 2397 44.5 Rancho Santa Margarita city 032054 2 276 620 44.5 Aliso Viejo CDP 042320 4 858 1931 44.4 Anaheim city 087703 4 225 507 44.4 Laguna Woods city 062623 5 263 592 44.4 Santa Ana city 074107 1 375 845 44.4 Anaheim city 086701 3 487 1099 44.3 Irvine city 052513 5 457 1032 44.3 La Habra city 001705 1 1020 2303 44.3 Orange city 021918 3 200 452 44.2 Anaheim city 086701 2 571 1296 44.1 Laguna Hills city 042320 2 180 408 44.1 Orange city 076205 4 3171 720 44.0 Orange city 076206 1 12531 2850 44.0 321 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Santa Ana city 089107 1 1129 2568 44.0 Fullerton city 011707 3 752 1713 43.9 Santa Ana city 099202 1 893 2038 43.8 Garden Grove city 088203 1 952 2184 43.6 Santa Ana city 075405 2 404 927 43.6 Aliso Viejo CDP 062634 3 134 308 43.5 Anaheim city 087602 4 452 1040 43.5 Fullerton city 011102 3 391 899 43.5 Westminster city 099803 3 823 1894 43.5 Fullerton city 011102 4 525 1211 43.4 La Habra city 001303 4 722 1665 43.4 Los Alamitos city 110014 3 547 1261 43.4 Anaheim city 087503 3 266 614 43.3 Lake Forest city 052411 1 893 2060 43.3 Westminster city 088905 1 523 1208 43.3 Stanton city 088101 1 933 2158 43.2 Westminster city 099904 3 424 982 43.2 076202 2 137 317 43.2 Anaheim city 086301 2 758 1759 43.1 Anaheim city 086406 3 408 946 43.1 Anaheim city 086801 1 191 443 43.1 Cypress city 110111 1 602 1398 43.1 Dana Point city 042313 2 401 931 43.1 Laguna Hills city 062647 1 557 1293 43.1 Fullerton city 011504 1 503 1170 43.0 Huntington Beach city 099216 4 309 721 42.9 Anaheim city 086903 3 388 907 42.8 Garden Grove city 088802 3 565 1320 42.8 Laguna Beach city 062605 1 378 883 42.8 Westminster city 099222 3 559 1307 42.8 Fullerton city 011300 3 553 1296 42.7 Dana Point city 042313 6 438 1029 42.6 Stanton city 087801 3 348 817 42.6 Garden Grove city 110001 2 707 1667 42.4 La Habra city 001303 3 548 1293 42.4 Dana Point city 042201 5 383 905 42.3 Huntington Beach city 099305 1 1051 2482 42.3 Huntington Beach city 099307 2 533 1259 42.3 Irvine city 052520 1 173 409 42.3 Lake Forest city 052424 1 703 1660 42.3 Westminster city 099703 1 578 1367 42.3 001101 3 63 149 42.3 Anaheim city 086803 4 286 677 42.2 Anaheim city 087105 2 1159 2746 42.2 Fullerton city 011403 1 273 647 42.2 076208 3 38 90 42.2 Cypress city 110106 2 451 1071 42.1 Orange city 075805 3 597 1417 42.1 Orange city 076205 3 289 687 42.1 Anaheim city 087501 4 230 548 42.0 Huntington Beach city 099306 2 536 1281 41.8 322 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Placentia city 011711 2 110 263 41.8 Cypress city 110117 3 487 1169 41.7 Buena Park city 110201 2 841 2023 41.6 Cypress city 110109 4 707 1704 41.5 Garden Grove city 088302 3 629 1521 41.4 Garden Grove city 088401 2 943 2280 41.4 Westminster city 099222 4 407 984 41.4 Brea city 001504 2 602 1458 41.3 Fullerton city 011000 3 481 1165 41.3 La Habra city 001102 3 528 1277 41.3 Orange city 075902 5 303 733 41.3 Huntington Beach city 099408 1 776 1883 41.2 Tustin Foothills CDP 075504 2 259 629 41.2 Buena Park city 110110 2 449 1093 41.1 Fullerton city 011101 2 649 1579 41.1 075808 2 309 752 41.1 Buena Park city 110401 1 593 1445 41.0 Garden Grove city 087902 1 48 117 41.0 Santa Ana city 074107 2 1028 2516 40.9 Westminster city 088904 1 421 1030 40.9 Brea city 001505 2 766 1879 40.8 Garden Grove city 088401 1 582 1425 40.8 Buena Park city 110402 1 468 1149 40.7 La Palma city 110115 1 382 941 40.6 Anaheim city 086402 2 431 1064 40.5 Los Alamitos city 110015 1 593 1465 40.5 Newport Beach city 063500 1 156 385 40.5 Yorba Linda city 021802 5 598 1476 40.5 063101 1 973 2404 40.5 Buena Park city 110302 3 270 669 40.4 Orange city 075902 4 161 399 40.4 062604 3 295 730 40.4 Huntington Beach city 099235 3 727 1805 40.3 Buena Park city 110604 2 557 1386 40.2 Irvine city 062627 1 543 1350 40.2 Anaheim city 087601 2 433 1081 40.1 Fountain Valley city 099233 2 672 1674 40.1 Orange city 075806 3 318 794 40.1 Placentia city 011715 1 407 1016 40.1 Brea city 021815 2 261 652 40.0 Placentia city 011717 1 517 1294 40.0 Anaheim city 086903 4 593 1485 39.9 Huntington Beach city 099416 3 401 1006 39.9 Newport Beach city 063603 1 1127 2822 39.9 Santa Ana city 074106 2 780 1956 39.9 Westminster city 099801 1 493 1236 39.9 099513 1 121 303 39.9 Fullerton city 011102 1 531 1335 39.8 021816 1 304 764 39.8 087101 1 284 713 39.8 Buena Park city 110607 1 3891 980 39.7 323 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Garden Grove city 087602 2 112 282 39.7 Lake Forest city 052411 2 693 1747 39.7 Rancho Santa Margarita city 032042 2 395 994 39.7 Anaheim city 087701 1 459 1161 39.5 Santa Ana city 074004 4 883 2236 39.5 La Habra city 001301 1 342 871 39.3 Buena Park city 110301 3 593 1511 39.2 Cypress city 110104 1 1021 2603 39.2 Orange city 075902 1 374 955 39.2 Tustin Foothills CDP 075603 3 382 974 39.2 Buena Park city 086801 2 361 923 39.1 Dana Point city 042201 2 611 1564 39.1 Fullerton city 011502 3 497 1273 39.0 Irvine city 052519 3 281 720 39.0 Irvine city 052519 4 510 1307 39.0 Santa Ana city 075303 2 908 2326 39.0 Westminster city 099603 1 514 1318 39.0 Anaheim city 086305 2 687 1768 38.9 Dana Point city 042313 3 610 1569 38.9 Garden Grove city 088105 1 976 2506 38.9 Laguna Woods city 062623 7 339 872 38.9 087703 3 530 1362 38.9 Dana Point city 042313 1 481 1239 38.8 Rancho Santa Margarita city 032053 3 662 1708 38.8 Anaheim city 087601 4 264 682 38.7 Anaheim city 087704 4 592 1529 38.7 Dana Point city 042205 4 357 923 38.7 Newport Beach city 063010 2 645 1667 38.7 Huntington Beach city 099413 2 714 1851 38.6 Anaheim city 087200 1 351 912 38.5 Newport Beach city 063500 7 327 850 38.5 Anaheim city 086802 3 428 1115 38.4 Lake Forest city 032029 1 546 1421 38.4 Buena Park city 110203 2 868 2268 38.3 Garden Grove city 088701 4 293 766 38.3 La Habra city 001101 4 149 389 38.3 Anaheim city 088302 1 449 1174 38.2 Fullerton city 001901 1 514 1346 38.2 Garden Grove city 087503 2 192 503 38.2 Irvine city 052527 3 419 1096 38.2 110604 3 120 314 38.2 Anaheim city 011722 3 315 827 38.1 Garden Grove city 088002 1 587 1543 38.0 Orange city 075901 2 329 866 38.0 Lake Forest city 052416 1 296 781 37.9 Lake Forest city 052425 1 596 1574 37.9 Huntington Beach city 099410 1 423 1121 37.7 Irvine city 052511 4 399 1058 37.7 Irvine city 052521 1 621 1647 37.7 La Habra city 001402 1 419 1113 37.6 Santa Ana city 074005 4 557 1480 37.6 324 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Buena Park city 110402 2 155 413 37.5 Cypress city 110117 4 498 1329 37.5 Irvine city 052511 5 311 829 37.5 Yorba Linda city 021802 1 514 1372 37.5 Laguna Beach city 062605 3 457 1223 37.4 011718 2 137 367 37.3 Huntington Beach city 099220 2 305 819 37.2 Newport Beach city 063004 3 331 890 37.2 Santa Ana city 075902 4 202 543 37.2 Anaheim city 086402 3 518 1398 37.1 La Palma city 110102 3 166 447 37.1 Rancho Santa Margarita city 032051 1 402 1084 37.1 Dana Point city 042310 1 682 1849 36.9 Lake Forest city 052410 1 494 1337 36.9 Orange city 076000 2 644 1743 36.9 Orange city 076102 2 270 731 36.9 Westminster city 099902 2 612 1658 36.9 Cypress city 110106 3 641 1743 36.8 Fullerton city 011000 5 331 899 36.8 Seal Beach city 110008 3 315 855 36.8 Buena Park city 110304 2 671 1828 36.7 La Palma city 110111 3 47 128 36.7 Brea city 001507 2 270 738 36.6 Santa Ana city 075403 4 468 1280 36.6 Brea city 001501 1 578 1584 36.5 Fullerton city 001707 2 253 694 36.5 Huntington Beach city 099235 4 310 849 36.5 Huntington Beach city 099311 2 594 1626 36.5 Anaheim city 086303 1 353 971 36.4 Fullerton city 110605 1 341 936 36.4 Huntington Beach city 099245 2 597 1641 36.4 La Habra city 001705 2 420 1156 36.3 Buena Park city 110401 2 340 942 36.1 Huntington Beach city 099214 2 347 962 36.1 Huntington Beach city 099212 2 386 1073 36.0 La Palma city 110304 2 275 764 36.0 Westminster city 099602 1 381 1057 36.0 087701 2 501 1397 35.9 Garden Grove city 099203 2 234 653 35.8 Huntington Beach city 099416 1 759 2118 35.8 La Habra city 001401 2 345 964 35.8 Anaheim city 087200 4 307 861 35.7 Brea city 001503 2 310 868 35.7 Brea city 021814 2 700 1968 35.6 Laguna Hills city 062622 4 246 691 35.6 La Habra city 001601 4 71 200 35.5 Orange city 076206 3 315 894 35.2 Garden Grove city 088301 3 359 1025 35.0 Huntington Beach city 099306 4 408 1167 35.0 Irvine city 052523 1 270 772 35.0 Anaheim city 021903 3 384 1100 34.9 325 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Irvine city 052527 4 209 599 34.9 Dana Point city 042201 6 243 698 34.8 Orange city 076205 2 346 995 34.8 Los Alamitos city 110014 1 235 678 34.7 Aliso Viejo CDP 062636 1 417 1206 34.6 Huntington Beach city 099242 1 533 1542 34.6 Irvine city 052513 4 361 1044 34.6 La Habra city 001101 1 441 1273 34.6 Huntington Beach city 099242 2 765 2215 34.5 Irvine city 062610 1 508 1472 34.5 Orange city 076201 5 434 1258 34.5 Garden Grove city 110004 2 293 852 34.4 Santa Ana city 099203 2 512 1489 34.4 Yorba Linda city 021810 1 240 698 34.4 063102 1 168 489 34.4 Garden Grove city 088302 2 448 1308 34.3 Irvine city 052418 1 520 1518 34.3 Santa Ana city 075403 1 357 1040 34.3 Brea city 021814 4 584 1707 34.2 Fountain Valley city 099232 2 401 1171 34.2 Dana Point city 042323 3 457 1342 34.1 Orange city 075901 1 260 762 34.1 Anaheim city 021812 3 526 1549 34.0 Anaheim city 086303 3 294 865 34.0 Buena Park city 110304 1 739 2173 34.0 Laguna Beach city 062619 5 190 560 33.9 Newport Beach city 063400 6 295 871 33.9 001401 1 41 121 33.9 Irvine city 052515 4 529 1567 33.8 Laguna Woods city 062635 2 80 237 33.8 Newport Beach city 063006 5 203 600 33.8 021817 1 304 899 33.8 Huntington Beach city 099311 1 404 1201 33.6 075506 2 299 891 33.6 Fullerton city 011000 1 269 804 33.5 032049 1 53 158 33.5 Placentia city 011710 3 226 676 33.4 Westminster city 099903 1 587 1759 33.4 Anaheim city 087602 1 351 1054 33.3 Fountain Valley city 099250 1 513 1542 33.3 Placentia city 021821 2 1181 3542 33.3 Westminster city 088904 3 413 1242 33.3 Yorba Linda city 011718 1 191 576 33.2 Huntington Beach city 099408 2 429 1295 33.1 Irvine city 052519 1 319 963 33.1 Fullerton city 001505 4 409 1238 33.0 Garden Grove city 110004 1 348 1053 33.0 Irvine city 062612 5 402 1217 33.0 Anaheim city 087103 2 231 702 32.9 Orange city 076208 2 275 835 32.9 Anaheim city 087001 2 394 1203 32.8 32(0 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 086407 1 753 2308 32.6 Buena Park city 110401 4 287 880 32.6 Huntington Beach city 099603 1 550 1688 32.6 Westminster city 099241 2 197 605 32.6 Fullerton city 001505 3 368 1131 32.5 Fullerton city 001601 6 316 971 32.5 Laguna Hills city 062621 2 548 1688 32.5 Brea city 001503 1 506 1562 32.4 Dana Point city 042206 2 177 547 32.4 Garden Grove city 088202 2 495 1527 32.4 La Habra city 001102 2 297 918 32.4 Orange city 076000 4 548 1690 32.4 Santa Ana city 074004 3 599 1847 32.4 Orange city 021914 3 264 817 32.3 Orange city 075806 1 404 1249 32.3 Fountain Valley city 099224 2 485 1505 32.2 Placentia city 011721 2 136 423 32.2 Huntington Beach city 099239 2 327 1023 32.0 Huntington Beach city 099413 3 668 2085 32.0 Dana Point city 042313 4 178 558 31.9 Newport Beach city 063006 2 173 542 31.9 Orange city 076201 3 438 1375 31.9 Santa Ana city 075401 1 547 1722 31.8 Anaheim city 021922 2 262 826 31.7 Brea city 001403 2 60 189 31.7 Newport Beach city 062642 2 264 833 31.7 Orange city 076208 3 373 1177 31.7 Seal Beach city 099512 3 184 580 31.7 Irvine city 062628 2 467 1476 31.6 Lake Forest city 052410 2 336 1064 31.6 Newport Beach city 063400 1 281 888 31.6 Newport Beach city 063010 4 206 654 31.5 099506 3 147 466 31.5 Anaheim city 086902 3 491 1564 31.4 Fullerton city 011000 6 374 1194 31.3 Laguna Beach city 062620 4 328 1048 31.3 Orange city 075815 1 755 2410 31.3 Huntington Beach city 099406 2 851 2726 31.2 Huntington Beach city 099508 1 502 1607 31.2 Laguna Hills city 042320 1 531 1703 31.2 Orange city 075812 4 334 1070 31.2 Seal Beach city 099511 4 272 871 31.2 063009 1 24 77 31.2 Rancho Santa Margarita city 032051 2 282 907 31.1 Brea city 001507 3 605 1951 31.0 Buena Park city 110303 2 745 2404 31.0 Lake Forest city 052423 3 431 1391 31.0 Newport Beach city 062800 2 468 1512 31.0 Westminster city 088904 4 458 1476 31.0 Laguna Beach city 062632 4 371 1204 30.8 Rancho Santa Margarita city 032054 1 6621 2147 30.8 327 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Cypress city 110114 3 544 1771 30.7 Yorba Linda city 021830 4 240 783 30.7 Laguna Beach city 062619 3 338 1104 30.6 Westminster city 099905 2 390 1276 30.6 Cypress city 110110 3 529 1733 30.5 Garden Grove city 088203 3 206 675 30.5 Anaheim city 087501 1 581 1912 30.4 La Habra city 001403 2 328 1079 30.4 Laguna Beach city 062604 1 224 738 30.4 Dana Point city 042201 3 162 534 30.3 Huntington Beach city 099220 3 384 1268 30.3 Buena Park city 110201 1 521 1725 30.2 Huntington Beach city 099306 5 263 870 30.2 Huntington Beach city 099404 1 724 2397 30.2 Anaheim city 021919 1 441 1465 30.1 Cypress city 110114 1 506 1682 30.1 Dana Point city 042205 2 106 352 30.1 Garden Grove city 110004 3 341 1134 30.1 Huntington Beach city 099309 2 463 1539 30.1 087902 2 191 634 30.1 Cypress city 110113 1 563 1877 30.0 Fountain Valley city 099227 1 258 859 30.0 Los Alamitos city 110012 4 6 20 30.0 Anaheim city 086304 1 480 1606 29.9 Huntington Beach city 099237 1 500 1670 29.9 Huntington Beach city 099402 1 173 578 29.9 Yorba Linda city 021826 2 464 1552 29.9 087703 4 215 720 29.9 Garden Grove city 110003 2 535 1796 29.8 Newport Beach city 063006 6 114 383 29.8 Newport Beach city 063500 2 249 835 29.8 Anaheim city 021916 2 565 1900 29.7 Garden Grove city 088105 2 379 1276 29.7 Irvine city 052517 1 689 2317 29.7 Newport Beach city 063500 4 274 923 29.7 Fullerton city 001505 2 105 355 29.6 Westminster city 099701 1 351 1184 29.6 Fountain Valley city 099202 1 185 627 29.5 Fullerton city 001706 2 315 1067 29.5 Fullerton city 011503 2 266 903 29.5 Garden Grove city 088904 2 156 528 29.5 Huntington Beach city 099405 1 358 1214 29.5 Irvine city 052521 3 207 702 29.5 Laguna Hills city 042307 3 310 1055 29.4 Seal Beach city 099506 1 126 428 29.4 Lake Forest city 052424 3 478 1630 29.3 Newport Beach city 063004 2 476 1627 29.3 Anaheim city 021915 1 553 1896 29.2 Santa Ana city 074110 2 328 1124 29.2 Stanton city 087805 2 50 171 29.2 Placentia city 011717 2 237 814 29.1 328 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Yorba Linda city 021802 4 413 1420 29.1 Buena Park city 110203 1 202 696 29.0 Westminster city 099906 2 385 1329 29.0 Fountain Valley city 099230 2 695 2401 28.9 Laguna Woods city 062623 6 204 707 28.9 Rossmoor CDP 110006 1 402 1395 28.8 Irvine city 052513 2 254 886 28.7 Yorba Linda city 021815 1 526 1832 28.7 Buena Park city 110202 1 398 1394 28.6 Huntington Beach city 099602 2 447 1563 28.6 Lake Forest city 052425 4 527 1841 28.6 Huntington Beach city 099246 3 198 694 28.5 Tustin Foothills CDP 075603 2 383 1343 28.5 Westminster city 099241 1 578 2025 28.5 Buena Park city 110202 2 167 591 28.3 Buena Park city 110604 1 527 1862 28.3 Cypress city 110106 1 210 742 28.3 La Habra city 001101 3 289 1023 28.3 Orange city 076206 2 192 681 28.2 Brea city 021814 1 642 2286 28.1 Fullerton city 001503 4 257 913 28.1 Santa Ana city 075301 2 333 1185 28.1 Fountain Valley city 099231 2 513 1831 28.0 Fullerton city 001705 3 252 900 28.0 Fullerton city 110605 5 682 2440 28.0 Huntington Beach city 099310 2 488 1744 28.0 Laguna Hills city 062621 1 472 1687 28.0 Orange city 021913 3 541 1932 28.0 La Palma city 110116 1 418 1499 27.9 Garden Grove city 110005 2 471 1693 27.8 Huntington Beach city 099407 1 692 2485 27.8 Laguna Hills city 042327 2 254 914 27.8 Santa Ana city 075401 2 505 1816 27.8 Anaheim city 086306 3 278 1003 27.7 Buena Park city 110301 4 287 1036 27.7 Lake Forest city 052410 3 140 505 27.7 Seal Beach city 099512 2 231 835 27.7 Buena Park city 110604 4 242 881 27.5 Yorba Linda city 021802 2 271 987 27.5 Dana Point city 042324 1 200 729 27.4 Anaheim city 086306 2 288 1054 27.3 Fountain Valley city 099225 1 445 1629 27.3 Irvine city 052525 2 280 1026 27.3 Irvine city 052525 6 264 968 27.3 Newport Beach city 062800 1 154 564 27.3 Fullerton city 001601 5 444 1635 27.2 Irvine city 052505 3 199 731 27.2 La Habra city 001708 1 301 1111 27.1 Yorba Linda city 021822 3 272 1004 27.1 Fullerton city 001901 2 365 1351 27.0 Garden Grove city 110010 1 2771 1026 27.0 329 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Orange city 021918 1 340 1259 27.0 Rancho Santa Margarita city 032050 1 173 643 26.9 Rancho Santa Margarita city 032050 2 482 1790 26.9 Santa Ana city 075100 3 445 1657 26.9 Aliso Viejo CDP 042320 3 401 1503 26.7 Anaheim city 021903 1 394 1474 26.7 Huntington Beach city 099216 1 222 833 26.7 Laguna Hills city 042307 2 237 889 26.7 001101 4 133 498 26.7 Dana Point city 042311 4 379 1427 26.6 Dana Point city 042338 1 142 533 26.6 Fountain Valley city 099232 1 433 1627 26.6 Huntington Beach city 099214 1 207 777 26.6 Huntington Beach city 099416 2 390 1464 26.6 Irvine city 052519 2 319 1200 26.6 Irvine city 062629 2 218 821 26.6 Huntington Beach city 099605 1 520 1960 26.5 Placentia city 011716 1 1117 4213 26.5 Westminster city 099703 2 637 2401 26.5 Yorba Linda city 021802 3 340 1283 26.5 Yorba Linda city 021817 1 498 1880 26.5 087805 3 117 441 26.5 Newport Beach city 063500 3 237 897 26.4 Newport Beach city 063603 3 361 1365 26.4 Buena Park city 086803 2 223 847 26.3 Newport Beach city 063007 2 514 1955 26.3 Huntington Beach city 099216 2 402 1537 26.2 Rancho Santa Margarita city 032054 4 328 1258 26.1 Westminster city 099702 3 293 1121 26.1 Irvine city 052526 3 481 1853 26.0 Irvine city 052528 1 174 669 26.0 La Habra city 001301 3 311 1198 26.0 Seal Beach city 099512 4 200 768 26.0 Aliso Viejo CDP 062640 1 403 1557 25.9 La Habra city 001707 1 546 2107 25.9 Newport Beach city 062702 5 334 1292 25.9 Tustin Foothills CDP 075604 3 178 690 25.8 Westminster city 099601 4 224 873 25.7 Yorba Linda city 021827 2 252 982 25.7 Huntington Beach city 099237 2 473 1848 25.6 Irvine city 052505 1 200 784 25.5 Irvine city 052515 3 528 2076 25.4 Orange city 075805 2 339 1337 25.4 Orange city 076101 2 386 1520 25.4 Westminster city 099906 3 372 1462 25.4 Newport Beach city 063006 4 119 471 25.3 Placentia city 011709 4 351 1390 25.3 Seal Beach city 099511 3 150 594 25.3 Newport Beach city 062800 4 141 559 25.2 Dana Point city 042338 2 1074 4273 25.1 Garden Grove city 110001 1 435 1731 25.1 330 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Huntington Beach city 099604 2 456 1817 25.1 Anaheim city 087103 5 363 1452 25.0 Laguna Beach city 062604 4 138 551 25.0 Orange city 021913 2 312 1250 25.0 Brea city 001501 3 694 2788 24.9 Cypress city 110114 2 350 1405 24.9 Dana Point city 042339 1 180 723 24.9 Huntington Beach city 099240 3 423 1702 24.9 Seal Beach city 110007 2 205 822 24.9 Westminster city 099603 3 292 1171 24.9 Irvine city 052506 1 254 1026 24.8 Irvine city 052513 1 205 827 24.8 Irvine city 052525 5 141 569 24.8 Orange city 021914 1 251 1016 24.7 Santa Ana city 074110 1 663 2687 24.7 Aliso Viejo CDP 062639 2 495 2013 24.6 Cypress city 110109 3 294 1194 24.6 Irvine city 052511 3 221 899 24.6 Placentia city 021810 2 273 1110 24.6 Rossmoor CDP 110008 1 237 965 24.6 Orange city 075806 2 247 1008 24.5 Anaheim city 087805 2 108 442 24.4 Huntington Beach city 099306 1 362 1484 24.4 Huntington Beach city 099417 2 401 1643 24.4 Dana Point city 042311 3 204 841 24.3 Garden Grove city 088202 1 315 1297 24.3 Huntington Beach city 099214 3 225 929 24.2 Huntington Beach city 099405 2 291 1204 24.2 Orange city 075812 3 293 1210 24.2 001402 1 8 33 24.2 063102 4 113 467 24.2 Dana Point city 042323 1 352 1459 24.1 Irvine city 052521 4 232 961 24.1 Orange city 075807 2 459 1902 24.1 Placentia city 011709 2 171 711 24.1 001101 2 91 377 24.1 Fountain Valley city 099234 1 314 1308 24.0 Huntington Beach city 099238 1 465 1938 24.0 Aliso Viejo CDP 062634 1 208 872 23.9 Anaheim city 086305 1 240 1005 23.9 Huntington Beach city 099604 1 454 1897 23.9 Irvine city 052517 2 598 2500 23.9 Yorba Linda city 021809 3 171 714 23.9 Fountain Valley city 099204 3 114 479 23.8 Laguna Beach city 042305 1 226 950 23.8 Lake Forest city 052408 4 266 1117 23.8 Fountain Valley city 099229 2 517 2181 23.7 Fountain Valley city 099250 2 266 1121 23.7 Newport Beach city 063400 3 241 1016 23.7 Tustin Foothills CDP 075701 1 204 861 23.7 Fullerton city 001708 3 339 1438 23.6 331 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Fullerton city 011200 4 162 685 23.6 Huntington Beach city 099410 2 184 779 23.6 Laguna Hills city 062625 3 311 1319 23.6 Laguna Woods city 062623 2 26 110 23.6 Placentia city 011710 2 468 1986 23.6 Huntington Beach city 099406 1 400 1699 23.5 Irvine city 052520 3 229 973 23.5 Huntington Beach city 099215 2 407 1743 23.4 Irvine city 052505 5 522 2227 23.4 Laguna Beach city 062619 4 92 394 23.4 Huntington Beach city 099411 1 181 776 23.3 Irvine city 062611 4 123 529 23.3 Tustin Foothills CDP 075702 3 224 960 23.3 Tustin Foothills CDP 075703 2 408 1750 23.3 Newport Beach city 063400 5 79 341 23.2 Orange city 075807 1 264 1137 23.2 Westminster city 099223 3 265 1140 23.2 Fountain Valley city 099224 1 439 1903 23.1 Garden Grove city 110010 3 162 701 23.1 Huntington Beach city 099603 4 299 1296 23.1 Newport Beach city 062800 3 195 844 23.1 Brea city 001501 2 250 1086 23.0 Fountain Valley city 099231 1 426 1855 23.0 Fountain Valley city 099232 3 366 1598 22.9 Brea city 001404 1 83 364 22.8 Huntington Beach city 099311 3 216 946 22.8 Fullerton city 011503 1 174 768 22.7 Newport Beach city 062800 5 284 1251 22.7 Placentia city 011708 3 180 792 22.7 Huntington Beach city 099508 2 189 835 22.6 Rancho Santa Margarita city 032051 6 122 540 22.6 Anaheim city 021919 2 293 1303 22.5 Fullerton city 001704 2 176 782 22.5 Newport Beach city 062644 3 530 2352 22.5 Fountain Valley city 099223 3 124 554 22.4 Laguna Woods city 062621 3 110 491 22.4 Cypress city 110104 2 471 2110 22.3 Fullerton city 011300 2 239 1074 22.3 Orange city 076202 1 256 1148 22.3 Placentia city 021821 1 378 1697 22.3 Dana Point city 042323 4 172 777 22.1 Garden Grove city 110004 4 356 1613 22.1 Tustin Foothills CDP 075702 2 280 1269 22.1 Yorba Linda city 021816 1 244 1103 22.1 Huntington Beach city 099605 2 386 1758 22.0 Lake Forest city 052408 2 553 2509 22.0 Newport Beach city 062642 3 308 1398 22.0 Fountain Valley city 099234 2 375 1716 21.9 Lake Forest city 052425 2 173 790 21.9 Santa Ana city 074107 3 255 1165 21.9 Aliso Viejo CDP 062637 2 2861 1309 21.8 332 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Orange city 075605 1 139 638 21.8 Seal Beach city 099511 5 209 960 21.8 Anaheim city 086305 3 201 928 21.7 Huntington Beach city 099217 2 146 673 21.7 Huntington Beach city 099235 2 177 814 21.7 Huntington Beach city 099243 2 314 1447 21.7 Huntington Beach city 099310 1 373 1725 21.6 Huntington Beach city 099310 3 221 1023 21.6 Irvine city 052515 1 378 1750 21.6 Garden Grove city 088201 3 217 1008 21.5 Garden Grove city 110003 1 297 1379 21.5 Irvine city 052514 3 265 1233 21.5 Westminster city 099702 2 151 702 21.5 Buena Park city 086801 1 141 660 21.4 Laguna Beach city 062619 1 254 1187 21.4 Cypress city 110010 1 303 1425 21.3 Orange city 075811 1 368 1736 21.2 021914 3 182 860 21.2 Aliso Viejo CDP 062636 2 272 1292 21.1 Aliso Viejo CDP 062637 1 313 1486 21.1 Aliso Viejo CDP 062640 2 394 1871 21.1 Dana Point city 042206 1 76 361 21.1 Irvine city 062612 1 390 1848 21.1 Irvine city 062612 6 347 1647 21.1 Newport Beach city 062642 1 161 762 21.1 Newport Beach city 062644 4 303 1444 21.0 Orange city 021918 2 480 2282 21.0 Orange city 075813 1 337 1604 21.0 Cypress city 110111 2 405 1938 20.9 Irvine city 052513 3 240 1147 20.9 Lake Forest city 052410 4 284 1357 20.9 Fountain Valley city 099226 1 396 1906 20.8 Irvine city 062611 3 167 804 20.8 La Palma city 110102 1 338 1622 20.8 Seal Beach city 099512 1 133 638 20.8 Yorba Linda city 021825 1 400 1922 20.8 Fountain Valley city 099226 2 418 2019 20.7 Seal Beach city 099511 1 143 690 20.7 Yorba Linda city 021816 3 124 598 20.7 Brea city 001403 1 313 1520 20.6 Fountain Valley city 099227 3 331 1606 20.6 La Habra city 001301 2 267 1299 20.6 Lake Forest city 052422 1 243 1182 20.6 Garden Grove city 110005 1 300 1461 20.5 Huntington Beach city 099412 2 236 1153 20.5 La Palma city 110102 2 456 2226 20.5 Huntington Beach city 099235 1 247 1212 20.4 Yorba Linda city 021820 2 288 1409 20.4 Fountain Valley city 099251 3 256 1262 20.3 Huntington Beach city 099513 2 161 794 20.3 Newport Beach city 062644 2 240 1180 20.3 333 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Rossmoor CDP 110007 1 250 1233 20.3 Fullerton city 011200 1 191 947 20.2 Huntington Beach city 099217 3 208 1031 20.2 Seal Beach city 110012 4 312 1541 20.2 Fullerton city 001602 4 246 1226 20.1 Portola Hills CDP 052428 2 192 957 20.1 Yorba Linda city 021822 2 352 1755 20.1 021913 2 89 442 20.1 Fullerton city 011707 2 258 1289 20.0 Newport Beach city 062900 1 212 1059 20.0 Anaheim city 021905 1 335 1684 19.9 Anaheim city 021905 2 406 2040 19.9 Irvine city 062612 4 144 724 19.9 Lake Forest city 052422 3 233 1173 19.9 Westminster city 099906 1 398 1997 19.9 Brea city 011717 1 70 353 19.8 Tustin Foothills CDP 075603 1 239 1209 19.8 Yorba Linda city 021816 2 311 1573 19.8 Huntington Beach city 099216 3 189 957 19.7 Irvine city 052511 1 283 1435 19.7 Irvine city 062628 1 255 1292 19.7 Seal Beach city 099504 1 482 2447 19.7 Laguna Beach city 062620 5 110 562 19.6 Lake Forest city 032027 2 626 3192 19.6 Yorba Linda city 021823 1 560 2859 19.6 Cypress city 110010 2 229 1176 19.5 Irvine city 062629 1 361 1854 19.5 La Habra city 001403 1 91 467 19.5 Huntington Beach city 099602 1 104 535 19.4 Irvine city 052514 2 250 1290 19.4 Lake Forest city 052423 1 291 1498 19.4 Villa Park city 075810 2 213 1100 19.4 Yorba Linda city 021809 1 226 1165 19.4 Fullerton city 001704 1 274 1419 19.3 Garden Grove city 088001 1 257 1335 19.3 Newport Beach city 063500 6 223 1155 19.3 Yorba Linda city 021826 1 186 965 19.3 Aliso Viejo CDP 062634 4 173 902 19.2 Huntington Beach city 099309 1 389 2021 19.2 La Palma city 110116 2 360 1877 19.2 Newport Beach city 063400 4 153 798 19.2 032052 1 83 433 19.2 Huntington Beach city 099417 1 443 2315 19.1 Laguna Beach city 062605 4 124 648 19.1 Newport Beach city 063004 1 337 1768 19.1 Yorba Linda city 021810 2 80 418 19.1 011715 1 76 398 19.1 Irvine city 062614 1 421 2219 19.0 Laguna Hills city 042307 6 268 1409 19.0 Newport Beach city 062900 2 143 752 19.0 Placentia city 021820 2 320 1687 19.0 3S4 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% 075701 4 11 58 19.0 Fountain Valley city 099233 1 314 1658 18.9 Orange city 076201 1 146 774 18.9 021914 1 54 285 18.9 Dana Point city 042339 4 178 945 18.8 Laguna Hills city 042328 2 191 1017 18.8 032011 1 204 1086 18.8 Anaheim city 021905 3 277 1484 18.7 Huntington Beach city 099243 1 489 2617 18.7 Lake Forest city 052428 5 182 975 18.7 Orange city 076201 4 161 864 18.6 Placentia city 011712 3 144 775 18.6 Laguna Beach city 062604 2 123 666 18.5 Orange city 075808 1 162 874 18.5 Orange city 075812 2 212 1143 18.5 Orange city 075813 3 334 1808 18.5 Rossmoor CDP 110008 2 204 1103 18.5 Anaheim city 021807 2 340 1843 18.4 Villa Park city 075810 3 144 781 18.4 Aliso Viejo CDP 062638 1 452 2470 18.3 Huntington Beach city 099239 3 171 935 18.3 La Palma city 110115 2 211 1152 18.3 032041 1 72 393 18.3 Huntington Beach city 099245 1 260 1426 18.2 Newport Beach city 062701 1 353 1943 18.2 Placentia city 011709 1 197 1080 18.2 Rancho Santa Margarita city 032048 3 239 1313 18.2 Irvine city 052526 2 344 1904 18.1 Irvine city 062612 2 189 1042 18.1 Laguna Hills city 062621 3 184 1018 18.1 Newport Beach city 062702 1 120 664 18.1 Orange city 075808 2 208 1149 18.1 Fullerton city 001707 3 265 1470 18.0 Lake Forest city 052416 2 349 1937 18.0 Yorba Linda city 021820 1 197 1097 18.0 021917 2 111 621 17.9 Cypress city 110117 2 182 1025 17.8 Laguna Hills city 042307 1 281 1577 17.8 Newport Beach city 063009 1 280 1577 17.8 Santa Ana city 074111 1 208 1169 17.8 Huntington Beach city 099217 1 134 756 17.7 Laguna Beach city 062623 6 205 1159 17.7 Orange city 076202 2 129 730 17.7 Yorba Linda city 021822 1 167 941 17.7 099506 2 64 361 17.7 Newport Beach city 063603 2 254 1447 17.6 Cypress city 110118 2 242 1385 17.5 Santa Ana city 075303 1 180 1031 17.5 Placentia city 011710 1 133 763 17.4 Irvine city 052525 3 149 859 17.3 Los Alamitos city 110015 2 323 1862 17.3 335 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Newport Beach city 063005 2 118 683 17.3 011718 1 47 272 17.3 Fullerton city 001706 3 131 762 17.2 Laguna Beach city 042305 3 263 1527 17.2 Anaheim city 021923 3 190 1110 17.1 Fullerton city 001505 1 311 1823 17.1 Huntington Beach city 099415 1 184 1076 17.1 Huntington Beach city 099702 2 66 385 17.1 Dana Point city 042323 2 194 1139 17.0 Fullerton city 011402 1 163 957 17.0 Huntington Beach city 099240 1 309 1818 17.0 Irvine city 052511 6 154 904 17.0 Lake Forest city 052422 2 292 1713 17.0 042335 1 168 990 17.0 Dana Point city 042305 2 84 496 16.9 Fullerton city 001601 4 74 437 16.9 Lake Forest city 052415 2 346 2043 16.9 021812 2 64 378 16.9 075808 1 74 438 16.9 Newport Beach city 063007 3 330 1969 16.8 Tustin Foothills CDP 075701 3 77 458 16.8 Anaheim city 021920 1 137 818 16.7 Irvine city 052515 2 250 1496 16.7 Irvine city 062630 1 283 1699 16.7 Garden Grove city 076103 1 38 229 16.6 La Habra city 001708 2 230 1385 16.6 Anaheim city 021915 2 85 514 16.5 Cypress city 110118 1 255 1550 16.5 Lake Forest city 052424 2 239 1448 16.5 Irvine city 052417 4 172 1049 16.4 Laguna Beach city 062632 1 313 1921 16.3 Lake Forest city 032029 2 527 3226 16.3 Newport Beach city 063006 3 100 614 16.3 Rancho Santa Margarita city 032055 4 207 1268 16.3 Westminster city 099603 2 126 774 16.3 032011 2 35 215 16.3 Fullerton city 001707 4 280 1727 16.2 Rancho Santa Margarita city 032055 3 177 1095 16.2 Yorba Linda city 021809 2 113 697 162 Anaheim city 021922 4 231 1432 16.1 Fullerton city 001601 2 190 1180 16.1 Irvine city 052522 1 233 1451 16.1 Placentia city 011709 3 195 1208 16.1 Buena Park city 110301 1 207 1297 16.0 Fullerton city 011402 2 208 1301 16.0 Irvine city 052520 2 136 848 16.0 Laguna Beach city 042305 2 128 799 16.0 Orange city 075814 1 400 2497 16.0 Placentia city 011715 3 262 1639 16.0 Tustin Foothills CDP 075604 5 2401 1504 16.0 Fullerton city 011401 2 2121 1332 15.9 33O Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Huntington Beach city 099404 2 369 2323 15.9 Tustin Foothills CDP 075604 1 189 1190 15.9 021918 1 27 170 15.9 Aliso Viejo CDP 062635 2 245 1553 15.8 Anaheim city 021812 2 318 2012 15.8 Orange city 075815 3 164 1037 15.8 Yorba Linda city 021827 1 52 330 15.8 Cypress city 110001 1 166 1056 15.7 Fountain Valley city 099225 2 272 1728 15.7 Orange city 021917 1 146 931 15.7 Rancho Santa Margarita city 032056 2 136 864 15.7 Fountain Valley city 099202 3 49 315 15.6 Anaheim city 021923 1 217 1400 15.5 Huntington Beach city 099412 3 255 1648 15.5 Orange city 075809 3 9 58 15.5 Tustin Foothills CDP 075606 4 195 1258 15.5 Newport Beach city 063500 5 50 324 15.4 Seal Beach city 110012 1 200 1300 15.4 Tustin Foothills CDP 075703 1 343 2224 15.4 Aliso Viejo CDP 062639 1 178 1165 15.3 Fullerton city 001601 3 159 1038 15.3 Huntington Beach city 099514 3 194 1272 15.3 Newport Beach city 062702 3 169 1102 15.3 Irvine city 052421 4 62 408 15.2 Lake Forest city 052427 2 371 2446 15.2 Irvine city 052520 4 194 1287 15.1 Anaheim city 075813 1 59 394 15.0 Dana Point city 042201 4 102 680 15.0 Irvine city 062631 2 116 771 15.0 Rossmoor CDP 110006 2 226 1503 15.0 Tustin Foothills CDP 075606 5 33 220 15.0 Villa Park city 075809 1 152 1010 15.0 Brea city 001506 2 320 2147 14.9 Laguna Beach city 062604 3 63 424 14.9 Yorba Linda city 021829 1 315 2108 14.9 Fountain Valley city 099230 1 293 1985 14.8 Huntington Beach city 099240 4 117 789 14.8 Irvine city 052527 2 439 2964 14.8 Rossmoor CDP 110008 3 204 1381 14.8 Anaheim city 021903 2 203 1384 14.7 Anaheim city 021924 1 640 4357 14.7 Dana Point city 042311 2 132 899 14.7 063103 1 109 742 14.7 Irvine city 052522 4 115 787 14.6 Laguna Beach city 062620 3 127 869 14.6 Lake Forest city 052416 3 194 1333 14.6 Irvine city 052421 3 183 1258 14.5 Placentia city 011718 1 111 766 14.5 Placentia city 011718 2 196 1352 14.5 Rancho Santa Margarita city 032034 3 1911 1316 14.5 Fountain Valley city 099232 4 1461 1014 14.4 337 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Huntington Beach city 099240 2 121 843 14.4 La Palma city 110115 3 207 1450 14.3 Laguna Hills city 042327 3 344 2414 14.3 Laguna Beach city 062620 1 171 1202 14.2 Fullerton city 001602 1 194 1377 14.1 Aliso Viejo CDP 062635 3 158 1131 14.0 Fullerton city 001706 4 109 781 14.0 Irvine city 052514 4 220 1575 14.0 Newport Beach city 063007 1 165 1180 14.0 Aliso Viejo CDP 062636 3 166 1198 13.9 Aliso Viejo CDP 062639 3 323 2323 13.9 Yorba Linda city 021824 1 156 1119 13.9 Newport Beach city 063103 1 51 370 13.8 Aliso Viejo CDP 062641 3 127 925 13.7 Buena Park city 110301 2 179 1303 13.7 Irvine city 052417 1 269 1966 13.7 Laguna Beach city 062620 2 189 1384 13.7 Aliso Viejo CDP 062634 5 177 1300 13.6 Aliso Viejo CDP 062639 4 101 740 13.6 Lake Forest city 052426 2 293 2162 13.6 Anaheim city 021921 2 408 3012 13.5 Huntington Beach city 099514 4 80 594 13.5 Irvine city 052527 1 407 3022 13.5 Laguna Beach city 062632 3 84 620 13.5 Huntington Beach city 099239 1 276 2055 13.4 Irvine city 052528 3 145 1085 13.4 Orange city 075605 4 180 1341 13.4 Brea city 021815 1 60 450 13.3 Buena Park city 086801 3 20 150 13.3 Huntington Beach city 099220 4 194 1458 13.3 Huntington Beach city 099238 2 288 2161 13.3 Fountain Valley city 099231 3 262 1981 13.2 Rancho Santa Margarita city 032043 2 200 1512 13.2 Cypress city 110011 2 169 1292 13.1 Irvine city 052511 2 99 753 13.1 Newport Beach city 063005 1 102 779 13.1 Rossmoor CDP 110007 4 228 1735 13.1 Villa Park city 075809 3 127 973 13.1 Anaheim city 021920 2 166 1279 13.0 Laguna Beach city 062619 2 93 717 13.0 Newport Beach city 063400 2 135 1040 13.0 Placentia city 011715 2 344 2640 13.0 Rancho Santa Margarita city 032053 1 320 2459 13.0 Huntington Beach city 099415 3 84 649 12.9 Orange city 075810 1 29 224 12.9 Villa Park city 075809 2 140 1089 12.9 Dana Point city 042339 2 48 374 12.8 Fountain Valley city 099229 1 221 1725 12.8 Newport Beach city 063010 3 173 1355 12.8 Newport Beach city 063601 3 78 609 12.8 Rancho Santa Margarita city 032053 2 2161 1686 12.8 338 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 021923 2 282 2221 12.7 Las Flores CDP 032053 4 252 1986 12.7 Tustin Foothills CDP 075702 1 115 909 12.7 Fullerton city 001706 1 113 894 12.6 Newport Beach city 062702 4 87 692 12.6 Newport Beach city 063006 1 63 505 12.5 Newport Beach city 063008 9 110 877 12.5 Coto de Caza CDP 032044 3 222 1789 12.4 Newport Beach city 063500 8 97 788 12.3 Orange city 075605 3 244 1978 12.3 Rancho Santa Margarita city 032049 3 195 1588 12.3 Newport Beach city 062643 1 85 694 12.2 Rancho Santa Margarita city 032049 1 294 2411 12.2 Orange city 021912 3 135 1115 12.1 Irvine city 052522 2 144 1202 12.0 Newport Beach city 062701 2 115 959 12.0 Orange city 021917 2 158 1314 12.0 Anaheim city 021920 4 230 1926 11.9 Huntington Beach city 099415 4 301 2531 11.9 Huntington Beach city 099513 1 140 1189 11.8 Anaheim city 021920 3 152 1307 11.6 Laguna Hills city 042327 1 210 1805 11.6 Laguna Hills city 042328 1 152 1312 11.6 Aliso Viejo CDP 062635 1 139 1209 11.5 Cypress city 110011 1 167 1456 11.5 Orange city 021912 2 152 1318 11.5 Orange city 021913 1 96 840 11.4 Anaheim city 021922 1 159 1401 11.3 Coto de Caza CDP 032045 2 189 1674 11.3 Lake Forest city 052428 3 101 893 11.3 Lake Forest city 052428 4 253 2248 11.3 Villa Park city 075810 1 101 892 11.3 Aliso Viejo CDP 062634 2 250 2226 11.2 Coto de Caza CDP 032045 1 131 1170 11.2 Yorba Linda city 021830 1 153 1372 11.2 Newport Beach city 063007 4 91 822 11.1 Rancho Santa Margarita city 032049 4 299 2699 11.1 Lake Forest city 052408 1 133 1208 11.0 Irvine city 052523 2 201 1841 10.9 Irvine city 052525 1 130 1191 10.9 Newport Beach city 062643 2 149 1361 10.9 Newport Beach city 062645 1 190 1746 10.9 Irvine city 052528 2 93 865 10.8 Newport Beach city 062702 2 99 928 10.7 Lake Forest city 052426 1 113 1071 10.6 Newport Beach city 062645 2 95 900 10.6 Newport Beach city 063004 4 139 1313 10.6 Rancho Santa Margarita city 032051 5 66 622 10.6 Anaheim city 021923 4 83 791 10.5 Placentia city 021810 1 461 439 10.5 Yorba Linda city 021825 2 1541 1469 10.5 339 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 021915 3 164 1573 10.4 Fullerton city 110605 4 106 1018 10.4 Huntington Beach city 099308 1 519 5044 10.3 Irvine city 052513 6 92 893 10.3 Orange city 075604 5 145 1404 10.3 Coto de Caza CDP 032044 2 184 1811 10.2 Laguna Beach city 062632 2 27 265 10.2 Yorba Linda city 021817 2 91 894 10.2 Yorba Linda city 021829 2 183 1795 10.2 Rancho Santa Margarita city 032042 1 379 3768 10.1 Santa Ana city 075806 3 42 417 10.1 Seal Beach city 110012 3 94 927 10.1 Huntington Beach city 099703 1 37 370 10.0 Irvine city 052506 2 149 1496 10.0 Irvine city 052523 3 148 1477 10.0 Irvine city 062631 3 81 810 10.0 Fullerton city 001602 2 99 998 9.9 Lake Forest city 052427 1 263 2658 9.9 Huntington Beach city 099514 1 145 1487 9.8 Newport Beach city 062645 4 67 682 9.8 Yorba Linda city 011717 1 22 226 9.7 Coto de Caza CDP 032046 4 110 1148 9.6 Tustin Foothills CDP 075605 2 189 1966 9.6 Anaheim city 021916 1 158 1667 9.5 Huntington Beach city 099246 2 178 1872 9.5 Irvine city 052417 3 183 1943 9.4 Orange city 075604 4 114 1213 9.4 Los Alamitos city 110108 1 112 1207 9.3 Lake Forest city 052411 3 108 1168 9.2 Yorba Linda city 021824 2 162 1765 9.2 Seal Beach city 110012 2 99 1085 9.1 Cypress city 110109 1 64 711 9.0 Irvine city 052525 4 142 1574 9.0 Newport Beach city 062645 3 97 1080 9.0 021917 1 44 496 8.9 Orange city 075814 2 73 829 8.8 Orange city 075816 2 120 1369 8.8 Yorba Linda city 021830 2 137 1564 8.8 021816 3 45 513 8.8 Rancho Santa Margarita city 032050 3 167 1924 8.7 Yorba Linda city 021810 3 84 991 8.5 Huntington Beach city 099246 1 102 1217 8.4 Newport Beach city 063010 1 162 1924 8.4 Newport Beach city 063010 5 76 907 8.4 Yorba Linda city 021830 3 180 2157 8.3 Huntington Beach city 099413 1 147 1802 8.2 Lake Forest city 052415 1 169 2064 8.2 Anaheim city 021921 1 118 1493 7.9 032041 1 46 580 7.9 032049 2 51 646 7.9 Newport Coast CDP 062643 3 101 1297 7.8 340 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Yorba Linda city 021829 3 116 1489 7.8 Fullerton city 001602 3 52 671 7.7 Coto de Caza CDP 032044 1 76 1009 7.5 Coto de Caza CDP 032046 2 117 1594 7.3 Huntington Beach city 099244 1 153 2099 7.3 Aliso Viejo CDP 062633 1 194 2704 7.2 Huntington Beach city 099514 5 69 961 7.2 Irvine city 052420 3 193 2746 7.0 Laguna Hills city 062647 3 59 839 7.0 Las Flores CDP 032056 4 112 1594 7.0 Orange city 021912 1 58 832 7.0 Aliso Viejo CDP 062638 2 132 1919 6.9 Portola Hills CDP 052428 1 90 1318 6.8 Yorba Linda city 021828 3 126 1845 6.8 Laguna Hills city 042333 1 129 1913 6.7 Rancho Santa Margarita city 032048 4 122 1823 6.7 Tustin Foothills CDP 075606 2 48 715 6.7 Irvine city 052420 2 140 2141 6.5 Yorba Linda city 021827 3 112 1724 6.5 032011 2 28 434 6.5 Aliso Viejo CDP 062633 2 58 914 6.3 Irvine city 052421 2 84 1331 6.3 Rossmoor CDP 110007 3 58 923 6.3 Yorba Linda city 021828 2 81 1359 6.0 Tustin Foothills CDP 075604 2 89 1546 5.8 Tustin Foothills CDP 075606 1 60 1047 5.7 Irvine city 062631 1 63 1138 5.5 Irvine city 052522 3 33 615 5.4 Newport Beach city 062644 1 86 1599 5.4 Huntington Beach city 099514 2 80 1507 5.3 Placentia city 021815 1 9 174 5.2 021816 2 20 382 5.2 075807 2 6 115 5.2 Irvine city 052526 1 31 622 5.0 Stanton city 110113 1 19 388 4.9 Irvine city 052420 1 123 2551 4.8 Dana Point city 042324 2 46 996 4.6 Coto de Caza CDP 032044 4 63 1447 4.4 Irvine city 052421 1 78 1823 4.3 Laguna Hills city 042333 2 109 2514 4.3 Rancho Santa Margarita city 032042 3 59 1365 4.3 Anaheim city 021922 3 38 922 4.1 Rancho Santa Margarita city 032050 4 31 786 3.9 Tustin Foothills CDP 075606 3 40 1038 3.9 Lake Forest city 052408 3 59 1551 3.8 Yorba Linda city 021812 1 32 834 3.8 Huntington Beach city 099415 2 43 1231 3.5 Rancho Santa Margarita city 032043 1 96 2775 3.5 062604 3 351 1 042 3.4 Yorba Linda city 021828 1 47 1501 3.1 Rancho Santa Margarita city 032056 1 221 803 2.7 S41 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Irvine city 062631 4 20 822 2.4 Las Flores CDP 032056 3 35 2072 1.7 Brea city 021814 3 9 1036 0.9 Lake Forest city 052426 3 8 1397 0.6 Anaheim city 021813 9 0 10 0.0 Anaheim city 021923 2 0 342 0.0 Anaheim city 075813 3 0 106 0.0 Coto de Caza CDP 032046 3 0 189 0.0 Coto de Caza CDP 032046 1 0 756 0.0 Coto de Caza CDP 032046 3 0 470 0.0 Cypress city 110010 3 0 75 0.0 Garden Grove city 088904 1 0 125 0.0 Garden Grove city 110010 2 0 157 0.0 Irvine city 052518 1 0 2 0.0 Newport Beach city 062610 1 0 7 0.0 Newport Beach city 062645 1 0 416 0.0 Orange city 021915 2 0 85 0.0 Orange city 075810 3 0 60 0.0 Villa Park city 075811 1 0 79 0.0 Villa Park city 075813 1 0 28 0.0 Villa Park city 075814 2 0 58 0.0 Yorba Linda city 021823 2 0 338 0.0 Yorba Linda city 021827 1 0 520 0.0 001707 2 0 184 0.0 021912 3 0 95 0.0 052404 1 0 20 0.0 052426 1 0 36 0.0 063102 3 0 64 0.0 075604 4 0 34 0.0 087801 3 01 22 0.0 Technical Appendix D 2008 Home Mortgage Disclosure Act Data for Orange County �4S Table D -1 Orange County Disposition of Loan Applications By Race /Ethnicity — 2008 FHA, FSA/RHS and VA Home Purchase Loans Loans Originated Applications Approved, but Not Accepted Applications Denied Total Applications Percent Denied American Indian /Alaska Native 29 4 9 42 21.4% Asian 238 28 80 346 23.1% Black or African American 64 13 20 97 20.6% Nat. Hawaiian /Other Pacific Isl. 41 4 8 53 15.1% White 2,408 313 671 3,392 19.8% Two or More Races 4 0 1 5 20.0% Joint (White/Minority Race 104 14 28 146 19.2% Race Not Available 275 54 130 459 28.3% Total 3,163 430 947 4,540 20.9% Hispanic or Latino 795 104 340 1,239 27.4% Joint (Hispanic /Latino & Non Hispanic /Latino ) 167 16 29 212 13.7% Conventional Home Purchase Loans Loans Originated Applications Approved, but Not Accepted Applications Denied Total Applications Percent Denied American Indian /Alaska Native 74 20 46 140 32.9% Asian 4,824 979 1,261 7,064 17.9% Black or African American 117 30 56 203 27.6% Nat. Hawaiian /Other Pacific Isl. 108 21 34 163 20.9% White 10,917 2,360 3,685 16,962 21.7% Two or More Races 20 1 5 26 19.2% Joint (White/Minority Race 458 72 109 639 17.1% Race Not Available 2,515 644 1,011 4,170 24.2% Total 19,033 4,127 6,207 29,367 21.1% Hispanic or Latino 1,788 690 1,181 3,659 32.3% Joint (Hispanic /Latino & Non Hispanic /Latino) 411 72 111 594 18.7% mjzji Table D -1 continued Orange County Disposition of Loan Applications By Race /Ethnicity — 2008 Refinance Loan Applications Loans Originated Applications Approved, but Not Accepted Applications Denied Total Applications Percent Denied American Indian /Alaska Native 123 48 408 579 70.5% Asian 2,686 763 1,604 5,053 31.7% Black or African American 160 58 242 460 52.6% Nat. Hawaiian /Other Pacific Isl. 175 44 223 442 50.5% White 18,419 4,302 10,791 33,512 32.2% Two or More Races 29 1 24 54 44.4% Joint (White/Minority Race 490 87 311 888 35.0% Race Not Available 5,037 1,374 3,407 9,818 34.7% Total 27,119 6,677 17,010 50,806 33.5% Hispanic or Latino 2,902 1,178 3,651 7,731 47.2% Joint (Hispanic /Latino & Non Hispanic /Latino ) 647 113 398 1,158 34.4% Home Improvement Loans Loans Originated Applications Approved, but Not Accepted Applications Denied Total Applications Percent Denied American Indian /Alaska Native 39 7 100 146 68.5% Asian 189 47 242 478 50.6% Black or African American 24 4 45 73 61.6% Nat. Hawaiian /Other Pacific Isl. 10 4 25 39 64.1% White 1,848 336 1,409 3,593 39.2% Two or More Races 0 0 3 3 100.0% Joint (White/Minority Race 45 5 45 95 47.4% Race Not Available 722 222 633 1,577 40.1% Total 2,877 625 2,502 6,004 41.7% Hispanic or Latino 342 96 556 994 55.9% Joint (Hispanic /Latino & Non Hispanic /Latino) 88 9 64 161 39.8% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 4 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 4 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 4 -3 Disposition of Applications to Refinance Loans on 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 4-4 Disposition of Applications for Home Improvement Loans 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Table construction by Castaneda & Associates S45 Table D -2 Orange County Disposition of FHA Loan Applications By Race /Ethnicity -2004 and 2008 Race/Ethnicity Loans Originated App. Approved But Not Accepted Applications Denied Total Applications Percent Denied 2004 2008 2004 2008 2004 2008 2004 2008 2004 2008 White, Non Hispanic 67 1,613 0 209 4 331 71 2,153 5.6% 15.4% Hispanic 79 795 8 104 18 340 105 1,239 17.1% 27.4% Asian 14 238 3 28 3 80 20 346 15.0% 23.1% American Indian /Alaska Native 10 29 0 4 0 9 10 42 0.0% 21.4% Black or African American 6 64 0 13 1 20 7 97 14.3% 20.6% Nat. Hawaiian/Other Pac.ISI. 3 41 1 4 0 8 4 53 0.0% 15.1% 2 or More Minority Races 0 4 0 0 2 1 2 5 100.0% 20.0% Joint White/Minority 7 104 0 14 1 28 8 146 12.5% 19.2% Race Not Available 48 275 12 54 14 130 74 459 18.9% 28.3% Subtotal 234 3,163 24 430 43 947 301 4,540 14.3% 20.9% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 4 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2004 and 2008 Table construction by Castaneda & Associates OJIM Table D -3 Orange County Disposition of Conventional Loan Applications By Race /Ethnicity -2004 and 2008 Race/Ethnicity Loans Originated App. Approved But Not Accepted Applications Denied Total Applications Percent Denied 2004 2008 2004 2008 2004 2008 2004 2008 2004 2008 White, Non Hispanic 23,785 9,129 3,806 1,670 3,871 2,504 31,462 13,303 12.3% 18.8% Hispanic 12,275 1,788 2,382 690 3,868 1,181 18,525 3,659 20.9% 32.3% Asian 8,501 4,824 2,004 979 1,911 1,261 12,416 7,064 15.4% 17.9% American Indian /Alaska Native 899 74 118 20 219 46 1,236 140 17.7% 32.9% Black or African American 603 117 94 30 216 56 913 203 23.7% 27.6% Nat. Hawaiian /Other Pac. Isl. 611 108 129 21 204 34 944 163 21.6% 20.9% 2 or More Minority Races 57 20 16 1 15 5 88 26 17.0% 19.2% Joint White/Minority 1,005 458 202 72 167 109 1,374 639 12.2% 17.1% Race Not Available 12,041 2,515 3,523 644 4,081 1,011 19,645 4,170 20.8% 24.2% Subtotal 59,777 19,033 12,274 4,127 14,552 6,207 86,603 29,367 16.8% 21.1% Source: Aggregate Table 4 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2004 and 2008 Table construction by Castaneda & Associates 347 Table D -4 Orange County FHA/VA Denial Rates by Income and Race /Ethnicity — 2008 Income Category Loans Ori inated App. Approved But Not Accepted Applications Denied Total Applications Percent Denied Very Low White, Non Hispanic 19 1 5 25 20.0% Hispanic 40 1 20 61 32.8% Asian 2 0 1 3 33.3% American Indian /Alaska Native 0 0 0 0 0.0% Black or African American 1 0 0 1 0.0% Nat. Hawaiian /Other Pac. IsI. 1 0 0 1 0.0% 2 or More Minority Races 0 0 0 0 0.0% Joint White/Minority 0 0 0 0 0.0% Race Not Available 3 4 11 18 61.1% Subtotal 66 6 37 109 33.9% Low White, Non Hispanic 182 17 40 239 16.7% Hispanic 179 23 96 298 32.2% Asian 28 4 16 48 33.3% American Indian /Alaska Native 10 0 4 14 28.6% Black or African American 17 1 4 22 18.2% Nat. Hawaiian /Other Pac. Isl. 2 0 1 3 33.3% 2 or More Minority Races 0 0 0 0 0.0% Joint White/Minority 8 1 5 14 35.7% Race Not Available 32 8 28 68 41.2% Subtotal 458 54 194 706 27.5% Moderate White, Non Hispanic 429 65 78 572 13.6% Hispanic 327 45 138 510 27.1 % Asian 87 11 21 119 17.6 % American Indian /Alaska Native 9 1 3 13 23.1% Black or African American 15 5 7 27 25.9% Nat. Hawaiian /Other Pac. Isl. 14 1 3 18 16.7% 2 or More Minority Races 2 0 1 3 33.3% Joint White/Minority 31 3 4 38 10.5% Race Not Available 99 12 37 148 25.0% Subtotal 1,013 143 292 1,448 20.2% 348 Table D -4 continued Orange County FHA/VA Denial Rates by Income and Race /Ethnicity — 2008 Income Category Loans Originate App. Approved But Not Accepted Applications Denied Total Applications Percent Denied Above Moderate White, Non Hispanic 940 115 183 1,238 14.8% Hispanic 234 34 73 341 21.4% Asian 118 13 38 169 22.5% American Indian /Alaska Native 10 3 2 15 13.3% Black or African American 28 7 9 44 20.5% Nat. Hawaiian /Other Pac. Isl. 23 3 3 29 10.3% 2 or More Minority Races 2 0 0 2 0.0% Joint White/Minority 56 10 18 84 21.4% Race Not Available 137 29 48 214 22.4% Subtotal 1,548 214 374 2,136 17.5% All Income Levels White, Non Hispanic 1,570 198 306 2,074 14.8% Hispanic 780 103 327 1,210 27.0% Asian 235 28 76 339 22.4% American Indian /Alaska Native 29 4 9 42 21.4% Black or African American 61 13 20 94 21.3% Nat. Hawaiian /Other Pac. Isl. 40 4 7 51 13.7% 2 or More Minority Races 4 0 1 5 20.0% Joint White/Minority 95 14 27 136 19.90/c Race Not Available 271 53 124 448 27.7% Subtotal 3,085 417 897 4,399 20.4% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5- 1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Table construction by Castaneda & Associates S -" Table D -5 Orange County Conventional Denial Rates by Income and Race /Ethnicity -2008 Income Category Loans Originated App. Approved But Not Accepted Applications Denied Total Applications Percent Denied Very Low White, Non Hispanic 192 47 79 318 24.8% Hispanic 76 32 88 196 44.9% Asian 100 20 59 179 33.0% American Indian /Alaska Native 1 1 3 5 60.0% Black or African American 5 3 4 12 33.3% Nat. Hawaiian /Other Pac. Isl. 6 1 4 11 36.4% 2 or More Minority Races 0 0 1 1 100.0% Joint White/Minority 3 1 1 5 20.6% Race Not Available 44 9 70 123 56.9% Subtotal 427 114 309 850 36.4% Low White, Non Hispanic 907 162 243 1,312 18.5% Hispanic 455 179 272 906 30.0% Asian 805 133 164 1,102 14.9% American Indian /Alaska Native 18 4 11 33 33.5% Black or African American 12 7 17 36 47.2% Nat. Hawaiian /Other Pac. Isl. 11 2 4 17 23.5% 2 or More Minority Races 4 0 2 6 33.3% Joint White/Minority 18 3 7 28 25.0% Race Not Available 239 93 128 460 27.8% Subtotal 2,469 583 848 3,900 21.7% Moderate White, Non Hispanic 1,942 326 446 2,714 16.4% Hispanic 600 244 413 1,257 32.9% Asian 1,372 265 313 1,950 16.1% American Indian /Alaska Native 13 3 14 30 467% Black or African American 44 6 12 62 19.4% Nat. Hawaiian /Other Pac. Isl. 33 9 8 50 16.0% 2 or More Minority Races 3 0 0 3 0.0% Joint White/Minority 70 12 21 103 20.4% Race Not Available 466 135 197 798 24.7% Subtotal 4,543 1,000 1,424 6,967 20.4% 350 Table D -5 continued Orange County Conventional Denial Rates by Income and Race /Ethnicity -2008 Income Category Loans Originate App. Approved But Not Accepted Applications Denied Total Applications Percent Denied Above Moderate White, Non Hispanic 6,032 1,131 1,689 8,852 19.1% Hispanic 647 224 400 1,271 31.5% Asian 2,463 549 694 3,706 18.7% American Indian /Alaska Native 42 12 16 70 22.9% Black or African American 56 14 22 92 23.9% Nat. Hawaiian /Other Pac. Isl. 57 9 17 83 20.5% 2 or More Minority Races 13 1 2 16 12.5% Joint White/Minority 358 53 78 489 16.0% Race Not Available 1,720 397 590 2,707 21.8% Subtotal 11,388 2,390 3,508 17,286 20.3% All Income Levels White, Non Hispanic 9,073 1,666 2,457 13,196 18.6% Hispanic 1,778 679 1,173 3,630 32.3% Asian 4,740 967 1,230 6,937 17.7% American Indian /Alaska Native 74 20 44 138 31.9% Black or African American 117 30 55 202 27.2% Nat. Hawaiian /Other Pac. Isl. 107 21 33 161 20.5% 2 or More Minority Races 20 1 5 26 19.2% Joint White/Minority 449 69 107 625 17.1% Race Not Available 2,469 634 985 4,088 24.1% Subtotal 18,827 4,087 6,089 29,003 21.0% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5- 2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Table construction by Castaneda & Associates Notes: 1. APPLICANTS ARE SHOWN IN ONLY ONE RACE CATEGORY. FOR PURPOSES OF CATEGORIZATION, THE GENERAL RULE IS: THE RACE (INCLUDING SITUATIONS WHERE RACE WAS REPORTED AS NOT PROVIDED OR NOT APPLICABLE) OF THE APPLICATION IS CATEGORIZED BY THE RACE OF THE FIRST PERSON LISTED ON THE APPLICATION UNLESS THE "JOINT" RACE DEFINITION APPLIES. ('JOINT- MEANS ONE APPLICANT REPORTS A SINGLE RACIAL DESIGNATION OF 'WHITE" AND THE OTHER APPLICANT REPORTS ONE OR MORE MINORITY RACIAL DESIGNATIONS.) IF THE "JOINT" DEFINITION DOES NOT APPLY, THE RACE OF THE FIRST PERSON ON THE APPLICATION IS CATEGORIZED AS FOLLOWS: • THE REPORTED RACE WHEN A SINGLE RACIAL DESIGNATION IS REPORTED; OR • "2 OR MORE MINORITY RACES" W HEN TWO OR MORE MINORITY RACIAL DESIGNATIONS ARE REPORTED; OR • THE MINORITY RACE WHEN TWO RACIAL DESIGNATIONS ARE REPORTED AND ONE IS WHITE. 2. "NOT AVAILABLE" INCLUDES SITUATIONS WHERE INFORMATION WAS REPORTED AS NOT PROVIDED OR NOT APPLICABLE. FOR THE INCOME CLASSIFICATION, ZEROS AND INVALID CODES ARE INCLUDED. 3. APPLICANTS ARE SHOWN IN ONLY ONE ETHNICITY CATEGORY. FOR PURPOSES OF CATEGORIZATION, THE GENERAL RULE IS: THE ETHNICITY (INCLUDING SITUATIONS WHERE ETHNICITY WAS REPORTED AS NOT PROVIDED OR NOT APPLICABLE) OF THE APPLICATION IS CATEGORIZED BY THE ETHNICITY OF THE FIRST PERSON LISTED ON THE APPLICATION UNLESS THE "JOINT' ETHNICITY DEFINITION APPLIES. ( "JOINT" MEANS ONE APPLICANT REPORTS ETHNICITY AS HISPANIC OR LATINO AND THE OTHER APPLICANT REPORTS ETHNICITY AS NOT HISPANIC OR LATINO.) 4. "MINORITY STATUS" COMBINES INFORMATION REPORTED ON RACE AND ETHNICITY. "WHITE NON - HISPANIC" CONSISTS OF APPLICANTS OF WHITE RACE WHO ARE NOT OF HISPANIC OR LATINO ORIGIN. THE "OTHERS, INCLUDING HISPANIC" CATEGORY CONSISTS OF APPLICANTS OF MINORITY RACES OR HISPANIC OR LATINO ORIGIN. APPLICANTS NOT SHOWN ARE NON - HISPANICS WHERE RACE IS NOT AVAILABLE, WHITES WHERE ETHNICITY IS NOT AVAILABLE AND THOSE WHERE BOTH RACE AND ETHNICITY ARE NOT AVAILABLE. 5151 Table D -6 Orange County Disposition of FHA Loans by Characteristics of Census Tract in Which Property is Located — 2008 Income Category Loans Originated Application Approved But Not Accepted Applications Denied Total Applications Percent Denied Very Low Less Than 10% Minority 10 -19% Minority 20 -49% Minority 50 -79% Minority 80 -100% Minority 67 5 46 118 39.0 % Low Less Than 10% Minority 10 -19% Minority 20 -49% Minority 114 22 22 158 13.9% 50 -79% Minority 657 72 218 947 23.0% 80 -100% Minority 265 45 125 435 28.7% Moderate Less Than 10% Minority 11 1 4 16 25.0% 10 -19% Minority 18 51 9 1 32 28.1% 20 -49% Minority 739 96 182 1,017 17.9% 50 -79% Minority 384 491 94 527 17.8% 80 -100% Minority 25 21 11 38 28.9% Above Moderate Less Than 10% Minority 10 -19% Minority 222 37 56 315 17.8% 20 -49% Minority 639 93 176 908 19.4% 50 -79% Minority 22 2 4 28 14.3% 80 -100% Minority All Other Tracts 1 1 0.0% Total 1 3,163 4301 947 1 4,540 20.9% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 7 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Characteristics of Census Tract in Which Property is Located, 2008 Table construction by Castaneda & Associates Notes: "MINORITY" MEANS (1) ALL RACES OTHER THAN WHITE AND (2) WHITES OF HISPANIC OR LATINO ORIGIN THE VERY LOW- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS LESS THAN 50 PERCENT OF THE MEDIAN MSAIMD INCOME, BASED ON THE 2000 CENSUS OF POPULATION AND HOUSING. THE LOW- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS AT LEAST 50 PERCENT AND LESS THAN 80 PERCENT OF THE MEDIAN MSA/MD INCOME. THE MODERATE- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS AT LEAST 80 PERCENT AND LESS THAN 120 PERCENT OF THE MEDIAN MSAIMD INCOME. THE ABOVE MODERATE- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS 120 PERCENT OR MORE OF THE MEDIAN MSA/MD INCOME EXCLUDES CENSUS TRACTS WITH NO REPORTED INCOME 5152 Table D -7 Orange County Disposition of Conventional Loans by Characteristics of Census Tract in Which Property is Located — 2008 Income Category Loans Originated Application Approved But Not Accepted Applications Denied Total Applications Percent Denied Very Low Less Than 10% Minority 10 -19% Minority 20 -49% Minority 50 -79% Minority 80 -100% Minority 223 85 175 483 36.2% Low Less Than 10% Minority 74 2 2 78 2.6% 10 -19% Minority 45 6 15 66 22.7% 20 -49% Minority 526 114 148 788 18.8% 50 -79% Minority 2,583 608 932 4,123 22.6% 80-100% Minority 974 302 578 1,854 31.2% Moderate Less Than 10% Minority 149 271 28 1 204 13.7% 10 -19% Minority 361 73 151 585 25.8% 20 -49% Minority 3,764 705 1,166 5,635 20.7% 50 -79% Minority 1,736 3871 563 2,686 21.0% 80 -100% Minority 103 251 42 170 24.7% Above Moderate Less Than 10% Minority 234 60 103 397 25.9% 10 -19% Minority 2,689 601 872 4,162 21.0% 20 -49% Minority 5,287 1,066 1,349 7,702 17.5% 50 -79% Minority 283 65 83 431 19.3% 80 -100% Minority All Other Tracts 2 1 0 3 0.0% Total 1 19,033 4,1271 6,207 1 29,367 21.1% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 7- 2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Characteristics of Census Tract in Which Property is Located, 2008 Table construction by Castaneda & Associates Notes: "MINORITY" MEANS (1) ALL RACES OTHER THAN WHITE AND (2) WHITES OF HISPANIC OR LATINO ORIGIN THE VERY LOW- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS LESS THAN 50 PERCENT OF THE MEDIAN MSAIMD INCOME, BASED ON THE 2000 CENSUS OF POPULATION AND HOUSING. THE LOW- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS AT LEAST 50 PERCENT AND LESS THAN 80 PERCENT OF THE MEDIAN MSA/MD INCOME. THE MODERATE- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS AT LEAST 80 PERCENT AND LESS THAN 120 PERCENT OF THE MEDIAN MSAIMD INCOME. THE ABOVE MODERATE- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS 120 PERCENT OR MORE OF THE MEDIAN MSA/MD INCOME EXCLUDES CENSUS TRACTS WITH NO REPORTED INCOME 3153 Table D -8 Orange County Reasons for Loan Denial by Race /Ethnicity - 2008 _ FHA, FSA/RHS Home Purchase Loans Race/Ethnicity Debt -to- Income Ratio Employ. History Credit History Collateral Insufficient Cash Unverifiable Information Credit App. Incomplete Mortgage Insurance Denied Other Total American Indian /Alaska Native 40.0% 0.0% 20.0% 20.0% 0.0% 0.0% 10.0% 0.0% 10.0% 10 Asian 44.2% 2.3% 15.1% 10.5% 2.3% 7.0% 4.7% 0.0% 14.0% 86 Black or African American 27.3% 0.0% 22.7% 18.2% 4.5% 4.5% 4.5% 0.0% 18.2% 22 Nat. Hawaiian /Other Pacific Isl. 57.1% 0.0% 14.3% 0.0% 0.0% 0.0% 14.3% 0.0% 14.3% 7 White 37.9% 2.3% 13.3% 10.3% 3.4% 5.0% 6.4% 0.3% 21.1% 700 2 or More Races 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0 Joint (White/Minority Race 32.10 7.1% 7.1% 3.60 7.10 0.706 10.7% 0.0% 21.4% 28 Race Not Available 39.2% 2.8% 14.0% 6.3% 4.9% 7.0% 11.2% 0.0% 14.7% 143 Hispanic or Latino 40.2% 1.4% 16.0% 8.7% 3.4% 5.6% 4.8% 0.3% 19.7% 356 Joint (Hispanic /Latino & Non- Hispanic/Latino 32.1% 3.6% 17.9% 7.1% 0.0% 7.1% 0.0% 0.0% 32.1% 28 Conventional Race/Ethnicity Debt -to- Income Ratio Employ. History Credit History Collateral Insufficient Cash Unverifiable Information Credit App. Incomplete Mortgage Insurance Denied Other Total American Indian /Alaska Native 26.4% 0.0% 5.7% 7.5% 17.0% 9.4% 7.5% 0.0% 26.4% 53 Asian 20.9% 2.0% 6.6% 15.4% 5.3% 11.3% 15.1% 0.6% 22.9% 1,420 Black or African American 23.3% 0.0% 15.0% 6.7% 3.3% 6.7% 20.0% 1.7% 23.3% 60 Nat. Hawaiian /Other Pacific Isl. 39.4% 3.0% 3.0% 9.1% 3.0% 3.0% 6.1% 0.0% 33.3% 33 White 23.1% 1.5% 8.5% 14.4% 5.2% 10.2% 12.6% 1.2% 23.3% 4,086 2 or More Races 40.0% 0.0% 20.0% 0.0% 0.0% 0.0% 20.0% 0.0% 20.0% 5 Joint White /Minorit Race 22.9% 1.7% 3.4% 19.5% 3.4% 10.2% 12.7% 0.8% 25.4% 118 Race Not Available 24.3% 2.2% 8.8% 12.1% 5.7% 11.8% 11.3% 0.6% 23.2% 1,034 Hispanic or Latino 21.1% 1.0% 10.3% 13.5% 6.6% 11.1% 7.2% 1.6% 27.6% 1,252 Joint (Hispanic /Latino & Non- Hispanic/Latino 25.0% 0.8% 9.2% 13.3% 7.5% 5.8% 16.7% 0.8% 20.8% 120 354 Table D -8 continued Orange County Reasons for Loan Denial by Race /Ethnicity - 2008 Refinance Race/Ethnicity Debt -to- Income Ratio Employ. History Credit History Collateral Insufficient Cash Unverifiable Information Credit App. Incomplete Mortgage Insurance Denied Other Total American Indian /Alaska Native 31.5% 0.6% 14.3% 26.8% 1.8% 3.0% 6.0% 1.2% 14.9% 168 Asian 21.4% 1.3% 5.8% 31.2% 2.4% 6.9% 12.8% 0.2% 17.9% 1,458 Black or African American 31.6% 2.2% 14.7% 21.3% 2.9% 5.9% 3.7% 0.0% 17.6% 136 Nat. Hawaiian /Other Pacific Isl. 25.9% 2.1% 8.4% 37.1% 1.4% 7.7% 7.7% 0.7% 9.1% 143 White 24.5% 0.9% 10.5% 26.2% 2.6% 7.5% 10.7% 0.2% 16.9% 9,235 2 or More Races 22.2% 0.0% 0.0% 55.6% 0.0% 0.0% 0.0% 0.0% 22.2% 9 Joint (White/Minority Race 17.4% 0.0% 15.2% 31.3% 3.1% 4.9% 11.6% 0.0% 16.5% 224 Race Not Available 26.6% 1.0% 11.8% 25.8% 2.3% 7.3% 8.8% 0.2% 16.2% 3,131 Hispanic or Latino 28.1% 0.9% 12.2% 27.6% 2.7% 7.1% 6.8% 0.3% 14.2% 3,064 Joint (Hispanic /Latino & Non - Hispanic /Latino 26.0% 1.7% 12.5% 28.7% 2.4% 3.7% 8.8% 0.3% 15.9% 296 3155 Table D -8 continued Orange County Reasons for Loan Denial by Race /Ethnicity - 2008 Home Improvement Race/Ethnicity Debt -to- Income Ratio Employ. History Credit History Collateral Insufficient Cash Unverifiable Information Credit App. Incomplete Mortgage Insurance Denied Other Total American Indian /Alaska Native 27.0% 0.0% 40.5% 10.8% 0.0% 2.7% 10.8% 0.0% 8.1% 37 Asian 25.7% 1.1% 20.2% 21.3% 1.1% 9.8% 2.7% 0.0% 18.0% 183 Black or African American 28.6% 0.0% 52.4% 4.8% 4.8% 0.0% 4.8% 0.0% 4.8% 21 Nat. Hawaiian /Other Pacific Isl. 27.8% 0.0% 22.2% 22.2% 0.0% 5.6% 5.6% 0.0% 16.7% 18 White 28.9% 0.9% 23.4% 20.3% 1.2% 5.0% 6.4% 0.0% 13.9% 926 2 or More Races 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1 Joint White /Minoru Race 22.7% 0.0% 13.6% 40.9% 0.0% 0.0% 9.1% 0.0% 13.6% 22 Race Not Available 14.9% 0.2% 55.6% 9.9% 1.0% 3.6% 3.2% 0.0% 11.6% 585 Hispanic or Latino 33.1% 0.6% 28.0% 18.3% 0.9% 3.4% 5.4% 0.0% 10.3% 350 Joint (Hispanic /Latino & Non - Hispanic /Latino 17.2% 0.0% 34.5% 34.5% 3.4% 0.0% 6.9% 0.0% 3.4% 29 Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 8 -1 Reasons for Denial of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 8 -2 Reasons for Denial of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 8 -3 Reasons for Denial of Applications to Refinance Loans on 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 8 -4 Reasons for Denial of Applications for Home Improvement Loans 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Table construction by Castaneda & Associates 315(0 Technical Appendix E Loan Denial Rates for Census Tracts with a High Number of Loan Applications 357 Table E -1 Entitlement Cities FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 755.15 Irvine 79% 51.4% 755.15 Santa Ana 79% 51.4% 877.01 Anaheim 54% 43.8% 752.02 Santa Ana 95% 41.2% 868.02 Anaheim 67% 40.7% 762.01 Orange 34% 36.4% 742.00 Santa Ana 95% 36.4% 320.51 Rancho Santa Margarita 32% 35.3% 870.02 Anaheim 59% 34.6% 864.04 Anaheim 82% 33.3% 891.02 Garden Grove 82% 33.3% 750.02 Santa Ana 96% 33.3% 891.02 Santa Ana 82% 33.3% 320.14 Lake Forest 47% 33.3% 741.06 Santa Ana 62% 30.4% 878.02 Anaheim 65% 29.4% 1105.00 Buena Park 79% 27.8% 320.53 Rancho Santa Margarita 23% 27.3% 992.27 Fountain Valle 61% 26.7% 881.01 Garden Grove 45% 26.7% 749.01 Santa Ana 98% 26.7% 741.03 Santa Ana 93% 25.0% 863.01 Anaheim 74% 25.0% 219.13 Orange 70% 25.0% 1103.02 Buena Park 63% 23.8% 320.29 Lake Forest 30% 23.5% 320.27 Lake Forest 44% 23.3% 868.01 Anaheim 50% 22.7% 868.01 Buena Park 50% 22.7% 864.07 Anaheim 58% 22.2% 747.02 Santa Ana 96% 22.2% 525.25 Irvine 42% 22.2% 320.50 Rancho Santa Margarita 27% 21.9% 741.02 Santa Ana 93% 21.1% 884.03 Anaheim 74% 20.6% 884.03 Garden Grove 74% 20.6% 876.02 Anaheim 62% 20.0% 876.02 Garden Grove 62% 20.0% 524.11 Lake Forest 49% 18.8% 524.22 Lake Forest 26% 18.8% 3158 Table E -1 continued Entitlement Cities FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Denied 754.05 Santa Ana 18.8% 320.56 Rancho Santa Margarita q49% 18.5% 746.01 Santa Ana 18.2% 219.23 Anaheim 17.6% 754.01 Santa Ana 17.6% 867.01 Anaheim 65% 16.7% 867.01 Fullerton 65% 16.7% 524.16 Lake Forest 34% 16.7% 762.02 Orange 39% 16.7% 878.06 Anaheim 78% 16.7% 878.06 Garden Grove 78% 16.7% 866.01 Anaheim 87% 15.8% 754.03 Santa Ana 62% 15.7% 1102.03 Anaheim 41% 15.0% 1102.03 Buena Park 41% 15.0% 320.54 Rancho Santa Margarita 28% 14.3% 888.01 Garden Grove 81% 13.3% 740.06 Santa Ana 75% 12.9% 863.03 Anaheim 53% 12.8% 874.01 Anaheim 72% 12.1% 1103.01 Buena Park 56% 11.8% 218.12 Anaheim 33% 11.1% 760.00 Orange 51% 10.7% 760.00 Santa Ana 51% 10.7% 740.04 Santa Ana 73% 10.5% 13.03 La Habra 68% 10.0% 1102.01 Anaheim 53% 10.0% 1102.01 Buena Park 53% 10.0% 877.04 Anaheim 58% 8.0% 871.03 Anaheim 58% 5.9% 1103.04 Buena Park 55% 5.6% 1104.01 Buena Park 51% 5.6% 762.08 Orange 30% 4.0% 867.02 Anaheim 75% 0.0% 320.55 Rancho Santa Margarita 37% 0.0% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates 3� Table E -2 Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 746.02 Santa Ana 97% 44.2% 752.02 Santa Ana 95% 44.2% 742.00 Santa Ana 95% 41.6% 749.01 Santa Ana 98% 41.3% 740.03 Santa Ana 95% 40.4% 998.01 Westminster 67% 38.9% 873.00 Anaheim 85% 37.7% 320.55 Rancho Santa Margarita 37% 37.5% 747.01 Santa Ana 98% 36.8% 627.02 Newport Beach 8% 36.4% 750.02 Santa Ana 96% 36.2% 747.02 Santa Ana 96% 36.0% 864.07 Anaheim 58% 35.6% 320.54 Rancho Santa Margarita 28% 35.1% 635.00 Newport Beach 11% 34.6% 320.51 Rancho Santa Margarita 32% 34.1% 890.01 Garden Grove 90% 33.8% 890.01 Santa Ana 90% 33.8% 754.03 Santa Ana 62% 33.3% 1105.00 Buena Park 79% 33.3% 996.01 Westminster 73% 32.8% 889.02 Garden Grove 81% 32.7% 891.02 Garden Grove 82% 32.5% 891.02 Santa Ana 82% 32.5% 872.00 Anaheim 65% 32.1% 994.16 Huntington Beach 24% 31.4% 761.03 Garden Grove 78% 30.5% 761.03 Orange 78% 30.5% 320.53 Rancho Santa Margarita 23% 30.1% 626.43 Newport Beach 22% 29.9% 320.50 Rancho Santa Margarita 27% 29.7% 762.06 Orange 32% 29.4% 876.02 Anaheim 62% 29.3% 876.02 Garden Grove 62% 29.3% 320.14 Lake Forest 47% 28.9% 864.04 Anaheim 82% 28.8% 219.18 Orange 38% 28.3% 993.10 Huntington Beach 20% 28.0% 762.08 Orange 30% 27.8% 878.05 Anaheim 68% 27.8% Soo Table E -2 continued Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 740.06 Santa Ana 75% 27.5% 992.24 Fountain Valle 42% 27.3% 992.27 Fountain Valle 61% 26.9% 626.45 Newport Beach 17% 26.8% 741.07 Santa Ana 43% 26.8% 997.03 Huntington Beach 48% 26.0% 997.03 Westminster 48% 26.0% 996.03 Huntington Beach 30% 25.9% 996.03 Westminster 30% 25.9% 524.10 Irvine 34% 25.9% 524.10 Lake Forest 34% 25.9% 636.03 Newport Beach 14% 25.7% 1104.01 Buena Park 51% 25.4% 758.13 Orange 36% 25.0% 1102.01 Anaheim 53% 25.0% 1102.01 Buena Park 53% 25.0% 741.02 Santa Ana 93% 24.7% 626.44 Newport Beach 13% 24.7% 880.01 Garden Grove 61% 24.6% 888.01 Garden Grove 81% 24.6% 884.01 Garden Grove 58% 24.2% 219.21 Anaheim 35% 24.1% 993.11 Huntington Beach 18% 23.9% 867.02 Anaheim 75% 23.9% 740.04 Santa Ana 73% 23.6% 877.04 Anaheim 58% 23.5% 1102.03 Anaheim 41% 23.5% 1102.03 Buena Park 41% 23.5% 759.01 Orange 50% 23.3% 890.04 Santa Ana 89% 23.3% 15.01 La Habra 27% 23.2% 525.15 Irvine 60% 23.2% 877.01 Anaheim 54% 23.1% 748.03 Santa Ana 92% 23.0% 320.29 Lake Forest 30% 22.7% 885.02 Garden Grove 75% 22.6% 762.01 Orange 34% 22.2% 756.04 Orange 22% 22.2% 762.02 Orange 39% 22.2% 117.07 Fullerton 29% 22.1% Sol Table E -2 continued Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 994.08 Huntington Beach 22% 22.0% 524.16 Lake Forest 34% 22.0% 758.15 Orange 34% 22.0% 15.05 Fullerton 31% 22.0% 755.15 Irvine 79% 21.8% 755.15 Santa Ana 79% 21.8% 741.06 Santa Ana 62% 21.7% 883.01 Garden Grove 58% 21.6% 320.27 Lake Forest 44% 21.5% 218.12 Anaheim 33% 21.0% 760.00 Orange 51% 20.9% 760.00 Santa Ana 51% 20.9% 1103.02 Buena Park 63% 20.8% 885.01 Garden Grove 74% 20.8% 1102.02 Anaheim 61% 20.7% 1102.02 Buena Park 61% 20.7% 320.34 Rancho Santa Margarita 23% 20.6% 992.15 Huntington Beach 30% 20.3% 626.04 Irvine 11% 20.3% 110.00 Fullerton 40% 20.3% 863.03 Anaheim 53% 20.0% 993.06 Huntington Beach 20% 20.0 % 992.32 Fountain Valle 29% 20.0% 886.01 Garden Grove 74% 20.0% 320.49 Rancho Santa Margarita 24% 20.0% 867.01 Anaheim 65% 19.7% 867.01 Fullerton 65% 19.7% 887.02 Garden Grove 76% 19.7% 863.01 Anaheim 74% 19.7% 869.03 Anaheim 63% 19.6% 995.14 Huntington Beach 17% 19.5% 746.01 Santa Ana 93% 19.5% 524.08 Irvine 22% 19.4% 524.08 Lake Forest 22% 19.4% 626.12 Irvine 31% 19.4% 1103.01 Buena Park 56% 18.9% 871.03 Anaheim 58% 18.8% 320.43 Rancho Santa Margarita 15% 18.8% 219.03 Anaheim 42% 18.6% 993.09 Huntington Beach 15% 18.6% 302 Table E -2 continued Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 994.15 Huntington Beach 20% 18.5% 997.02 Huntington Beach 64% 18.5% 997.02 Westminster 64% 18.5% 525.27 Irvine 53% 18.5% 524.18 Irvine 48% 18.4% 634.00 Newport Beach 7% 17.9% 751.00 Santa Ana 78% 17.7% 883.02 Anaheim 47% 17.6% 883.02 Garden Grove 47% 17.6% 320.48 Rancho Santa Margarita 24% 17.6% 756.05 Orange 27% 17.3% 17.04 Fullerton 48% 17.3% 116.02 Anaheim 83% 17.3% 116.02 Fullerton 83% 17.3% 868.02 Anaheim 67% 17.2% 874.01 Anaheim 72% 16.8% 320.56 Rancho Santa Margarita 28% 16.5% 994.13 Huntington Beach 33% 16.5% 626.10 Irvine 41% 16.4% 626.10 Newport Beach 41% 16.49/a 994.17 Huntington Beach 20% 16.3% 525.17 Irvine 41% 16.2 % 630.07 Newport Beach 12% 16.0% 524.21 Irvine 28% 15.9% 1106.04 Buena Park 55% 15.7% 525.25 Irvine 42% 15.3% 219.23 Anaheim 37% 15.0% 13.03 La Habra 68% 15.0% 13.01 La Habra 43% 14.9% 524.25 Lake Forest 32% 14.9% 884.03 Anaheim 74% 14.6% 884.03 Garden Grove 74% 14.6% 888.02 Garden Grove 76% 14.3% 888.02 Westminster 76% 14.3% 524.17 Irvine 36% 14.3% 219.22 Anaheim 36% 14.3% 524.24 Lake Forest 33% 14.0% 992.31 Fountain Valle 30% 14.0% 16.01 Fullerton 26% 13.7% 16.01 La Habra 26% 13.7% 3003 Table E -2 continued Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 Census Tract City Percent Minority Percent Denied 992.43 Huntington Beach 19% 13.0% 993.08 Huntington Beach 22% 12.9% 219.13 Orange 70% 12.7% 219.12 Anaheim 19% 12.5% 219.12 Orange 19% 12.5% 889.01 Garden Grove 77% 12.5% 889.01 Westminster 77% 12.5% 16.02 Fullerton 25% 12.0% 1106.03 Buena Park 78% 11.9% 524.20 Irvine 50% 11.9% 219.20 Anaheim 26% 11.7% 17.07 Fullerton 69% 11.3% 17.07 La Habra 69% 11.3% 879.01 Garden Grove 72% 9.2% 992.44 Huntington Beach 12% 7.8% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates WON Table E -3 Urban County Cities FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 877.01 Unincorporated 54% 43.8% 423.10 Dana Point 37% 30.8% 878.02 Stanton 65% 29.4% 320.53 Unincorporated 23% 27.3% 881.01 Stanton 45% 26.7% 626.38 Aliso Viejo 29% 25.0% 219.13 Unincorporated 70% 25.0% 626.35 Aliso Viejo 28% 22.2% 626.35 Laguna Woods 28% 22.2% 320.23 Unincorporated 16% 19.4% 524.22 Unincorporated 26% 18.8% 320.56 Unincorporated 28% 18.5% 320.52 Unincorporated 13% 17.8% 867.01 Unincorporated 65% 16.7% 762.02 Unincorporated 39% 16.7% 878.06 Stanton 78% 16.7% 878.06 Unincorporated 78% 16.7% 1102.03 Stanton 41% 15.0% 524.27 Unincorporated 32% 13.3% 1103.01 La Palma 56% 11.8% 218.21 Placentia 46% 11.8% 218.12 Unincorporated 33% 11.1% 218.12 Yorba Linda 33% 11.1% 626.25 Aliso Viejo 39% 8.6% 626.25 Laguna Hills 39% 8.6% 626.25 Laguna Woods 39% 8.6% 626.37 Aliso Viejo 27% 6.3% 423.20 Aliso Viejo 33% 4.3% 423.20 Laguna Hills 33% 4.3% 762.08 Unincorporated 30% 4.0% 626.39 Aliso Viejo 30% 0.0% 524.28 Unincorporated 22% 0.0% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates S05 Table E -4 Urban County Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 218.27 Yorba Linda 31% 34.9% 626.21 Laguna Hills 30% 33.9% 626.21 Laguna Woods 30% 33.9% 422.01 Dana Point 20% 33.3% 626.43 Unincorporated 22% 29.9% 218.02 Yorba Linda 25% 28.4% 219.18 Unincorporated 38% 28.3% 762.08 Unincorporated 30% 27.8% 878.05 Stanton 68% 27.8% 878.05 Unincorporated 68% 27.8% 626.20 Laguna Beach 11% 27.1% 626.45 Unincorporated 17% 26.8% 218.16 Unincorporated 17% 26.2% 218.16 Yorba Linda 17% 26.2% 997.03 Unincorporated 48% 26.0% 1101.02 Cypress 56% 25.4% 1101.02 La Palma 56% 25.4% 758.13 Villa Park 36% 25.0% 881.01 Stanton 45% 24.6% 320.23 orated 16% 24.6% 423.35 Hills *Dana 29% 24.5% 423.35 porated 29% 24.5% 423.24 oint 12% 24.1% 423.23 Dana Point 12% 24.0% 423.07 Laguna Hills 36% 23.7% 1102.03 Stanton 41% 23.5% 423.05 Dana Point 9% 23.5% 423.05 Laguna Beach 9% 23.5% 320.52 Unincorporated 13% 23.4% 15.01 Brea 27% 23.2% 15.01 Unincorporated 27% 23.2% 877.01 Unincorporated 54% 23.1% 423.38 Dana Point 14% 22.7% 626.22 Laguna Hills 11% 22.7% 626.22 Laguna Woods 11% 22.7% 218.21 Placentia 46% 22.7% 626.34 Aliso Vie'o 2606 22.2% 756.04 Unincorporated 22% 22.2% 762.02 Unincorporated 39% 22.2% 15.05 Brea 31% 22.0% Soo Table E -4 continued Urban County Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 320.53 Unincorporated 23% 21.4% 218.12 Unincorporated 33% 21.0% 218.12 Yorba Linda 33% 21.0% 1102.02 Cypress 61% 20.7% 524.27 Unincorporated 32% 20.4% 626.04 Laguna Beach 11% 20.3% 626.04 Unincorporated 11% 20.3% 320.49 Unincorporated 24% 20.0% 756.03 Unincorporated 22% 20.0% 867.01 Unincorporated 65% 19.7% 756.06 Unincorporated 24% 19.7% 218.22 Yorba Linda 21% 19.7% 117.15 Placentia 27% 19.6% 117.15 Unincorporated 27% 19.6% 423.10 Dana Point 37% 19.6% 1103.01 La Palma 56% 18.9% 626.19 Laguna Beach 9% 18.9% 631.02 Unincorporated 19% 18.5% 997.02 Unincorporated 64% 18.5% 524.26 Unincorporated 30% 17.6% 422.05 Dana Point 23% 17.5% 756.05 Unincorporated 27% 17.3% 320.46 Unincorporated 14% 17.3% 626.35 Aliso Viejo 28% 17.2% 626.38 Aliso Viejo 29% 17.2% 626.35 Laguna Woods 28% 17.2% 423.20 Aliso Viejo 33% 16.7% 423.20 Laguna Hills 33% 16.7% 320.56 Unincorporated 28% 16.5% 994.17 Unincorporated 20% 16.3% 1100.08 Seal Beach 17% 16.1% 1100.08 Unincorporated 17% 16.1% 524.21 Unincorporated 28% 15.9% 626.23 Laguna Beach 8% 15.7% 626.23 Laguna Hills 8% 15.7% 626.23 Laguna Woods 8% 15.7% 1106.04 Unincorporated 55% 15.7% 626.39 Aliso Viejo 30% 15.3% 218.15 Brea 20% 15.2% 218.15 Placentia 20% 15.2% S07 Table E -4 continued Urban County Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 218.15 Unincorporated 20% 15.2% 218.15 Yorba Linda 20% 15.2% 626.25 Aliso Viejo 39% 14.3% 626.25 Laguna Hills 39% 14.3% 626.25 Laguna Woods 39% 14.3% 219.13 Unincorporated 70% 12.7% 626.41 Aliso Viejo 38% 12.5% 626.41 Laguna Woods 38% 12.5% 626.41 Unincorporated 38% 12.5% 219.12 Unincorporated 19% 12.5% 524.20 Unincorporated 50% 11.9% 320.44 Unincorporated 13% 11.8% 626.33 Aliso Viejo 26% 11.7% 17.07 Unincorporated 69% 11.3% 626.40 Aliso Viejo 27% 1 10.9% 879.01 Stanton 72% 9.2% 524.28 Unincorporated 22% 9.1% 626.37 Aliso Viejo 27% 7,7% 626.46 Laguna Woods 7% 1.4% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates m Technical Appendix F FHA and Conventional Loan Denial Rates by City and Census Tract 309 Table F -1 Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 116.02 Anaheim 83% 57% 9 1 3 13 23.1% 117.14 Anaheim 81% 56% 0 0 1 1 100.0% 117.20 Anaheim 93% 47% 2 0 3 5 60.0% 117.22 Anaheim 67% 74% 5 0 1 6 167% 218.07 Anaheim 28% 100% 7 1 0 8 0.0% 218.12 Anaheim 33% 109% 15 1 2 18 11.1% 218.13 Anaheim 74% 82% 1 0 0 1 0.0% 219.03 Anaheim 42% 118% 9 1 2 12 16.7% 219.05 Anaheim 29% 144% 11 0 2 13 15.4% 219.12 Anaheim 19% 194% 0 0 0 0 0.0% 219.15 Anaheim 33% 151% 4 1 3 8 37.5% 219.16 Anaheim 24% 171% 1 0 0 1 0.0% 219.19 Anaheim 26% 153% 4 0 0 4 0.0% 219.20 Anaheim 26% 160% 8 0 0 8 0.0% 219.21 Anaheim 35% 180% 0 0 1 1 100.0% 219.22 Anaheim 36% 1 127% 1 10 21 2 14 1 14.3% 219.23 Anaheim 1 37% 1 157% 11 31 3 17 17.6% 219.24 Anaheim 1 43% 1 145% 2 1 1 2 5 40.0% 761.01 Anaheim 1 63% 1 79% 8 01 5 13 38.5% 761.02 Anaheim 64% 69% 0 0 0 0 0.0% 863.01 Anaheim 74% 78% 12 0 4 16 25.0% 863.03 Anaheim 53 % 78% 30 4 5 39 12.8% 863.04 Anaheim 53% 93% 7 1 1 9 11.1% 863.05 Anaheim 44% 107% 8 0 2 10 20.0% 863.06 Anaheim 53% 92% 3 2 1 6 16.7% 864.02 Anaheim 68% 80% 12 1 1 14 7.1% 864.04 Anaheim 82% 71% 10 2 6 18 33.3% 864.05 Anaheim 83% 58% 7 1 4 12 33.3% 864.06 Anaheim 64% 74% 1 0 01 1 0.0% 864.07 Anaheim 58% 81% 17 4 61 27 22.2% 865.01 Anaheim 85% 57% 7 1 1 9 11.1% 865.02 Anaheim 92% 58% 6 3 5 14 35.7% 866.01 Anaheim 87% 53% 13 3 3 19 15.8% 867.01 Anaheim 65% 79% 24 1 5 30 167% 867.02 Anaheim 75% 61% 19 4 0 23 0.0% 868.01 Anaheim 50% 96% 17 0 5 22 22.7% 868.02 Anaheim 67% 71% 10 6 11 27 40.7% 868.03 Anaheim 58% 71% 11 0 2 13 15.4% 869.01 Anaheim 66% 55% 4 0 0 4 0.0% 869.02 Anaheim 51% 83% 6 1 1 8 12.5% S7 L) Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 869.03 Anaheim 63% 67% 6 1 1 8 12.5% 870.01 Anaheim 66% 67% 5 0 0 5 0.0% 870.02 Anaheim 59% 65% 16 1 9 26 34.6% 871.01 Anaheim 67% 66% 3 0 2 5 40.0% 871.02 Anaheim 78% 63% 5 0 0 5 0.0% 871.03 Anaheim 58% 83% 14 2 1 17 5.9% 871.05 Anaheim 62% 91% 1 0 1 2 50.0% 871.06 Anaheim 72% 72% 2 2 1 5 20.0% 872.00 Anaheim 65% 66% 5 2 3 10 30.0% 873.00 Anaheim 85% 57% 8 3 2 13 15.4% 874.01 Anaheim 72% 76% 26 3 4 33 12.1% 874.03 Anaheim 86% 49% 1 0 0 1 0.0% 874.04 Anaheim 91% 60% 1 0 0 1 0.0% 874.05 Anaheim 89% 52% 6 0 7 13 53.8% 875.01 Anaheim 80% 65% 7 1 3 11 27.3% 875.03 Anaheim 75% 1 66% 1 2 01 51 7 1 71 A% 875.04 Anaheim 1 87% 1 45% 1 1 01 01 1 1 0.0% 876.01 Anaheim 1 70% 1 64% 1 4 01 1 1 5 1 20.0% 876.02 Anaheim 1 62% 1 79% 1 11 1 1 31 15 1 20.0% 877.01 Anaheim 54% 82% 9 0 71 16 43.8% 877.03 Anaheim 72% 89% 10 1 3 14 21.4% 877.04 Anaheim 58% 80% 20 3 2 25 8.0% 878.01 Anaheim 56% 75% 10 1 2 13 15.4% 878.02 Anaheim 65% 70% 12 0 5 17 29.4% 878.03 Anaheim 87% 49% 4 0 2 6 33.3% 878.05 Anaheim 68% 67% 9 2 3 14 21.4% 878.06 Anaheim 78% 52% 12 3 3 18 167% 883.02 Anaheim 47% 88% 1 0 2 3 66.7% 884.02 Anaheim 75% 73% 0 0 4 4 100.0% 884.03 Anaheim 74% 80% 25 2 7 34 20.6% 1102.01 Anaheim 53% 84% 15 3 2 20 10.0% 1102.02 Anaheim 61% 68% 7 1 2 10 20.0% 1102.03 Anaheim 41% 88% 15 2 3 20 15.0% 1104.02 Anaheim 69% 65% 7 0 3 10 30.0% Subtotal 611 79 186 876 21.2% 371 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 18.01 Buena Park 71% 63% 5 0 2 7 28.6% 868.01 Buena Park 50% 96% 17 0 5 22 22.7% 1101.10 Buena Park 51% 80% 4 1 2 7 28.6% 1102.01 Buena Park 53% 84% 15 3 2 20 10.0% 1102.02 Buena Park 61% 68% 7 1 2 10 20.0% 1102.03 Buena Park 41% 88% 15 2 3 20 15.0% 1103.01 Buena Park 56% 101% 13 2 2 17 11.8% 1103.02 Buena Park 63% 85% 16 0 5 21 23.8% 1103.04 Buena Park 55% 89% 15 2 1 18 5.6% 1104.01 Buena Park 51% 89% 15 2 1 18 5.6% 1105.00 Buena Park 79% 56% 9 4 5 18 27.8% 1106.03 Buena Park 78% 57% 7 0 1 8 12.5% 1106.04 Buena Park 55% 102% 4 0 1 5 20.0% 1106.06 Buena Park 84% 46% 2 1 0 3 0.0% 1106.07 Buena Park 62% 66% 7 2 0 9 0.0% Subtotal 151 20 32 203 15.8% 992.02 Fountain My. 83% 83% 6 0 0 6 0.0% 992.03 Fountain My. 75% 89% 1 0 1 2 50.0% 992.04 Fountain V1 y. 65% 81% 1 0 0 1 0.0% 992.23 Fountain My. 69% 84% 0 0 0 0 0.0% 992.24 Fountain My. 42% 123% 0 0 0 0 0.0% 992.25 Fountain VI . 42% 132% 1 0 0 1 0.0% 992.26 Fountain VI . 56% 128% 1 0 0 1 0.0% 992.27 Fountain My. 61% 94% 9 2 4 15 26.7% 992.29 Fountain My. 41% 111% 3 4 7 14 50.0% 992.30 Fountain My. 26% 119% 8 1 2 11 18.2% 992.31 Fountain My. 30% 148% 3 0 0 3 0.0% 992.32 Fountain VI . 29% 128% 2 0 0 2 0.0% 992.33 Fountain My. 36% 110% 2 0 1 3 33.3% 992.34 Fountain My. 35% 122% 4 1 2 7 28.6% 992.50 Fountain My. 38% 112% 0 0 0 0 0.0% 992.51 Fountain My. 52% 84% 1 0 0 1 0.0% Subtotal 42 8 17 67 25.4% 15.03 Fullerton 38% 93% 2 0 1 3 33.3% 15.05 Fullerton 31% 115% 5 1 0 6 0.0% 16.01 Fullerton 26% 122% 4 0 0 4 0.0% 16.02 Fullerton 25% 161% 5 0 0 5 0.0% 17.04 Fullerton 48% 128% 3 0 3 6 50.0% 17.05 Fullerton 50% 98% 4 1 3 8 37.5% S72 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract Cit Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 17.06 Fullerton 24% 174% 0 0 0 0 0.0% 17.07 Fullerton 69% 131% 4 0 0 4 0.0% 17.08 Fullerton 48% 143% 4 1 0 5 0.0% 18.01 Fullerton 71% 63% 5 0 2 7 28.6% 18.02 Fullerton 68% 61% 7 1 0 8 0.0% 19.01 Fullerton 52% 91% 6 2 3 11 27.3% 19.02 Fullerton 50% 78% 7 2 4 13 30.8% 19.03 Fullerton 56% 67% 5 0 1 6 16.7 % 110.00 Fullerton 40% 92% 10 0 0 10 0.0% 111.01 Fullerton 55% 75% 5 1 2 8 25.0% 111.02 Fullerton 66% 88% 9 2 0 11 0.0% 112.00 Fullerton 37% 86% 5 0 0 5 0.0% 113.00 Fullerton 32% 95% 3 0 0 3 0.0% 114.01 Fullerton 29% 117% 0 0 0 0 0.0% 114.02 Fullerton 19% 141% 1 0 0 1 0.0% 114.03 Fullerton 54% 70% 8 1 0 9 0.0% 115.02 Fullerton 57% 66% 1 1 0 2 0.0% 115.03 Fullerton 26% 124% 1 1 0 2 0.0% 115.04 Fullerton 49% 58% 3 1 0 4 0.0% 116.01 Fullerton 78% 55% 2 0 3 5 60.0% 116.02 Fullerton 83% 57% 9 1 3 13 23.1% 117.07 Fullerton 29% 106% 11 0 3 14 21.4% 117.08 Fullerton 43% 74% 1 0 0 1 0.0% 117.11 Fullerton 62% 63% 6 2 4 12 33.3% 117.12 Fullerton 60% 80% 6 0 2 8 25.0% 867.01 Fullerton 65% 79% 24 1 5 30 16.7% 1106.05 Fullerton 71% 94% 5 0 0 5 0.0% Subtotal 171 19 39 229 17.0% 761.03 Garden Gr. 78% 66% 3 0 1 4 25.0% 875.03 Garden Gr. 75% 66% 2 0 5 7 71.4% 876.02 Garden Gr. 62% 79% 11 1 3 15 20.0% 878.06 Garden Gr. 78% 52% 12 3 3 18 16.7% 879.01 Garden Gr. 72% 71% 11 0 1 12 8.3% 879.02 Garden Gr. 82% 67% 1 0 2 3 66.7% 880.01 Garden Gr. 61% 91% 3 0 0 3 0.0% 880.02 Garden Gr. 55% 100% 3 1 3 7 42.9% 881.01 Garden Gr. 45% 90% 10 1 4 15 26.7% 881.04 Garden Gr. 55% 75% 2 0 0 2 0.0% 881.05 Garden Gr. 61% 96% 2 0 4 6 66.7% 881.06 Garden Gr. 61% 59% 7 0 1 8 12.5% 373 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 881.07 Garden Gr. 73% 63% 7 0 2 9 22.2% 882.01 Garden Gr. 54% 88% 1 1 1 3 33.3% 882.02 Garden Gr. 52% 110% 4 1 0 5 0.0% 882.03 Garden Gr. 58% 77% 2 0 0 2 0.0% 883.01 Garden Gr. 58% 78% 5 1 0 6 0.0% 883.02 Garden Gr. 47% 88% 1 0 2 3 66.7% 884.01 Garden Gr. 58% 91% 3 0 2 5 40.0% 884.02 Garden Gr. 75% 73% 0 0 4 4 100.0% 884.03 Garden Gr. 74% 80% 25 2 7 34 20.6% 885.01 Garden Gr. 74% 65% 4 0 4 8 50.0% 885.02 Garden Gr. 75% 74% 9 1 0 10 0.0% 886.01 Garden Gr. 74% 62% 5 0 2 7 28.6% 886.02 Garden Gr. 65% 72% 0 0 0 0 0.0% 887.01 Garden Gr. 77% 58% 4 0 2 6 33.3% 887.02 Garden Gr. 76% 59% 1 0 0 1 0.0% 888.01 Garden Gr. 81% 57% 12 1 2 15 13.3% 888.02 Garden Gr. 76% 76% 3 1 3 7 42.9% 889.01 Garden Gr. 77% 70% 1 0 0 1 0.0% 889.02 Garden Gr. 81% 78% 1 0 0 1 0.0% 889.03 Garden Gr. 86% 79% 0 0 2 2 100.0% 889.04 Garden Gr. 82% 97% 0 0 1 1 100.0% 890.01 Garden Gr. 90% 72% 2 1 1 4 25.0% 890.03 Garden Gr. 89% 62% 3 1 4 8 50.0% 891.02 Garden Gr. 82% 75% 11 1 6 18 33.3% 891.04 Garden Gr. 93% 43% 2 0 1 3 33.3% 891.06 Garden Gr. 82% 50% 1 0 0 1 0.0% 891.07 Garden Gr. 78% 89% 7 0 0 7 0.0% 999.02 Garden Gr. 55% 81% 3 1 0 4 0.0% 999.03 Garden Gr. 70% 67% 2 0 0 2 0.0% 999.05 Garden Gr. 33% 76% 2 0 1 3 33.3% 999.06 Garden Gr. 30% 122% 10 1 1 12 8.3% 1100.01 Garden Gr. 29% 111% 3 1 0 4 0.0% 1100.03 Garden Gr. 26% 115% 10 0 0 10 0.0% 1100.04 Garden Gr. 23% 120% 8 0 2 10 20.0% 1100.05 Garden Gr. 23% 126% 2 0 0 2 0.0% Subtotal 221 20 77 318 24.2% 992.12 Hunt. Beach 42% 79% 6 1 1 8 12.5% 992.14 Hunt. Beach 23% 99% 4 0 0 4 0.0% 992.15 Hunt. Beach 30% 98% 6 1 2 9 22.2% 992.16 Hunt. Beach 25% 118% 3 1 2 6 33.3% 992.17 Hunt. Beach 17% 141% 5 2 0 7 0.0% S74 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 992.20 Hunt. Beach 20% 102% 0 0 0 0 0.0% 992.35 Hunt. Beach 26% 105% 4 1 2 7 28.6% 992.37 Hunt. Beach 23% 124% 3 0 1 4 25.0% 992.38 Hunt. Beach 26% 156% 0 1 2 3 66.7% 992.39 Hunt. Beach 23% 152% 3 0 3 6 50.0% 992.40 Hunt. Beach 20% 132% 1 0 3 4 75.0% 992.41 Hunt. Beach 43% 98% 1 0 0 1 0.0% 992.42 Hunt. Beach 47% 103% 4 0 0 4 0.0% 992.43 Hunt. Beach 19% 122% 9 1 3 13 23.1% 992.44 Hunt. Beach 12% 136% 3 2 0 5 0.0% 992.45 Hunt. Beach 24% 126% 0 0 1 1 100.0% 992.46 Hunt. Beach 29% 151% 2 0 0 2 0.0% 993.05 Hunt. Beach 34% 71% 7 2 1 10 10.0% 993.06 Hunt. Beach 20% 91% 3 1 0 4 0.0% 993.07 Hunt. Beach 18% 88% 2 0 0 2 0.0% 993.08 Hunt. Beach 22% 236% 1 0 0 1 0.0% 993.09 Hunt. Beach 15% 139% 2 0 1 3 33.3% 993.10 Hunt. Beach 20% 159% 1 0 0 1 0.0% 993.11 Hunt. Beach 18% 126% 0 0 1 1 100.0% 994.02 Hunt. Beach 76% 57% 0 0 0 0 0.0% 994.04 Hunt. Beach 20% 136% 1 0 0 1 0.0% 994.05 Hunt. Beach 28% 104% 7 0 1 8 12.5% 994.06 Hunt. Beach 27% 112% 2 1 0 3 0.0% 994.07 Hunt. Beach 20% 122% 3 0 0 3 0.0% 994.08 Hunt. Beach 22% 115% 1 0 0 1 0.0% 994.10 Hunt. Beach 42% 80% 2 2 1 5 20.0% 994.11 Hunt. Beach 46% 74% 4 1 0 5 0.0% 994.12 Hunt. Beach 23% 119% 4 0 1 5 20.0% 994.13 Hunt. Beach 33% 134% 7 3 3 13 23.1% 994.15 Hunt. Beach 20% 161% 0 1 0 1 0.0% 994.16 Hunt. Beach 24% 88% 2 0 1 3 33.3% 994.17 Hunt. Beach 20% 129% 3 0 1 4 25.0% 995.08 Hunt. Beach 26% 87% 3 0 1 4 25.0% 995.13 Hunt. Beach 14% 187% 0 0 0 0 0.0% 995.14 Hunt. Beach 17% 197% 0 0 0 0 0.0% 996.02 Hunt. Beach 33% 106% 3 0 0 3 0.0% 996.03 Hunt. Beach 30% 111% 7 0 1 8 12.5% 996.04 Hunt. Beach 26% 116% 4 1 0 5 0.0% 996.05 Hunt. Beach 30% 127% 1 0 0 1 0.0% 997.02 Hunt. Beach 64% 88% 3 0 1 4 25.0% 375 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract -- 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 997.03 Hunt. Beach 48% 116% 1 0 2 3 66.7% Subtotal 128 22 36 186 19.4% 524.08 Irvine 22% 140% 6 1 2 9 22.2% 524.10 Irvine 34% 94% 3 0 1 4 25.0% 524.17 Irvine 36% 150% 6 1 2 9 22.2% 524.18 Irvine 48% 77% 6 1 0 7 0.0% 524.20 Irvine 50% 183% 7 3 2 12 16.7% 524.21 Irvine 28% 154% 4 1 2 7 28.6% 525.05 Irvine 46% 100% 2 1 1 4 25.0% 525.06 Irvine 25% 153% 0 0 0 0 0.0% 525.11 Irvine 28% 134% 2 0 2 4 50.0% 525.13 Irvine 33% 133% 3 1 1 5 20.0% 525.14 Irvine 37% 130% 3 1 2 6 33.3% 525.15 Irvine 60% 130% 3 0 0 3 0.0% 525.17 Irvine 41% 102% 9 0 2 11 18.2% 525.18 Irvine 100% 0% 0 1 0 1 0.0% 525.19 Irvine 38% 110% 7 0 2 9 22.2% 525.20 Irvine 30% 135% 2 0 0 2 0.0% 525.21 Irvine 51% 87% 1 1 0 2 0.0% 525.22 Irvine 52% 143% 3 0 0 3 0.0% 525.23 Irvine 50% 152% 1 0 0 1 0.0% 525.25 Irvine 42% 137% 12 2 4 18 22.2% 525.26 Irvine 44% 132% 3 0 1 4 25.0% 525.27 Irvine 53% 142% 4 0 2 6 33.3% 525.28 Irvine 39% 123% 1 0 0 1 0.0% 626.04 Irvine 11% 177% 3 0 2 5 40.0% 626.10 Irvine 41% 105% 3 0 0 3 0.0% 626.11 Irvine 52% 86% 1 0 0 1 0.0% 626.12 Irvine 31% 124% 2 0 3 5 60.0% 626.14 Irvine 60% 94% 0 0 0 0 0.0% 626.26 Irvine 65% 63% 0 0 0 0 0.0% 626.27 Irvine 49% 82% 0 0 0 0 0.0% 626.28 Irvine 39% 158% 0 1 1 2 50.0% 626.29 Irvine 28% 162% 0 0 0 0 0.0% 626.30 Irvine 23% 185% 0 0 0 0 0.0% 626.31 Irvine 23% 239% 0 0 2 2 100.0% 755.15 Irvine 79% 62% 16 1 18 35 51.4% Subtotal 113 16 52 181 28.7% S70 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 11.01 La Habra 38% 108% 9 0 2 11 18.2% 11.02 La Habra 45% 94% 10 0 0 10 0.0% 11.03 La Habra 60% 75% 6 0 1 7 14.3% 12.01 La Habra 82% 57% 7 2 2 11 18.2% 12.02 La Habra 75% 65% 6 0 1 7 14.3% 13.01 La Habra 43% 92% 13 0 1 14 7.1% 13.03 La Habra 68% 75% 27 0 3 30 10.0% 13.04 La Habra 77% 57% 6 2 1 9 11.1% 14.01 La Habra 53% 78% 4 1 1 6 16.7% 14.02 La Habra 53% 90% 10 0 2 12 16.7% 14.03 La Habra 28% 119% 6 1 1 8 12.5% 14.04 La Habra 75% 69% 6 1 2 9 22.2% 15.01 La Habra 27% 125% 6 0 0 6 0.0% 16.01 La Habra 26% 122% 4 0 0 4 0.0% 17.05 La Habra 50% 98% 4 1 3 8 37.5% 17.07 La Habra 69% 131% 4 0 0 4 0.0% 17.08 La Habra 48% 143% 4 1 0 5 0.0% Subtotal 132 9 20 161 12.4% 320.14 Lake Forest 47% 73% 9 1 5 15 33.3% 320.27 Lake Forest 44% 102% 36 10 14 60 23.3% 320.29 Lake Forest 30% 125% 12 1 4 17 23.5% 320.47 Lake Forest 26% 89% 7 0 1 8 12.5% 524.08 Lake Forest 22% 140% 6 1 2 9 22.2% 524.10 Lake Forest 34% 94% 3 0 1 4 25.0% 524.11 Lake Forest 49% 104% 10 3 3 16 18.8% 524.15 Lake Forest 19% 160% 4 1 1 6 16.7% 524.16 Lake Forest 34% 118% 17 3 4 24 16.7% 524.22 Lake Forest 26% 136% 13 0 3 16 18.8% 524.23 Lake Forest 34% 120% 5 1 0 6 0.0% 524.24 Lake Forest 33% 113% 10 1 2 13 15.4% 524.25 Lake Forest 32% 104% 12 1 1 14 7.1% Subtotal 144 23 41 208 19.7% 626.10 Newport Bch. 41% 105% 3 0 0 3 0.0% 626.42 Newport Bch. 11% 166% 0 0 0 0 0.0% 626.43 Newport Bch. 22% 272% 0 0 1 1 100.0% 626.44 Newport Bch. 13% 214% 0 0 0 0 0.0% 626.45 Newport Bch. 17% 245% 1 0 0 1 0.0% 627.01 Newport Bch. 8% 200% 0 0 0 0 0.0% 627.02 Newport Bch. 8% 196% 0 0 0 0 0.0% 628.00 Newport Bch. 10% 135% 0 0 0 0 0.0% 377 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 629.00 Newport Bch. 5% 221% 0 0 0 0 0.0% 630.04 Newport Bch. 10% 143% 0 0 0 0 0.0% 630.05 Newport Bch. 8% 190% 0 0 0 0 0.0% 630.06 Newport Bch. 7% 166% 0 0 0 0 0.0% 630.07 Newport Bch. 12% 211% 0 0 0 0 0.0% 630.08 Newport Bch. 11% 149% 0 0 0 0 0.0% 630.09 Newport Bch. 12% 199% 0 0 0 0 0.0% 630.10 Newport Bch. 13% 203% 0 2 0 2 0.0% 631.01 Newport Bch. 26% 94% 0 0 0 0 0.0% 631.03 Newport Bch. 12% 145% 1 0 0 1 0.0% 634.00 Newport Bch. 7% 153% 0 0 0 0 0.0% 635.00 Newport Bch. 11% 130% 0 0 0 0 0.0% 636.01 Newport Bch. 31% 103% 3 0 2 5 40.0% 636.03 Newport Bch. 14% 112% 2 0 1 3 33.3% Subtotal 10 2 4 16 25.0% 219.12 Orange 19% 194% 01 01 01 0 0.0% 219.13 Orange 70% 96% 9 31 41 16 25.0% 219.14 Orange 44% 110% 4 01 01 4 0.0% 219.15 Orange 33% 151% 4 1 1 31 8 37.5% 219.17 Orange 18% 161% 2 0 0 2 0.0% 219.18 Orange 38% 120% 9 2 3 14 21.4% 756.04 Orange 22% 197% 4 0 1 5 20.0% 756.05 Orange 27% 177% 5 0 1 6 16.7% 758.05 Orange 42% 102% 6 0 1 7 14.3% 758.06 Orange 48% 90% 4 0 1 5 20.0% 758.07 Orange 52% 108% 5 1 6 12 50.0% 758.08 Orange 21% 129% 4 2 0 6 0.0% 758.09 Orange 21% 185% 0 0 1 1 100.0% 758.10 Oran a 23% 186% 2 0 0 2 0.0% 758.11 Orange 58% 98% 2 0 0 2 0.0% 758.12 Orange 52% 86% 3 0 0 3 0.0% 758.13 Orange 36% 127% 5 1 2 8 25.0% 758.14 Orange 37% 176% 1 0 0 1 0.0% 758.15 Orange 34% 102% 11 2 1 14 7.1% 758.16 Orange 56% 98% 6 0 0 6 0.0% 759.01 Oran a 50% 78% 6 0 5 11 45.5% 759.02 Orange 43% 75% 7 1 0 8 0.0% 760.00 Orange 51% 86% 23 2 3 28 10.7% 761.01 Orange 63% 79% 8 0 5 13 38.5% 761.02 Orange 64% 69% 0 0 0 0 0.0% S72 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 761.03 Orange 78% 66% 3 0 1 4 25.0% 762.01 Orange 34% 105% 20 1 12 33 36.4% 762.02 Orange 39% 86% 16 4 4 24 16.7% 762.04 Orange 79% 61% 3 0 0 3 0.0% 762.05 Orange 46% 88% 6 0 4 10 40.0% 762.06 Orange 32% 96% 8 1 1 10 10.0% 762.08 Orange 30% 90% 22 2 1 251 4.0% Subtotal 208 23 60 291 20.6% 320.34 Ran. St. Marg. 23% 195% 7 1 2 10 20.0% 320.42 Ran. St. Marg. 19% 165% 3 1 2 6 33.3% 320.43 Ran. St. Marg. 15% 230% 6 0 0 6 0.0% 320.48 Ran. St. Marg. 24% 133% 7 1 1 9 11.1% 320.49 Ran. St. Marg. 24% 158% 8 1 3 12 25.0% 320.50 Ran. St. Marg. 27% 128% 19 6 7 32 21.9% 320.51 Ran. St. Marg. 32% 97% 18 4 12 34 35.3% 320.53 Ran. St. Marg. 23% 130% 22 2 9 33 27.3% 320.54 Ran. St. Marg. 28% 103% 15 3 3 21 14.3% 320.55 Ran. St. Marg. 37% 106% 12 3 0 15 0.0% 320.56 Ran. St. Marg. 28% 163% 19 3 5 27 18.5% Subtotal 136 25 44 205 21.5% 740.03 Santa Ana 95% 59% 9 0 5 14 35.7% 740.04 Santa Ana 73% 85 % 16 1 2 19 10.5% 740.05 Santa Ana 86% 69% 2 0 1 3 33.3% 740.06 Santa Ana 75% 63% 25 2 4 31 12.9% 741.02 Santa Ana 93% 80% 12 3 4 19 21.1% 741.03 Santa Ana 93% 78% 13 2 5 20 25.0% 741.06 Santa Ana 62% 76% 12 4 7 23 30.4% 741.07 Santa Ana 43% 94% 2 0 0 2 0.0% 741.08 Santa Ana 43% 94% 2 0 0 2 0.0% 741.09 Santa Ana 95% 78% 2 0 3 5 60.0% 741.10 Santa Ana 78% 118% 5 0 2 7 28.6% 741.11 Santa Ana 81% 93% 6 2 2 10 20.0% 742.00 Santa Ana 95 % 75% 13 1 8 22 36.4% 743.00 Santa Ana 97% 70% 4 2 2 8 25.0% 744.03 Santa Ana 95% 48% 0 0 0 0 0.0% 744.05 Santa Ana 95% 41% 6 0 5 11 45.5% 744.06 Santa Ana 92% 45% 5 0 2 7 28.6% 744.07 Santa Ana 93% 48% 7 0 5 12 41.7% 745.01 Santa Ana 99% 48% 1 0 4 5 80.0% 745.02 Santa Ana 97% 74% 6 0 5 11 45.5% 3�9 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 746.01 Santa Ana 93% 55% 15 3 4 22 18.2% 746.02 Santa Ana 97% 59% 8 2 2 12 16.7% 747.01 Santa Ana 98% 72% 8 1 4 13 30.8% 747.02 Santa Ana 96% 71% 19 2 6 27 22.2% 748.01 Santa Ana 98% 60% 6 0 4 10 40.0% 748.02 Santa Ana 94% 49% 3 1 2 6 33.3% 748.03 Santa Ana 92% 66% 4 0 1 5 20.0% 748.05 Santa Ana 98% 49% 4 0 2 6 33.3% 748.06 Santa Ana 99% 49% 0 0 3 3 100.0% 749.01 Santa Ana 98% 46% 9 2 4 15 26.7% 749.02 Santa Ana 99% 45% 4 1 4 9 44.4% 750.02 Santa Ana 96% 47% 12 0 6 18 33.3% 750.03 Santa Ana 96% 41% 1 0 0 1 0.0% 750.04 Santa Ana 96% 42% 1 0 2 3 66.7% 751.00 Santa Ana 78% 51% 9 1 2 12 16.7% 752.01 Santa Ana 97% 1 71% 1 9 1 1 21 121 16.7% 752.02 Santa Ana 95% 59% 6 4 7 17 41.2% 753.01 Santa Ana 70% 80% 2 1 1 4 25.0% 753.02 Santa Ana 82% 67% 8 1 3 12 25.0% 753.03 Santa Ana 44% 112% 7 1 0 8 0.0% 754.01 Santa Ana 49% 112% 14 0 3 17 17.6% 754.03 Santa Ana 62% 76% 39 4 8 51 15.7% 754.04 Santa Ana 61% 77% 5 0 1 6 16.7% 754.05 Santa Ana 37% 76% 11 2 3 16 18.8% 755.15 Santa Ana 79% 62% 16 1 18 35 51.4% 757.01 Santa Ana 43% 94% 5 0 1 6 16.7% 758.06 Santa Ana 48% 90% 4 0 1 5 20.0% 759.02 Santa Ana 43% 75% 7 1 0 8 0.0% 760.00 Santa Ana 51% 86% 23 2 3 28 10.7% 889.03 Santa Ana 86% 79% 0 0 2 2 100.0% 890.01 Santa Ana 90% 72 % 2 1 1 4 25.0% 890.04 Santa Ana 89% 56% 4 1 3 8 37.5% 891.02 Santa Ana 82% 75% 11 1 6 18 33.3% 891.04 Santa Ana 93% 43% 2 0 1 3 33.3% 891.05 Santa Ana 97% 45% 1 0 1 2 50.0% 891.07 Santa Ana 78% 89% 7 0 0 7 0.0% 992.02 Santa Ana 83% 83% 6 0 0 6 0.0% 992.03 Santa Ana 75% 89 % 1 0 1 2 50.0% 992.47 Santa Ana 89% 76% 1 0 1 2 50.0% 992.48 Santa Ana 89% 55% 2 0 1 3 33.3% rM Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 992.49 Santa Ana 97% 59% 0 0 0 0 0.0% Subtotal 444 51 180 675 26.7% 888.02 Westminster 76% 76% 3 1 3 7 42.9% 889.01 Westminster 77% 70% 1 0 0 1 0.0% 889.04 Westminster 82% 97% 0 0 1 1 100.0% 889.05 Westminster 79% 85% 1 0 0 1 0.0% 992.03 Westminster 75% 89% 1 0 1 2 50.0% 992.04 Westminster 65% 81% 1 0 0 1 0.0% 992.22 Westminster 59% 77% 1 0 1 2 50.0% 992.23 Westminster 69% 84% 0 0 0 0 0.0% 992.41 Westminster 43% 98% 1 0 0 1 0.0% 996.01 Westminster 73% 62% 4 2 4 10 40.0% 996.02 Westminster 33% 106% 3 0 0 3 0.0% 996.03 Westminster 30% 111% 7 0 1 8 12.5% 997.01 Westminster 72% 80% 1 0 0 1 0.0% 997.02 Westminster 64% 88% 3 0 1 4 25.0% 997.03 Westminster 48% 116% 1 0 2 3 66.7% 998.01 Westminster 67% 82% 0 0 0 0 0.0% 998.02 Westminster 75% 54% 1 0 1 2 50.0% 998.03 Westminster 78% 62% 0 0 0 0 0.0% 999.02 Westminster 55% 81% 3 1 0 4 0.0% 999.03 Westminster 70% 67% 2 0 0 2 0.0% 999.04 Westminster 72% 56% 2 0 0 2 0.0% 999.05 Westminster 33% 76% 2 0 1 3 33.3% 999.06 Westminster 30% 122% 10 1 1 12 8.3% Subtotal 48 5 17 70 24.3% Total 2,436 314 790 3,540 22.3% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates SRI Table F -2 Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 116.02 Anaheim 83% 57% 37 6 9 52 17.3% 117.14 Anaheim 81% 56% 0 1 0 1 0.0% 117.20 Anaheim 93% 47% 11 3 12 26 46.2% 117.22 Anaheim 67% 74% 14 4 3 21 14.3% 218.07 Anaheim 28% 100% 17 5 4 26 15.4% 218.12 Anaheim 33% 109% 41 8 13 62 21.0% 218.13 Anaheim 74% 82% 0 3 0 3 0.0% 219.03 Anaheim 42% 118% 44 4 11 59 18.6% 219.05 Anaheim 29% 144% 25 5 16 46 34.8% 219.12 Anaheim 19% 194% 59 4 9 72 12.5% 219.15 Anaheim 33% 151% 27 6 8 41 19.5% 219.16 Anaheim 24% 171% 24 6 8 38 21.1% 219.19 Anaheim 26% 153% 20 8 7 35 20.0% 219.20 Anaheim 26% 160% 100 13 15 128 11.7% 219.21 Anaheim 35% 180% 37 7 14 58 24.1% 219.22 Anaheim 36% 127% 1 47 71 91 63 14.3% 219.23 Anaheim 37% 157% 82 14 17 113 15.0% 219.24 Anaheim 43% 145% 31 1 7 39 17.9% 761.01 Anaheim 63% 79% 14 3 7 24 29.2% 761.02 Anaheim 64% 69% 4 1 3 8 37.5% 863.01 Anaheim 74% 78% 34 15 12 61 19.7% 863.03 Anaheim 53% 78% 84 12 24 120 20.0% 863.04 Anaheim 53% 93% 24 3 8 35 22.9% 863.05 Anaheim 44% 107% 29 5 5 39 12.8% 863.06 Anaheim 53% 92% 19 2 5 26 19.2% 864.02 Anaheim 68% 80% 27 2 10 39 25.6% 864.04 Anaheim 82% 71% 38 9 19 66 28.8% 864.05 Anaheim 83% 58% 13 6 8 27 29.6% 864.06 Anaheim 64 % 74% 12 1 1 14 7.1% 864.07 Anaheim 58% 81% 23 15 21 59 35.6% 865.01 Anaheim 85% 57% 16 1 7 24 29.2% 865.02 Anaheim 92% 58% 14 13 14 41 34.1% 866.01 Anaheim 87% 53% 29 5 13 47 27.7% 867.01 Anaheim 65% 79% 47 14 15 76 19.7% 867.02 Anaheim 75% 61% 38 13 16 67 23.9% 868.01 Anaheim 50% 96% 28 5 7 40 17.5% 868.02 Anaheim 67 % 71% 38 10 10 58 17.2% 868.03 Anaheim 58% 71% 20 11 8 39 20.5% 869.01 Anaheim 66% 55% 14 7 3 24 12.5% 869.02 Anaheim 51% 83% 25 4 10 39 25.6. 382 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 869.03 Anaheim 63% 67% 28 13 10 51 19.6% 870.01 Anaheim 66% 67% 15 3 9 27 33.3% 870.02 Anaheim 59% 65% 28 6 3 37 8.1% 871.01 Anaheim 67% 66% 9 2 7 18 38.9% 871.02 Anaheim 78% 63% 14 10 8 32 25.0% 871.03 Anaheim 58% 83% 57 8 15 80 18.8% 871.05 Anaheim 62% 91% 24 6 9 39 23.1% 871.06 Anaheim 72% 72% 17 5 5 27 18.5% 872.00 Anaheim 65% 66% 32 6 18 56 32.1% 873.00 Anaheim 85% 57% 32 11 26 69 37.7% 874.01 Anaheim 72% 76% 74 25 20 119 16.8% 874.03 Anaheim 86% 49% 5 2 3 10 30.0% 874.04 Anaheim 91% 60% 14 4 8 26 30.8% 874.05 Anaheim 89% 52% 11 1 5 17 29.4% 875.01 Anaheim 80% 65% 19 7 9 35 25.7% 875.03 Anaheim 75% 66% 1 23 101 121 45 26.7% 875.04 Anaheim 87% 45% 6 5 9 20 45.0% 876.01 Anaheim 70% 64% 16 4 9 29 31.0% 876.02 Anaheim 62% 79% 34 7 17 58 29.3% 877.01 Anaheim 54% 82% 31 9 12 52 23.1% 877.03 Anaheim 72% 89% 26 3 9 38 23.7% 877.04 Anaheim 58% 80% 41 11 16 68 23.5% 878.01 Anaheim 56% 75% 35 3 9 47 19.1% 878.02 Anaheim 65% 70% 31 5 11 47 23.4% 878.03 Anaheim 87% 49% 15 2 3 20 15.0% 878.05 Anaheim 68% 67% 29 10 15 54 27.8% 878.06 Anaheim 78% 52% 24 8 14 46 30.4% 883.02 Anaheim 47% 88% 39 3 9 51 17.6% 884.02 Anaheim 75% 73% 23 3 12 38 31.6% 884.03 Anaheim 74% 80% 118 17 23 158 14.6% 1102.01 Anaheim 53% 84% 33 12 15 60 25.0% 1102.02 Anaheim 61% 68% 43 3 12 58 20.7% 1102.03 Anaheim 41% 88% 49 3 16 68 23.5% 1104.02 Anaheim 69% 65% 18 2 7 27 25.9% Subtotal 2,219 491 773 3,483 22.2% 383 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 18.01 Buena Park 71% 63% 12 3 4 19 21.1% 868.01 Buena Park 50% 96% 28 5 7 40 17.5% 1101.10 Buena Park 51% 80% 30 3 3 36 8.3% 1102.01 Buena Park 53% 84% 33 12 15 60 25.0% 1102.02 Buena Park 61% 68% 43 3 12 58 20.7% 1102.03 Buena Park 41% 88% 49 3 16 68 23.5% 1103.01 Buena Park 56% 101% 42 1 10 53 18.9% 1103.02 Buena Park 63% 85 % 34 8 11 53 20.8% 1103.04 Buena Park 55% 89% 32 4 9 45 20.0% 1104.01 Buena Park 51% 89% 38 6 15 59 25.4% 1105.00 Buena Park 79% 56% 24 12 18 54 33.3% 1106.03 Buena Park 78% 57% 53 6 8 67 11.9% 1106.04 Buena Park 55% 102% 55 15 13 83 15.7% 1106.06 Buena Park 84% 46% 5 1 3 9 33.3% 1106.07 Buena Park 62% 66% 15 3 9 27 33.3% Subtotal 1 1 493 85 153 731 20.9% 992.02 Fountain My. 83% 83% 33 6 10 49 20.4% 992.03 Fountain My. 75% 89% 17 10 5 32 15.6% 992.04 Fountain My. 65% 81% 23 7 8 38 21.1% 992.23 ain VI . 69% 84% 21 0 2 23 8.7% 992.24 ain VI *Fountain 42% 123% 40 16 21 77 27.3% 992.25 ain VI 42% 132% 26 6 4 36 11.1% 992.26 VI . 56% 128% 17 4 6 27 22.2% 992.27 Fountain My. 61% 94% 31 7 14 52 26.9% 992.29 Fountain My. 41% 111% 28 15 5 48 10.4% 992.30 Fountain My. 26% 119% 32 5 11 48 22.9% 992.31 Fountain My. 30% 148% 35 8 7 50 14.0% 992.32 Fountain My. 29% 128% 36 4 10 50 20.0% 992.33 Fountain My. 36% 110% 20 1 8 29 27.6% 992.34 Fountain My. 35% 122% 22 8 10 40 25.0% 992.50 Fountain My. 38% 112 % 7 1 6 14 42.9% 992.51 Fountain My. 52% 84% 28 7 9 44 20.5% Subtotal 416 105 136 657 20.7% 15.03 Fullerton 38% 93% 25 5 3 33 9.1% 15.05 Fullerton 31% 115% 59 12 20 91 22.0% 16.01 Fullerton 26% 122% 55 8 10 73 13.7% 16.02 Fullerton 25% 161% 40 4 6 50 12.0% 17.04 Fullerton 48% 128 % 75 11 18 104 17.3% 17.05 Fullerton 50% 98% 23 8 7 38 18.4% 17.06 Fullerton 24% 174% 15 3 8 26 30.8% r Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 17.07 Fullerton 69% 131% 49 6 7 62 11.3% 17.08 Fullerton 48% 143% 24 9 9 42 21.4% 18.01 Fullerton 71% 63% 12 3 4 19 21.1% 18.02 Fullerton 68% 61% 21 6 9 36 25.0% 19.01 Fullerton 52% 91% 15 3 6 24 25.0% 19.02 Fullerton 50% 78% 20 3 6 29 20.7% 19.03 Fullerton 56% 67% 13 0 3 16 18.8% 110.00 Fullerton 40% 92% 44 7 13 64 20.3% 111.01 Fullerton 55% 75% 15 1 3 19 15.8% 111.02 Fullerton 66% 88% 20 2 8 30 26.7% 112.00 Fullerton 37% 86% 30 4 12 46 26.1% 113.00 Fullerton 32% 95% 12 0 0 12 0.0% 114.01 Fullerton 29% 117% 12 3 2 17 11.8% 114.02 Fullerton 19% 141% 20 3 6 29 20.7% 114.03 Fullerton 54% 70% 22 1 7 30 23.3% 115.02 Fullerton 57% 66% 14 4 3 21 14.3% 115.03 Fullerton 26% 124% 4 3 3 10 30.0% 115.04 Fullerton 49% 58% 10 4 2 16 12.5% 116.01 Fullerton 78% 55% 14 7 2 23 8.7% 116.02 Fullerton 83% 57% 37 6 9 52 17.3% 117.07 Fullerton 29% 106% 44 9 15 68 22.1% 117.08 Fullerton 43% 74% 18 2 5 25 20.0% 117.11 Fullerton 62% 63% 27 3 7 37 18.9% 117.12 Fullerton 60% 80% 19 2 12 33 36.4% 867.01 Fullerton 65% 79% 47 14 15 76 19.7% 1106.05 Fullerton 71% 94% 33 6 5 44 11.4% Subtotal 888 162 245 1,295 18.9% 761.03 Garden Gr. 78% 66% 30 11 18 59 30.5% 875.03 Garden Gr. 75 % 66% 23 10 12 45 26.7% 876.02 Garden Gr. 62% 79% 34 7 17 58 29.3% 878.06 Garden Gr. 78% 52% 24 8 14 46 30.4% 879.01 Garden Gr. 72% 71% 53 6 6 65 9.2% 879.02 Garden Gr. 82% 67% 25 4 9 38 23.7% 880.01 Garden Gr. 61% 91% 40 9 16 65 24.6% 880.02 Garden Gr. 55% 100% 31 8 9 48 18.8% 881.01 Garden Gr. 45% 90% 26 2 6 34 17.6% 881.04 Garden Gr. 55% 75% 11 1 3 15 20.0% 881.05 Garden Gr. 61% 96% 21 3 5 29 17.2% 881.06 Garden Gr. 61% 59% 21 11 6 38 15.8% 385 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract city Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 881.07 Garden Gr. 73% 63% 26 3 8 37 21.6% 882.01 Garden Gr. 54% 88% 25 4 7 36 19.4% 882.02 Garden Gr. 52% 110% 34 7 7 48 14.6% 882.03 Garden Gr. 58% 77% 20 1 4 25 16.0% 883.01 Garden Gr. 58% 78% 33 7 11 51 21.6% 883.02 Garden Gr. 47% 88% 39 3 9 51 17.6% 884.01 Garden Gr. 58% 91% 46 4 16 66 24.2% 884.02 Garden Gr. 75% 73% 23 3 12 38 31.6% 884.03 Garden Gr. 74% 80% 118 17 23 158 14.6% 885.01 Garden Gr. 74% 65% 37 5 11 53 20.8% 885.02 Garden Gr. 75% 74% 27 14 12 53 22.6% 886.01 Garden Gr. 74% 62% 34 6 10 50 20.0% 886.02 Garden Gr. 65% 72% 25 6 12 43 27.9% 887.01 Garden Gr. 77% 58% 22 4 6 32 18.8% 887.02 Garden Gr. 76% 59% 41 12 13 66 19.7% 888.01 Garden Gr. 81% 57% 36 10 15 61 24.6% 888.02 Garden Gr. 76% 76% 75 3 13 91 14.3% 889.01 Garden Gr. 77% 70% 38 11 7 56 12.5% 889.02 Garden Gr. 81% 78% 22 13 17 52 32.7% 889.03 Garden Gr. 86% 79% 30 11 8 49 16.3% 889.04 Garden Gr. 82% 97% 29 6 8 43 18.6% 890.01 Garden Gr. 90% 72% 40 9 25 74 33.8% 890.03 Garden Gr. 89% 62% 17 8 15 40 37.5% 891.02 Garden Gr. 82% 75% 43 11 26 80 32.5% 891.04 Garden Gr. 93% 43% 5 1 6 12 50.0% 891.06 Garden Gr. 82% 50% 13 0 8 21 38.1% 891.07 Garden Gr. 78% 89% 25 6 11 42 26.2% 999.02 Garden Gr. 55% 81% 17 6 2 25 8.0% 999.03 Garden Gr. 70% 67% 32 3 5 40 12.5% 999.05 Garden Gr. 33% 76% 6 2 1 9 11.1% 999.06 Garden Gr. 30% 122% 36 4 7 47 14.9% 1100.01 Garden Gr. 29% 111% 25 6 5 36 13.9% 1100.03 Garden Gr. 26% 115% 22 3 11 36 30.6% 1100.04 Garden Gr. 23% 120% 28 6 2 36 5.6% 1100.05 Garden Gr. 23% 126% 18 5 5 28 17.9% Subtotal 1,446 300 479 2,225 21.5% 992.12 Hunt. Beach 42% 79% 25 7 5 37 13.5% 992.14 Hunt. Beach 23% 99% 19 4 5 28 17.9% 992.15 Hunt. Beach 30% 98% 42 5 12 59 20.3% 992.16 Hunt. Beach 25% 118% 13 3 12 28 42.9% MW Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 992.17 Hunt. Beach 17% 141% 27 5 9 41 22.0% 992.20 Hunt. Beach 20% 102% 16 5 9 30 30.0% 992.35 Hunt. Beach 26% 105% 14 1 6 21 28.6% 992.37 Hunt. Beach 23% 124% 27 5 9 41 22.0% 992.38 Hunt. Beach 26% 156% 13 3 8 24 33.3% 992.39 Hunt. Beach 23% 152% 20 1 7 28 25.0% 992.40 Hunt. Beach 20% 132% 20 4 4 28 14.3% 992.41 Hunt. Beach 43% 98 % 16 4 3 23 13.0% 992.42 Hunt. Beach 47% 103% 19 11 8 38 21.1% 992.43 Hunt. Beach 19% 122% 63 4 10 77 13.0% 992.44 Hunt. Beach 12% 136% 38 9 4 51 7.8% 992.45 Hunt. Beach 24% 126% 20 6 6 32 18.8% 992.46 Hunt. Beach 29% 151% 25 1 3 29 10.3% 993.05 Hunt. Beach 34% 71% 31 4 7 42 16.7% 993.06 Hunt. Beach 20% 91% 46 6 13 65 20.0% 993.07 Hunt. Beach 18% 88% 24 3 12 39 30.8% 993.08 Hunt. Beach 22% 236% 52 9 9 70 12.9% 993.09 Hunt. Beach 15% 139% 58 12 16 86 18.6% 993.10 Hunt. Beach 20% 159% 33 3 14 50 28.0% 993.11 Hunt. Beach 18% 126% 48 6 17 71 23.9% 994.02 Hunt. Beach 76% 57% 17 5 14 36 38.9% 994.04 Hunt. Beach 20% 136% 18 5 12 35 34.3% 994.05 Hunt. Beach 28% 104% 16 3 6 25 24.0% 994.06 Hunt. Beach 27% 112% 31 4 10 45 22.2% 994.07 Hunt. Beach 20% 122% 22 3 6 31 19.4% 994.08 Hunt. Beach 22% 115% 34 5 11 50 22.0% 994.10 Hunt. Beach 42% 80% 17 3 3 23 13.0% 994.11 Hunt. Beach 46% 74% 9 2 1 12 8.3% 994.12 Hunt. Beach 23% 119% 19 2 8 29 27.6% 994.13 Hunt. Beach 33% 134% 62 14 15 91 16.5% 994.15 Hunt. Beach 20% 161 % 35 9 10 54 18.5% 994.16 Hunt. Beach 24% 88% 28 7 16 51 31.4% 994.17 Hunt. Beach 20% 129% 56 16 14 86 16.3% 995.08 Hunt. Beach 26% 87% 24 0 8 32 25.0% 995.13 Hunt. Beach 14% 187% 14 3 9 26 34.6% 995.14 Hunt. Beach 17% 197% 53 13 16 82 19.5% 996.02 Hunt. Beach 33% 106% 20 3 5 28 17.9% 996.03 Hunt. Beach 30% 111 % 35 5 14 54 25.9% 996.04 Hunt. Beach 26% 116% 19 8 5 32 15.6% 996.05 Hunt. Beach 30% 127% 19 3 4 26 15.4% S27 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 997.02 Hunt. Beach 64% 88% 32 12 10 54 18.5% 997.03 Hunt. Beach 48% 116% 27 10 13 50 26.0% Subtotal 1,316 256 418 1,990 21.0% 524.08 Irvine 22% 140% 48 10 14 72 19.4% 524.10 Irvine 34% 94% 34 9 15 58 25.9% 524.17 Irvine 36% 150% 56 16 12 84 14.3% 524.18 Irvine 48% 77% 136 28 37 201 18.4% 524.20 Irvine 50% 183% 204 47 34 285 11.9% 524.21 Irvine 28% 154% 45 13 11 69 15.9% 525.05 Irvine 46% 100% 19 6 12 37 32.4% 525.06 Irvine 25% 153% 20 2 1 23 4.3% 525.11 Irvine 28% 134% 32 8 6 46 13.0% 525.13 Irvine 33% 133% 26 6 6 38 15.8% 525.14 Irvine 37% 130% 27 4 6 37 16.2% 525.15 Irvine 60% 130% 94 22 35 151 23.2% 525.17 Irvine 41% 102% 76 17 18 111 16.2% 525.18 Irvine 100% 0% 2 1 0 3 0.0% 525.19 Irvine 38% 110% 21 8 7 36 19.4% 525.20 Irvine 30% 135% 26 3 3 32 9.4% 525.21 Irvine 51% 87% 17 7 5 29 17.2% 525.22 Irvine 52% 143% 14 5 3 22 13.6% 525.23 Irvine 50% 152% 16 3 6 25 24.0% 525.25 Irvine 42% 137% 101 15 21 137 15.3% 525.26 Irvine 44% 132% 21 9 7 37 18.9% 525.27 Irvine 53% 142% 42 11 12 65 18.5% 525.28 Irvine 39% 123% 10 3 2 15 13.3% 626.04 Irvine 11% 177% 196 47 62 305 20.3% 626.10 Irvine 41% 105% 155 24 35 214 16.4% 626.11 Irvine 52% 86% 10 3 9 22 40.9% 626.12 Irvine 31% 124% 49 5 13 67 19.4% 626.14 Irvine 60% 94 % 22 3 3 28 10.7% 626.26 Irvine 65% 63% 4 0 0 4 0.0% 626.27 Irvine 49% 82% 24 4 5 33 15.2% 626.28 Irvine 39% 158% 12 12 4 28 14.3% 626.29 Irvine 28% 162% 17 3 6 26 23.1% 626.30 Irvine 23% 185% 8 1 1 10 10.0% 626.31 Irvine 23% 239% 30 3 12 45 26.7% 755.15 Irvine 79% 62% 214 40 71 325 21.8% Subtotal 1,828 398 494 2,720 18.2% :: Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 11.01 La Habra 38% 108% 39 3 7 49 14.3% 11.02 La Habra 45% 94% 25 9 10 44 22.7% 11.03 La Habra 60% 75% 13 1 3 17 17.6% 12.01 La Habra 82% 57% 20 9 11 40 27.5% 12.02 La Habra 75% 65% 11 2 7 20 35.0% 13.01 La Habra 43% 92% 46 11 10 67 14.9% 13.03 La Habra 68% 75% 44 7 9 60 15.0% 13.04 La Habra 77% 57% 15 9 11 35 31.4% 14.01 La Habra 53% 78% 19 4 2 25 8.0% 14.02 La Habra 53% 90% 24 7 7 38 18.4% 14.03 La Habra 28% 119% 15 4 4 23 17.4% 14.04 La Habra 75% 69% 19 11 5 35 14.3% 15.01 La Habra 27% 125% 45 8 16 69 23.2% 16.01 La Habra 26% 122% 55 8 10 73 13.7% 17.05 La Habra 50% 98% 23 8 7 38 18.4% 17.07 La Habra 69% 131% 49 6 7 62 11.3% 17.08 La Habra 48% 143% 24 9 9 42 21.4% Subtotal 486 116 135 737 18.3% 320.14 Lake Forest 47% 73% 42 17 24 83 28.9% 320.27 Lake Forest 44% 102% 70 14 23 107 21.5% 320.29 Lake Forest 30% 125% 42 9 15 66 22.7% 320.47 Lake Forest 26% 89% 31 8 6 45 13.3% 524.08 Lake Forest 22% 140% 48 10 14 72 19.4% 524.10 Lake Forest 34% 94% 34 9 15 58 25.9% 524.11 Lake Forest 49% 104% 32 5 5 42 11.9% 524.15 Lake Forest 19% 160% 32 6 6 44 13.6% 524.16 Lake Forest 34% 118% 33 6 11 50 22.0% 524.22 Lake Forest 26% 136% 37 3 4 44 9.1% 524.23 Lake Forest 34% 120% 17 3 8 28 28.6% 524.24 Lake Forest 33% 113% 37 12 8 57 14.0% 524.25 Lake Forest 32% 104 %p 47 10 10 67 14.9% Subtotal 502 112 149 763 19.5% 626.10 Newport Bch. 41% 105% 155 24 35 214 16.4% 626.42 Newport Bch. 11% 166% 23 7 8 38 21.1% 626.43 Newport Bch. 22% 272% 49 5 23 77 29.9% 626.44 Newport Bch. 13% 214% 44 11 18 73 24.7% 626.45 Newport Bch. 17% 245% 34 7 15 56 26.8% 627.01 Newport Bch. 8% 200 % 29 8 7 44 15.9% 627.02 Newport Bch. 8% 196% 46 10 32 88 36.4% 628.00 Newport Bch. 10% 135% 15 4 8 27 29.6% Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 629.00 Newport Bch. 5% 221% 13 2 6 21 28.6% 630.04 Newport Bch. 10% 143% 18 3 4 25 16.0% 630.05 Newport Bch. 8% 190% 1 1 2 4 50.0% 630.06 Newport Bch. 7% 166% 19 0 12 31 38.7% 630.07 Newport Bch. 12% 211% 32 10 8 50 16.0% 630.08 Newport Bch. 11% 149% 11 1 2 14 14.3% 630.09 Newport Bch. 12% 199% 13 5 5 23 21.7% 630.10 Newport Bch. 13% 203 % 30 4 4 38 10.5% 631.01 Newport Bch. 26% 94% 10 5 1 16 6.3% 631.03 Newport Bch. 12% 145% 12 3 5 20 25.0% 634.00 Newport Bch. 7% 153% 44 20 14 78 17.9% 635.00 Newport Bch. 11% 130% 40 11 27 78 34.6% 636.01 Newport Bch. 31% 103% 21 5 9 35 25.7% 636.03 Newport Bch. 14% 112% 44 8 18 70 25.7% Subtotal 703 154 263 1,120 23.5% 219.12 Orange 19% 194% 1 59 1 4 1 91 72 1 12.5% 219.13 70% 96% 44 11 8 63 12.7% 219.14 tOrange a 44% 110% 16 6 10 32 31.3% 219.15 e 33% 151% 1 27 1 61 81 41 1 19.5% 219.17 Orange 18% 161% 141 5 8 27 1 29.6% 219.18 Oran a 38% 120% 36 7 17 60 28.3% 756.04 Oran e 22% 197% 53 10 18 81 22.2% 756.05 Orange 27% 177% 54 8 13 75 17.3% 758.05 Orange 42% 102% 15 3 8 26 30.8% 758.06 Orange 48% 90% 30 3 4 37 10.8% 758.07 Orange 52% 108% 23 6 18 47 38.3% 758.08 Orange 21% 129% 21 3 3 27 11.1% 758.09 Orange 21% 185% 25 5 4 34 11.8% 758.10 Orange 23% 186% 23 6 4 33 12.1% 758.11 Orange 58% 98% 7 3 1 11 9.1% 758.12 Orange 52% 86 % 27 6 3 36 8.3% 758.13 Orange 36% 127% 37 11 16 64 25.0% 758.14 Oran e 37% 176% 27 6 6 39 15.4% 758.15 Orange 34% 102% 30 9 11 50 22.0% 758.16 Orange 56% 98% 29 4 2 35 5.7% 759.01 Orange 50% 78% 42 4 14 60 23.3% 759.02 Orange 43% 75% 23 10 4 37 10.8% 760.00 Orange 51% 86 % 64 27 24 115 20.9% 761.01 Orange 63% 79% 14 3 7 24 29.2% 761.02 Orange 64% 69% 4 1 3 8 37.5% 39 D Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 761.03 Orange 78% 66% 30 11 18 59 30.5% 762.01 Orange 34% 105% 74 17 26 117 22.2% 762.02 Orange 39% 86% 42 7 14 63 22.2% 762.04 Orange 79% 61% 14 7 8 29 27.6% 762.05 Orange 46% 88% 28 3 11 42 26.2% 762.06 Orange 32% 96% 33 3 15 51 29.4% 762.08 Orange 30% 90% 103 11 44 158 27.8% Subtotal 1,068 226 359 1,653 21.7% 320.34 Ran. St. Mar. 23% 195% 41 9 13 63 20.6% 320.42 Ran. St. Mar. 19% 165% 32 9 6 47 12.85 320.43 Ran. St. Mar. 15% 230% 40 12 12 64 18.85 320.48 Ran. St. Mar. 24% 133% 50 6 12 68 17.6% 320.49 Ran. St. Mar. 24% 158% 74 10 21 105 20.0% 320.50 Ran. St. Mar. 27% 128% 65 13 33 111 29.7% 320.51 Ran. St. Mar. 32% 97% 45 11 29 85 34.1% 320.53 Ran. St. Mar. 23% 130% 125 35 69 229 30.1% 320.54 Ran. St. Mar. 28% 103% 50 13 34 97 35.1% 320.55 Ran. St. Mar. 37% 106% 51 9 36 96 37.5% 320.56 Ran. St. Mar. 28% 163% 65 21 17 103 16.5% Subtotal 638 148 282 1,068 26.4% 740.03 Santa Ana 95% 59% 22 12 23 57 40.4% 740.04 Santa Ana 73% 85% 46 9 17 72 23.6% 740.05 Santa Ana 86% 69% 19 6 17 42 40.5% 740.06 Santa Ana 75% 63% 40 10 19 69 27.5% 741.02 Santa Ana 93% 80% 42 16 19 77 24.7% 741.03 Santa Ana 93% 78% 21 8 15 44 34.1% 741.06 Santa Ana 62% 76% 33 14 13 60 217% 741.07 Santa Ana 43% 94% 42 10 19 71 26.8% 741.08 Santa Ana 43% 94% 15 5 9 29 31.0% 741.09 Santa Ana 95% 78% 16 6 8 30 26.7% 741.10 Santa Ana 78% 118% 12 1 6 19 31.6% 741.11 Santa Ana 81% 93% 26 8 15 49 30.6% 742.00 Santa Ana 95% 75% 35 10 32 77 41.6% 743.00 Santa Ana 97% 70% 19 4 7 30 23.3% 744.03 Santa Ana 95% 48% 1 1 1 3 33.3% 744.05 Santa Ana 95% 41% 20 8 8 36 22.2% 744.06 Santa Ana 92% 45% 7 4 5 16 31.3% 744.07 Santa Ana 93% 48% 12 6 14 32 43.8% 745.01 Santa Ana 99% 48% 7 3 6 16 37.5% 745.02 Santa Ana 97% 74% 11 4 10 25 40.0% 3�1 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 746.01 Santa Ana 93% 55% 47 15 15 77 19.5% 746.02 Santa Ana 97% 59% 24 5 23 52 44.2% 747.01 Santa Ana 98% 72% 26 10 21 57 36.8% 747.02 Santa Ana 96% 71% 28 4 18 50 36.0% 748.01 Santa Ana 98% 60% 19 4 15 38 39.5% 748.02 Santa Ana 94% 49% 14 5 15 34 44.1% 748.03 Santa Ana 92% 66% 42 5 14 61 23.0% 748.05 Santa Ana 98% 49% 7 5 4 16 25.0% 748.06 Santa Ana 99% 49% 10 0 5 15 33.3% 749.01 Santa Ana 98% 46% 33 4 26 63 41.3% 749.02 Santa Ana 99% 45% 9 8 17 34 50.0% 750.02 Santa Ana 96% 47% 23 14 21 58 36.2% 750.03 Santa Ana 96% 41% 4 4 1 9 11.1% 750.04 Santa Ana 96% 42% 1 1 2 4 50.0% 751.00 Santa Ana 78% 51% 37 14 11 62 17.7% 752.01 Santa Ana 97% 71% 22 7 15 44 34.1% 752.02 Santa Ana 95% 59% 23 6 23 52 44.2% 753.01 Santa Ana 70% 80% 23 10 10 43 23.3% 753.02 Santa Ana 82% 67% 23 5 9 37 24.3% 753.03 Santa Ana 44% 112% 20 6 13 39 33.3% 754.01 Santa Ana 49% 112% 28 4 5 37 13.5% 754.03 Santa Ana 62% 76% 59 3 31 93 33.3% 754.04 Santa Ana 61% 77% 22 7 9 38 23.7% 754.05 Santa Ana 37% 76% 10 4 2 16 12.5% 755.15 Santa Ana 79% 62% 214 40 71 325 21.8% 757.01 Santa Ana 43% 94% 32 2 7 41 17.1% 758.06 Santa Ana 48% 90% 30 3 4 37 10.8% 759.02 Santa Ana 43% 75% 23 10 4 37 10.8% 760.00 Santa Ana 51% 86% 64 27 24 115 20.9% 889.03 Santa Ana 86% 79% 30 11 8 49 16.3% 890.01 Santa Ana 90% 72% 40 9 25 74 33.8% 890.04 Santa Ana 89% 56% 43 13 17 73 23.3% 891.02 Santa Ana 82% 75% 43 11 26 80 32.5% 891.04 Santa Ana 93% 43% 5 1 6 12 50.0% 891.05 Santa Ana 97% 45% 15 8 6 29 20.7% 891.07 Santa Ana 78% 89% 25 6 11 42 26.2% 992.02 Santa Ana 83% 83% 33 6 10 49 20.4% 992.03 Santa Ana 75% 89% 17 10 5 32 15.6% 992.47 Santa Ana 89% 76% 10 10 11 31 35.5% 992.48 Santa Ana 89% 55% 14 3 10 27 37.0% 3J°2 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 992.49 Santa Ana 97% 59% 9 3 7 19 36.8% Subtotal 1,647 468 840 2,955 28.4% 888.02 Westminster 76% 76% 75 3 13 91 14.3% 889.01 Westminster 77% 70% 38 11 7 56 12.5% 889.04 Westminster 82% 97% 29 6 8 43 18.6% 889.05 Westminster 79% 85% 29 5 5 39 12.8% 992.03 Westminster 75% 89% 17 10 5 32 15.6% 992.04 Westminster 65% 81 % 23 7 8 38 21.1% 992.22 Westminster 59% 77% 26 5 8 39 20.5% 992.23 Westminster 69% 84% 21 0 2 23 8.7% 992.41 Westminster 43% 98% 16 4 3 23 13.0% 996.01 Westminster 73% 62% 28 11 19 58 32.8% 996.02 Westminster 33% 106% 20 3 5 28 17.9% 996.03 Westminster 30% 111% 35 5 14 54 25.9% 997.01 Westminster 72% 80% 23 5 7 35 20.0% 997.02 Westminster 64% 88% 32 12 10 54 18.5% 997.03 Westminster 48% 116% 27 10 13 50 26.0% 998.01 Westminster 67% 82% 30 3 21 54 38.9% 998.02 Westminster 75% 54% 7 7 8 22 36.4% 998.03 Westminster 78% 62% 25 5 8 38 21.1% 999.02 Westminster 55% 81% 17 6 2 25 8.0% 999.03 Westminster 70% 67% 32 3 5 40 12.5% 999.04 Westminster 72% 56% 20 4 4 28 14.3% 999.05 Westminster 33% 76% 6 2 1 9 11.1% 999.06 Westminster 30% 122% 36 4 7 47 14.9% Subtotal 612 131 183 926 19.8% TOTAL 1 14,262 1 3,1521 4,909 1 22,323 1 22.0% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates 3J° 3 Table F -3 Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 423.20 Aliso Viejo 33% 95% 22 0 1 23 4.3% 423.33 Aliso Viejo 32% 103% 7 2 1 10 10.0% 626.25 Aliso Viejo 39% 76% 29 3 3 35 8.6% 626.33 Aliso Viejo 26% 177% 10 1 2 13 15.4% 626.34 Aliso Viejo 26% 144% 8 4 2 14 14.3% 626.35 Aliso Viejo 28% 142% 12 2 4 18 22.2% 626.36 Aliso Viejo 33% 107% 2 1 2 5 40.0% 626.37 Aliso Viejo 27% 130 % 14 1 1 16 6.3% 626.38 Aliso Viejo 29% 122% 10 2 4 16 25.0% 626.39 Aliso Viejo 30% 135% 24 5 0 29 0.0% 626.40 Aliso Viejo 27% 129% 8 0 2 10 20.0% 626.41 Aliso Viejo 38% 93% 7 5 2 14 14.3% 626.47 Aliso Viejo 22% 101% 1 0 1 2 50.0% Subtotal 154 26 25 205 12.2% 14.03 Brea 28% 119% 6 1 1 8 12.5% 14.04 Brea 1 75% 1 69% 1 61 1 1 2 1 9 1 22.2% 15.01 Brea 27% 125% 6 0 01 6 1 0.0% 15.03 Brea 38% 93% 2 01 1 1 3 1 33.3% 15.04 Brea 49% 79% 3 21 01 5 1 0.0% 15.05 Brea 31% 115% 5 1 0 6 0.0% 1 5.06 Brea 31% 128% 4 0 1 5 20.0% 15.07 Brea 34% 92% 8 1 2 11 18.2% 117.09 Brea 22% 134% 1 0 0 1 0.0% 117.17 Brea 21% 113% 1 0 0 1 0.0% 218.14 Brea 31% 126% 5 0 1 6 16.7% 218.15 Brea 20% 125% 9 1 2 12 16.7% Subtotal 56 7 10 73 13.7% 1100.01 Cypress 29% 111% 3 1 0 4 0.0% 1100.10 Cypress 37% 121% 2 0 0 2 0.0% 1100.11 Cypress 31% 149% 4 0 0 4 0.0% 1101.02 Cypress 56% 115 %p 3 0 0 3 0.0% 1101.04 Cypress 45% 100% 5 1 1 7 14.3% 1101.06 Cypress 32% 101% 2 0 1 3 33.3% 1101.09 Cypress 43% 100% 0 0 0 0 0.0% 1101.10 Cypress 51% 80% 4 1 2 7 28.6% 1101.11 Cypress 42% 98% 8 4 1 13 7.7% 1101.13 Cypress 46% 112% 0 0 0 0 0.0% 1101.14 Cypress 34% 110% 2 1 1 4 25.0% 1101.17 Cypress 39% 105% 0 0 1 1 100.0% 1101.18 Cypress 66% 173% 0 01 0 0 0.0% 39 � Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 1102.02 Cypress 61% 68% 7 1 2 10 20.0% Subtotal 40 9 9 58 15.5% 422.01 Dana Point 20% 96% 2 1 4 7 57.1% 422.05 Dana Point 23% 125% 1 0 2 3 66.7% 422.06 Dana Point 11% 102% 1 0 2 3 66.7% 423.05 Dana Point 9% 176% 0 0 0 0 0.0% 423.10 Dana Point 37% 85% 16 2 8 26 30.8% 423.11 Dana Point 21% 127% 3 0 1 4 25.0% 423.13 Dana Point 38% 86% 1 0 1 2 50.0% 423.23 Dana Point 12% 129% 1 1 1 3 33.3% 423.24 Dana Point 12% 163% 2 0 0 2 0.0% 423.38 Dana Point 14% 135% 5 2 2 9 22.2% 423.39 Dana Point 25% 119% 1 0 0 1 0.0% Subtotal 33 6 21 60 35.0% 1101.02 La Palma 56% 115% 3 0 0 3 0.0% 1101.11 La Palma 1 42% 1 98% 1 81 41 1 131 7.7% 1101.15 La Palma 63% 123% 4 1 0 5 0.0% 1101.16 La Palma 72% 107% 1 0 0 1 0.0% 1103.01 La Palma 56% 101% 13 2 2 171 11.8% 1103.04 Palma 55% 102% 6 1 0 7 0.0% Subtotal 4Laguna 35 8 3 46 6.5% 423.05 una Bch. 9% 176% 0 0 0 0 0.0% 626.04 Bch. 11% 177% 3 0 2 5 40.0% 626.05 Laguna Bch. 16% 103% 0 0 1 1 100.0% 626.19 Laguna Bch. 9% 142% 0 0 0 0 0.0% 626.20 Laguna Bch. 11% 172% 0 0 1 1 100.0% 626.23 Laguna Bch. 8% 102% 3 0 1 4 25.0% 626.32 Laguna Bch. 12% 189% 0 0 0 0 0.0% Subtotal 6 0 5 11 45.5% 423.07 Laguna Hills 36% 108% 5 1 1 7 14.3% 423.20 Laguna Hills 33% 95% 22 0 1 23 4.3% 423.27 Laguna Hills 23% 147% 2 0 0 2 0.0% 423.28 Laguna Hills 15% 217 % 0 0 0 0 0.0% 423.33 Laguna Hills 32% 103% 7 2 1 10 10.0% 423.35 Laguna Hills 29% 110% 8 0 1 9 11.1% 626.21 Laguna Hills 30% 104% 4 3 3 10 30.0% 626.22 Laguna Hills 11% 71% 0 0 0 0 0.0% 626.23 Laguna Hills 8 % 102% 3 0 1 4 25.0% 626.25 Laguna Hills 39% 76% 29 3 3 35 8.6% 626.47 Laguna Hills 22% 101% 1 0 1 2 50.0% Subtotal 81 9 12 102 11.8% 3J° 5 Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 626.21 Laguna Woods 30% 104% 4 3 3 10 30.0% 626.22 Laguna Woods 11% 71% 0 0 0 0 0.0% 626.23 Laguna Woods 8% 102% 3 0 1 4 25.0% 626.25 Laguna Woods 39% 76% 29 3 3 35 8.6% 626.35 Laguna Woods 28% 142% 12 2 4 18 22.2% 626.41 Laguna Woods 38% 93% 7 5 2 14 14.3% 626.46 Laguna Woods 7% 61% 0 0 0 0 0.0% 626.47 Laguna Woods 22% 101% 1 0 1 2 50.0% Subtotal 56 13 14 83 16.9% 1100.07 Los Alamitos 15% 148% 1 0 0 1 0.0% 1100.12 Los Alamitos 24% 164% 2 0 0 2 0.0% 1100.14 Los Alamitos 38% 79% 1 1 1 3 33.3% 1100.15 Los Alamitos 22% 111% 1 0 1 2 50.0% 1101.06 Los Alamitos 32% 101% 2 0 1 3 33.3% 1101.08 Los Alamitos 34% 112% 0 0 0 0 0.0% 1101.13 Los Alamitos 1 46% 1 112% 1 01 01 01 01 0.0% 1101.17 Los Alamitos 39 % 105% 0 0 1 1 100.0% Subtotal 7 1 4 12 33.3% 117.08 Placentia 43% 74% 6 0 0 6 0.0% 117.09 Placentia 22% 134% 1 0 0 1 0.0% 117.10 Placentia 25% 123% 3 0 0 3 0.0% 117.11 Placentia 62% 63% 6 2 4 12 33.3% 117.12 Placentia 60% 80% 6 0 2 8 25.0% 117.15 Placentia 27% 134% 6 1 2 9 22.2% 117.17 Placentia 21% 113% 1 0 0 1 0.0% 117.18 Placentia 25% 127% 2 0 2 4 50.0% 117.20 Placentia 93% 47% 2 0 3 5 60.0% 117.21 Placentia 72% 61% 8 1 4 13 30.8% 117.22 Placentia 67% 74% 5 0 1 6 16.7% 218.10 Placentia 23% 112% 6 1 0 7 0.0% 218.13 Placentia 74% 82% 1 0 0 1 0.0% 218.15 Placentia 20% 125% 9 1 2 12 16.7% 218.20 Placentia 34% 133% 1 0 1 2 50.0% 218.21 Placentia 46% 102% 14 1 2 17 11.8% Subtotal 77 7 23 107 21.5% 995.02 Seal Beach 62% 51% 0 0 0 0 0.0% 995.04 Seal Beach 12% 151% 0 0 0 0 0.0% 995.06 Seal Beach 13% 129% 0 0 0 0 0.0% 995.09 Seal Beach 6% 60% 0 0 0 0 0.0% 995.10 Seal Beach 8% 57% 0 0 0 0 0.0% 3J° (o Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 995.11 Seal Beach 14% 124% 0 0 0 0 0.0% 995.12 Seal Beach 18% 145% 1 1 1 3 33.3% 1100.07 Seal Beach 15% 148% 1 0 0 1 0.0% 1100.08 Seal Beach 17% 125% 1 0 1 2 50.0% 1100.12 Seal Beach 24% 164% 2 0 0 2 0.0% Subtotal 5 1 2 8 25.0% 878.01 Stanton 56% 75% 10 1 2 13 15.4% 878.02 Stanton 65% 70% 12 0 5 17 29.4% 878.03 Stanton 87% 49% 4 0 2 6 33.3% 878.05 Stanton 68% 67% 9 2 3 14 21.4% 878.06 Stanton 78% 52% 12 3 3 18 16.7% 879.01 Stanton 72% 71% 11 0 1 12 8.3% 879.02 Stanton 82% 67% 1 0 2 3 66.7% 881.01 Stanton 45% 90% 10 1 4 15 26.7% 881.04 Stanton 55% 75% 2 0 0 2 0.0% 881.05 Stanton 61% 96% 2 0 4 6 66.7% 881.06 Stanton 61% 59% 7 0 1 8 12.5% 1101.13 Stanton 46% 112% 0 0 0 0 0.0% 1102.03 Stanton 41% 88% 15 2 3 20 15.0% Subtotal 95 9 30 134 22.4% 758.09 Villa Park 21% 185% 0 0 1 1 100.0% 758.10 Villa Park 23% 186% 2 0 0 2 0.0% 758.11 Villa Park 58% 98% 2 0 0 2 0.0% 758.12 Villa Park 52% 86% 3 0 0 3 0.0% 758.13 Villa Park 36% 127 % 5 1 2 8 25.0% 758.14 Villa Park 37% 176 % 1 0 0 1 0.0% Subtotal 13 1 3 17 17.6% 117.17 Yorba Linda 21% 113% 1 0 0 1 0.0% 117.18 Yorba Linda 25% 127% 2 0 2 4 50.0% 218.02 Yorba Linda 25% 122% 8 2 3 13 23.1% 218.09 Yorba Linda 18% 126% 2 0 0 2 0.0% 218.10 Yorba Linda 23% 112% 6 1 0 7 0.0% 218.12 Yorba Linda 33% 109% 15 1 2 18 11.1% 218.15 Yorba Linda 20% 125% 9 1 2 12 16.7% 218.16 Yorba Linda 17% 138% 9 1 2 12 16.7% 218.17 Yorba Linda 23% 122% 8 0 2 10 20.0% 218.20 Yorba Linda 34% 133% 1 0 1 2 50.0% 218.22 Yorba Linda 21 % 143% 6 0 2 8 25.0% 218.23 Yorba Linda 26% 139% 4 0 0 4 0.0% 218.24 Yorba Linda 24% 168% 1 0 0 1 0.0% S�7 Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Ori inated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 218.25 Yorba Linda 26% 163% 3 1 0 4 0.0% 218.26 Yorba Linda 30% 105% 3 0 0 3 0.0% 218.27 Yorba Linda 31% 183% 4 2 1 7 14.3% 218.28 Yorba Linda 33% 197% 3 0 2 5 40.0% 218.29 Yorba Linda 29% 184% 1 0 0 1 0.0% 218.30 Yorba Linda 22% 169% 2 0 0 2 0.0% 219.24 Yorba Linda 43% 145% 2 1 2 5 40.0% Subtotal 90 10 21 121 17.4% 11.01 Unincorp. 38% 108% 9 0 2 11 18.2% 12.01 Unincorp. 82% 57% 7 2 2 11 18.2% 14.01 Unincorp. 53% 78% 4 1 1 6 16.7% 14.02 Unincorp. 53% 90% 10 0 2 12 16.7% 15.01 Unincorp. 27% 125% 6 0 0 6 0.0% 15.06 Unincorp. 31% 128% 4 0 1 5 20.0% 17.07 Unincorp. 69% 131% 4 0 0 4 0.0% 19.03 Unincorp. 56% 67% 5 0 1 6 16.7% 117.11 Unincorp. 62% 63% 6 2 4 12 33.3% 117.15 Unincorp. 27% 134% 6 1 21 9 22.2% 117.18 Unincorp. 25% 127% 2 0 2 4 50.0% 218.12 33% 109% 15 1 2 18 11.1 218.15 *in 20% 125% 9 1 2 12 16.7% 218.16 p. 17% 138% 9 1 2 12 16.7% 218.17 . 23% 122% 8 0 2 10 20.0% 219.12 Unincorp. 19% 194% 0 0 0 0 0.0% 219.13 Unincorp. 70% 96% 9 3 4 16 25.0% 219.14 Unincorp. 44% 110% 4 0 0 4 0.0% 219.17 Unincorp. 18% 161% 2 0 0 2 0.0% 219.18 Unincorp. 38% 120% 9 2 3 14 21.4% 219.24 Unincorp. 43% 145% 2 1 2 5 40.0% 320.11 Unincorp. 10% 162% 3 1 0 4 0.0% 320.23 Unincorp. 16% 157% 21 4 6 31 19.4% 320.41 Unincorp. 21% 212% 0 0 0 0 0.0% 320.42 Unincorp. 19% 165% 3 1 2 6 33.3% 320.44 Unincorp. 13% 255% 0 0 0 0 0.0% 320.45 Unincorp. 22% 151% 10 1 2 13 15.4% 320.46 Unincorp. 14% 262% 1 0 2 3 66.7% 320.49 Unincorp. 24% 158% 8 1 3 12 25.0% 320.52 Unincorp. 13% 203% 78 10 19 107 17.8% 320.53 Unincorp. 23% 130% 22 2 9 33 27.3% 320.56 Unincorp. 28% 163% 19 3 5 27 18.5% Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 423.35 Unincorp. 29% 110% 8 0 1 9 11.1% 524.04 Unincorp. 63% 107% 0 0 0 0 0.0% 524.20 Unincorp. 50% 183% 7 3 2 12 16.7% 524.21 Unincorp. 28% 154% 4 1 2 7 28.6% 524.22 Unincorp. 26% 136% 13 0 3 16 18.8% 524.26 Unincorp. 30% 161% 9 0 4 13 30.8% 524.27 Unincorp. 32% 150% 7 6 2 15 13.3% 524.28 Unincorp. 22% 149% 19 3 0 22 0.0% 626.04 Unincorp. 11% 177% 3 0 2 5 40.0% 626.41 Unincorp. 38% 93% 7 5 2 14 14.3% 626.43 Unincorp. 22% 272% 0 0 1 1 100.0% 626.45 Unincorp. 17% 245% 1 0 0 1 0.0% 630.09 Unincorp. 12% 199% 0 0 0 0 0.0% 631.01 Unincorp. 26% 94% 0 0 0 0 0.0% 631.02 Unincorp. 19% 100% 4 0 3 7 42.9% 631.03 Unincorp. 12% 145% 1 0 0 1 0.0% 755.04 Unincorp. 37% 112% 6 0 1 7 14.3% 755.06 Unincorp. 31% 121% 3 1 3 7 42.9% 756.03 Unincorp. 22% 122% 5 1 3 9 33.3% 756.04 Unincorp. 22% 197% 4 0 1 5 20.0% 756.05 Unincorp. 27% 177% 5 0 1 6 16.7% 756.06 Unincorp. 24% 207% 1 1 0 2 0.0% 757.01 Unincorp. 43% 94% 5 0 1 6 16.7% 757.02 Unincorp. 21% 125% 3 0 1 4 25.0% 757.03 Unincorp. 18% 150% 3 0 0 3 0.0% 758.07 Unincorp. 52% 108% 5 1 6 12 50.0% 758.08 Unincorp. 21% 129% 4 2 0 6 0.0% 762.02 Unincorp. 39% 86% 16 4 4 24 16.7% 762.04 Unincorp. 79% 61% 3 0 0 3 0.0% 762.08 Unincorp. 30% 90% 22 2 1 25 4.0% 867.01 Unincorp. 65 % 79% 24 1 5 30 16.7% 871.01 Unincorp. 67% 66% 3 0 2 5 40.0% 877.01 Unincorp. 54% 82% 9 0 7 16 43.8% 877.03 Unincorp. 72% 89% 10 1 3 14 21.4% 878.01 Unincorp. 56% 75% 10 1 2 13 15.4% 878.05 Unincorp. 68% 67% 9 2 3 14 21.4% 878.06 Unincorp. 78% 52% 12 3 3 18 16.7% 879.02 Unincorp. 82% 67% 1 0 2 3 66.7% 992.30 Unincorp. 26% 119% 8 1 2 11 18.2% 994.17 Unincorp. 20% 129% 3 0 1 4 25.0% 3�1 Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract — 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 995.06 Unincorp. 13% 129% 0 0 0 0 0.0% 995.13 Unincorp. 14% 187% 0 0 0 0 0.0% 997.01 Unincorp. 72% 80% 1 0 0 1 0.0% 997.02 Unincorp. 64% 88% 3 0 1 4 25.0% 997.03 Unincorp. 48% 116% 1 0 2 3 66.7% 1100.06 Unincorp. 18% 149% 0 0 0 0 0.0% 1100.07 Unincorp. 15% 148% 1 0 0 1 0.0% 1100.08 Unincorp. 17% 125% 1 0 1 2 50.0% 1106.04 Unincorp. 55% 102% 4 0 1 5 20.0% Subtotal 563 77 161 801 20.1% TOTAL 1,311 184 343 1,838 18.7% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates Gi Table F -4 Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 423.20 Aliso Viejo 33% 95% 58 17 15 90 16.7% 423.33 Aliso Viejo 32% 103% 29 6 7 42 16.7% 626.25 Aliso Viejo 39% 76% 83 7 15 105 14.3% 626.33 Aliso Viejo 26% 177% 77 14 12 103 11.7% 626.34 Aliso Viejo 26% 144% 57 13 20 90 22.2% 626.35 Aliso Viejo 28% 142% 65 7 15 87 17.2% 626.36 Aliso Viejo 33% 107% 30 5 12 47 25.5% 626.37 Aliso Viejo 27% 130% 50 10 5 65 7.7% 626.38 Aliso Viejo 29% 122% 63 9 15 87 17.2% 626.39 Aliso Viejo 30% 135% 123 27 27 177 15.3% 626.40 Aliso Viejo 27% 129% 41 8 6 55 10.9% 626.41 Aliso Viejo 38% 93% 79 12 13 104 12.5% 626.47 Aliso Viejo 22% 101% 36 5 1 42 2.4% Subtotal 791 140 163 1,094 14.9% 14.03 Brea 28% 119% 15 4 4 23 17.4% 14.04 Brea 75% 69% 19 11 5 35 14.3% 15.01 Brea 27% 125% 45 8 16 69 23.2% 15.03 Brea 38% 93% 25 5 3 33 9.1% 15.04 Brea 49% 79% 24 2 6 32 18.8% 15.05 Brea 31% 115% 59 12 20 91 22.0% 15.06 Brea 31% 128% 32 7 6 45 13.3% 15.07 Brea 34% 92% 20 3 8 31 25.8% 117.09 Brea 22% 134% 19 2 5 26 19.2% 117.17 Brea 21% 113% 20 3 5 28 17.9% 218.14 Brea 31% 126% 29 5 3 37 8.1% 218.15 Brea 20% 125% 63 21 15 99 15.2% Subtotal 370 83 96 549 17.5% 1100.01 Cypress 29% 111% 25 6 5 36 13.9% 1100.10 Cypress 37% 121% 30 3 3 36 8.3% 1100.11 Cypress 31% 149% 23 1 0 24 0.0% 1101.02 Cypress 56% 115% 42 5 16 63 25.4% 1101.04 Cypress 45% 100% 31 6 7 44 15.9% 1101.06 Cypress 32% 101% 27 5 5 37 13.5% 1101.09 Cypress 43% 100% 29 2 6 37 16.2% 1101.10 Cypress 51% 80% 23 3 5 31 16.1% 1101.11 Cypress 42% 98% 33 3 6 42 14.3% 1101.13 Cypress 46% 112% 11 2 2 15 13.3% 1101.14 Cypress 34% 110% 32 9 6 47 12.8% 1101.17 Cypress 39% 105% 51 2 8 25 32.0% 1101.18 Cypress 66% 173% 7 3 2 12 10% SMI Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 1102.02 Cypress 61% 68% 43 3 12 58 20.7% Subtotal 371 53 83 507 16.4% 422.01 Dana Point 20% 96% 41 9 25 75 33.3% 422.05 Dana Point 23% 125% 56 10 14 80 17.5% 422.06 Dana Point 11% 102% 32 5 7 44 15.9% 423.05 Dana Point 9% 176% 34 5 12 51 23.5% 423.10 Dana Point 37% 85% 64 14 19 97 19.6% 423.11 Dana Point 21% 127% 38 8 2 48 4.2% 423.13 Dana Point 38% 86% 24 7 7 38 18.4% 423.23 Dana Point 12% 129% 62 11 23 96 24.0% 423.24 Dana Point 12% 163% 29 15 14 58 24.1% 423.38 Dana Point 14% 135% 42 9 15 66 22.7% 423.39 Dana Point 25% 119% 27 7 6 40 15.0% Subtotal 449 100 144 693 20.8% 1101.02 La Palma 56% 115% 42 5 16 63 25.4% 1101.11 La Palma 42% 1 98% 1 33 1 31 6 42 1 14.3% 1101.15 La Palma 63% 123% 12 3 2 17 11.8% 1101.16 La Palma 72% 107% 171 4 3 241 12.5% 1103.01 La Palma 56% 101% 42 1 10 53 18.9% 1103.04 La Palma 55% 102% 32 4 9 45 20.0% Subtotal 178 20 46 244 18.9% 423.05 La E Bch. 9% 176% 34 5 12 51 23.5% 626.04 La Bch. 11% 177% 196 47 62 305 20.3% 626.05 Laguna Bch. 16% 103% 16 4 7 27 25.9% 626.19 Laguna Bch. 9% 142% 33 10 10 53 18.9% 626.20 Laguna Bch. 11% 172% 45 6 19 70 27.1% 626.23 Laguna Bch. 8% 102% 72 14 16 102 15.7% 626.32 Laguna Bch. 12% 189% 25 5 16 46 34.8% Subtotal 421 91 142 654 21.7% 423.07 Laguna Hills 36% 108% 42 3 14 59 23.7% 423.20 Laguna Hills 33% 95% 58 17 15 90 16.7% 423.27 Laguna Hills 23% 147% 26 5 8 39 20.5% 423.28 Laguna Hills 15% 217% 20 1 2 23 8.7% 423.33 Laguna Hills 32% 103% 29 6 7 42 16.7% 423.35 Laguna Hills 29% 110% 87 24 36 147 24.5% 626.21 Laguna Hills 30% 104% 63 15 40 118 33.9% 626.22 Laguna Hills 11% 71% 45 6 15 66 22.7% 626.23 Laguna Hills 8% 102% 72 14 16 102 15.7% 626.25 Laguna Hills 39% 76% 83 7 15 105 14.3% 626.47 Laguna Hills 22% 101% 36 5 1 42 2.4% Subtotal 561 103 169 833 20.3% iw-j Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 626.21 Laguna Woods 30% 104% 63 15 40 118 33.9% 626.22 Laguna Woods 11% 71% 45 6 15 66 22.7% 626.23 Laguna Woods 8% 102% 72 14 16 102 15.7% 626.25 Laguna Woods 39% 76% 83 7 15 105 14.3% 626.35 Laguna Woods 28% 142% 65 7 15 87 17.2% 626.41 Laguna Woods 38% 93% 79 12 13 104 12.5% 626.46 Laguna Woods 7% 61% 71 1 1 73 1.4% 626.47 Laguna Woods 22% 101% 36 5 1 42 2.4% Subtotal 514 67 116 697 16.6% 1100.07 Los Alamitos 15% 148% 22 9 5 36 13.9% 1100.12 Los Alamitos 24% 164% 33 5 4 42 9.5% 1100.14 Los Alamitos 38% 79% 15 1 0 16 0.0% 1100.15 Los Alamitos 22% 111% 29 7 6 42 14.3% 1101.06 Los Alamitos 32% 101% 27 5 5 37 13.5% 1101.08 Los Alamitos 34% 112% 11 0 2 13 15.4% 1101.13 Los Alamitos 46% 112% 11 2 2 15 13.3% 1101.17 Los Alamitos 39% 105% 15 2 8 25 32.0% Subtotal 163 31 32 226 14.2% 117.08 Placentia 43% 74% 18 2 5 25 20.0% 117.09 Placentia 22% 134% 19 2 5 26 19.2% 117.10 Placentia 25% 123% 16 3 2 21 9.5% 117.11 Placentia 62% 63% 27 3 7 37 18.9% 117.12 Placentia 60% 80% 19 2 12 33 36.4% 117.15 Placentia 27% 134% 41 4 11 56 19.6% 117.17 Placentia 21% 113% 20 3 5 28 17.9% 117.18 Placentia 25% 127% 24 2 6 32 18.8% 117.20 Placentia 93% 47% 11 3 12 26 46.2% 117.21 Placentia 72% 61% 12 6 6 24 25.0% 117.22 Placentia 67% 74% 14 4 3 21 14.3% 218.10 Placentia 23% 112% 20 1 5 26 19.2% 218.13 Placentia 74% 82% 0 3 0 3 0.0% 218.15 Placentia 20% 125% 63 21 15 99 15.2% 218.20 Placentia 34% 133% 32 1 8 41 19.5% 218.21 Placentia 46% 102% 43 8 15 66 22.7% Subtotal 379 68 117 564 20.7% 995.02 Seal Beach 62% 51% 1 0 0 1 0.0% 995.04 Seal Beach 12% 151% 15 2 10 27 37.0% 995.06 Seal Beach 13% 129% 3 1 7 11 63.6% 995.09 Seal Beach 6% 60% 3 0 1 4 25.0% 995.10 Seal Beach 8% 57% 0 1 0 1 0.0% +lr Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 995.11 Seal Beach 14% 124% 17 3 0 20 0.0% 995.12 Seal Beach 18% 145% 15 7 6 28 21.4% 1100.07 Seal Beach 15% 148% 22 9 5 36 13.9% 1100.08 Seal Beach 17% 125% 45 7 10 62 16.1% 1100.12 Seal Beach 24% 164% 33 5 4 42 9.5% Subtotal 154 35 43 232 18.5% 878.01 Stanton 56% 75% 35 3 9 47 19.1% 878.02 Stanton 65% 70% 31 5 11 47 23.4% 878.03 Stanton 87% 49% 15 2 3 20 15.0% 878.05 Stanton 68% 67% 29 10 15 54 27.8% 878.06 Stanton 78% 52% 24 8 14 46 30.4% 879.01 Stanton 72% 71% 53 6 6 65 9.2% 879.02 Stanton 82% 67% 25 4 9 38 23.7% 881.01 Stanton 45% 90% 40 9 16 65 24.6% 881.04 Stanton 55% 75% 11 1 3 15 20.0% 881.05 Stanton 61% 96% 21 6 5 32 15.6% 881.06 Stanton 61% 59% 21 11 6 38 15.8% 1101.13 Stanton 46% 112% 11 2 2 15 13.30 1102.03 Stanton 41% 88% 491 3 16 68 23.5% Subtotal 365 70 115 550 20.9% 758.09 Villa Park 21% 185% 25 5 4 34 11.8% 758.10 Villa Park 23% 186% 23 6 4 33 12.15 758.11 Villa Park 58% 98% 7 3 1 11 9.1% 758.12 Villa Park 52% 86% 27 6 3 36 8.3% 758.13 Villa Park 36% 127% 37 11 16 64 25.0% 758.14 Villa Park 37% 176% 27 6 6 39 15.4% Subtotal 146 37 34 217 15.7% 117.17 Yorba Linda 21% 113% 20 3 5 28 17.9% 117.18 Yorba Linda 25% 127% 24 2 6 32 18.8% 218.02 Yorba Linda 25% 122% 52 16 27 95 28.4% 218.09 Yorba Linda 18% 126% 18 2 8 28 28.6% 218.10 Yorba Linda 23% 112% 20 1 5 26 19.2% 218.12 Yorba Linda 33% 109% 41 8 13 62 21.0% 218.15 Yorba Linda 20% 125% 63 21 15 99 15.2% 218.16 Yorba Linda 17% 138% 40 8 17 65 26.2% 218.17 Yorba Linda 23% 122% 24 10 5 39 12.8% 218.20 Yorba Linda 34% 133% 32 1 8 41 19.5% 218.22 Yorba Linda 21% 143% 150 46 48 244 19.7% 218.23 Yorba Linda 26% 139% 28 8 6 42 14.3% 218.24 Yorba Linda 24% 168% 11 4 2 17 11.8% 1' =: Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 218.25 Yorba Linda 26% 163% 28 13 8 49 16.3% 218.26 Yorba Linda 30% 105% 29 5 2 36 5.6% 218.27 Yorba Linda 31% 183% 33 8 22 63 34.9% 218.28 Yorba Linda 33% 197% 29 7 2 38 5.3% 218.29 Yorba Linda 29% 184% 35 3 9 47 19.1% 218.30 Yorba Linda 22% 169% 32 8 3 43 7.0% 219.24 Yorba Linda 43% 145% 31 1 7 39 17.9% Subtotal 740 175 218 1,133 19.2% 11.01 Unincorp. 38% 108% 39 3 7 49 14.3% 12.01 Unincorp. 82% 57% 20 9 11 40 27.5% 14.01 Unincorp. 53% 78% 19 4 2 25 8.0% 14.02 Unincorp. 53% 90% 24 7 7 38 18.4% 15.01 Unincorp. 27% 125% 45 8 16 69 23.2% 15.06 Unincorp. 31% 128% 32 7 6 45 13.3% 17.07 Unincorp. 69% 131% 49 6 7 62 11.3% 19.03 Unincorp. 56% 67% 13 0 3 16 18.8% 117.11 Unincorp. 62% 63% 27 3 7 37 18.9% 117.15 Unincorp. 27% 134% 41 4 11 56 19.6% 117.18 Unincorp. 25% 127% 24 2 6 32 18.8% 218.12 Unincorp. 33% 109% 41 8 13 62 21.0% 218.15 Unincorp. 20% 125% 63 21 15 99 15.2% 218.16 Unincorp. 17% 138% 40 8 17 65 26.2% 218.17 Unincorp. 23% 122% 24 10 5 39 12.8% 219.12 Unincorp. 19% 194% 59 4 9 72 12.5% 219.13 Unincorp. 70% 96% 44 11 8 63 12.7% 219.14 Unincorp. 44% 110% 16 6 10 32 31.3% 219.17 Unincorp. 18% 161% 14 5 8 27 29.6% 219.18 Unincorp. 38% 120% 36 7 17 60 28.3% 21924 Unincorp. 43% 145% 31 1 7 39 17.9% 320.11 Unincorp. 10% 162% 8 1 4 13 30.8% 320.23 Unincorp. 16% 157% 206 67 89 362 24.6% 320.41 Unincorp. 21% 212% 7 5 4 16 25.0% 320.42 Unincorp. 19% 165% 32 9 6 47 12.8% 320.44 Unincorp. 13% 255% 53 14 9 76 11.8% 320.45 Unincorp. 22% 151% 19 3 6 28 21.4% 320.46 Unincorp. 14% 262% 81 24 22 127 17.3% 320.49 Unincorp. 24% 158% 74 10 21 105 20.0% 320.52 Unincorp. 13% 203% 363 76 134 573 23.4 % 320.53 Unincorp. 23% 130% 97 17 31 145 21.4% 320.56 Unincorp. 28% 163% 65 21 17 103 16.5% 2M Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 423.35 Unincorp. 29% 110% 87 24 36 147 24.5% 524.04 Unincorp. 63% 107% 4 0 1 5 20.0% 524.20 Unincorp. 50% 183% 204 47 34 285 11.9% 524.21 Unincorp. 28% 154% 45 13 11 69 15.9% 524.22 Unincorp. 26% 136% 27 3 4 34 11.8% 524.26 Unincorp. 30% 161% 155 27 39 221 17.6% 524.27 Unincorp. 32% 150% 57 17 19 93 20.4% 524.28 Unincorp. 22% 149% 56 4 6 66 9.1% 626.04 Unincorp. 11% 177% 196 47 62 305 20.3% 626.41 Unincorp. 38% 93% 79 12 13 104 12.5% 626.43 Unincorp. 22% 272% 49 5 23 77 29.9% 626.45 Unincorp. 17% 245% 34 7 15 56 26.8% 630.09 Unincorp. 12% 199% 13 5 5 23 21.7% 631.01 Unincorp. 26% 94% 10 5 1 16 6.3% 631.02 Unincorp. 19% 100% 54 12 15 81 18.5% 631.03 Unincorp. 12% 145% 12 3 5 20 25.0% 755.04 Unincorp. 37% 122% 23 4 7 34 20.6% 755.06 Unincorp. 31% 121% 25 1 6 32 18.8% 756.03 Unincorp. 22% 122% 29 15 11 55 20.0% 756.04 Unincorp. 22% 197% 53 10 18 81 22.2% 756.05 Unincorp. 27% 177% 54 8 13 75 17.3% 756.06 Unincorp. 24% 207% 50 7 14 71 19.7% 757.01 Unincorp. 43% 94% 32 2 7 41 17.1% 757.02 Unincorp. 21% 125% 25 3 14 42 33.3% 757.03 Unincorp. 18% 150% 33 4 9 46 19.6% 758.07 Unincorp. 52% 108% 23 6 18 471 38.3% 758.08 Unincorp. 21% 129% 21 3 3 27 11.1% 762.02 Unincorp. 39% 86% 42 7 14 63 22.2% 762.04 Unincorp. 79% 61% 14 7 8 29 27.6% 762.08 Unincorp. 30% 90% 103 11 44 158 27.8% 867.01 Unincorp. 65% 79% 47 14 15 76 19.7% 871.01 Unincorp. 67% 66% 9 2 7 18 38.9% 877.01 Unincorp. 54% 82% 31 9 12 52 23.1% 877.03 Unincorp. 72% 89% 26 3 9 38 23.7% 878.01 Unincorp. 56% 75% 35 3 9 47 19.1% 878.05 Unincorp. 68% 67% 29 10 15 54 27.8% 878.06 Unincorp. 78% 52% 24 8 14 46 30.4% 879.02 Unincorp. 82% 67% 25 4 9 38 23.7% 992.30 Unincorp. 26% 119% 32 5 11 48 22.9% Im Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract — 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 994.17 Unincorp. 20% 129% 56 16 14 86 16.3% 995.06 Unincorp. 13% 129% 3 1 7 11 63.6% 995.13 Unincorp. 14% 187% 14 3 9 26 34.6% 997.01 Unincorp. 72% 80% 23 5 7 35 20.0% 997.02 Unincorp. 64% 88% 32 12 10 54 18.5% 997.03 Unincorp. 48% 116% 27 10 13 50 26.0% 1100.06 Unincorp. 18% 149% 24 4 4 32 12.5% 1100.07 Unincorp. 15% 148% 22 9 5 36 13.9% 1100.08 Unincorp. 17% 125% 45 7 10 62 16.1% 1106.04 Unincorp. 55% 102% 55 15 13 83 15.7% Subtotal 3,874 840 1,203 5,917 20.3% TOTAL 9,476 1 1,913 2,721 114,1101 19.3% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates 407 This Page Intentionally Left Blank 4 02 Technical Appendix G Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice 409 FAIR HOUSING COUNCIL OF ORANGE COUNTY Fwfl Drhpgn n rbueM6 201 S. Broadway • Santa Ana, CA 92701 714/569 -0823 • Fax 714/835 -0281 • www.fairhousingoc.org SURVEY OF ZONING AND PLANNING CODES, POLICIES AND PRACTICES THAT MAY POSE AN IMPEDIMENT TO FAIR HOUSING CHOICE Name of Jurisdiction: Completing Department: Completed By: Date Completed: INTRODUCTION City of Newport Beach Planning Department Melinda Whelan 4/19/2010 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 24 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 and local developers of housing. 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. QUESTIONS [NOTE: For document automation please enable macros and then double click check boxes to check or uncheck I 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 Background 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 situating of group homes for individuals with 410 disabilities (but not families similarly sized and situated). Such definitions are prohibited because they could have the effect 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. 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 who were allowed to do so to five. Under the invalidated 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. For example, a city may have a definition of 'family' as follows: "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. [emphasis added] A definition of family should look to whether the household functions as a cohesive unit instead of distinguishing between related and unrelated persons. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: The 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 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 definition of "family" or "single housekeeping unit" 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 definition of "dwelling unit" or "residential unit" have the effect of discriminating against unrelated individuals with disabilities who reside together in a congregate or group living arrangement? Yes ❑ No X Background The definition of a "dwelling unit" or "residential unit" may exclude or restrict housing opportunities for individuals with disabilities by mischaracterizing congregate or group 411 living arrangements as "boarding or rooming house" a "hotel' or a "residential care facility'. Both State and Federal fair housing laws prohibit definitions of dwelling that either intentionally discriminate against people with disabilities or have the effect of excluding such individuals from housing. Generally, all dwellings are covered by fair housing laws, with a "dwelling" being defined as "a temporary or permanent dwelling place, abode or habitation to which one intends to return as distinguished from the place of temporary sojourn or transient visit." Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: The Zoning Code definition of a "dwelling unit" is: Any area within a structure on any parcel which: A. Contains separate or independent living facilities for one or more persons, with area or equipment for sleeping, sanitation and food preparation, and which has independent exterior access to ground level; or B. Is being utilized for residential purposes by one or more persons separately or independently from occupants of other areas within the structure. This definition does not have the effect of excluding or restricting housing opportunities for individuals with disabilities, or discriminating against unrelated individuals with disabilities who reside together in a congregate or group living arrangement. 3. Does the code or any policy document define "disability ", if at all, at least as broadly as the federal Fair Housing Act? Yes X No ❑ Background The federal Fair Housing Act (FHA) defines disability /handicap as follows: "Handicap" means, with respect to a person- - (1) a physical or mental impairment which substantially limits one or more of such person's major life activities, (2) a record of having such an impairment, or (3) being regarded as having such an impairment, but such term does not include current, illegal use of or addiction to a controlled substance (as defined in section 102 of the Controlled Substances Act (21 U.S.C. 802)). The term "physical or mental impairment" 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. 412 The California Fair Employment and Housing Act (FEHA) definition is somewhat broader, in that removes the word "substantially ". The FEHA definition is: (1) A physical or mental impairment that limits one or more of a person's major life activities (2) A record of having, or being perceived as having, a physical or mental impairment. It does not include current illegal use of, or addiction to, a controlled substance (as defined by Section 102 of the Federal Controlled Substance Act, 21 U.S.C. Sec. 802). Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: The 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 person who has a record of that type of impairment, not including current, illegal use of a controlled substance." This definition of disability is similar to the FEHA definition. 4. Are personal characteristics of residents, including, but not necessarily limited to, disability, considered? Yes ❑ No X Backoround 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 people, 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 conditional use permit or 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 DOXHUD 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 -4-13 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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 2 and 3. Explanation of Answer Given Above In light of the background provided, please arrived at the answer: provide a brief explanation of the how you Except when granting access to disabled individuals and groups that exceeds housing access granted to other similarly situated groups, the code does 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. 5. Does the code limit housing opportunities for disabled individuals through restrictions on the provision of on -site supportive services? Yes ❑ No X Background Housing for disabled persons, to be sustainable, successful and to allow them to fully use and enjoy the housing, 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." Joint Statement of the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 2. Explanation of Answer Given Above In light of the background provided, please arrived at the answer: provide a brief explanation of the how you The code places no restrictions on the provision of any on -site supportive services required by disabled individuals. 6. Does the jurisdiction policy have more restrictive limits for occupancies involving disabled residents than for other occupancies of unrelated, non - disabled persons? Yes ❑ No X Background 414 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." Joint Statement of the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 3. Explanation of Answer Given Above In light of the background provided, please arrived at the answer: provide a brief explanation of the how you The code does not consider whether groups living together are related or unrelated. 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, the City makes an exception for groups of disabled individuals. The 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. 7. 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? Yes X No ❑ Background Ajoint 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 415 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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 4 and 5. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: Zoning Code Chapter 20.98 provides for reasonable accommodation. 8. If the jurisdiction supplies or manages housing, is there a clear policy to allow disabled persons residing in or seeking to reside in the housing to make or request reasonable physical modifications or to request reasonable accommodations? Yes ❑ No ❑ N/A X If `Yes', is the policy communicated to applicants or residents? Yes ❑ No ❑ Explanation of Answer Given Above Please Drovide a brief description of the Dolicv. its dissemination and its 9. Does the jurisdiction require a public hearing for disabled persons seeking specific exceptions to zoning and land -use rules (variances) necessary for them to be able fully use and enjoy housing? Yes X No ❑ If `Yes', is the process the same as for other applications for variances, or does it impose added requirements? Background 410 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. In acting consistently with "affirmatively furthering fair housing," it is considered preferable to have a reasonable accommodation procedure intended to facilitate a disabled applicant's request for exceptions to zoning and land use rules, that does not require a public hearing process. As previously explained in the joint statement by DOJ and HUD: "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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 5. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you ernveo ar me answer, ano an explanaton of any ouierences for persons wrrn arsaomues: 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 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. 10.Does the zoning code distinguish housing for persons with disabilities from other residential uses by requiring an application for a conditional use permit (CUP)? Yes ❑ No X Background See the Background section for questions 7 and 9 above. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you ernveo ar me answer ana wear aspeULS of use mUraer me need ror a The code does not distinguish housing for persons with disabilities who are residing as a single housekeeping unit from any other residential use in which individuals are residing as a single housekeeping unit. Licensed residential care facilities with six or fewer residents can also establish in any residential zone without a use permit or reasonable accommodation. Licensed residential care facilities with seven or more residents, and unlicensed residential care facilities, may establish in residential zones with a CUP or reasonable accommodation, but they are the only group not living as a single housekeeping unit that can do so. By providing an opportunity to establish residences with a CUP or reasonable accommodation to disabled groups only, the code gives more favorable treatment to disabled groups not living as single housekeeping units than it gives to non - disabled groups that are not living as a single housekeeping unit. Therefore, groups of disabled individuals are distinguished only to 417 11.Describe the development standards, if any, for the provision of disabled - accessible parking for multiple - family projects. Disabled - accessible parking standards for new multiple - family projects are provided within the 2007 Edition of the California Building Code. 12. Does the code contain any development standards or special provisions for making housing accessible to persons with disabilities? Yes ❑ No X Does it specifically reference the accessibility requirements contained in the Fair Housing Amendments Act of 1988? Yes ❑ No X Background Generally, under the federal Fair Housing Amendments Act of 1988, both privately owned and publicly assisted single- story, multi - family housing units built for first occupancy on or after March 13, 1991— including both 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, or 2) are ground floor units in non - elevator buildings containing four or more units. These standards, encompassing seven basic provisions, are codified at Code of Federal Regulations Title 24, Part 100.205. Additionally, under Section 504 of the Rehabilitation Act of 1973, it is unlawful to discriminate based on disability in federally assisted programs. This section provides that no otherwise qualified individual shall, solely by reason of his or her disability, be excluded from participation (including employment), denied program benefits, or be subjected to discrimination on account of disability under any program or activity receiving federal funding assistance. Section 504 also contains accessibility provisions for dwellings developed or substantially rehabilitated with federal funds. For the purposes of compliance with Section 504, "accessible" means ensuring that programs and activities, when viewed in their entirety, are accessible to and usable by individuals with disabilities. For housing purposes, the Section 504 regulations define an accessible dwelling unit as a unit that is located on an accessible route and can be approached, entered, and used by individuals with physical disabilities. A unit that is on an accessible route and is adaptable and otherwise in compliance with the standards set forth in Code of Federal Regulations Title 24, Part 8.32 is accessible. In addition, the Section 504 regulations impose specific accessibility requirements for new construction and alteration of housing and non - housing facilities in HUD assisted programs. Section 8.32 of the regulations states that compliance with the appropriate technical criteria in the Uniform Federal Accessibility Standards (UFAS), or a standard that is equivalent to or stricter than the UFAS, is an acceptable means of meeting the technical accessibility requirements in Sections 8.21, 8.22, 8.23 and 8.25 of the Section 504 regulations. However, meeting Section 504 accessibility requirements does not exempt housing from other accessibility requirements that may be required under fair housing laws. The following Section 504 requirements apply to all federally assisted newly constructed housing and to substantial rehabilitation of housing with 15 or more units: 4Z8 A minimum of five percent of total dwelling units (but not less than one unit) accessible for individuals with mobility impairments; An additional two percent of dwelling units (but not less than one) accessible for persons with hearing or vision impairments; and All units made adaptable that are on the ground level or can be reached by an elevator. Fair housing laws do not impose a duty on local jurisdictions to include accessibility provisions in their codes, or to enforce the accessibility provisions of fair housing laws. However, the inclusions of accessibility standards and /or plan checking for accessibility compliance are significant ways that jurisdictions can affirmatively further fair housing choice for persons with disabilities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and of the standards, if any: The provision for making housing accessible to persons with disabilities is found within the 2007 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 jurisdiction conduct plan checking for accessibility compliance of covered multi - family new construction? Yes 21 No ❑ Background See the final paragraph of the Background section of question 12. If `Yes', please give a brief description of process and what items are checked. During plan check the Building Department enforces requirements from the 2007 Edition of the California Building Code regarding accessibility of covered multi - family new construction. 14.Is there a zoning ordinance or other development policy that encourages or requires the inclusion of housing units affordable to low and /or moderate income households (so- called 'inclusionary housing')? Yes ® No ❑ Background An analysis of impediments to fair housing choice must be careful to not substitute or conflate housing affordability policy with policies intended to affirmatively further fair housing. While household income is not a characteristic addressed by fair housing laws, it is appropriate to recognize that a lack of affordable housing can have a disparate impact on housing choice, on the basis of characteristics protected by fair housing laws. As demonstrated in the outcome in the recent court case of U.S. ex rel. Anti - Discrimination Center v. Westchester County, which involved failures to affirmatively further fair housing by Westchester County, New York, in appropriate circumstances the provision 4?q and situation of affordable housing can be a tool to address a lack of fair housing choice in highly segregated communities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: Currently Housing Element Program 2.21 requires a proportion of affordable housing in new residential developments or levies an in -lieu fee. A draft Inclusionary Housing Ordinance has been prepared and is currently available for public review on the City's website. The Ordinance creates a new chapter that will be included in Title 19 (Subdivision Code) of the Municipal Code and provides the basis for the in -lieu fees and procedures for the implementation of Housing Program 2.2.1. The Ordinance is anticipated to be adopted mid -year 2010. 15. Does the zoning ordinance allow for mixed uses? Yes X No ❑ If `Yes', does the ordinance or other planning policy document consider the ability of mixed -use development to enhance housing affordability? Also, do development standards for mixed -uses take into consideration the challenges of providing housing accessible to persons with disabilities in such mixed uses? Background The purpose of this inquiry relates to housing affordability and fair housing choice as discussed in the Background section of question 14. Also, 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 CFR Title 24, Part 100.205 and CCR Title 24 accessibility requirements. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief overview of the development standards: Yes, the zoning ordinance allows for mixed uses. The ordinance considers the ability of mixed -use development to enhance housing affordability and the Building Code includes standards or mixed -uses to take into consideration the challenges of providing housing accessible to persons with disabilities in such mixed -uses. 16.Does the zoning ordinance provide for any of the following: 1) development incentives for the provision of affordable housing beyond those provided by state law; 2) development by right of affordable housing; or, 3) a zoning overlay to allow for affordable housing development? Yes X No ❑ Background The purpose of this inquiry relates to housing affordability and fair housing choice as discussed in the Background section of the question 14. 420 Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you 3rriveo at the answer ano a oneT overview OT the oevelopment stanoaras: The zoning ordinance does not provide any incentives for the provision of affordable housing beyond those provided by state law but the Housing Element does. The zoning ordinance does allow the development of affordable housing by right with no special permits required when it is provided voluntarily and there are no deviations from the development standards found within the Zoning Code requested. 17.Does the zoning ordinance describe any areas in this jurisdiction as exclusive? Yes ❑ No X Are there exclusions or discussions in the ordinance or any planning policy document of limiting housing on the basis of any of the following characteristics covered by fair housing laws? Yes ❑ No X If `Yes', check all of the following that apply: Race ❑ Color ❑ Sex ❑ Religion ❑ Age ❑ Disability ❑ Familial Status ❑ National Origin ❑ 18.Are there any standards for Senior Housing in the zoning ordinance? Yes X No ❑ If `Yes', do the standards comply with state or federal law on housing for older persons (i.e., solely occupied by persons 62 years of age or older, or occupied by at least one person 55 years of age, or other qualified permanent resident pursuant to Civil Code §51.3)? Yes X No ❑ Is the location of Senior Housing treated differently than that other rental or for -sale housing? Yes ❑ No X If 'Yes', explain. Background Under federal law housing discrimination against families with children is permitted only in housing in which all the residents are 62 years of age or older or where at least 80% of the occupied units have one person who is 55 years of age or older. Generally, California law states that a housing provider using the lower age limitation of 55 years must have at least 35 units to use the familial status discrimination exemption. Also, California law, with narrow exceptions, requires all residents to be "senior citizens" or "qualified permanent residents ", pursuant to Civil Code §51.3. The 1988 amendments to the federal Fair Housing Act exempt "housing for older persons" from the prohibitions against familial discrimination. This means that housing 421- communities and facilities that meet the criteria for the federal Housing for Older Persons Act (HOPA) may legally exclude families with children. Such housing is still bound by all other aspects of fair housing law (such as prohibition of discrimination based on race, national origin or disability). Section 3607(b)(2) defines "housing for older persons" as housing: (A) provided under any State or Federal program that the Secretary determines is specifically designed and operated to assist elderly persons (as defined in the State of Federal program); or (B) intended for, and solely occupied by, persons 62 years of age or older; or (C) intended and operated for occupancy by persons 55 years of age or older and — (i) at least 80 percent of the occupied units are occupied by at least one person who is 55 years of age or older; (ii) the housing facility or community publishes and adheres to policies and procedures that demonstrate the intent required under this subparagraph; and (iii) the housing facility or community complies with rules issued by the Secretary for verification of occupancy, which shall — (1) provide for verification by reliable surveys and affidavits, and (11) include examples of the types of policies and procedures relevant to a determination of compliance with the requirement of clause (ii). Such surveys and affidavits shall be admissible in administrative and judicial proceedings for the purposes of such verification. Subsection (C) was changed by the Housing for Older Persons Act of 1995 (HOPA) to remove some of the uncertainties created by a provision in the 1988 Amendments that required the "existence of significant facilities and services specifically designed to meet the physical and social needs of older persons." The HOPA also provides for a good faith defense in an action for monetary damages under this subsection. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you irnvea at me answer ana a onef overview of the Zoning Code Ch. 20.85 allows for the creation of granny units pursuant to California Government Code Section 65852.1 in zoning districts where there is only one dwelling unit permitted. Other than Ch. 20.85, there are no other standards for senior housing within the zoning ordinance and it is not treated differently than other rental or for -sale housinq. 19.Does the zoning code distinguish senior citizen housing from other residential uses by the application of a conditional use permit (CUP)? Yes ❑ No X 422 Background Senior housing is an important component of the community's housing stock. Demographic projections show that many communities will experience a growth in the elderly population. As a population ages, seniors need a variety of housing opportunities. Also, there is a higher prevalence of persons with disabilities within the senior population. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and what aspects of use trigger the need for a permit: The Zoning Code distinguishes between convalescent housing and residential uses but not between senior citizen housing and residential uses. 20.Does the zoning code or other planning policy document address housing for "special needs" populations? Yes X No 0 Background Special needs populations typically are considered to be homeless people, victims of domestic violence, people with disabilities (including those recovering from substance abuse), youth in crisis, people living with HIV /AIDS and the frail elderly. Of these groups, homeless people, victims of domestic violence, people with disabilities, and people living with HIV /AIDS have direct fair housing implications. There is a high incidence of disability in the homeless population, domestic violence overwhelming impacts women; and people living with HIV /AIDS are considered disabled under fair housing laws. While age is not a characteristic protected under federal fair housing law, it is covered under state law, and the higher incidence of disability in the frail elderly introduces possible fair housing implication for that population as well. These populations often rely on group homes or service - enriched multi - family settings for housing opportunities. To the extent that zoning and other planning policy documents fail to provide for, or impose barriers to, these types of housing an impediment to fair housing choice might exist. As previously noted, according to the DOJ and HUD, the term 'group home' does not have a specific legal meaning. While it often implies a living situation for people with disabilities, it also applies to any group of unrelated persons, often sharing common characteristics, who live together in a dwelling. This broader use of the term encompasses 'special needs' individuals. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief explanation of 'special needs' provisions, if any: Housing Element Goal H5 and Housing Programs 5.1.1 through 5.1.6 found in the Housing Element address the housing needs of the special needs population within the City. 423 21. Does the zoning ordinance establish occupancy standards or maximum occupancy limits that are more restrictive than state law, which incorporates the Uniform Housing Code (UHC)? Yes ❑ No X Background Occupancy standards sometimes can impede housing choice for families with children or for disabled persons. For example, some jurisdiction's zoning regulations have attempted to limit occupancy to five related persons occupying a single family home, or to strictly establish an occupancy standard of no more than two persons per bedroom. Such regulations can limit housing availability for some families with children, or prevent the development of housing for disabled persons. The federal Fair Housing Act (FHA) also 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." [Section 807(b)(1)] HUD implements section 589 of the Quality Housing and Work Responsibility Act (QHWRA) of 1988 by adopting as its policy on occupancy standards for purposes of enforcement actions under the FHA, the standards provided in the Memorandum of General Counsel Frank Keating to Regional Counsel dated March 20, 1991. The purpose of that Memorandum was "to articulate more fully the Department's position on reasonable occupancy policies and to describe the approach that the Department takes on its review of occupancy cases." The Memorandum states the following: "Specifically, the Department believes that an occupancy policy of two persons in a bedroom, as a general rule, is reasonable under the Fair Housing Act. [. .] However, the reasonableness of any occupancy policy is rebuttable, and neither the February 21 [1991] memorandum nor this memorandum implies that Department will determine compliance with the Fair Housing Act based solely on the number of people permitted in each bedroom." [emphasis added] The memorandum goes on to reiterate statements taken from the final rule implementing the Fair Housing Amendments Act of 1988 as follows: • "[T]here is nothing in the legislative history that indicates any intent on the part of Congress to provide for the development of a national occupancy code ...." "Thus, the Department 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 that, in connection with a complaint alleging discrimination on the basis of familial status, the Department will carefully examine any such nongovernmental restriction to determine whether it operates unreasonably to limit or exclude families with children." "U.S. Department of Housing and Urban Development, Memorandum to All Regional Counsel from Frank Keating on the subject of Fair Housing Enforcement Policy: Occupancy Cases, March 20, 1991. O i Essentially, HUD has established a starting point for assessing the reasonableness of occupancy restrictions, but has stated that the specific facts of each living situation must inform the final determination of reasonableness. While the above discussion relates to matters of discrimination affecting families with children, a similar analysis applies to standards that may limit housing choice for persons with disabilities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrivea at me answer ana the star The specific facts of each living situation inform the final determination of any occupancy limits imposed when uses apply for a use permit. For uses granted a use permit in residential zones, the Zoning Code sets forth a general occupancy limit of two residents per bedroom plus one additional resident, but allows flexibility for an applicant to request and receive a different number of occupants when appropriate. NBMC Section 20.91A.050.C.2 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." 22.Does the jurisdiction encourage or require affordable housing developments to give an admission preference to individuals already residing within the jurisdiction? Yes ❑ No X If 'Yes', is it a requirement? Yes ❑ No ❑ Background This practice may have fair housing implications if the population of the jurisdiction lacks diversity or does not reflect the demographic makeup of the larger region in which it is located. There may be a barrier to fair housing choice, in that the policy can have a discriminatory affect on the basis of characteristics considered by fair housing laws. For example if a jurisdiction already lacks housing suitable to people with mobility - related disabilities, the local population may have an under representation of such individuals, when compared to the population generally. Newly developed accessible housing that could meet the needs of such individuals, but which has a local resident admission preference, would be less likely to improve the ability of people with mobility - related disabilities to live in the jurisdiction. Likewise, a jurisdiction with an under representation of minority residents is likely to perpetuate that situation if a local resident admission preference is implemented for new affordable housing development. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 425 23. Does the jurisdiction have any redevelopment areas? Yes X No If `Yes', does the jurisdiction analyze possible impacts on fair housing choice resulting from its redevelopment activities? Yes ❑ No X Background Redevelopment activities can result in the permanent displacement of residents. If the housing opportunities created by the redevelopment activity could result in a different demographic mix of residents, consideration needs to be given as to whether this difference represents an impediment, an enhancement or is neutral with respect to fair housing choice. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: Santa Ana Heights is considered a redevelopment area however the County oversees the redevelopment activities. 24.Does the zoning ordinance or other planning or policy document include a discussion of fair housing? Yes X No ❑ If 'Yes', how does the jurisdiction propose to further fair housing? Background Affirmatively furthering fair housing is an important responsibility of local government. In order to receive certain federal funds a jurisdiction must certify that it is taking actions to "affirmatively further fair housing" (AFFH). Although a jurisdiction may have numerous plans, policies, and standards, fair housing is rarely discussed in a zoning ordinance. Other documents of a jurisdiction may discuss the need to affirmatively further fair housing and the policies and actions that are in place to do so. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer, a description of where AFFH discussions, if any, may be found, and a brief summary of how AFFH is accomplished: The Zoning Code provides a definition of fair housing laws. In accordance with federal and state Fair Housing laws Zoning Code Chapter 20.98 provides reasonable accommodations in the City's zoning and land use regulations, policies and practices, when needed to provide an individual with a disability an equal opportunity to use and enjoy a dwelling. IDENTIFIED IMPEDIMENTS AND PROPOSED CORRECTIVE ACTIONS Based on your responses to questions 1 -24, please: 420 a) provide a concise list of the zoning and planning impediments to fair housing choice hat you nave iaentunea The City does not believe its Code contains any zoning or planning impediments to fair housing choice. b) describe the actions that will be taken over the next five years to remove or ameliorate the identified impediments. ACKNOWLEDGMENTS: Thanks go to David A. Acevedo and Jesus Velo, of the HUD Los Angeles Fair Housing and Equal Opportunity Office, and Ralph Castaneda, Jr., of Castaneda & Associates, for providing substantial content that went into the preparation of this survey. PLEASE RETURN COMPLETED SURVEY VIA E -MAIL TO DAVID LEVY AT: dievy(a)-fairhousingoc.org Attachment B Draft 2010 -2015 Regional Analysis of Impediments to Fair Housing Choice 9 Page Intentionally Blank 10 ORANGE COUNTY FAIR HOUSING PLAN 2010 -2015 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE FAIR HOUSING ACTION PLAN -1 -t This Page Intentionally Left Blank 12 Table of Contents Section 1 Introduction A. Affirmatively Further Fair Housing (AFFH) Certification ......................... ............................1 -1 B. Meaning and Scope of Fair Housing Impediments ................................. ............................1 -3 C. Participants in the Regional AI ................................................................. ............................1 -4 D. Citizen Participation ................................................................................... ............................1 -6 E. Report Format ........................................................................................... ...........................1 -12 F. Protected Classes 1 -13 ................................................................................. ............................... Attachment A -Fair Housing Protected Classes .................................................. ...........................1 -14 List of Tables 1 -1 Regional Analysis of Fair Housing Impediments: Survey Comparison to 2009 American Community Survey .................................................................. ............................1 -7 1 -2 Regional Analysis of Fair Housing Impediments: Resident Survey Results — Questions #3 and #7 Cross Tab 1 -7 1 -3 Regional Analysis of Fair Housing Impediments: Fair Housing Survey Summary .......... 1 -9 is Table of Contents Section 2 Fair Housing Progress Report A. Introduction 2 -1 .............................................................................................. ............................... 1. Private Sector Impediments ................................................................ ............................2 -1 2. Public Sector Impediments .............................................................. ............................... 2 -1 B. Progress on Eliminating or Ameliorating Impedi 1. Confusion among Residents, Housing Providers and Local Government Officials Regarding the Protection Provided by Fair Housing Laws (both State and Federal) .................................................................... ............................2 -1 2. Intentional Discrimination by Some Members of the Housing Industry Including, but not necessarily Limited to, Rental, Lending, Insurance, Zoning, Appraisals, andAdvertising ................................................................................... ............................2 -3 3. "Color" Blind Policy Causes Disparate Impact (i.e., Credit Scores in Determining a Person's Insurability and Occupancy Restrictions) ...................... ............................2 -3 4. Employer's Lack of Support for Affordable Housing Results in SegregatedHousing ........................................................................... ............................2 -3 5. High Loan Denial Rates are 3 Times among Upper Income Blacks and 2 Times for Equally Situated Hispanics ................................................................. ............................ ? -4 6. CRA Funds are not Targeted in ways Assisting Low Income Persons and Neighborhoods in Home Ownership and Financial Stability ,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,2 -5 7. Some Jurisdictions Underestimate the Extent of Discrimination, Therefore Reducing or not Paying Fair Share of Services Provided by FHCOC, ........................................ 2 -6 List of Tables 2 -1 Orange County - Disparities in Loan Denial Rates for Black and Hispanic Borrowers - 2008 2-4 N94119 Table of Contents Section 3 Fair Housing Action Plan A. Introduction 3 -1 .............................................................................................. ............................... B. Fair Housing Community Profile ........................................................... ............................... 3 -1 1. Orange County Population Growth Trends,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 3 -1 2. Population Characteristics of the Protected Classes ................................................... 3 -2 C. Private Sector Impediments and Actions to be T 1. Housing Discrimination ...................................................................... ...........................3 -12 2. Discriminatory Advertising ................................................................. ...........................3 -14 3. Blockbusting ........................................................................................ ...........................3 -16 4. Denial of Reasonable Modifications /Reasonable Accommodations .......................... 3 -17 5. Hate Crimes ..................................................................................... ............................... 3 -18 6. Unfair Lending... .................................................................................. ...........................3 -19 D. Actions to Address Public Sector Imped 1. Public Sector Impediments Common to Most Participating Jurisdictions,,,,,,,,,,,,,,,,, 3 -21 2. City Identified Public Sector Impediments .................................... ............................... 3 -25 3. Actions to be Taken by the FHCOC and City to Ameliorate or Eliminate Public Sector Impediments ..................................................................... ...........................3 -26 E. Actions to AFFH through the Location of Affordable Housing ......... ............................... 3 -27 List of Tables 3 -1 Regional Analysis of Fair Housing Impediments — Characteristics of the Protected Classes 3 -4 List of Charts 3 -1 Private Sector Impediments Fair Housing Action Plan: 2010 - 2015 .. ............................... 3 -6 15 Table of Contents Section 4 Fair Housing Community Profile A. Introduction 4 -1 B. Population and Housing Characteristics ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,4 -2 1. Population ............................................................................................ ............................4 -2 2. Housing Characteristics ...................................................................... ............................4 -3 C. Population Growth in Orange County ..................................................... ............................4 -4 1. Population by Race and Ethnicity ...................................................... ............................4 -4 2. Projected Population ........................................................................... ............................4 -5 3. Housing Needs .................................................................................... ............................4 -6 D. Population Characteristics of the Protected Classes,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 4 -7 1. Race /Color :• 2. Sex (of Householder) ......................................................................... ...........................4 -16 3. National Origin/ Ancestry .................................................................... ...........................4 -17 4. Familial Status ................................................................................. ............................... 4 -19 5. Handicap / Disability .............................................................................. ...........................4 -20 6. Marital Status ................................................................................... ............................... 4 -23 E. Household Income Characteristics ...................................................... ............................... 4 -23 Median Household Income 4 -23 ............................................................. ............................... Areas of Low /Moderate Income Concentration 4 -27 Attachment A- Definitions of Housing and Population Characteristics and Census Boundaries 4 -29 10 List of Tables 4 -1 Orange County Population by Race and Ethnicity - 2000 and 2007 . ............................... 4 -4 4 -2 Components of Population Change by Race and Ethnicity - 2000 and 2007,,,,,,,,,,,,,,,,, 4 -5 4 -3 County of Orange Population and Race Projections 2000 to 2030 ... ............................... 4 -6 4 -4 Regional Analysis of Fair Housing Impediments - Characteristics of the Protected 17 Classes................................................................................................... ............................... 4 -8 4 -5 Orange County Population by Hispanic /Latino and Race - 2000 and 2008,,,,,,,,,,,,,,,,,, 4 -11 4 -6 Regional Analysis of Fair Housing Impediments - Areas of Minority Population Concentrations Number Census Tracts by City/ Area - 2000,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,4 -14 4 -7 Regional Analysis of Fair Housing Impediments - List and Characteristics of Split Census Tracts with 80.1 %+ Minority Population ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,4 -15 4 -8 Regional Analysis of Fair Housing Impediments - Estimated Sex of Householder — 2008 ...................................................................................................... ............................... 4 -17 4 -9 Orange County - Place of Birth and National Origin - 2008 ................. ...........................4 -18 4 -10 Orange County - City of Residence of Foreign Born Population from Asia and Latin America - 2008 ...................................................................................... ............................... 4 -18 4 -11 Regional Analysis of Fair Housing Impediments - Disabled Population for Entitlement Cities - 2008 4 -22 4 -12 Regional Analysis of Fair Housing Impediments - Median Household Income in 1999 Dollars by Race /Ethnicity of Householder Entitlement Cities - 2000,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,4 -25 4 -13 Regional Analysis of Fair Housing Impediments - Median Household Income in 1999 Dollars by Race /Ethnicity of Householder Urban County Cities - 2000 .........................4 -26 4 -14 Regional Analysis of Fair Housing Impediments - Number of Census Tract Block Groups by City /Location and Percent Low /Mod - 2000 ...................................... ...........................4 -28 17 Table of Contents Section 5 Regional Private Sector Fair Housing Analysis A. Housing Discrimination ............................................................................. ............................5 -1 1. Prohibited Housing Discrimination Practices,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 5 -1 2. Discrimination Complaints .................................................................. ............................5 -3 3. Housing Discrimination Complaint Services ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -10 4. Actions to be Taken 5 -10 ......................................................................... ............................... B. Discriminatory Advertising.. ..................................................................... ...........................5 -11 C. 1. Background ......................................................................................... ...........................5 -11 2. Review of Print Ads and Online Advertising,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 5 -12 3. Examples of Possible Advertising Impediments.......................................................... 5 -14 4. Fair Housing Notices .......................................................................... ...........................5 -18 5. Internet Advertising .............................................. ............................... ...........................5 -18 6. Actions to be Taken 5 -20 ......................................................................... ............................... 1. Background ......................................................................................... ...........................5 -20 2. Actions to be Taken 5 -21 ......................................................................... ............................... D. Denial of Reasonable Accommodations 5 -22 ............................................. ............................... 1. Background ......................................................................................... ...........................5 -22 2. Actions to be Taken 5 -22 ......................................................................... ............................... E. Hate Crimes 5 -22 ........................................................................................... ............................... 1. Background ......................................................................................... ...........................5 -22 2. Hate Crime Events 5 -23 .......................................................................... ............................... 3. Actions to be Taken 5 -27 F. Unfair Lending ...................................................................................... ............................... 5 -28 1. Fair Housing Act, Equal Credit Opportunity Act and the California Holden Act,,,,,,, 5 -28 2. Underwriting, Marketing and Price Discrimination ........................... ...........................5 -29 3. Home Mortgage Disclosure Act,, ,,,,,.. ........................ ......... ......... ............ 5 -30 4. Analysis of 2008 HMDA Data,,,, ......... ......... ......... ......... .......... 5 -30 5. Actions to be Taken ......................................................................... ............................... 5 -38 Attachment A- California Newspaper Publishers Association Guidance on Advertising Words and Phrases ..................................................................... ............................... 5 -40 Attachment B -Hate Crime Glossary ................................................................... ...........................5 -43 12 List of Tables 5 -1 Regional Analysis of Fair Housing Impediments - Housing Discrimination Cases Filed by Year 5 -4 .......................................................................................................... ............................... 5 -2 Regional Analysis of Fair Housing Impediments - Housing Discrimination Cases Closed byYear ....................................................................................................... .............................5. 5 -3 Regional Analysis of Fair Housing Impediments - Housing Discrimination Cases Filed by Bases 2005 -2009 for Entitlement Cities 5 -7 5 -4 Regional Analysis of Fair Housing Impediments - Housing Discrimination Cases Filed by Bases 2005 -2009 for Urban County Cities ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -8 5 -5 Regional Analysis of Fair Housing Impediments - Housing Cases Filed By Alleged Act — 2005 -2009 5 -10 5 -6 Regional Analysis of Fair Housing Impediments - Number of Apartment Complexes Publishing For Rent Ads by Jurisdiction (Apartment.com) — January 2010,,,,,,,,,,,,,,,,,,,,5 -13 5 -7 Analysis of Rental Ads in Entitlement Cities Orange County Register January2010 ............................................................................................. ...........................5 -15 5 -8 Analysis of Rental Ads in Urban County Cities Orange County Register January2010 ............................................................................................. ...........................5 -16 5 -9 Regional Analysis of Fair Housing Impediments - Number of Hate Crime Events by Jurisdiction /City -2004 to 2008. ................................................................. ...........................5 -24 5 -10 State of California Hate Crimes Events and Bias Motivation 5 -25 ............ ............................... 5 -11 Hate Crimes in Orange County 2007 and 2008,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -26 5 -12 State of California Location of Hate Crimes- 2004 to 2008 5 -27 5 -13 HMDA Census Tract Income Categories —2008 .............................................................. 5-32 5 -14 Orange County - Disparities in FHA Loan Denial Rates by Income Group and Race /Ethnicity — 2008 ............................................................... ............................... 5 -15 Orange County - Disparities in Conventional Loan Denial Rates by Income Group and Race /Ethnicity — 2008 ................................................................................ ...........................5 -33 5 -16 Orange County - Denial Rates for Neighborhoods with 20 % -79% Minority Populations by Income Level of Census Tracts — 2008,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -35 5 -17 Analysis of Maximum Likelihood Estimates ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,5 -37 19 Table of Contents Section 6 Public Sector Fair Housing Analysis A. Introduction 6 -1 .............................................................................................. ............................... B. Description of Housing Authority Fair Housing Policies ..................... ............................... 6 -2 1. Fair Housing Policies of Housing Authorities,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 6 -2 2. Section 8 Housing Policies on Reasonable Physical Modifications and Reasonable Accommodations 6 -6 3. Fair Housing and Lead Based Paint,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 6 -7 C. Description of City and County Public Sector Impediments ............... ............................... 6 -9 1. Public Sector Impediments Common to Most Participating Jurisdictions,,,,,,,,,,,,,,,,, 6 -11 2. City Identified Public Sector Impediments,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 6 -15 D. Actions to be Taken by the FHCOC and City to Ameliorate or Eliminate Public Sector Impediments............................................................................................. ...........................6 -16 1. Actions to be Taken by FHCOC ........................................................ ...........................6 -16 2. Actions to be Taken by the City .................................................... ............................... 6 -16 Attachment A - Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice .................................................................... ...........................6 -17 Attachment B — City of La Habra — Reasonable Accommodations in Housing to Disabled Individuals 6 -34 ........................................................................................................... ............................... Attachment C — City of La Habra — Special Needs Housing ......................................................... Attachment D — City of San Francisco — Fair Housing Implementation Ordinance,,,,,,,,,,,,,,,,,,, 6 -47 List of Charts 6 -1 Orange County Regional Analysis of Impediments to Fair Housing Choice Topics Included in the Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice ...... ...........................6 -10 20 Table of Contents Section 7 AFFH Through the Location of Affordable Housing A. Background ........................................................................................... ............................... 7-1 B. Data Sources 7 -2 C. Analysis of the Location of the Affordable Housing Inventory ........... ............................... 7 -3 1. Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Minority Populations ............................................................. ............................... 7 -3 2. Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Minority Populations ........................................................... ............................... 7 -11 3. Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Low Income Populations ....................................................... ...........................7 -14 4. Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Low Income Populations ........................ ............................... ...........................7 -14 D. Analysis of the Location of the Section 8 Housing Inventory ........... ............................... 7 -19 1. Garden Grove Housing Authority ( GGHA),,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,7 -19 2. Santa Ana Housing Authority (SAHA)...... ......... ......... ......... .......... 7 -21 3. Anaheim Housing Authority ( AHA) ..................................................... ...........................7 -24 4. Orange County Housing Authority ( OCHA) .................................. ............................... 7 -24 E. Actions to be Taken 7 -28 .............................................................................. ............................... Attachment A- Census Tracts with 80 %+ Minority Populations ................... ............................... 7 -29 Attachment B- Affordable Housing Inventory Arranged by Census Tract ... ............................... 7 -32 21 List of Tables 7 -1 Regional Analysis of Fair Housing Impediments - Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Minority Populations - 2010,,,,,,,,,,,, 7 -5 7 -2 Regional Analysis of Fair Housing Impediments - Census Tracts with a High Percentage of Affordable Housing Units ..................................................................... ............................7 -7 7 -3 Regional Analysis of Fair Housing Impediments - Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Minority Populations - 2010,,,,,,,,,,, 7 -12 7 -4 Regional Analysis of Fair Housing Impediments - Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Low Income Populations — 2010 7 -15 ....................................................................................................... ............................... 7 -5 Regional Analysis of Fair Housing Impediments - Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Low Income Populations — 2010 7 -16 ....................................................................................................... ............................... 7 -6 Garden Grove Housing Authority — Section 8 Assisted Families by City,,,,,,,,,,,,,,,,,,,,,,, 7 -19 7 -7 Garden Grove Housing Authority — Number of Section 8 Housing Units Located in Census Tracts with a High Percentage ( >80 %) of Minority Populations ....................... 7 -20 7 -8 Santa Ana Housing Authority — Section 8 Assisted Families by Census Tract,,,,,,,,,,,,, 7 -21 7 -9 Santa Ana Housing Authority — Number of Section 8 Housing Units Located in Census Tracts with a High Percentage ( >80 %) of Minority Populations ....................... 7 -23 7 -10 Orange County Housing Authority — Section 8 Assisted Families by Entitlement City, 7 -25 7 -11 Orange County Housing Authority — Section 8 Assisted Families by Urban CountyCity ............................................................................................... ...........................7 -25 7 -12 Orange County Housing Authority — Number of Section 8 Housing Units Located in Census Tracts with a High Percentage ( >80 %) of Minority Populations ....................... 7 -26 7 -13 Orange County Housing Authority — Number of Section 8 Housing Units Located in Census Tracts with a Low Percentage ( >20 %) of Minority Populations ........................ 7 -27 22 Technical Appendix A Orange County Fair Housing Community Profile List of Tables A -1 Regional Analysis of Fair Housing Impediments - Entitlement Cities - Year 2010 Population Estimates by City ................................................................... ............................A -1 A -2 Regional Analysis of Fair Housing Impediments - Urban County - Year 2010 Population Estimatesby City ...................................................................................... ............................A -2 A -3 Regional Analysis of Fair Housing Impediments - Entitlement Cities - Population Growth April 1, 1990, April 1, 2000 and January 1, 2010,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,A -3 A -4 Regional Analysis of Fair Housing Impediments - Urban County - Population Growth April 1, 1990, April 1, 2000 and January 1, 2010,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,A -4 A -5 Regional Analysis of Fair Housing Impediments - Entitlement Cities - Year 2010 Housing SupplyEstimate by City ........................................................................... ............................A -5 A -6 Regional Analysis of Fair Housing Impediments - Urban County - Year 2010 Housing SupplyEstimate by City ........................................................................... ............................A -6 A -7 Regional Analysis of Fair Housing Impediments - Entitlement Cities - Housing Supply Growth April 1, 1990, April 1, 2000 and January 1, 2010, ................................................. A -7 A -8 Regional Analysis of Fair Housing Impediments - Urban County - Housing Supply Growth April 1, 1990, April 1, 2000 and January 1, 20101 ................................................. A-8 A -9 Orange County Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities A -9 A -10 Orange County Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban County Cities ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,A -13 A -11 Regional Analysis of Fair Housing Impediments - Household Type for Entitlement Cities —2008 A -17 ................................................................................................... ............................... A -12 Regional Analysis of Fair Housing Impediments - Household Type for Urban County Cites — 2008 A -18 A -13 Regional Analysis of Fair Housing Impediments - Households with Children under 18 Years of Age by Type of Household Entitlement Cities — 2008 ...... ............................... A -19 A -14 Regional Analysis of Fair Housing Impediments - Households with Children under 18 Years of Age by Type of Household Urban County Cities — 2008,, A -20 A -15 Regional Analysis of Fair Housing Impediments - Poverty Rates for Female Householders and Presence of Children for Entitlement Cities — 2008 A -21 ......................... 23 A -16 Regional Analysis of Fair Housing Impediments -Poverty Rates for Female Householders and Presence of Children for Urban County Cities — 2008,,,,,,,,,,,,,,,,,,,, A -22 A -17 Regional Analysis of Fair Housing Impediments - Marital Status for Entitlement Cities — 2008 A -23 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A -18 Regional Analysis of Fair Housing Impediments - Marital Status for Urban County - 2008 M4i Technical Appendix D 2008 Home Mortgage Disclosure Act Data for Orange County List of Tables D -1 Orange County - Disposition of Loan Applications by Race /Ethnicity — 2008 .................D -1 D -2 Orange County - Disposition of FHA Loan Applications by Race /Ethnicity -2004 and 2008 ................................................................................................. ............................... D -3 D -3 Orange County - Disposition of Conventional Loan Applications By Race /Ethnicity-2004 and 2008 ................................................................. ............................D -4 D -4 Orange County - FHA/VA Denial Rates by Income and Race /Ethnicity — 2008 .............D -5 D -5 Orange County - Conventional Denial Rates by Income and Race /Ethnicity — 2008 ..... D -7 D -6 Orange County - Disposition of FHA Loans by Characteristics of Census Tract in Which Property is Located — 2008............ ............................................... ............................D -9 D -7 Orange County - Disposition of Conventional Loans by Characteristics of Census Tract in Which Property is Located — 2008 ............................................ ...........................D -10 D -8 Orange County Reasons for Loan Denial by Race /Ethnicity — 2008... ..... ......................D -11 25 Technical Appendix E Loan Denial Rates for Census Tracts with a High Number of Loan Applications List of Tables E -1 Entitlement Cities - FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 .......................................................................... ............................... E -1 E -2 Entitlement Cities - Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 .......................................................................... ............................... E -3 E -3 Urban County Cities - FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 .......................................................................... ............................... E -8 E -4 Urban County Cities - Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 .......................................................................... ............................... E -9 20 Technical Appendix F FHA and Conventional Loan Denial Rates by City and Census Tract List of Tables F -1 Entitlement Cities - FHA Loan Application Denial Rates by City and Census Tract — 2008 F -1 .............................................................................. ............................... F -2 Entitlement Cities - Conventional Loan Application Denial Rates by City and Census Tract — 2008 F -13 ............................................................................ ............................... F -3 Urban County Cities - FHA Loan Application Denial Rates by City and Census Tract — 2008 F -4 Urban County Cities - Conventional Loan Application Denial Rates by City and Census Tract — 2008 F -32 ............................................................................ ............................... 27 This Page Intentionally Left Blank 22 Section 1 Introduction & Summary ?9 SECTION 1 INTRODUCTION A. AFFIRMATIVELY FURTHERING FAIR HOUSING (AFFH) CERTIFICATION An Affirmatively Furthering Fair Housing (AFFH) certification is required of communities that administer the following U.S. Department of Housing and Urban Development (HUD) Community Planning and Development (CPD) programs: • Community Development Block Grants (CDBG) • Home Investments Partnership Program (HOME) • Emergency Shelter Grants (ESG) • Housing Opportunities for People with AIDS Program (HOPWA) The AFFH certification states that the community receiving HUD funds: "...will affirmatively further fair housing ... by conducting an analysis to identify impediments to fair housing choice within its jurisdiction, taking appropriate actions to overcome the effects of any impediments identified through the analysis, and maintaining records reflecting the analysis and actions in this regard." The certification is included in the Consolidated Plans and Action Plans that are submitted to HUD by Orange County's Entitlement Cities and the Urban County Program. HUD interprets the board objectives of the AFFH obligation to mean: • Analyze and eliminate housing discrimination in the jurisdiction. • Promote fair housing choice for all persons. • Provide opportunities for inclusive patterns of occupancy regardless of race, color, religion, sex, familial status, disability and national origin. • Promote housing that is structurally accessible to, and usable by, all persons, particularly persons with disabilities. • Foster compliance with the nondiscrimination provisions of the Fair Housing Act. The first requirement of the AFFH certification is satisfied by the following: • Conducting an analysis of impediments to fair housing choice. This is commonly called the AI. • Identify appropriate actions to overcome the effects of identified impediments. This is accomplished through preparation of a fair housing action plan. It is the responsibility of the Entitlement Cities and Urban County Program to "take' the actions identified in the fair housing action plan and to "maintain records on the actions taken ". 30 HUD's Consolidated Plan Review Guidance (i.e., Checklist) explains that the following guidance should be used by HUD CPD representatives to determine if the Certification is not satisfactory: Disregard of regulatory requirements to conduct an analysis of impediments to fair housing choice, take appropriate actions to address identified impediments, or maintain adequate records on the steps taken to affirmatively further fair housing in the jurisdiction. • Lack of action taken on outstanding findings regarding performance under affirmatively furthering fair housing certification requirements of the Consolidated Plan or the Community Development Block Grant Program. More specifically, HUD has issued the following guidance: HUD can require the submission of an Al in the event of a complaint or as part of routine monitoring. If, after reviewing all documents and data, HUD concludes that (1) the jurisdiction does not have an Al; (2) an AI was substantially incomplete; (3) no actions were taken to address identified impediments; (4) the actions taken to address identified impediments were plainly inappropriate; or (5) the jurisdiction has no records the Department would notify the jurisdiction that it believes the certification to be in- accurate, or, in the case of certifications applicable to the CDBG program, the certification is not satisfactory to the Secretary. Source: Memorandum from Nelson R. Bregon, General Deputy Assistant Secretary for Community Planning and Development to CPD Office Directors, FHEO HUB Directors, FHEO Program Center Directors and FHEO Equal Opportunity Specialists, September 2, 2004, page 2 HUD also has stated: Rejection of the certification provides the basis for HUD to disapprove the jurisdiction's Consolidated Plan. Source: U.S. Department of Housing and Urban Development, Office of Community Planning and Development, Fair Housing for HOME Participants, May 2005, page 1 The way HUD determines compliance with the AFFH Certification is through a review of each entitlement city's and the Urban County's Consolidated Plan Annual Performance and Evaluation Report (CAPER). In the CAPER, the entitlement city and Urban County submit a narrative statement on actions taken to affirmatively further fair housing during the prior program year (July 1 to June 30). HUD has issued the following guidance: Once the jurisdiction completes the Al, it must report on its implementation by summarizing the impediments identified in the analysis and describing the actions taken to overcome the effects of the impediments identified through the analysis in its Consolidated Annual Performance and Evaluation Report (CAPER). Although Als are not submitted or approved by HUD, each jurisdiction should maintain its Al and update 31 the Al annually where necessary. Jurisdictions may also include actions the jurisdiction plans to take to overcome the effects of impediments to fair housing choice during the coming year in the Annual Plan that is submitted as part of the Consolidated Plan submission. Source: Memorandum from Nelson R. Bregon, General Deputy Assistant Secretary for Community Planning and Development to CPD Office Directors, FHEO HUB Directors, FHEO Program Center Directors and FHEO Equal Opportunity Specialists, September 2, 2004, page 2 B. MEANING AND SCOPE OF FAIR HOUSING IMPEDIMENTS What is an impediment? According to HUD, impediments are -- Any actions, omissions, or decisions taken because of race, color, religion, sex, disability, familial status, or national origin which restrict housing choices or the availability of housing choices. (Intent) Any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices because of race, color, religion, sex, disability, familial status, or national origin. (Effect) A lack of affordable housing in and of itself, HUD has pointed out, is not an impediment to fair housing choice, unless it creates an impediment to housing choice because of membership in a protected class. Impediments may exist due to one or more of the following: • Saying or doing something openly discriminatory. • Treating some people differently than others because of their protected class. • A policy that on its face seems neutral, but has a disparate impact on members of a protected class. There are two types of impediments — private and public impediments. The nature and scope of private sector impediments are essentially actions or practices that are prohibited by the following fair housing laws: • 1968 Federal Fair Housing Act • 1974 Federal Equal Credit Opportunity Act • 1980 State Fair Employment and Housing Act • 1959 Unruh Civil Rights Act • 1977 Housing Financial Discrimination Act These laws prohibit housing discrimination, discriminatory advertising, blockbusting, steering, denial of reasonable accommodations, redlining, and other unlawful practices. 32 California's Fair Employment and Housing Act states it is unlawful: To discriminate through public or private land use practices, decisions, and authorizations because of race, color, religion, sex, sexual orientation, familial status, marital status, disability, national origin, source of income, or ancestry. Discrimination includes, but is not limited to, restrictive covenants, zoning laws, denials of use permits, and other actions authorized under the Planning and Zoning Law (Title 7 (commencing with Section 65000)), that make housing opportunities unavailable. Examples of public sector impediments include a definition of "family" inconsistent with fair housing laws, conditional use permit requirements for housing for the disabled, and the lack of a reasonable accommodation procedure. C. PARTICIPANTS IN THE REGIONAL Al The lead agency for preparation of the Regional Al is the Fair Housing Council of Orange County ( FHCOC). Under contract to 15 Entitlement Cities and the Urban County Program, FHCOC provides fair housing services and tenant/landlord counseling services to the residents of Orange County. The FHCOC - a nonprofit organization - has been serving Orange County residents since 1965. The FHCOC also was the lead agency for the preparation of the 2000- 2005 and 2005 -2010 Regional Als. The key rationale for preparation of a Regional AI is that private sector impediments are regional in nature and affect multiple communities — that is, they are not limited to a single jurisdiction responsible for AFFH. During HUD's Affirmatively Furthering Fair Housing webcast on July 22, 2009 several participants supported the concept of addressing the AFFH certification through a regional approach, although specific models were not discussed during the webcast. The FHCOC has a wealth of experience in dealing with fair housing impediments that occur in the private sector. HUD guidance indicates that the Regional Al must describe appropriate actions to overcome the effects of the private sector impediments that are identified through the analysis. The FHCOC understands the private sector and is well equipped to analyze impediments, describe appropriate actions, and to follow- through on those actions. The Regional Al also identifies the public sector impediments to fair housing choice and describes the actions that participating cities and the Urban County will take to reduce and ameliorate these impediments. Some of the public impediments were first identified in 2008 and 2009 in the housing element updates of each jurisdiction. According to State law, each jurisdiction must adopt a housing element as part of its General Plan. A housing element must analyze constraints on housing for disabled persons and include a program for providing equal housing opportunity. The Entitlement Cities and the Urban County Program will continue to maintain records and report annually on the actions taken to overcome the public sector impediments. 33 The following jurisdictions participated in the preparation of the Regional Al: Entitlement Cities • Anaheim • Buena Park • Fountain Valley • Fullerton • Garden Grove • Huntington Beach • Irvine • La Habra • Lake Forest • Newport Beach • Orange • Rancho Santa Margarita • Santa Ana • Westminster Urban County Unincorporated County Target Areas, Urban County Program • Aliso Viejo • Brea • Cypress • Dana Point • La Palma • Laguna Beach • Laguna Hills • Laguna Woods • Los Alamitos • Placentia • Seal Beach • Stanton • Villa Park • Yorba Linda Non - Participating Jurisdictions • Costa Mesa • Laguna Niguel • Mission Viejo • San Clemente • San Juan Capistrano • Tustin The scope of work for the Regional Al was developed by the FHCOC in coordination with the Los Angeles Office of the U.S. Department of Housing and Urban Development (HUD -LA). HUD -LA and the FHCOC identified the types of private sector impediments that should be investigated in the Regional Al. The scope of work was developed in part with the Mil understanding that the FHCOC would take the lead for taking actions to ameliorate or eliminate the identified private sector impediments, given adequate support from participating jurisdictions. Additionally, the scope of work incorporated the identification of public sector impediments by each city participating in the Regional Al. Each participating jurisdiction completed a survey of planning and zoning practices that may affect fair housing choices, particularly by disabled persons. The "Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice" was prepared by the FHCOC and approved by HUD -LA. Each jurisdiction participating in the Regional Al completed the 24 question survey and self identified planning and zoning impediments and the actions that would be taken to ameliorate and eliminate the impediments. D. CITIZEN PARTICIPATION HUD has stated that because fair housing planning is a component of the Consolidated Plan, the citizen participation requirements for the Consolidated Plan (24 CFR 91) applies to the preparation of the AI and Fair Housing Action Plan. Source: U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Fair Housing Planning Guide, Volume 1, March 1996, page 4 -3 The major effort undertaken by the Fair Housing Council of Orange County to obtain citizen participation was the completion of a fair housing survey. The purpose of the survey was to obtain resident opinions on housing discrimination. Respondents, for instance, were asked whether they thought housing discrimination exists in Orange County and to give examples of discriminatory practices. Additionally, information was obtained on the characteristics of the respondents in order to compare them to those of Orange County's entire population. The survey respondents differ from Orange County's population. For example, the percentage of respondents having families with children was much higher compared to the Orange County percentage. The disability rate among the survey respondents was twice as high as that of the Orange County population. And a lower percentage of respondents belonged to a minority population compared to the Orange County population characteristics. Table 1 -1 on the next page shows the comparison data. Overall, about 47% of the respondents believe there is housing discrimination in Orange County. A higher percentage (58 %) of the minority population compared to the non - minority population (40 %) believes there is housing discrimination in Orange County. Table 1 -2 shows the responses to the question Do you believe that there is housing discrimination in Orange County? 35 Table 1 -1 Regional Analysis of Fair Housing Impediments Survey Comparison to 2009 American Community Survey Question /Reponses Survey Percentage ACS Percentage 1. What is your family status ?' Non - Minority Have Children 60.2% 37.6% Do not have children 39.8% 62.4% 2. Does anyone in your household have a disability?' 5 Yes 14.0% 7.3% No 86.0% 92.7% Minority Status' 40.0% Yes 40.9% 54.7% No 59.1% 45.3% Tenure Status (Excluding Homeless' Own 38.5% 60.1% Rent 61.5% 38.5% 'American Community Survey 1 -Year Estimates 2009, Selected Social Characteristics, Selected Demographic Characteristics, and Selected Housing Characteristics Table 1 -2 Regional Analysis of Fair Housing Impediments Resident Survey Results- Question #3 and #7 Cross Tab Do you believe that there is housing discrimination in Orange County? Answer Options Minority Percent Non - Minority Percent Yes 22 57.9% 22 40.0% No 5 13.2% 11 20.0% Unsure 11 28.9% 22 40.0% Total 38 100.0% 55 100.0% so Table 1 -3 shows the complete survey results. Among the key findings are: • Half of the respondents stated they were "very well informed" or "somewhat informed" about housing discrimination. • Almost 32% of the respondents stated they or someone they know has encountered housing discrimination. • The two most common examples of housing discrimination cited by the respondents were "housing provider refuses to rent or deal with a person," and "different terms and conditions ". • Only 8% of those that believed they encountered housing discrimination reported the incident. • However, almost 47% of the respondents stated they would report housing discrimination if they encountered it in the future. The survey results indicate that a sizeable proportion of the population is "informed" about housing discrimination. Moreover, the general public recognizes examples of discriminatory practices. And in the future more people would report housing discrimination than they have in past. Although the number of survey responses is limited, it appears that a large share of the public are willing to report housing discrimination to agencies such as the Fair Housing Council of Orange County which indicates a continuing need for processing of discrimination complaints. 37 Table 1 -3 Regional Analysis of Fair Housing Impediments Fair Housing Survey Summary 1. What is your family status? Have Children Do not have children 2. Does anyone in your household have a disability Yes No 3. The U.S. Census Bureau considers the following to be "minority groups ": Black, Hispanic, Asian, Pacific Islander, or American India /Alaska Native. Response ercenta a Response Count Answered Question Skipped Question 1 own a home 93 0 60.2% 56 60.2% 39.8% 37 0.0% 0 93 0 14.0 %0 13 5. What is your income level? 86.0% 1 80 4. What type of housing do you currently have? 93 0 1 own a home 37.6% 35 1 rent 60.2% 56 1 live in a hotel /motel 0.0% 0 1 am homeless 2.2% 2 5. What is your income level? 93 0 High Income 9.6% 9 Medium Income 45.2% 42 Low Income 45.2% 42 6. In which Orange County City do you live? Top 5 93 0 Anaheim 6.5% 1 6 Newport Beach Subtotal 7. Do you believe there is housing discrimination in Orange County? Yes No Unsure 10.8% 10 74.4% 69 47.3% 44 17.2% 16 35.5% 33 931 01 3g Table 1 -3 - continued Orange County Regional Fair Housing Impediments Analysis Resident Survey Results Question /Reponses Response Percentage Response Count Answered Question Skipped Question 8. Do you believe that there is housing discrimination in the Orange County city in which you current) /previous) reside? 93 0 Yes 34.4% 32 No 28.0% 26 Unsure 37.6% 35 9. Have you or someone you know ever encountered any forms of housing discrimination described above? Check all that app) 64 29 Yes, I have 15.8% 12 76 total responses 1 think I may have 6.6% 5 No, I have not 30.3% 23 Yes, I know someone who has 15.8% 12 1 think I may know someone who has 2.6% 2 No, I don't know someone who has 19.7% 15 1 don't know 9.2% 7 10. (See examples above) If you believe or think that someone you know encountered housing discrimination, please check the type in the list at the beginning of this page. (Check all that apply). 64 29 A. Housing provider refuses to rent or deal with a person 20.0% 11 55 examples were given by 34 respondents; N/A was stated by 30 respondents B. Housing provider falsely denies that housing was available 10.9% 6 C. Housing provider refuses to make reasonable accommodations for a tenant with one or more disabilities 10.9% 6 D. Housing provider uses discriminatory advertising 10.9% 6 E. Real estate agent refuses to sell or deal with a person 3.6% 2 F. Real estate agent direct persons to certain neighborhoods 7.3% 4 G. Housing mortgage lender discriminates by denying mortgage 7.3% 4 H. Housing lender directs persons to certain neighborhoods 3.6% 2 I. Different terms and conditions 18.2% 10 Other please specify) 7.3% 4 N/A 30 39 Table 1 -3 - continued Orange County Regional Fair Housing Impediments Analysis Resident Survey Results Question /Reponses Response Percentage Response Count Answered Question Skipped Question 11. If you believe you have encountered any form of housing discrimination in question #10 did you report it? 58 35 Yes 3.4% 2 No 39,7% 23 N/A 56.9% 33 12. How well informed are you about housing discrimination 64 29 Very well informed 25.0% 16 Somewhat informed 25.0% 16 A little informed 21.9% 14 Not informed at all 28.1% 18 13. What would you do if you encountered housing discrimination? 64 29 Do nothing and seek other housing options 10.9% 7 Less than 100% due to rounding Tell the person that you believe they are discriminating 23.4% 15 Report it 46.9% 30 Would not know what to do 17.2% 11 Other option 1.6% 1 ION E. REPORT FORMAT Besides this Introduction, the Report includes the following Sections: Section 2 — Fair Housing Progress Report: The prior Analysis of Impediments to Fair Housing Choice contained actions that would be taken during the 2005 -2010 time period. Section 2 describes the actions taken during the past five years to eliminate or ameliorate the identified impediments. Section 3 — Fair Housing Action Plan: This Section presents a new multi -year Fair Housing Action Plan. There are two impediment categories — public sector and private sector impediments. A summary description is given of each identified impediment. The actions the FHCOC plans to undertake to overcome the private sector impediments are described in the Fair Housing Action Plan. Additionally, actions to be taken by the Entitlement Cities and Urban County are described in Section 3. Finally, actions are described to address affirmatively furthering fair housing through the location of affordable housing. Section 4 — Fair Housing Community Profile: This Section presents demographic information on housing and population characteristics, population growth in Orange County, the protected classes, and household income for different racial groups and Hispanic households. Section 5 — Private Sector Fair Housing Analysis: This Section presents information on the following private sector impediments: housing discrimination, discriminatory advertising, blockbusting, denial of reasonable accommodations or modifications, hate crimes and unfair lending. Section 6 - Public Sector Fair Housing Analysis: This Section summarizes the public sector impediments. These impediments were identified through a survey 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. The survey 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. 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. Section 7 — AFFH Through the Location of Affordable Housing: A lack of affordable housing in and of itself, HUD has pointed out, is not an impediment to fair housing choice, unless it creates an impediment to housing choice because of membership in a protected class. However, recent court cases and recent events have demonstrated that the location of affordable housing is regarded as a means of AFFH. This Section presents information on the location of affordable and Section 8 housing in census tracts with a high and low percentage of minority populations. Additionally, the location of affordable and Section 8 housing is analyzed in terms of the income characteristics of the census tracts. Fiji" In addition, the Al contains seven Technical Appendices: Technical Appendix A - Orange County Fair Housing Community Profile Technical Appendix B - Minority Population by Census Tract Technical Appendix C - Low Income Population by Census Tract and Block Group Technical Appendix D - 2008 Home Mortgage Disclosure Act Data for Orange County Technical Appendix E - Loan Denial Rates for Census Tracts with a High Number of Loan Applications Technical Appendix F - FHA and Conventional Loan Denial Rates by City and Census Tract Technical Appendix G — Completed Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice F. PROTECTED CLASSES The Federal and State fair housing laws prohibit discrimination against certain categories of people. These categories are referred to as "protected classes." Attachment A provides definitions for the following protected classes: Federal and State "Protected Classes" • Race • Color • Sex • National Origin • Religion • Familial Status • Handicap /Disability Additional State of California "Protected Classes' • Sexual Orientation • Marital Status • Ancestry • Source of Income • Age Fiji" Attachment A Fair Housing Protected Classes Title VIII of the Civil Rights Act of 1968 (Fair Housing Act), as amended, prohibits discrimination in the sale, rental, and financing of dwellings, and in other housing - related transactions, based on race, color, national origin, religion, sex, familial status (including children under the age of 18 living with parents or legal custodians, pregnant women, and people securing custody of children under the age of 18), and handicap (disability). These categories of persons are "protected classes" under the provisions of the Fair Housing Act. Race: The Fair Housing Act does not define race. Data on race is required for many federal programs and the Census Bureau collects race data in accordance with guidelines provided by the U.S. Office of Management and Budget (OMB) and these data are based on self - identification. The racial categories included in the census form generally reflect a social definition of race recognized in this country, and are not an attempt to define race biologically, anthropologically or genetically. In addition, the Census Bureau recognizes that the categories of the race item include both racial and national origin or socio - cultural groups. Census 2010 and the American Community Survey provide for six race categories: White; Black, African American or Negro; American Indian or Alaska Native; Asian; Native Hawaiian or Other Pacific Islander; and Some Other Race. Color: The Fair Housing Act does not define color. However, it must refer to the complexion of a person's skin color or pigmentation. The 2010 racial categories can be traced to Statistical Policy Directive No. 15, promulgated by the OMB on May 12, 1977. "The four racial categories stipulated in the (1977) directive parallel the classic nineteenth - century color designations of black, white, red (American Indian or Alaska native), and yellow (Asian or Pacific Islander); there is no brown race in the American ethnoracial taxonomy." [Victoria Hattam, "Ethnicity & the Boundaries of Race: Re- reading Directive 15," Daedalus, Winter 2005, page 631 Sex: This basis refers to gender identity. California's Fair Employment and Housing Act defines "sex" as including, but not limited to, pregnancy, childbirth, medical conditions related to pregnancy or childbirth and a person's gender, as defined in Section 422.56 of the Penal Code. Government Code Section 12926(p) National Origin: This basis refers to the real or perceived country of an individual's birth, ancestry, language and /or customs. Religion: According to the United States Department of Justice, this prohibition covers instances of overt discrimination against members of a particular religion as well as less direct actions, such as zoning ordinances designed to limit the use of private homes as places of worship. Gm Familial Status: According to Section 802(k) of the Fair Housing Act, as amended, means one or more individuals (who have not attained the age of 18 years) being domiciled with -- (1) a parent or another person having legal custody of such individual or individuals; or (2) the designee of such parent or other person having such custody, with the written permission of such parent or other person. The protections afforded against discrimination on the basis of familial status shall apply to any person who is pregnant or is in the process of securing legal custody of any individual who has not attained the age of 18 years. Handicap (Disability): According to Section 802(h) of the Fair Housing Act, as amended, handicap /disability means - (1) a physical or mental impairment which substantially limits one or more of such person's major life activities, (2) a record of having such an impairment, or (3) being regarded as having such an impairment, but such term does not include current, illegal use of or addiction to a controlled substance (as defined in section 102 of the Controlled Substances Act (21 U.S.C. 802)). California's Fair Employment and Housing Act (FEHA) is the primary state law which prohibits discrimination in the sale, rental, lease negotiation, or financing of housing. The FEHA has five additional protected classes: sexual orientation, marital status, ancestry, source of income and age. Sexual Orientation: The FEHA defines this basis as heterosexuality, homosexuality, and bisexuality. Government Code Section 12926(q) Marital Status: This basis refers to whether a person is married or not. The U.S. Census Bureau has four major "marital status" categories: never married, married, widowed, and divorced. These terms refer to the marital status at the time of the enumeration. The category married includes "married, spouse present" and "married, spouse absent." RZ9 Ancestry: According to the U.S. Census Bureau, ancestry refers to a person's ethnic origin or descent, "roots," or heritage, or the place of birth of the person or the person's parents or ancestors before their arrival in the United States. Some ethnic identities, such as "German" or "Jamaican" can be traced to geographic areas outside the United States, while other ethnicities such as "Pennsylvania Dutch" or "Cajun" evolved in the United States. The intent of the ancestry question is not to measure the degree of attachment the respondent had to a particular ethnicity. For example, a response of "Irish" might reflect total involvement in an "Irish" community or only a memory of ancestors several generations removed from the individual. A person's ancestry is not necessarily the same as his or her place of birth, i.e., not all people of German ancestry were born in Germany. Source of Income: The FEHA defines this basis as lawful, verifiable income paid directly to a tenant or paid to a representative of a tenant. A landlord is not considered a representative of the tenant. Government Code Section 12955(p) Age: Refers to a person's chronological age. Civil Code Section 51.2 et. seq. Ki This Page Intentionally Left Blank in Section 2 Fair Housing Progress Report 47 SECTION 2 FAIR HOUSING PROGRESS REPORT A. INTRODUCTION The 2005 -2010 Regional Al identified seven impediments to fair housing choice. The purpose of the "progress report" is to describe the progress made on eliminating or ameliorating the identified impediments. The 2005 -2010 Regional Al identified the following private and public sector impediments to fair housing choice. 1. Private Sector Impediments Population and local government can't differentiate landlord /tenant issues vs. discrimination 2. Housing, industry discrimination: zoning, insurance, appraisals, advertising 3. "Color" blind policy causes disparate impact (i.e., credit scores in determining a person's insurability and occupancy restrictions. 4. Employer's lack of support for affordable housing results in segregated housing. 5. High loan denial rates are x3 among upper income Blacks and x2 for equally situated Hispanics. 2. Public Sector Impediments Community Reinvestment Act (CRA) funds are not targeted in ways assisting low income persons and neighborhoods in home ownership and financial stability. (Refer to pages 2 -5 and 2 -6 for an explanation of the CRA.) 2. Some jurisdictions underestimate the extent of discrimination, therefore reducing or not paying fair share of services provided by FHCOC. B. PROGRESS ON ELIMINATING OR AMELIORATING IMPEDIMENTS The following pages describe the nature of the fair housing impediments identified in the 2005- 2010 Regional Al and the progress made in eliminating or ameliorating the adverse impacts caused by the impediments. 1. Confusion among Residents, Housing Providers and Local Government Officials Regarding the Protection Provided by Fair Housing Laws (both State and Federal) Laws regarding landlord and tenant relationships are not covered in State or Federal Fair Housing Laws but are frequently confused by industry professionals, residents and government officials with fair housing. Gaining knowledge of the differences between fair housing laws and tenant/landlord laws is a continuing process. It is necessary for people engaged in real estate transactions and apartment management to have knowledge of fair housing laws. ■ The State Department of Real Estate (DRE) requires real estate brokers and salespersons to complete DRE- approved continuing education including a course on fair housing. The Apartment Association of Orange County (AAOC) represents and supports apartment owners, managers and suppliers. Since 1961, the AAOC has been a major resource for anyone involved in the rental housing industry in Orange County. The AAOC helps it members to stay continually informed on fair housing. The AAOC, for instance, conducts fair housing seminars to educate its members. The AAOC also conducts a Certified Housing Provider Program for apartment owners, property supervisors and resident managers. A review of fair housing laws is one part of this program. With respect to tenant /landlord issues, the California Department of Consumer Affairs has published a 108 -page Guide to Residential Tenant's and Landlords" Rights and Responsibilities. The Guide offers information on a variety of subjects such as rental agreements and leases, landlord disclosures, evictions, and problem resolution. Many cities make this Guide available to the public at the planning or community development department counter. Additionally, the California Apartment Association has published Renting: A User Manual, a 16 -page guide for renters which discusses topics such as Tips for Renters, Moving In, Moving Out, and Rights and Responsibilities. In order to increase public knowledge, the FHCOC has posted on its website a 16 -page Landlord - Tenant Frequently Asked Questions, which provides useful information about the rights and obligations of tenants and landlords. The FAQ discusses important topics such as security deposits, failure to deliver a habitable rental unit, and terminating the tenancy. Although no studies have been completed in Orange County, HUD sponsored studies have shown that the general public has a basic awareness of the nature and scope of fair housing laws. According to a recent study: Both the 2000/1 and 2005 surveys posed a series of scenarios depicting actions taken by rental building owners, a home seller, a real estate agent and mortgage lenders, which might or might not have been discriminatory. Respondents were asked, first, if they agreed with each action and, second, if they believed it to be legal under Federal law. Steps were taken to protect against the scenarios and questions being too test -like, obvious, or patterned. The 2005 survey reveals that for five of the eight scenarios portraying discriminatory behavior under Federal law there is essentially no change in the extent of public knowledge since 2000/1. In a sixth scenario involving use of the words "Christians preferred' in advertising an apartment, fewer people in 2005 than in 2000/1 were aware of the fact that this is unlawful. For the remaining two scenarios —one involving a real estate agent restricting a client's housing search to geographical areas based on racial concentration, and the other an apartment owner restricting a family to a particular building because they had children —more people are aware in 2005 than were aware in 2000/1 that these actions are illegal. When all responses to scenarios depicting illegal actions are summed to create an index representing the number each respondent correctly identified as illegal, there is no difference in the distribution of scores observed in 2005 compared to 2000/1. In both cases, about one -half of the public knew the law with respect to six or more of the scenario depictions. While knowledge of fair housing law may not have expanded since the baseline survey, public support for it has. On a scenario -by- scenario basis support improved by as much as nine percentage points when it comes to opposing restricting home sales based on race, and eight percentage points for opposing real estate agents limiting client home searches based on neighborhood racial composition. Somewhat smaller increases in support for the law are also observed for differential treatment of families with children, advertising a religious preference for an apartment, and restricting rental occupancy based on an applicant's religion. When responses to each of eight scenarios depicting illegal actions are summed, the share of the public expressing support for the law in six or more scenario depictions strengthened from 66 percent in 2000/1 to 73 percent in 2005. Likewise, support for a hypothetical open- housing law that would prohibit home sellers from discriminating on the basis of race, religion or nationality also increased from 67 percent of the population in 2000/1 to 70 percent in 2005. Source: The Urban Institute, Do We Know More Now? Trends in Public Knowledoe. Support and Use of Fair Housing Law, prepared for the U.S. Department of Housing and Urban Development, Office of Policy Development and Research, February 2006, pages i and ii 2. Intentional Discrimination by Some Members of the Housing Industry Including, but not necessarily Limited to, Rental, Lending, Insurance, Zoning, Appraisals, and Advertising Discriminatory practices are likely to persist in these fields. However, 2005 benchmark data are generally unavailable thereby impeding efforts to track changes or progress. Although lending data are available, the significant changes in underwriting practices in the past three years make it unwise to compare 2008 and 2009 Home Mortgage Disclosure Act (HMDA) data to 2004 and 2005 HMDA data. Discriminatory advertising seems to have been reduced as questionable words and phrases pertain mostly to "no pets ", "source of income" and "age ". The 2005 -2010 Regional Al had no specific analysis on zoning - related fair housing issues. The Al update contains an analysis of how zoning impacts fair housing on a jurisdiction -by- jurisdiction basis. 3. "Color" Blind Policy Causes Disparate Impact (i.e., Credit Scores in Determining a Person's Insurability and Occupancy Restrictions) Data are unavailable to demonstrate the degree to which private sector policies have created disparate impacts for persons seeking a home loan, homeowners insurance, or how occupancy standards have reduced housing opportunities for families with children. Information is available on the degree to which "credit history" is a reason for denial of a home loan application. In 2008, 7.1% (White /Minority) to 22.5% (Blacks) of FHA loan applications were denied because of a poor credit history. In 2008, 3.0% (Native Hawaiian /Pacific Islander) to 20% (2 or more races) of conventional loan applications were denied because of poor credit history. However, too high a debt -to- income ratio is the most frequent reason for denial of a home loan application. 4. Employer's Lack of Support for Affordable Housing Results in Segregated Housing Data are unavailable to determine if this impediment has been ameliorated or eliminated between 2005 and 2010. 50 5. High Loan Denial Rates are 3 Times among Upper Income Blacks and 2 Times for Equally Situated Hispanics Evidence from the 2008 Home Mortgage Disclosure Act (HMDA) data indicates that loan denial disparities between White applicants and Black and Hispanic applicants have been reduced to less than 3 times for Blacks and less than 2 times for Hispanics in three of four income groups. With respect to FHA loans, Blacks in all income groups have loan denial rates of less than two times compared to White applicants. With regard to conventional loans, the disparities are not as high as 3 times except for low income Black applicants (2.55). Refer to Table 2 -1 for detailed rates. Moderate- income Hispanics have a loan denial rate for FHA and conventional loans that is two times greater than White applicants. The very low, low and above moderate income Hispanics have loan denial rates less than two times the White applicant rates. Refer to Table 2 -1 for detailed rates. The disparities in loan denial rates between White applicants and Black and Hispanic applicants have been reduced since the 2005 Regional Al was prepared. Table 2 -1 Orange County Disparities in Loan Denial Rates for Black and Hispanic Borrowers -2008 FHA Loans Income Group Blacks Hispanics Very Low N/A 1.64 Low 1.09 1.93 Moderate 1.90 1.87 Above Moderate 1.39 1.46 Conventional Loans Income Group Blacks Hispanics Very Low N/A 1.81 Low 2.55 1.62 Moderate 1.18 2.00 Above Moderate 1.25 1.65 Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 51 6. CRA Funds are not Targeted in ways Assisting Low Income Persons and Neighborhoods in Home Ownership and Financial Stability The Community Reinvestment Act (CRA), Title VIII of the Housing and Community Development Act of 1977, is a federal law designed to encourage commercial banks and savings and loans to meet the needs of borrowers in all segments of their communities, including low- and moderate - income neighborhoods. Congress passed the Act in 1977 to reduce discriminatory credit practices against low- and moderate income neighborhoods, a practice known as redlining. The CRA is implemented by regulations of the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of Thrift Supervision (OTS) (collectively, the agencies). CRA directs the agencies to encourage insured depository institutions to help meet the credit needs of the communities in which they are chartered. Institutions subject to data reporting requirements must report the aggregate number and amount of community development loans originated or purchased during the prior calendar year. A community development loan has community development as its primary purpose. As defined in the regulations, "community development" means— affordable housing (including multifamily rental housing) for low or moderate - income individuals; • community services targeted to low- or moderate - income individuals; All state member banks, state nonmember banks, national banks, and savings associations that are not small or special - purpose institutions are subject to the data collection and reporting requirements of the CRA. Institutions that are not small are considered large institutions. "Small" is defined as follows: "Small bank" or "small saving association" means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.098 billion. "Intermediate small bank" or "intermediate small savings association" means a small institution with assets of at least $274 million as of December 31 of both of the prior two calendar years, and less than $1.098 billion as of December 31 of either of the prior two calendar years. The CRA requires the Federal Deposit Insurance Corporation (FDIC) and other agencies to assess an institution's CRA performance. A financial institution's performance is evaluated in the context of information about the institution (financial condition and business strategies), its community (demographic and economic data), and its competitors. Upon completion of a CRA examination, the FDIC rates the overall CRA performance of the financial institution using a four - tiered rating system consisting of: • Outstanding • Satisfactory • Needs to Improve • Substantial Noncompliance 152 Between 2005 and 2010, 22 assessments have been conducted of financial institutions located in the area covered by the Regional Al. The performance evaluations resulted in the following ratings: • Outstanding = 4 • Satisfactory = 16 • Needs to Improve = 2 Based on these ratings, the institutions covered by the CRA are meeting the objectives of the law. The FHCOC will track whether institutions rated "need to improve' move to "satisfactory" when their next assessment is completed. Some Jurisdictions Underestimate the Extent of Discrimination, Therefore Reducing or not Paying Fair Share of Services Provided by FHCOC Data on the number of housing discrimination complaints filed by residents of each city are included in Section 5 of the 2010 -2015 Regional Al. These data can be used to develop a fair share formula for payment of services provided by the FHCOC. 153 This Page Intentionally Left Blank 54 Section 3 Fair Housing Action Plan 2010 -2015 5,5 SECTION 3 FAIR HOUSING ACTION PLAN A. INTRODUCTION Section 3 describes the following: • A summary of Section 4 - Fair Housing Community Profile which contains information on population and housing trends as well as the characteristics of the "protected classes." • A summary of Section 5 — Regional Private Sector Fair Housing Analysis which includes information on private sector impediments and a description of 25 actions to be taken by the Fair Housing Council of Orange County. • A summary of Section 6 — Public Sector Fair Housing Analysis which includes information on the public sector impediments and a description of the actions to be taken by the Fair Housing Council of Orange County, each participating city that identified impediments, and the County of Orange. • A summary of Section 7 — Affirmatively Furthering Fair Housing through the Location of Affordable Housing which examines if affordable housing is predominantly located outside areas of high minority and high low income population concentrations. B. FAIR HOUSING COMMUNITY PROFILE 1. Orange County Population Growth Trends Demographic information concerning the characteristics of the Entitlement Cities and Urban County Cities is a key element of the Analysis of Impediments to Fair Housing Choice and Fair Housing Action Plan. The Fair Housing Community Profile demonstrates the extensive size and diversity of the Fair Housing Council's service area. The Fair Housing Council provides services to a service area of about 2.7 million persons who reside in 29 jurisdictions and in an area that has recently transitioned to a minority- majority county, which indicates that there will be a continuing need for a variety of housing services. The racial and ethnic composition of Orange County's population has been experiencing dramatic change for the past 40 years but has recently passed a major milestone. In 2000, Whites accounted for more than 50% of Orange County's population. By 2007, the White population accounted for 43.6% of Orange County's population and it is now a minority- majority county. Orange County's Hispanic population has now passed the one - million mark and has grown from 30.9% of the population to 35% of the population. The Asian population has also experienced rapid growth. In 2000, the Asian population stood at 395,994 representing 13.8% of Orange County's population and in 2007 reached 520,401 representing 16.8% of the county's population. Both the Black population and those classified as "All Other Races" have experienced some growth since 2000. Population change is the result of three factors: births, deaths, and migration. The White population in Orange County has decreased since 2000, because the number of births just S0 slightly exceeded number of deaths by approximately 3,000, while at the same time, the number of Whites moving out of Orange County exceeded the number of Whites moving into Orange County by 129,805. The net result was that the White population declined by 126,623. On the other hand, the Hispanic population grew by 157,266 due to births and another 55,144 due to migration, while the total number of deaths was 13,159. The net result was that the Hispanic population grew by nearly 200,000 persons between 2000 and 2007. The pattern of growth for Asians is somewhat different than it is for Hispanics. Migration is the major factor for Asian population increase, while births are the major factor for Hispanic population increase. Between 2000 and 2007, the Asian population grew by 95,388 due to migration, while it added just fewer than 30,000 persons through natural increase (births minus deaths). As Orange County's remaining developable land is consumed, the level of growth will moderate each decade. However, some of the demographic trends that have marked the first decade of the twenty -first century will continue. The Hispanic population will nearly double by 2030 from 2000. Between 2010 and 2020 it will surpass the size of the White population and will be the largest population group in the county. The same factors that have marked change from 2000 to 2007 will also influence the change in the Hispanic population. Even though the Hispanic fertility will decline, numerically higher levels of births will increase the population while migration will play a significant role, but a secondary role, in its growth. The Asian population will also experience significant growth between 2000 and 2030, adding 283,656 persons to its population. Migration will play a larger role than fertility. The fertility rates of Asians have been diverse depending on the Asian group. It is anticipated that rates for those groups with higher fertility rates presently will decline. Thus, the number of Asian births is also expected to decline. Continued declines for the White population can be attributed to the overall aging of the White population. First of all, the number of persons in child bearing ages will decline. Even with constant fertility rates, the number of births will decline. Second of all, the overall level of mortality will rise as the population gets older. Whites are also expected to experience a net out - migration, thus resulting in further declines in their population. Although their impact on the population will not be as great as that of Asians, Hispanics and Whites, the Black population will decline while the population of "All Other Races" will increase. The factors that will influence the change in the White population are the same that will influence the decline in the Black population. For those classified as "All Other Races," it is births that will result in the population increase. The underlying factor will be more interracial couples having children as Orange County's population becomes more racially and ethnically diverse. 2. Population Characteristics of the Protected Classes The Fair Housing Act, 42 U.S.C. 3601 et. seq., prohibits discriminatory practices which make housing unavailable to persons because of: • Race • Color • Religion • Sex • National Origin 57 • Familial Status or • Handicap /Disability The California Fair Employment and Housing Act (Article 2, Section 12955) makes it unlawful: to discriminate against or harass any person because of the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or disability of that person. Under the provisions of Civil Code Section 51.2 et. seq. age is a protected class. Hence, the California law has added the following to the group of protected classes: • Sexual Orientation • Marital Status • Ancestry • Source of Income • Age The Unruh Civil Rights Act, California Civil Code sections 51 through 51.3, provides protection from discrimination by all business establishments in California, including housing and public accommodations. The Unruh Civil Rights Act specifically outlaws discrimination in housing and public accommodations based on sex, race, color, religion, ancestry, national origin, disability, or medical condition. While the Unruh Civil Rights Act specifically lists "sex, race, color, religion, ancestry, national origin, disability, or medical condition" as protected classes, the California Supreme Court has held that protections under the Unruh Act are not necessarily restricted to these characteristics. The Act is meant to cover all arbitrary and intentional discrimination by a business establishment on the basis of personal characteristics similar to those listed above. Part C of Section 4 presents demographic data on the following protected classes: race /color, sex, national origin /ancestry, familial status, handicap /disability, and marital status. Table 3 -1 on the next page is a summary of the demographic characteristics of the protected classes. The data on the number and percentage of housing discrimination complaints is based on the five year period from 2005 through 2009 as compiled for the Regional Al by the State Department of Fair Employment and Housing. The housing discrimination data are discussed in more detail in Section 5. ON Table 3 -1 Regional Analysis of Fair Housing Impediments Characteristics of the Protected Classes 159 Number of Percent of All Housing Housing Demographic Discrimination Discrimination Protected Class Characteristics Complaints Complaints Race /Color Population of 3,119,500 in 76 of 372 20.4% Orange County: 45.9% is White Alone; 54.1 % is Minority Sex 209,600 female householders 20 of 372 5.4% live in Regional Al area; 146,700 male householders live in Regional Al area. Estimates exclude married householders. National Origin/ County's foreign born 53 of 372 14.2% Ancestry population is 936,000, which represents 30% of the total population. Vast majority of foreign born population is from Latin America and Asia. Familial Status Almost 280,000 families with 45 of 372 12.1% children live in the Regional Al area — almost 30% of the families (80,000) reside in Anaheim and Santa Ana. Handicap /Disability 140,000 disabled persons 129 of 372 34.7% reside in Entitlement Cities; 7.4% of non - institutionalized population is disabled. 98,900 disabled persons live outside the Entitlement Cities; 8.1% of non - institutionalized population is disabled. Marital Status About 339,000 married 15 of 372 4.0% couples live in Entitlement Cities; 54% of all households. About 81,200 married couples live in Urban County Cities; 55% of all households. 159 C. PRIVATE SECTOR IMPEDIMENTS AND ACTIONS TO BE TAKEN The Regional Al examines the following private sector impediments: • Housing Discrimination • Discriminatory Advertising • Blockbusting • Denial of Reasonable Accommodation • Hate Crimes • Unfair Lending Part C provides a summary of the detailed information on each impediment contained in Section 5. Additionally, the actions to be taken by the FHCOC to ameliorate or eliminate the impediments are described in this part. The key rationale for preparation of a Regional Al is that private sector impediments are regional in nature and affect multiple communities — that is, they are not limited to a single jurisdiction responsible for AFFH. The FHCOC has a wealth of experience in dealing with fair housing impediments that occur in the private sector. HUD guidance indicates that the Regional Al must describe appropriate actions to overcome the effects of the private sector impediments that are identified through the analysis. The FHCOC understands the private sector and is well equipped to analyze impediments, describe appropriate actions, and to follow- through on those actions. The actions to be taken between 2010 and 2015 to remove or ameliorate impediments to fair housing choice and, thereby, affirmatively further fair housing are organized according to four timelines: • Ongoing: will be accomplished annually • Near -Term: will be accomplished in Program Year 2010 -2011 • Mid -Term: will be accomplished in Program Years 2011- 2012/2012 -2013 • Long -Term: will be accomplished in Program Year 2013 - 2014/2014 -2015 Chart 3 -1 on the following six pages describes each action to be taken according to the above timelines. All the actions will be implemented by the FHCOC. In August of each year, the FHCOC will report its progress on implementing the planned actions for the prior program year to the Entitlement Cities and County of Orange. A summary of the private sector impediments and list of planned actions follows Chart 3 -1. W Chart 3 -1 Regional Analysis of Fair Housing Impediments Private Sector Analysis Private Sector Impediments Fair Housing Action Plan: 2010 -2015 Fair Housing Action Ongoing Near -Term Mid -Term Long -Term Annually Program Year Program Years Program Years 2010 -2011 2011 - 2012!2012 -2013 2013 - 2014/ 2014 -2015 Housing Discrimination Continue to process Conduct testing of housing housing discrimination provider practices to complaints filed by city and determine whether there county residents. are differences in treatment based on a protected class. The 2005- 2009 housing discrimination complaint data and the fair housing community profile can be used to identify the protected classes and locations of housing providers that should be tested. Revise its website to provide direct access to a housing discrimination complaint form and provide a diagram or brief explanation of the process for investigating and resolvin a com taint. Revise its website to add more information on how residents can detect whether they have been victims of unlawful housing discrimination. 01 Chart 3- 1- continued Fair Housing Action Ongoing Near -Term Mid -Term Long -Term Annually Program Year Program Years Program Years 2010 -2011 2011 - 201212012 -2013 2013 - 2014/ 2014 -2015 Housing Discrimination Publish a quarterly report on the FHCOC website summarizing the remedies pertaining to filed housing discrimination complaints. Ensure that all jurisdictions provide a link to the FHCOC website Compile an Annual Report on housing discrimination complaints filed with the FHCOC, the State Department of Fair Employment and Housing (DFEH) and HUD. The report will include housing discrimination complaints unique to each participating jurisdiction as well as those of the entire County. The Annual Report will describe emerging trends within the cities and County. (Annually beginning in Program Year 2011 -2012 02 Chart 3- 1- continued Fair Housing Action Ongoing Annually Near -Term Program Year 2010 -2011 Mid -Term Program Years 2011 - 201212012 -2013 Long -Term Program Years 2013 - 2014/ 2014 -2015 Housing Discrimination Transmit the Annual Report to the participating jurisdictions by August of each calendar year. This schedule allows the jurisdictions to include a summary of the report findings in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. (Annually beginning in Pro ram Year 2011 -2012 Discriminatory Encourage the Orange Support an amendment to Advertising County Register to publish the Communications a Fair Housing Notice in Decency Act of 1996 to the for rent classified ad state no provider or user of section and to identify the an interactive computer FHCOC as an agency that service shall be treated as can respond to fair housing the publisher or speaker of questions. any information provided by another information Encourage apartment content provider, except rental websites to display for notices, statements, or more prominently their advertisements with Fair Housing Notice. respect to the sale, rental, financing or insuring, or any other service of a dwelling that violate the Fair Housing Act, 42 U.S.C. § 3601 et seq. (03 Chart 3- 1- continued Fair Housing Action Ongoing Near -Term Mid -Term Long -Term Annually Program Year Program Years Program Years 2010 -2011 2011 - 2012/2012 -2013 2013 - 2014/ 2014 -2015 Discriminatory Prepare a summary of the Encourage the Los Periodically review for rent Advertising accomplishments each Angeles Times and and for sale ads published year and transmit to the Orange County Register to in the print media. Entitlement Cities and publish a "no pets' Urban County in August of disclaimer that indicates each year. This schedule rental housing owners allows the Entitlement must provide reasonable Cities and Urban County to accommodations, including include a summary of the "service animals" and accomplishments in the "companion animals" for Consolidated Plan Annual disabled persons. Performance and Evaluation Report. That Report is published in Se tember of each year. Blockbusting Provide information on the FHCOC website on the unlawful practice of blockbusting including examples of this illegal practice. Work with the California Department of Real Estate to determine if any Orange County licensees have had their licenses suspended or revoked because of the illegal practice of blockbustin . =1 Chart 3- 1- continued Fair Housing Action Ongoing Near -Term Mid -Term Long -Term Annually Program Year Program Years Program Years 2010 -2011 2011 - 201212012 -2013 2013 - 2014/ 2014 -2015 Blockbusting In the event, a licensee has been found to have committed blockbusting, provide education and information on this practice to the responsible broker and all related salespersons. Denial of Reasonable Provide education and Modification /Reasonable information on why this Accommodation practice is unlawful to the owners and managers of apartment complexes and homeowner associations. Provide information on the unlawful practice of denying reasonable modifications and reasonable accommodations at fair housing seminars conducted by the Apartment Association of Orange County. Hate Crimes Coordinate with the Orange County Human Relations Commission, Center OC and the Orange County Victim Assistance Partnership. Provide affected residents — when needed - with referrals to hate crime victim resources. 05 Chart 3- 1- continued Fair Housing Action Ongoing Annually Near -Term Program Year 2010 -2011 Mid -Term Program Years 2011- 201212012 -2013 Long -Term Program Years 2013 - 2014/2014 -2015 Unfair Lending Monitor the HMDA data Complete a HMDA Conduct a follow -up annually using the 2008 analysis of the top 10 analysis of loan denial HMDA analysis as a lenders in Orange County rates at the neighborhood benchmark. to compare and contrast level to determine to what loan denial rates. 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. Conduct outreach to Provide homebuyer cultural, ethnic and education programs in minority organizations to neighborhoods with high potentially increase denial rates, high minority interest and readiness in population concentrations home purchases. and limited English speaking proficiency to help increase loan approval rates. 1. Housing Discrimination a. Impediment Housing discrimination, especially in the rental housing market, is an impediment to fair housing choice because 60 complaints annually are filed by residents of the participating entitlement cities and Urban County. The California Department of Fair Employment and Housing (DFEH) compiled data on housing discrimination complaints for this Regional Al. In the five -year period since the prior AI, about 300 housing discrimination complaints have been filed with DFEH. Annually, the number of housing discrimination complaints averaged 60 per year. The number of cases ranged from a low of 46 in 2005 to a high of 78 in 2006. The vast majority — 244 of 302 housing discrimination complaints — have been filed in the Entitlement Cities. Irvine (58) and Anaheim (40) accounted for the highest number of complaints. A housing discrimination complaint can have more than one basis. The bases include: • Physical Disability • Mental Disability • Race /Color • National Origin • Familial Status • Sex • Marital Status • Other - Retaliation; Religion; Source of Income; Association and Age About 35% of the housing discrimination complaints were based on a physical or mental disability. Since the prior Regional Al was completed, disability has been increasing as a basis for a housing discrimination complaint. Race and color (20 %) and national origin (14 %) rank second and third as a basis for making a housing discrimination complaint. Although Individual cities vary in terms of the basis for a housing discrimination complaint, disability, race /color and national origin comprise the basis for the highest number of complaints. The DFEH compiles data on number of housing discrimination cases according to nine types of alleged acts: • Refusal to Rent • Eviction • Refusal to Show • Loan Withheld Unequal Terms • Harassment • Unequal Access to Facilities • Denied Reasonable Modification /Accommodation A summary of the highest number and percentage of alleged acts is presented below: About 22% (101) of the housing discrimination complaints occurred during the eviction process. 07 • About 19% each of the alleged acts pertained to unequal terms (88) and to denial of a reasonable modification and /or accommodation (87). • About 15% each of the housing cases were filed because of harassment (72) and the refusal to rent (68). It appears that most of the alleged acts affect renters or persons seeking rental housing. This mirrors HUD's national study which found that about 70% of the persons who thought they were victims of discrimination were looking to rent at the time. b. Actions to be Taken During the 2010 -2015 period, the FHCOC will undertake the following actions: 1. Continue to process housing discrimination complaints filed by city and county residents. 2. Conduct testing of housing provider practices to determine whether there are differences in treatment based on a protected class. The 2005 -2009 housing discrimination complaint data and the fair housing community profile can be used to identify the protected classes and locations of housing providers that should be tested. 3. Revise its website to provide direct access to a housing discrimination complaint form and provide a diagram or brief explanation of the process for investigating and resolving a complaint. 4. Revise its 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 State Department of Fair Employment and Housing (DFEH) and HUD. The report will include housing discrimination complaints unique to each participating jurisdiction as well as those of the entire County. The Annual Report will describe emerging trends within the City and County. 8. Transmit the Annual Report to the participating jurisdictions by August of each calendar year. This schedule allows the jurisdictions to include a summary of the report findings in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. M 2. Discriminatory Advertising a. Impediment 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. Section 804 (c) of the 1968 Fair Housing Act prohibits discriminatory advertising; it is unlawful: To make, print, or publish, or cause to be made, printed, or published any notice, statement, or advertisement, with respect to the sale or rental of a dwelling that indicates any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. The California Fair Employment and Housing Act contains similar language prohibiting discriminatory advertising. To demonstrate whether discriminatory advertising meets the threshold for being considered a regional impediment to fair housing choice, print and online advertising was reviewed during the month of January 2010. Classified ads printed in the Los Angeles Times and Orange County Register were reviewed for words and phrases that might be viewed as discriminatory. During this period, however, few for -rent ads were published in either newspaper. Because of limited newspaper print advertising, an online search of apartment ads was conducted via Apartments. com, which is provided by the Los Angeles Times. Each ad was reviewed to determine if it might any indicate a "preference, limitation or discrimination." Advertisements which describe the property being advertised or the services available at the property are generally considered acceptable. The review, then, focused on words and phrases that deviated from physical descriptions of the property and available services. 1. Source of Income: Source of income is a protected class under California's fair housing law, effective January 1, 2000. Thus, it is unlawful to print or publish an advertisement that prefers, limits or discriminates on the basis of the source of the tenant's income. An ad stating "No Section 8" would not be illegal because under the California Fair Employment and Housing Act, "source of income" refers to income paid directly to a tenant or tenant's representative. A landlord that receives a Section 8 rental payment on behalf of a tenant from a housing authority is not considered a representative of the tenant. The rental housing market is currently accepting tenants that receive Section 8 rental assistance. Many ads contained phrases such as "Section 8 OK "; "HUD OK "; "Section 8 Welcome "; and "Section 8 Accepted ". When the rental housing market vacancy rates become significantly lower, landlords may not have an incentive to attract tenants receiving Section 8 assistance. Under these conditions, "No Section 8" ads may become an impediment to fair housing choice because, in part, they could make such housing unavailable disproportionately to a protected class such as persons with disabilities. i • 2. No Pets: An analysis was completed of the print ads with respect to the Entitlement City in which the apartment complex is located; number of ads placed; ads with non - property related words and phrases; and the number of ads published with those words and phrases. Forty seven of the 223 apartment ads contained non - property related words or phrases. The overwhelming majority of the non - property related words or phrases was "No Pets" which occurred in 38 (17 %) of the 223 apartment ads. Twenty -eight of the 204 homes for rent ads contained non - property related words or phrases. Once again, "no pets" was the most frequent non - property related word or phrase, having occurred in 26 (12.7 %) of the 204 ads. There were 62 unique ads for apartments and homes for rent in the Urban County jurisdictions. Ten ads had words and phrases that did not pertain to the physical description of the property: seven stated "no pets," two were "Section 8" related and one ad stated "Senior Citizen ". Under Federal and State fair housing laws, individuals with disabilities may ask their housing provider to make reasonable accommodations in the "no pets" policy to allow for their use of a companion /service animal. The housing provider may ask the disabled applicant/tenant to provide verification of the need for the animal from a qualified professional. Once that need is verified, the housing provider must generally allow the accommodation. Some disabled persons are unaware of their fair housing rights and, as a consequence, may not consider as available to them apartments with ads that state "no pets." 3. Age: Federal regulations specify that unless the housing being offered meets government requirements for "senior" or "senior only" housing, advertisers may not express a preference or limitation on the basis of age. A few ads contained phrases indicating a preference for seniors. One ad stated "senior citizen ". It appears that this ad was placed by an individual owner of a condominium. However, it is not known if the condominium complex met the requirements of a senior only complex. Two apartment complexes placed ads stating that a 5% discount was given to seniors. The complexes are located in Orange and Westminster and are managed by the same company. b. Actions to be Taken During the five -year of the Consolidated Plan, the FHCOC will undertake the following actions: 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, 70 financing or insuring, or any other service of a dwelling that violate the Fair Housing Act, 42 U.S.C. § 3601 et seq. 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 Entitlement Cities and Urban County in August of each year. This schedule allows the Entitlement Cities and Urban County to include a summary of the accomplishments in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. 3. Blockbusting a. Impediment Blockbusting is unlawful; however, it does not appear to be a significant impediment to fair housing choice. Section 804(e) of the 1968 Fair Housing Act makes the following act, commonly referred to as blockbusting, unlawful: For profit, to induce or attempt to induce any person to sell or rent any dwelling by representations regarding the entry or prospective entry into the neighborhood of a person or persons of a particular race, color, religion, sex, handicap, familial status, or national origin. With respect to blockbusting, the California law has more protected classes than the Federal Fair Housing Act. There is no local or county agency that maintains records on actual or potential blockbusting incidents. Such incidents would take place primarily as real estate agents attempt to solicit or induce homeowners to sell their homes. The California Real Estate Commissioner is authorized to take disciplinary action against licensees who have committed the prohibited discriminatory practice of blockbusting and panic selling. The Department of Real Estate stated in June 2010 that no Orange County licensee has had their license suspended or revoked because of the illegal practice of blockbusting. b. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: 1. Provide information on the FHCOC website on the unlawful practice of blockbusting including examples of this illegal practice. 2. Work with the California Department of Real Estate to determine if any Orange County licensees have had their licenses suspended or revoked because of the illegal practice of blockbusting. 71 3. In the event, a licensee has been found to have committed blockbusting, provide education and information on this practice to the responsible broker and all related salespersons. 4. Denial of Reasonable Modification /Reasonable Accommodation a. Impediment 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. It is unlawful to refuse to make reasonable accommodations for disabled persons. Section 804 (3) of the 1968 Fair Housing Act states that discrimination includes -- (A) a refusal to permit, at the expense of the handicapped person, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises, except that, in the case of a rental, the landlord may where it is reasonable to do so condition permission for a modification on the renter agreeing to restore the interior of the premises to the condition that existed before the modification, reasonable wear and tear excepted. (B) a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling. The DFEH compiles data on the number of housing discrimination cases according to nine types of alleged acts. During the 2005 -2009 period, 461 alleged discriminatory acts were committed in the cases processed by the DFEH. Of this total, 87 or 18.9% involved denial of a reasonable modification /reasonable accommodation. About 17 -18 denials of reasonable modification /reasonable accommodation occurred per year during the five -year period. b. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: 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. 72 5. Hate Crimes a. Impediment 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. Hate crime events were reviewed for the 5 -year period from 2004 to 2008 as reported by Criminal Justice Statistics Center of the California Department of Justice (DOJ). The annual average of events was 73 and, during the five -years there was a narrow low (69) to high (79) range. Except for the City of Huntington Beach, on a city -by -city basis, the number of hate crime events is low. In 2008, according to the Orange County Human Rights Commission ( OCHRC), there were 79 cases of hate crimes in Orange County, essentially unchanged from the 80 cases in 2007. Despite the fact that the African American population makes up less than 2% of Orange County's population, this group continues to be the most frequent target for hate crimes. Hate crimes against Latinos continues to increase. In fact, since 2006 there has been almost a 100% increase in the number of cases reported. After a four -year downward trend, hate crimes against Jews increased. Additionally, while there was a slight decrease in hate crimes reported against Gays and Lesbian, this group frequently underreports. In 2008, 29% and 19% of the hate crimes in Orange County had an anti - African American and anti - Latino bias motivation. The California DOJ reports the location of hate crime events for the entire state by 25 categories (e.g., church, park, college, etc). During the past five years two locations are predominant, accounting for about 60% of all hate crime locations: Highway /Road /Alley /Street (29.1 %) and Residence /Home /Driveway (29.7 %). The application of the statewide housing location average of 29.7% to the annual Orange County average of hate crime events of 73 yields at estimate of 22 annual events occurring at a residence, home or driveway. The application of the 40% factor cited by the OCHRC yields an estimate of 29 events occurring at a housing location. On an individual city basis, the number of hate crime events occurring at a housing location is small. However, the number at the countywide level is significant and, as a result, the resources to monitor and alleviate this impediment are best handled at the regional level. b. Actions to be Taken During the five -year of the Fair Housing Action Plan, the FHCOC will take the following actions 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. 73 6. Unfair Lending a. Impediment 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. Section 805 of the Fair Housing Act (42 U.S.C. 3605) states that it is "unlawful for any person or other entity whose business includes ... the making or purchasing of loans or providing other financial assistance for purchasing, constructing, improving, repairing, or maintaining a dwelling... to discriminate against any person... because of race, color, religion, sex, handicap, familial status, or national origin." The Equal Credit Opportunity Act (ECOA) 15 U.S.C. 1691 et seq. prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age, because an applicant receives income from a public assistance program, or because an applicant has in good faith exercised any right under the Consumer Credit Protection Act. To supplement federal legislation, state laws have been enacted to forbid the discriminatory practice known as "redlining;' a practice results in blanket refusals by some lenders to make loans in whole neighborhoods or geographic areas. Redlining is illegal in California pursuant to the Housing Financial Discrimination Act of 1977 (Holden Act). (Health & Safety Code Section 35800 - 35833) The Holden Act prohibits the consideration of race, color, religion, sex, marital status, national origin, or ancestry in lending for the purchase, construction, improvement, or rehabilitation of housing. Further, lenders cannot deny loan applications because of ethnic composition, conditions, characteristics, or expected trends in the neighborhood or geographic area surrounding the property. An analysis of the 2008 Home Mortgage Disclosure Act (HMDA) data was completed in order to determine loan denial rates by census tract, race /ethnicity and income. HMDA requires lenders to report on the action taken on each loan application, as follows: • Loan Originated • Application Approved, Not Accepted • Application Denied • Application Withdrawn • Filed Closed for Incompleteness Many determinants of a loan decision — such as borrower credit history, debt -to- income -ratio and loan -to -value ratio - are not included in the HMDA data. Although the loan denial rates do not support definitive conclusions regarding discrimination on the bases of race or ethnicity, they are a useful screen to identify disparities in loan approval rates by the race and ethnicity of applicants and geographic markets where differences in denial rates warrant further investigation. Additionally, identifying census tracts /neighborhoods with high loan denial rates helps to target credit counseling and homebuyer education programs. 74 Evidence from the 2008 Home Mortgage Disclosure Act (HMDA) data reveals the loan denial disparities between White applicants and Black and Hispanic applicants. Moderate income Blacks have an FHA loan denial rate almost two times greater than moderate income White applicants. Above moderate income Blacks have an FHA loan denial rate about 1.4 times greater than White applicants with identical incomes. The conventional loan disparities are lower for moderate and above moderate income applicants than for FHA loans. However, low income Blacks have a conventional loan denial rate 2.55 times greater than White applicants. Moderate - income Hispanics have a loan denial rate for FHA and conventional loans that is two times greater than White applicants. The very low, low and above moderate income Hispanics have loan denial rates 1.46 to 1.93 higher than White applicants. Unfair lending is manifested more in the loan denial disparities experienced by different racial /ethnic borrowers than by the denial rate disparities experienced in neighborhoods with 20 % -79% minority populations, regardless of income. Additionally, a regression analysis was completed to determine if race /ethnicity is associated with the denial of loan applications. Two types of loans applications were considered in the analysis: (1) home purchases with conventional loans and (2) home purchases with FHA loan. A logit regression was used to "predict' if a loan was denied based on the minority population and income ratio of the census tract, as well as the loan amount. These variables were chosen because the results of a preliminary analysis utilizing census tract level data suggested each of these variables were influencing denials. Each of the three variables was significant predictors of loan denials for conventional loan applications, while the percent minority and the income ratio of a census tract were significant predictors of denials for FHA loan applications. For conventional loans, the probability of a loan being denied increased as the percentage minority population in the census tract increased, as the income increased the probability of a denial decreased, and as the amount of the loan increased the probability of a loan denial increased. b. 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. 75 D. ACTIONS TO ADDRESS PUBLIC SECTOR IMPEDIMENTS 1. Public Sector Impediments Common to Most Participating Jurisdictions As part of the preparation of an Analysis of Impediments to Fair Housing Choice participating cities responded to a 24- question survey 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. The survey 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. 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. 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 Disabilit 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. 70 Government Code Section 65582(f) states: "'Supportive housing' has the same meaning as defined in subdivision (b) of Section 50675.14 of the Health and Safety Code" Health and Safety Code Section 50675.14(b) states: "For purposes of this section, 'supportive housing' means housing with no limit on length of stay, that is occupied by the target population as defined in subdivision (d) of Section 53260, and that is linked to onsite or offsite services that assist 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." Health and Safety Code Section 53260(d) states: "'Target population' means adults with low incomes having one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Act (Division 4.5 (commencing with Section 4500) of the Welfare and Institutions Code) and may, among other populations, include families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, or homeless people." [emphasis added] Government Code Section 65582(g) states: "'Transitional housing' has the same meaning as defined in subdivision (h) of Section 50675.2 of the Health and Safety Code." Health and Safety Code Section 50675.2(h) states: "'Transitional housing' and 'transitional housing development' means buildings configured as rental housing developments, but operated under program requirements that call for the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months." Health and Safety Code Section 50801(i) states: "'Transitional housing' means housing with supportive services for up to 24 months that is exclusively designated and targeted for recently homeless persons. Transitional housing includes self- sufficiency development services, with the ultimate goal of moving recently homeless persons to permanent housing as quickly as possible, and limits rents and service fees to an ability -to -pay formula reasonably consistent with the United States Department of Housing and Urban Development's requirements for subsidized housing for low- income persons. Rents and service fees paid for transitional housing may be reserved, in whole or in part, to assist residents to move to permanent housing." 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. 77 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. The federal Departments of Justice (DOJ) and Housing and Urban Development (HUD) as well as the California Attorney General have encouraged local governments to adopt a reasonable accommodation procedure. The DOJ and HUD have stated: "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 the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 5. On May 15, 2001 the State Attorney General transmitted a letter to all local governments advising the localities to consider adoption of a reasonable accommodation procedure. In that letter, the Attorney General stated: "Both the federal Fair Housing Act ('FHA') and the California Fair Employment and Housing Act ('FEHA') impose an affirmative duty on local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning laws and other land use regulations and practices when such accommodations 'may be necessary to afford' disabled persons 'an equal opportunity to use and enjoy a dwelling. "' Many jurisdictions currently handle requests for relief from the zoning ordinance through variance or conditional use permits. The Attorney General remarked that: "...the criteria for determining whether to grant a variance or conditional use permit typically differ from those which govern the determination whether a requested accommodation is reasonable within the meaning of fair housing laws. "Thus, municipalities relying upon these alternative procedures have found themselves in the position of having refused to approve a project as a result of considerations which, while sufficient to justify the refusal under the criteria applicable to grant of a variance or conditional use permit, were insufficient to justify the denial when judged in light of the fair housing laws' reasonable accommodations mandate." The Attorney General also stated that the variance and conditional use permit procedures — with their different governing criteria — serve to encourage community opposition to projects housing the disabled. The Attorney General wrote: "Yet this is the very type of opposition that, for example, the typical conditional use permit procedure, with its general health, safety and welfare standard, would seem rather predictably to invite, whereas a procedure conducted pursuant to the more focused criteria applicable to the reasonable accommodation determination would not." M The advice of the Attorney General is to establish a reasonable accommodation procedure instead of relying on the conditional use permit and variance procedures to process a request for disabled persons seeking specific exceptions to zoning and land -use rules (variances) necessary for them to be able to fully use and enjoy housing. A public hearing is not required for approval of a reasonable accommodation request. 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. Attachment B in Section 6 (page 6 -34) is an example of a reasonable accommodation procedure. d. Special Needs Zoning Question #20 asks: Does the zoning code or other planning document address housing for "special needs" populations. 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. There is a high incidence of disability in the homeless population, domestic violence overwhelmingly impacts women, and people with HIV /AIDS are considered disabled under fair housing law. While age is not a characteristic protected under federal fair housing law, it is covered under state law, and the higher incidence of disability in the frail elderly introduces possible fair housing implications for that population as well. Entitlement cities and the Urban County should consider enacting special needs housing zoning regulations. Attachment C in Section 6 (page 6 -37) provides an example of such zoning regulations. e. Fair Housing Discussion Question 24 asks: Does the zoning ordinance or other planning or policy document include a discussion of fair 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. Attachment D in Section 6 (page 6 -47) provides an example of such zoning regulations. �9 2. City Identified Public Sector Impediments Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the City of Newport Beach did not identify any public sector impediments. Reference: Technical Appendix G: Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice W 3. 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. b. Actions to be Taken by the City Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the City of Newport Beach did not identify any public sector impediments. Therefore, there are no actions to be taken at this time by the City with respect to public sector impediments. Reference: Technical Appendix G: Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice W1 E. ACTIONS TO AFFH THROUGH THE LOCATION OF AFFORDABLE HOUSING As explained in Section 7, the location of affordable housing is central to fulfilling the commitment to AFFH because it determines whether such housing will reduce or perpetuate residential segregation. The data analysis shows that affordable housing is predominantly located outside areas of high minority and high low income population concentrations. Many of the developments were constructed before localities were required to develop policies to guide the location of affordable housing. During the 2010 -2015 period, the FHCOC will take the following actions: • Provide technical assistance to participating jurisdictions on how the location of affordable housing contributes to AFFH. This action will be accomplished on an as needed, as requested basis Aggregate - for each census tract - the number of voucher holders assisted by all four housing authorities. This action will be accomplished in calendar year 2011. Conduct an analysis of the location of affordable housing in census tracts with a low concentration of minority and low income populations for purposes of determining whether they offer sufficient affordable housing opportunities. This action will be accomplished either in calendar year 2011 or as soon as Census 2010 and American Community Survey data are available. Extend the analysis to include census tracts with minority populations in the range of 60 to 80 %. This action will be accomplished either in calendar year 2011 or as soon as Census 2010 and American Community Survey data are available. Suggest policies that the Housing Authorities and/or entitlement cities and the Urban County Program can implement to promote affordable housing opportunities outside of census tracts with high percentages of poverty and minority populations. This action will be accomplished during the Fair Housing Council of Orange County's review of the housing authority annual plans. Additionally, the Council will provide input to the entitlement cities and Urban County Program on an as needed, as requested basis. :. Section 4 Fair Housing Community Profile 2S SECTION 4 FAIR HOUSING COMMUNITY PROFILE A. INTRODUCTION Demographic information concerning the characteristics of the Entitlement Cities and Urban County Cities is a key element of the Analysis of Impediments to Fair Housing Choice and Fair Housing Action Plan for the reasons explained below. First of all, the Fair Housing Community Profile demonstrates the extensive size and diversity of the Fair Housing Council's service area. The Fair Housing Council provides services to a service area of about 2.7 million persons who reside in 29 jurisdictions and in an area that has recently transitioned to a minority- majority county, which indicates that there will be a continuing need for a variety of housing services. Second, demographic data provide benchmark data for the entire service area, individual cities and the County of Orange. Emerging trends can be pinpointed as Census 2010 and the 2010 American Community Survey data are released. Future year data can be contrasted to the statistics presented in this Fair Housing Community Profile to detect emerging trends. Third, the Fair Housing Community Profile establishes a database that the Fair Housing Council can utilize for a number of purposes. For instance, information contained in the Profile can be used to compete for grants under HUD "s competitive Fair Housing Initiatives Program as well as other public and private grant programs. Fourth, the information in the Profile and future updates can be used to adjust and re -focus the delivery of fair housing services by the Fair Housing Council. For example, the data provide a basis to target or focus fair services geographically within Council's expansive service area. Another example is that the current and projected population characteristics indicate that a greater proportion of the population may have limited English speaking proficiency. And, fifth, individual cities may extract information from the Fair Housing Community Profile to develop a city- specific profile that includes some or all of the characteristics included in Section 4 and Technical Appendix A. The Regional Al's Fair Housing Community Profile presents an overview of the demographic characteristics of the 14 Entitlement Cities, the 14 Urban County Cities and unincorporated Orange County. The total population of the communities included in the Regional Al is almost 2,700,000 persons. The housing stock is comprised of about 873,600 housing units. The Profile contains information on the following: • Population and Housing Characteristics • Population Growth in Orange County • Population Characteristics of the Protected Classes • Household Income Characteristics Three Technical Appendices include the detailed tables referenced in Section 4: • Technical Appendix A —Fair Housing Community Profile • Technical Appendix B — Minority Population by Census Tract M Technical Appendix C— Low Income Population by Census Tract and Block Group B. POPULATION AND HOUSING CHARACTERISTICS 1. Population a. 2010 Population Table A -1 in Technical Appendix A shows that the 2010 population of the Entitlement Cities is almost 2,105,300 persons. Santa Ana (357,754) and Anaheim (353,643) have the largest populations of the 14 Entitlement Cities. Five cities have populations between 138,610 and 217,686 (Fullerton, Garden Grove, Orange, Irvine and Huntington Beach). Seven cities have populations ranging between 58,741 and 94,294. Table A -1 in Technical Appendix A also shows that the vast majority of people live in households; only a few people (1.6 %) live in group quarters. The average household sizes range from a low of 2.21 (Newport Beach) to a high of 4.74 (Santa Ana). Table A -2 in Technical Appendix A shows that the 2010 population of the Urban County is almost 594,000 persons. The unincorporated area comprises one -fifth (20.2 %) of the total Urban County population. Of the 14 cities in the Urban County, two have populations of more than 50,000 (Placentia, Yorba Linda) and 12 have populations of less than 50,000. Table A -2 in Technical Appendix A shows that 99.2% of the Urban County population lives in households. The average household sizes range from a low of 1.47 (Laguna Woods) to a high of 3.58 (Stanton). Attachment A on pages A -28 and A -29 contains definitions of population related terms. b. Population Growth Trends Table A -3 in Technical Appendix A shows that during the 10 -year period between the April 1990 and April 2000 Censuses, about 266,200 persons were added to the populations of 13 of the 14 Entitlement Cities. The City of Lake Forest was unincorporated in 1990. Additionally, the City of Rancho Santa Margarita was a Census Division Place (CDP) and not an incorporated city at the time of the 1990 Census. Thus, 1990 data for this city is based on the CDP population. Table A -3 in Technical Appendix A indicates that almost 230,450 persons were added to the populations of the Entitlement Cities between the April 2000 Census and January 1, 2010. The largest numerical gains between 2000 and 2010 were experienced in Irvine (74,614), Anaheim (25,269) and Lake Forest (20,013). In fact, these three cities accounted for 52% of the total population growth of the 14 Entitlement Cities. In the same period, the highest population growth rates occurred in Irvine (52 %), Lake Forest (34 %), and Newport Beach (24 %). The Newport Beach growth rate was not due to the occupancy of newly built housing, but rather to the annexation of the existing communities of Del Mar and Santa Ana Heights. Table A -4 in Technical Appendix A shows the growth trends for the Urban County. As of January 1, 2010, the Urban County population was almost 594,000 persons. M Three of the 14 Urban County Cities were unincorporated at the time of the 1990 Census ( Aliso Viejo, Laguna Hills and Laguna Woods). Only Aliso Viejo was unincorporated when the Census 2000 was taken. Table A -4 shows that the highest numerical population increases for the 11 cities incorporated at the time of the 1990 and 2000 Censuses occurred in Stanton (6,912), Yorba Linda (6,496) and Placentia (5,229). These cities also had the highest percentage increases at 22.7 %, 12.4% and 12.7% respectively. Between the April 2000 Census and January 2010, the highest numerical and percentage changes in population occurred in Yorba Linda (10,355, 17.6 %), Placentia (5,817, 12.5 %), Brea (4,967, 14.0 %) and Laguna Hills (3,702, 12.4 %). 2. Housing Characteristics a. 2010 Housing Supply Table A -5 in Technical Appendix A shows that as of January 2010 the housing supply of the Entitlement Cities was about 655,450 housing units. The cities of Anaheim (103,242), Irvine (81,011), Huntington Beach (78,060), and Santa Ana (75,943) have the largest housing stocks. Single - family detached dwellings comprise slightly less than one half (48 %) of housing units for the 14 Entitlement Cities. However, in nine of the 14 Entitlement Cities single family detached homes comprise the majority of the housing stock. The lowest percentage of single family detached homes occurred in Irvine (35 %) while Fountain Valley had the highest (66 %) Table A -6 in Technical Appendix A shows that the Urban County's housing stock is comprised of about 218,160 dwelling units. Of the incorporated cities, Yorba Linda (22,103) and Aliso Viejo (18,207) have the largest housing supplies among the Urban County Cities. Unincorporated Orange County has about 38,500 housing units. b. Housing Growth Trends Lake Forest was unincorporated at the time of the 1990 Census. Regarding the remaining 13 incorporated cities, Table A -7 in Technical Appendix A shows that between 1990 and 2000 almost 43,800 housing units were added to housing stock of those cities. Irvine, by far, had the highest housing growth, adding 11,490 (27.2 %) dwellings between 1990 and 2000. Between the April 2000 Census and January 1, 2010, the cities of Irvine (27,300, 33.7 %), Newport Beach (6,227, 14.3 %) and Lake Forest (5,898, 22.4 %) had the largest increases in the housing stock. Rancho Santa Margarita had an increase of some 234 %; however, it must be noted that it was a Census Division Place and not an incorporated city at the time of the 1990 Census Changing boundaries and incorporations make trend analysis difficult. However, the 2010 housing supply estimate for the Urban County is 218,158 dwellings. Between the 1990 and 2000 censuses, two cities (Yorba Linda and Placentia) had growth rates above 10 %. From the April 2000 Census to January 1, 2010 only Yorba Linda had a growth rate over 10 %. Yorba Linda has the largest housing stock at 22,103 units, while Villa Park has the smallest at 2,023. Single - family detached homes comprise about 55.6% of the housing stock in the 14 Urban County cities and the unincorporated area of Orange County. However, on a city -by -city basis it varies widely. Only about 5% of the housing stock in Laguna Woods is comprised of single family detached units. On the other hand, nearly 99% of Villa Park's housing stock is single family detached dwellings. MR Table A -8 in Technical Appendix A provides the more detailed data. Attachment A on page A -28 contains definitions of housing related terms. c. Vacancy Rates Vacancy rates reflect the supply /demand conditions that are unique to each community. Irvine has a 4.52% vacancy rate, which may be due to a significant portion (40 %) of its housing stock comprised of multiple family (5+ units) and unsold housing inventory. Newport Beach has a high vacancy rate at 10.87 %. This may be due to 24% of its stock being comprised of multiple family units in addition to vacation, second home and seasonal use of the housing stock. Some of the higher vacancy rates of Urban County communities reflect beach and retirement communities. Four cities, for instance, have higher than average vacancy rates: Laguna Beach, 11.2 %; Seal Beach, 8.2 %; Dana Point, 7.8 %; and Laguna Woods, 7.6 %. C. POPULATION GROWTH IN ORANGE COUNTY 1. Population by Race and Ethnicity The racial and ethnic composition of Orange County's population has been experiencing dramatic change for the past 40 years but has recently passed a major milestone. In 2000, Whites accounted for more than 50% of Orange County's population. By 2007, the White population accounted for 43.6% of Orange County's population and it is now a minority- majority county. Orange County's Hispanic population has now passed the one - million mark and has grown from 30.9% of the population to 35% of the population. The Asian population has also experienced rapid growth. In 2000, the Asian population stood at 395,994 representing 13.8 % of Orange County's population and in 2007 reached 520,401 representing 16.8% of the county's population. Both the Black population and those classified as "All Other Races" have experienced some growth since 2000. Refer to Table 4 -1. Table 4 -1 Orange County Population by Race and Ethnicity — 2000 and 2007 Race/Ethnicity 2000 2007 Number Percent Number Percent Asian 395,994 13.8% 520,401 16.8% Black 44,191 1.5% 50,556 1.6% Hispanic 885,377 30.9% 1,084,628 35.0% White 1,475,045 51.5% 1,348,422 43.6% All Other Races 62,761 2.2% 90,865 2.9% Total 2,863,368 100.0% 3,094,872 100.0% Source: California State Department of Finance Table construction by Castaneda & Associates Population change is the result of three factors: births, deaths, and migration. The White population in Orange County has decreased since 2000, because the number of births just slightly exceeded number of deaths by approximately 3,000, while at the same time, the number M of Whites moving out of Orange County exceeded the number of Whites moving into Orange County by 129,805. The net result was that the White population declined by 126,623. On the other hand, the Hispanic population grew by 157,266 due to births and another 55,144 due to migration, while the total number of deaths was 13,159. The net result was that the Hispanic population grew by nearly 200,000 persons between 2000 and 2007. The pattern of growth for Asians is somewhat different than it is for Hispanics. Migration is the major factor for Asian population increase, while births are the major factor for Hispanic population increase. Between 2000 and 2007, the Asian population grew by 95,388 due to migration, while it added just fewer than 30,000 persons through natural increase (births minus deaths). Refer to Table 4- 2. Table 4 -2 Components of Population Change By Race and Ethnicity — 2000 and 2007 Race/Ethnicity Births Deaths Net-Migration Net Change Asian 38,610 9,591 95,388 124,407 Black 2,505 1,459 5,319 6,365 Hispanic 157,266 13,159 55,144 199,251 White 96,375 93,193 - 129,805 - 126,623 All Other Races 19,058 773 9,799 28,084 Total 313,814 118,175 35,845 231,484 Source: California State Department of Finance Table construction by Castaneda & Associates 2. Projected Population As Orange County's remaining developable land is consumed, the level of growth will moderate each decade. However, some of the demographic trends that have marked the first decade of the twenty -first century will continue. The Hispanic population will nearly double by 2030 from 2000. Between 2010 and 2020 it will surpass the size of the White population and will be the largest population group in the county. The same factors that have marked change from 2000 to 2007 will also influence the change in the Hispanic population. Even though the Hispanic fertility will decline, numerically higher levels of births will increase the population while migration will play a significant role, but a secondary role, in its growth. The Asian population will also experience significant growth between 2000 and 2030, adding 283,656 persons to its population. Migration will play a larger role than fertility. The fertility rates of Asians have been diverse depending on the Asian group. It is anticipated that rates for those groups with higher fertility rates presently will decline. Thus, the number of Asian births is also expected to decline. Refer to Table 4 -3 on the next page. Continued declines for the White population can be attributed to the overall aging of the White population. First of all, the number of persons in child bearing ages will decline. Even with constant fertility rates, the number of births will decline. Second of all, the overall level of mortality will rise as the population gets older. Whites are also expected to experience a net out - migration, thus resulting in further declines in their population. :: Table 4 -3 Orange County Population and Race Projections 2000 to 2030 Year Total Asian Black Hispanic White All Other Races 2000 2,863,834 395,994 44,191 885,377 1,475,045 62,761 2010 3,227,836 517,787 44,873 1,158,270 1,419,887 87,019 2020 3,520,265 616,929 43,893 1,465,316 1,294,712 99,415 2030 3,705,322 679,650 40,410 1,765,105 1,107,029 113,128 Numerical Change 841,488 283,656 -3,781 879,728 - 368,016 50,367 Percent Change 29.4% 71.6% 1 -8.6% 99.4% -24.9% 80.3% Source: State of California, Department of Finance, Population Projections for California and Its Counties 2000 -2050, Sacramento, California, July 2007 Table construction by Castaneda & Associates Although their impact on the population will not be as great as that of Asians, Hispanics and Whites, the Black population will decline while the population of "All Other Races" will increase. The factors that will influence the change in the White population are the same that will influence the decline in the Black population. For those classified as "All Other Races," it is births that will result in the population increase. The underlying factor will be more interracial couples having children as Orange County's population becomes more racially and ethnically diverse. 3. Housing Needs Immigration has been and will continue to influence Orange County's population change. It is expected that most of the immigrants settling in Orange County will come from the same areas of the globe as those that now reside in the county: Asia and Central America. They will probably share similar characteristics as today's immigrants. They will be younger, have lower levels of education, have higher poverty rates, and have lower levels of English proficiency. Thus, the need for programs that assist immigrants in helping to provide safe and adequate housing will still persist, including fair housing services. D. POPULATION CHARACTERISTICS OF THE PROTECTED CLASSES The Fair Housing Act, 42 U.S.C. 3601 et. seq., prohibits discriminatory practices which make housing unavailable to persons because of: • Race • Color • Religion • Sex • National Origin • Familial Status or • Handicap /Disability The California Fair Employment and Housing Act (Article 2, Section 12955) makes it unlawful: to discriminate against or harass any person because of the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or disability of that person. Under the provisions of Civil Code Section 51.2 et. seq. age is a protected class. Hence, the California law has added the following to the group of protected classes: • Sexual Orientation • Marital Status • Ancestry • Source of Income • Age The Unruh Civil Rights Act, California Civil Code sections 51 through 51.3, provides protection from discrimination by all business establishments in California, including housing and public accommodations. The Unruh Civil Rights Act specifically outlaws discrimination in housing and public accommodations based on sex, race, color, religion, ancestry, national origin, disability, or medical condition. While the Unruh Civil Rights Act specifically lists "sex, race, color, religion, ancestry, national origin, disability, or medical condition" as protected classes, the California Supreme Court has held that protections under the Unruh Act are not necessarily restricted to these characteristics. The Act is meant to cover all arbitrary and intentional discrimination by a business establishment on the basis of personal characteristics similar to those listed above. Part D presents demographic data on the following protected classes: race /color, sex, national origin /ancestry, familial status, handicap /disability, and marital status. Table 4 -4 on the next page is a summary of the demographic characteristics of the protected classes. The data on the number and percentage of housing discrimination complaints is based on the five year period from 2005 through 2009 as compiled for the Regional Al by the State Department of Fair Employment and Housing. The housing discrimination data are discussed in more detail in Section 5. Table 4 -4 Regional Analysis of Fair Housing Impediments Characteristics of the Protected Classes 91 Number of Percent of All Housing Housing Demographic Discrimination Discrimination Protected Class Characteristics Complaints Complaints Race /Color Population of 3,119,500 in 76 of 372 20.4% Orange County: 45.9% is White Alone; 54.1 % is Minority Sex 209,600 female householders 20 of 372 5.4% live in Regional Al area; 146,700 male householders live in Regional Al area. Estimates exclude married householders. National Origin/ County's foreign born 53 of 372 14.2% Ancestry population is 936,000, which represents 30% of the total population. Vast majority of foreign born population is from Latin America and Asia. Familial Status Almost 280,000 families with 45 of 372 12.1% children live in the Regional Al area — almost 30% of the families (80,000) reside in Anaheim and Santa Ana. Handicap /Disability 140,000 disabled persons 129 of 372 34.7% reside in Entitlement Cities; 7.4% of non - institutionalized population is disabled. 98,900 disabled persons live outside the Entitlement Cities; 8.1% of non - institutionalized population is disabled. Marital Status About 339,000 married 15 of 372 4.0% couples live in Entitlement Cities; 54% of all households. About 81,200 married couples live in Urban County Cities; 55% of all households. 91 1. Race /Color During the 2005 through 2009 period, race /color was the basis for 20% of all housing discrimination complaints filed by residents of the cities covered by the Regional Al, according to statistics compiled by the State Department of Fair Employment and Housing (DFEH). The State Department of Justice (DOJ) reports that during the 2004 through 2008 period race /ethnicity /national origin was the bias motivation in about two- thirds of all hate crime events. Hate crime events with an anti -Black and anti - Hispanic bias motivation accounted for 34.6% and 10.7% respectively of all hate crime events in California during the five -year period. a. Race Categories and Definitions 1) Race Categories: The Fair Housing Act does not define race. Data on race is required for many federal programs and the Census Bureau collects race data in accordance with guidelines provided by the U.S. Office of Management and Budget (OMB) and these data are based on self- identification. The racial categories included in the census form generally reflect a social definition of race recognized in this country, and are not an attempt to define race biologically, anthropologically or genetically. In addition, the Census Bureau recognizes that the categories of the race item include both racial and national origin or socio - cultural groups. Census 2010 and the American Community Survey provide for six race categories: • White Alone • Black, African American or Negro Alone • American Indian or Alaska Native Alone • Asian Alone • Native Hawaiian or Other Pacific Islander Alone • Some Other Race Alone Individuals who chose more than one of the six race categories are referred to as the Two or more races population, or as the group that reported more than one race. All respondents who indicated more than one race can be collapsed into the Two or more races category, which combined with the six alone categories, yields seven mutually exclusive and exhaustive categories. Thus, the six race alone categories and the Two or more races category sum to the total population. 2) Race Category and Hispanic Definitions: Census 2000 adheres to the federal standards for collecting and presenting data on race and Hispanic origin as established by the Office of Management and Budget (OMB) Policy Directive No. 15 (May 12, 1977) and the revisions published in the Federal Register Notice on October 30, 1997 — Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity. The OMB's efforts are to standardize the racial and ethnic categories so that federal government agencies can monitor discrimination, as required by the Civil Rights Act of 1964, the Voting Rights Act of 1965, the Fair Housing Act of 1968, the Equal Credit Opportunity Act of 1974, and the Home Mortgage Disclosure Act of 1975. Source: Victoria Hattam, "Ethnicity & the American Boundaries of Race: Rereading Directive 15," Daedalus — Journal of the American Academy of the Arts & Sciences, Winter 2005, pgs. 61 -62. 92 The Census 2000 race and Hispanic definitions are given below: White — A person having origins in any of the original peoples of Europe, the Middle East, or North Africa. It includes people who indicate their race as "White' or report entries such as Irish, German, Italian, Lebanese, Near Easterner, Arab, or Polish. Black or African American — A person having origins in any of the Black racial groups of Africa. It includes people who indicate their race as 'Black, African American or Negro", or provide written entries such as African American, Afro - American, Nigerian, or Haitian. American Indian or Alaska Native — A person having origins in any of the original peoples of North and South America (including Central America) and who maintain tribal affiliation or community attachment. People who classified themselves as "American Indian or Alaska Native" were asked to report their enrolled or principal tribe. Asian — A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam. It includes "Asian Indian," "Chinese," "Filipino," "Korean," "Japanese," "Vietnamese," or "Other Asian." Native Hawaiian and Other Pacific Islander — A person having origins in any of the original peoples of Hawaii, Guam, Samoa or other Pacific Islands. It includes people who indicated their race as "Native Hawaiian," "Guamanian or Chamorm," "Samoan," and other "Pacific Islander." Some Other Race — Includes all other responses not included in the above race categories. Respondents providing write -in entries such as multiracial, mixed, interracial, or a Hispanic /Latino group (for example, Mexican, Puerto Rican, or Cuban) in the "Some other race' write -in space are included in this category. According to Census 2000, the terms "Hispanic," "Latino," and "Spanish" are used interchangeably. Hispanic or Latino origin include people who classify themselves in one of the specific Hispanic or Latino categories listed on the Census 2000 questionnaire — "Mexican," "Puerto Rican," or "Cuban" — as well as those who indicate that they are of "another Hispanic, Latino, or Spanish origin." People in the latter group include those whose origins are from Spain, the Spanish- speaking countries of Central or South America, the Dominican Republic, or people identifying themselves generally as Spanish, Spanish- American, Hispanic, Hispano, Latino, and so on. In data collection and presentation, federal agencies are required to use a minimum of two ethnicities — "Hispanic or Latino' and "Not Hispanic or Latino." b. Non - Hispanic White and Minority Population Characteristics The racial and ethnic groups comprising the "minority" populations are defined in essentially the same way by the Federal Office of Management and Budget, Department of Transportation, Federal Financial Institutions Examination Council (HMDA data), and Council on Environmental Quality (environmental justice guidelines). For instance, the FFIEC, for purposes of HMDA data collection, states that: 93 "...the percentage minority population means, for a particular census tract, the percentage of persons of minority races and whites of Hispanic or Latino Origin, in relation to the census tract's total population." The CEO environmental justice guidelines provide the following definition: "Minority individuals — Individuals who are members of the following population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, multiracial minority (two or more races, at least one of which is a minority race)." The non - minority population is White, Non - Hispanic or Latino. Table 4 -5 shows Orange County's 2000 and 2008 population by Hispanic /Latino and seven race categories. During the eight year period, there was a net decrease in the White alone population and this race category now comprises less than one -half (46 %) of the County's population. The Hispanic and Asian populations comprise 33.8% and 16.1% respectively of the County's population. All other minority populations equal 4.2% of Orange County's population. Table 4 -5 Orange County Population by Hispanic /Latino and Race -2000 and 2008 2000 1 Mid -Year 2008 Hispanic /Latino or Race Number Percent Number Percent Numerical Change Percent Change Hispanic or Latino of any race 875,579 30.8% 1,054,375 33.8% 189,209 21.6% White alone 1,458,978 51.3% 1,431,829 45.9% - 13,009 -0.9% Black or African American alone 42,639 1.5% 49,911 1.6% 7,765 18.2% American Indian and Alaska Native alone 8,414 0.3% 9,358 0.3% 1,037 12.3% Asian alone 383,810 13.5% 502,232 16.1% 123,382 32.1% Native Hawaiian and Other Pacific Islander alone 8,086 0.3% 9,358 0.3% 1,365 16.9% Some other race alone 4,525 0.2% 9,358 0.3% 4,926 108.9% Two or more races 64,258 2.3% 53,031 1.7% - 10,704 -16.7% Total 2,846,289 100.0% 3,119,452 100.0% 303,970 10.7% Note: The mid -year number is derived from applying the ACS 1 -Year Estimates to an average of the total population numbers from California Department of Finance (DOF) for January 1, 2008 and January 1, 2009 Source: American Community Survey 1 -Year Estimate, 2008: Select Demographic Characteristics. Census 2000, Summary File 1, Table P4 Hispanic or Latino by Race, Not Hispanic or Latino Table construction by Castaneda & Associates Between 2000 and 2008, Orange County's population increased by nearly 304,000 people. Two population groups accounted for most of the growth: Hispanic or Latino of any race (189,209) and Asian alone (123,382). 94 c. Hispanic Population Growth Trends According to the State Department of Finance, the Hispanic share of Orange County's total population increased from 30.9% in 2000 to 35% in 2007. The American Community Survey estimates that the Hispanic population comprised 33.8% of the County's population in 2008. The Hispanic population will nearly double by 2030 from the 2000 level. Between 2010 and 2020 it will surpass the size of the White alone population and will be the majority population group in the county. Entitlement Cities vary greatly in terms of growth trends and their 2008 racial and ethnic compositions. Table A -9 in Technical Appendix A provides the following information: • Population by race and Hispanic or Latino in 2000 and 2008 • Percentage of the total population by race and Hispanic or Latino in 2000 and 2008 • Numerical change by race and Hispanic or Latino in 2000 and 2008 • Percentage change by race and Hispanic or Latino in 2000 and 2008 The Entitlement Cities with the largest Hispanic populations are noted below: CCU Santa Ana Anaheim Garden Grove Orange Fullerton Hispanic Population Total 284,234 187,122 69,476 56,037 44,988 Percent of Total City Population 80.5% 54.0% 40.1% 39.8% 32.8% Table A -10 in Technical Appendix A contains Hispanic population data for the Urban County Cities. The Urban County Cities with the largest Hispanic populations are noted below: Hispanic Percent of city Population Total Total City Population Stanton 19,743 50.3% Placentia 19,664 38.1% d. Asian Population Growth Trends The Asian population will experience significant growth between 2000 and 2030, adding 283,656 persons to its population. Migration will play a larger role in population growth than fertility. The Entitlement Cities with the largest Asian populations are listed below and on the next page. Asian Percent of CCU Population Total Total City Population Irvine 75,844 36.1% Garden Grove 58,215 33.6% Anaheim 46,087 13.3% 95 Asian Percent of Citv Population Total Total City Population Westminster Fullerton Santa Ana 38,112 29,489 29,306 41.0% 21.5% 8.3% Table A -10 in Technical Appendix A contains Asian population data for the Urban County Cities. The Urban County Cities with the largest Asian populations are noted below: e. Black Population Growth Trends Between 2000 and 2007 Orange County's Black population increased by nearly 6,400 persons. However, this population group is projected to decrease by almost 3,800 persons between 2000 and 2030. The population decline will be due to fewer births, higher mortality and net out - migration from the County. The Entitlement Cities with the largest Black populations are noted below: Black Citv Population Total Anaheim Asian Percent of Citv Population Total Total City Population Cypress 13,842 28.0% Yorba Linda 9,390 13.8% Stanton 8,007 20.4% e. Black Population Growth Trends Between 2000 and 2007 Orange County's Black population increased by nearly 6,400 persons. However, this population group is projected to decrease by almost 3,800 persons between 2000 and 2030. The population decline will be due to fewer births, higher mortality and net out - migration from the County. The Entitlement Cities with the largest Black populations are noted below: Black Citv Population Total Anaheim 10,049 Fullerton 5,486 Santa Ana 3,885 Percent of Total City Population 2.9% 4.0% 1.1% Table A -10 in Technical Appendix A contains Black population data for the Urban County Cities. The Urban County Cities with a Black population of more than 1,000 persons include Aliso Viejo, Cypress, Stanton and Yorba Linda. f. Areas of Minority Pooulation Concentrations Census 2010 and 2008 American Community Survey data are unavailable at the census tract level. Thus, Technical Appendix B presents the race and ethnicity of the population residing in the Entitlement Cities and Urban County's 252 census tracts based on Census 2000 data. In 2000, "minority" persons comprised 45.3% of the County's population. The census tracts were grouped according to five intervals: • 0.0 -20.0% • 20.1 -45.3% • 45.4 -60.0% • 60.1 -80.0% • 80.1 - 100.0% M Table 4 -6 shows that 64 census tracts had "minority" population percentages greater than 80 %. Thirty-seven of the 64 census tracts are located in Santa Ana. Anaheim had 11 census tracts and Garden Grove had four census tracts exceeding the 80% threshold. Therefore, just over four -fifths of the census tracts with "high" minority population concentrations are located in these three large cities of Orange County. Ten of the 64 census tracts are split tracts — that is, the tract boundaries are located in two cities. Three of the 10 split tracts are located in Santa Ana /Garden Grove. Table 4 -7 lists the 10 split census tracts and the population living in each city. Ninety -four census tracts had "minority" population percentages ranging between 60% and 80 %. Twenty of the census tracts are located in Anaheim and 13 are located in Garden Grove. Santa Ana and Westminster each have eight census tracts with minority populations ranging between 60% and 80 %. Forty -five census tracts are located in other Orange County cities. Table 4 -6 Regional Analysis of Fair Housing Impediments Areas of Minority Population Concentrations Number of Census Tracts by City /Area - 2000 City/Area Census Tract Minority Population Percentages 80.1%-100.0% 60.1%-80.0% Santa Ana 37 8 Anaheim 11 20 Garden Grove 4 13 Santa Ana /Garden Grove 3 1 Stanton 1 2 Buena Park 1 4 Santa Ana /Tustin 1 0 Santa Ana /Fountain Valley 1 0 Anaheim /Placentia 1 1 Anaheim /Stanton 1 1 Anaheim /Fullerton 1 0 Garden Grove/Westminster 1 1 La Habra/Unincorporated 1 0 Fullerton 0 6 Westminster 0 8 La Habra 0 4 La Palma 0 2 Orange 0 3 Irvine 0 1 Huntington Beach 0 1 Seal Beach 0 1 Cypress 0 1 Placentia 0 1 Other 0 15 Total Census Tracts 64 94 'Includes split Census Tracts between two and three jurisdictions. Source: Technical Appendix B Table construction by Castaneda & Associates 97 Table 4 -7 Regional Analysis of Fair Housing Impediments List and Characteristics of Split Census Tracts With 80.1 %+ Minority Population Census Tract City Total Population Percent Minority 744.07 Santa Ana 3,822 98.56% Tustin 3,865 98.52% Total 7,687 92.55% 117.2 Placentia 5,339 93.73% Anaheim 2,196 89.66% Total 7,535 92.54% 891.04 LGarden Grove 3,687 93.38% Santa Ana 2,387 91.41% Total 6,074 92.31% 12.01 La Habra 7,974 80.76% County 397 91.44% Total 8,371 81.55% 889.03 Garden Grove 6,656 84.84% Santa Ana 1,938 88.85% Total 8,594 85.75% 878.03 Stanton 4,821 88.76% Anaheim 1,621 80.26% Total 6,442 86.62% 116.02 Fullerton 3,306 86.48% Anaheim 2,456 77.89% Total 5,762 82.82% 992.02 Santa Ana 7,232 85.26% Fountain Valley 885 62.03% Total 8,117 82.23% 889.04 Westminster 5,142 82.52% Garden Grove 667 78.41% Total 5,809 82.05% 891.02 Garden Grove 4,418 1 82.01% Santa Ana 2,536 80.80% Total 6,954 81.56% Source: California Department of Finance, Demographic Research Unit, Census 2000, Summary File 1, Population by Race /Ethnicity for Split Tracts in Orange County Table construction by Castaneda & Associates 2. Sex (of Householder) In the sale and rental of housing, fair housing laws protect several "classes" from discrimination. State and federal fair housing laws prohibit discrimination based a person's based sex. During the 2005 through 2009 period, "sex" was the basis for 5% of all housing discrimination complaints filed by residents of the cities covered by the Regional Al, according to statistics provided by the State DFEH to the FHCOC. The State DOJ reports that during the 2004 to 2008 period, "gender" was the bias motivation of 1.2% of all hate crime events. The DOJ also reports that "sexual orientation" was the bias motivation of 18.9% of all hate crime events. In Technical Appendix A, Tables A -11 and A -12 present estimates of the sex of householders for the Entitlement Cities and Urban County Cities. The estimates in the two tables are for: • Married - couple family. This category includes a family in which the householder and his or her spouse are enumerated as members of the same household. • Male householder, no wife present. This category includes a family with a male maintaining a household with no wife of the householder present. • Female householder, no husband present. This category includes a family with a female maintaining a household with no husband of the householder present. • Nonfamily household. This category includes a householder living alone or with nonrelatives only. The above are Census 2000 definitions of each household type. Table 4 -8 on the next page summarizes male and female householders for the Entitlement Cities and Urban County Cities. The counts exclude married couple families as homes are typically owned or rented in both spouses' names. The number of non - family householders — those who live alone or with nonrelatives — exceeds the number of family householders. The sex of the non - family householders was based on the Census 2000 ratios of 46% male and 54% female. Excluding married couples, there are an estimated 356,300 householders of which 59% (209,610) are female and 41% (146,709) are male. Female non - family householders — living alone or with nonrelatives - comprise about one -third of all householders. In Table 4 -8, the Urban County numbers are only for the cities that have American Community Survey data and exclude the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park all of which have populations of less than 20,000. The American Community Survey 3 -Year estimates are available for cities having populations between 20,000 and 65,000 persons. American Community Survey data for cities with populations of less than 20,000 should be available in late 2010 or early 2011. Table 4 -8 Regional Analysis of Fair Housing Impediments Estimated Sex of Householder — 2008 Location /Household Type Male Female Total Entitlement Cities Family 38,453 76,553 115,006 Non-Family 81,232 93,836 175,068 Sub -Total 119,685 170,389 290,074 Urban County Family 5,654 14,535 20,189 Non-Family 21,370 24,686 46,056 Sub -Total 27,024 39,221 66,245 Total 146,709 1209,610 1356,319 Source: Technical Appendix A, Tables A -11 and A -12 Table construction by Castaneda & Associates The United States Department of Justice has stated: The Fair Housing Act makes it unlawful to discriminate in housing on the basis of sex. In recent years, the Department's focus in this area has been to challenge sexual harassment in housing. Women, particularly those who are poor, and with limited housing options, often have little recourse but to tolerate the humiliation and degradation of sexual harassment or risk having their families and themselves removed from their homes. In addition, pricing discrimination in mortgage lending may also adversely affect women, particularly minority women. This type of discrimination is unlawful under both the Fair Housing Act and the Equal Credit Opportunity Act. Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, pages 2 and 3 During the 2005 -2009 period, harassment accounted for 15.9% of all alleged housing discriminatory acts in the jurisdictions covered by the Regional Al. 3. National Origin /Ancestry The Fair Housing Act and California Fair Employment and Housing Act prohibit discrimination based upon national origin. According to the United States Department of Justice, such discrimination can be based either upon the country of an individual's birth or where his or her ancestors originated. During the 2005 through 2009 period, "national origin" was the basis for 14% of all housing discrimination complaints filed by residents of the cities covered by the Regional Al, according to statistics provided by the State DFEH. The DFEH data reveal that the national origin housing discrimination complaints included 16 countries; for instance, anti -South Korea or anti - Romania. However, anti - Mexico accounted for 58% of all national origin housing discrimination complaints. 100 Table 4 -9 shows that the vast majority (70 %) of the county's population was born in the United States, Puerto Rico, a United States Island Area or abroad to American parents. Thus, 30% of the county's inhabitants are foreign -born. Orange County's foreign born population totals almost 936,000 people. The largest portions of the foreign -born population come from Latin America or Asia, which together account for more than 90% of the foreign -born population. Table 4 -9 Orange County: Place of Birth and National Origin — 2008 Place of Birth /National Origin Number Percent Born in the United States 2,152,421 69.0% Born in Puerto Rico, U.S. Island Area or Born Abroad to American Parent (s) 31,195 1.0% Foreign Born 128,628 13.7% Europe 53,031 1.7% Asia 380,573 12.2% Africa 12,478 0.4% Oceania 3,119 0.1% Latin America 474,157 15.2% North America 12,478 0.4% Subtotal 935,836 30.0% Total 3,119,452 100.0% Source: 2008 American Community Survey 1 -Year Estimates Selected Social Characteristics. Midpoint of 2008 and 2009 California Department of Finance (DOF) Population Estimates Table construction by Castaneda & Associates Data on a city -by -city basis is limited from the American Community Survey. However, data was available for three of the Entitlement Cities (Anaheim, Huntington Beach and Irvine). These three cities have a total foreign -born population of 231,148 persons. Table 4 -10 shows that Irvine has nearly 15% of the population that was born in Asia. Anaheim has about 18% of the population that was born in Latin America. Table 4 -10 Orange County: City Residence of Foreign Born Population from Asia and Latin American — 2008 Location ■ Total Population Total Foreign Born Percent of the Count Born in Asia Percent of the Count Born in Latin America Percent of the Count Anaheim 346,908 128,628 13.7% 33,983 8.9% 86,702 18.3% Huntington Beach 201,804 31,445 3.4% 16,047 4.2% 7,845 1.7% Irvine 210,321 71,075 7.6% 56,391 14.8% 5,104 1.1% Other 2,360,419 704,688 75.3% 274,152 72.1% 374,506 78.9% Orange County Total 3,119,452 935,836 100.0% 380,573 100.0% 474,157 15.1% Source: 2008 American Community Survey 1 -Year Estimates Selected Social Characteristics for Anaheim, Huntington Beach, Irvine and Orange County. Midpoint of 2008 and 2009 California Department of Finance (DOF) Population Estimates Table construction by Castaneda & Associates 101 4. Familial Status The Fair Housing Amendments Act of 1988 prohibits discriminatory housing practices based on familial status. In most instances, according to the United States Department of Justice, the Act prohibits a housing provider from refusing to rent or sell to families with children. However, housing may be designated as Housing for Older Persons (55 years + of age). This type of housing, which meets the standards set forth in the Housing for Older Persons Act of 1995, may operate as "senior housing" and exclude families with children. The Act protects families with children less than 18 years of age, pregnant women, or families in the process of securing custody of a child under 18 years of age. The Department of Justice has stated: In addition to prohibiting the outright denial of housing to families with children, the Act also prevents housing providers from imposing any special requirements or conditions on tenants with children. For example, landlords may not locate families with children in any single portion of a complex, place an unreasonable restriction on the number of persons who may reside in a dwelling, or limit their access to recreational services provided to other tenants. Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, page 3 In Orange County, complaints filed on the bases of familial status comprise 12% of all complaints filed with the State DFEH during the 2005 -2009 period. Numerically speaking, families with children are a large fair housing protected class. The Entitlement Cities have a combined total of 233,726 families with children. Table A -13 in Technical Appendix A shows, however, that families with children in the Entitlement Cities comprise less than one -half of all householders except in the City of Santa Ana. Stated another way, Santa Ana is the only Entitlement City where families with children comprise a majority (51.3 %) of all households. Anaheim, Buena Park and Rancho Santa Margarita are the only other cities where families with children comprise 40% or more of all households. The same pattern is true for the Urban County communities, as Table A -14 in Technical Appendix A shows. For the cities where data is available, none have families with children comprising more than 40% of all households. In fact, two cities, Laguna Beach and Seal Beach, have very low percentages of families with children with 17.2% and 11.8% respectively. Overall, in the area covered by the Regional Al there are an estimated 279,917 families with children: • Entitlement Cities 233,726 • Urban County* 46,191 *Excludes the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park Anaheim and Santa Ana are home to almost 30% of all the families with children living in the combined area of the Entitlement Cities and Urban County Cities. 102 There are nearly 39,400 and 7,200 female householders with children residing in the Entitlement Cities and Urban County Cities, respectively. Tables A -15 and A -16 in Technical Appendix A show that female householders with children less than 18 years of age experience high poverty rates. Many of these householders will have difficulty finding adequate housing not only because of their poverty incomes but also due to housing discrimination against women and /or families with children. 5. Handicap /Disability a. Background The Fair Housing Amendments Act of 1988 prohibits discriminatory housing practices based on handicap /disability status in all types of housing transactions. Among other prohibitions, the Act is intended to prohibit the application of special restrictive covenants and conditional or special use permits that have the effect of limiting the ability of such individuals to live in the residence of their choice. Fair housing laws, therefore, make it illegal to deny a housing opportunity on the basis of disabilities. In addition, the law prohibits applying one standard to one class of individuals while applying a different standard to another class of individuals. For example, it would be illegal to ask a disabled individual applying for an apartment to provide a credit report if non - disabled applicants did not have to provide one. In Orange County, complaints filed on the bases of disability status comprise 35% of all complaints filed with the State DFEH. A physical or mental disability bias motivation accounted for 0.2% of all hate crime events in California in 2008, according to the State DOJ. Housing opportunities for disabled persons are impeded by practices in both the private and public sectors. For instance, "denied reasonable modification /accommodation" comprise 18.9% of the alleged acts cited in housing discrimination complaints. Additionally, apartment rental ads often state "no pets allowed," even though disabled persons may have service or companion animals. In the public sector, housing opportunities can be impeded because a city has not adopted a reasonable accommodation procedure, or if adopted has not made the procedure widely known in the community. The United States Department of Justice has indicated a major focus of its efforts is on public sector impediments that may restrict housing opportunities for disabled persons. The Department has stated: The Division's enforcement of the Fair Housing Act's protections for persons with disabilities has concentrated on two major areas. One is insuring that zoning and other regulations concerning land use are not employed to hinder the residential choices of these individuals, including unnecessarily restricting communal, or congregate, residential arrangements, such as group homes. The second area is insuring that newly constructed multifamily housing is built in accordance with the Fair Housing Act's accessibility requirements so that it is accessible to and usable by people with disabilities, and, in particular, those who use wheelchairs. Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, page 4 ]LOS b. Disability Defined The disabled are defined as persons with a physical or mental impairment which substantially limits one or more of such person's major life activities. People who have a history of, or are regarded, as having a physical or mental impairment that substantially limits one or more major life activities, are also covered by fair housing laws. It should be noted that California law does not include the term "substantially" with regard to "major life activities' and "impairments." Major life activities include, but are not limited, to: • Caring for one's self • Walking • Seeing • Hearing • Speaking • Breathing • Working • Performing manual tasks • Learning Some examples of impairments, which may substantially limit major life activities, even with the help of medication or aids /devices, include, but are not limited, to: • AIDS • Alcoholism • Blindness or visual impairment Cancer • Deafness or hearing impairment • Diabetes • Drug addiction • Heart disease • Mental illness • Paraplegia • Multiple scleroses c. Disabled Population Estimates The 2008 American Community Survey asks questions regarding six types of disability: • Hearing disability • Vision disability • Cognitive disability • Mobility disability • Self -care disability • Independent living disability The ACS disability questions differ from the Census 2000 and therefore cannot be compared to the decennial census results. In effect, the ACS data provide a benchmark for comparisons in the future. Data on disability status are available for all of Orange County and 11 of the 14 Entitlement Cities. However, no data are available for any of the Urban County Cities. WON There are an estimated 238,900 disabled persons among Orange County's non - institutionalized population. The disability prevalence rate for the entire Orange County area is 7.7 %, according to the 2008 American Community Survey. Table 4 -11 shows the disability status for 11 of the 14 Entitlement Cities participating in the Regional Al. According to the 2008 ACS estimates, there are almost 140,000 disabled persons residing in the 11 Entitlement Cities. The overall disability prevalence rate was 7.4 %. Buena Park and Westminster had significantly higher rates at 11.1% and 11.8% respectively. Based on the data in the preceding two paragraphs, it can be estimated that there are about 98,900 (238,900 minus 140,000) disabled persons residing in areas outside the boundaries of the 11 Entitlement Cities. The disability rate for areas outside the Entitlement Cities is 8.1 %. Table 4 -11 Regional Analysis of Fair Housing Impediments Disabled Population for Entitlement Cites - 2008 city Non - Institutionalized Population' Disability Rate Number Disabled Anaheim 345,618 7.9% 27,304 Buena Park 82,576 11.1% 9,166 Fountain Valley 57,322 NA NA Fullerton 136,282 7.0% 9,540 Garden Grove 172,737 9.1% 15,719 Huntington Beach 201,308 7.8% 15,702 Irvine 210,201 5.3% 11,141 La Habra 61,943 NA NA Lake Forest 77,602 6.0% 4,656 Newport Beach 84,815 5.2% 4,410 Orange 137,571 7.0% 9,630 Rancho Santa Margarita 49,435 NA NA Santa Ana 350,095 6.2% 21,706 Westminster 92,758 11.8% 10,945 Total3 1,891,563 7.4% 139,919 N/A means disability data are unavailable for these three cities. iNon- Institutionalized population is calculated from Census 2000 Summary File 1 (SF1), Table PCT16 "Group Quarters Population" 2Disability rate is from 2008 American Community Survey (ACS), Select Social Characteristics. 3Totals are for the cities where data are available and percentages are based on the total for known cities Source: Census 2000, Summary File 1 (SF1), Table PCT Group Quarters Population. 2008 American Community Survey (ACS) 1 -Year Estimates, Select Social Characteristics State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates 105 During the 2005 through 2009 period, "disability" was the basis for 35% of all housing discrimination complaints filed by residents of the jurisdictions covered by the Regional Al. Therefore, disabled persons represent a much larger share of complainants than of the general population. This may be due to a greater understanding by disabled persons of their fair housing rights than other protected classes. 6. Marital Status California's fair housing law prohibits housing discrimination on the basis of marital status. This basis refers to whether a person is married or not. The U.S. Census Bureau has four major .,marital status" categories: never married, married, widowed, and divorced. These terms refer to the marital status at the time of the enumeration. A married couple includes a family in which the householder and his or her spouse are enumerated as members of the same household. The DFEH reports that 4% of the cases filed were discrimination complaints based marital status. Table A -17 in Technical Appendix A shows that there are about 339,000 married couples residing in the Entitlement Cities, or about 54% of all households. Married couples comprise a majority of all households in 13 of the 14 Entitlement Cities. In Newport Beach less than 50% of the City's households are married. In Fountain Valley and Rancho Santa Margarita more than 60% of all households are married couples. Table A -18 in Technical Appendix A shows that there are about 81,200 married couples living in the Urban County Cities, or 55% of all households. Married couples are the majority of all households in eight of the 10 cities for which data are available. Married couples comprise more than 70% of all households residing in Yorba Linda and more than 60% of all households having a home in Cypress and Laguna Hills. Married couples comprise less than one -half of all households in Laguna Beach and Seal Beach. E. HOUSEHOLD INCOME CHARACTERISTICS `Fair housing choice', according to HUD, means the ability of persons of similar income levels regardless of race, color, religion, sex, national origin, handicap and familial status to have available to them the same housing choices. [emphasis added] This means, for instance, that households of different races but with similar income levels should have available to them the same housing choices. Another example is that female householders, male householders and married couples with similar income levels should have available to them the same housing choices. A housing market that treats female and male householders with incomes of $60,000 differently would not be providing fair housing choice. 1. Median Household Income According to Census 2000, the median household income is based on the total number of households including those with no income. The median divides the income distribution in two equal parts — one -half of the cases falling below the median and one -half above the median. 100 Table 4 -12 on the next page shows the median household income for the following householders for each Entitlement City: • Black or African American Alone Householder • American Indian and Alaska Native Alone Householder • Asian Alone Householder • Native Hawaiian and Other Pacific Islander Alone Householder • Some Other Race Alone Householder • Two or More Races Householder • Hispanic or Latino Householder • White Alone, Not Hispanic or Latino Householder • All Householders The entries in Table 4 -12 show that the Entitlement Cities differ from one another. The general patterns are: • Non - Hispanic White households generally have among the highest median household income, generally ranking first, second or third among the various jurisdictions. • The Asian population usually has slightly lower medians than the Non - Hispanic White householders, but typically rank first, second or third in the various cities. • The householders with the lowest median incomes are the Black or African American householders and Hispanic householders. • The Hispanic householders typically have incomes slightly higher the Black/African American householders. Table 4 -13 on page 4 -26 shows the median household income for the Urban County Cities. The general patterns are: • On the whole, the median incomes of each racial /ethnic category are higher in the Urban County as compared to the Entitlement Cities. • The relative ranks of each race /ethnic category show more variation than among the Entitlement Cities. For instance, the Non Hispanic White householders rank the highest in only two of the 14 jurisdictions. The Asian and Black /African American householders rank among the highest median income householders in most communities. • The median income of Hispanic householders is generally higher in the Urban County compared to the Entitlement Cities. Cities with a large percentage of retirees, such as Laguna Woods and Seal Beach, have comparatively low median household incomes. 107 Table 4 -12 Regional Analysis of Fair Housing Impediments Median Household Income in 1999 Dollars by Race /Ethnicity of Householder Entitlement Cities - 2000 Entitlement City BAA AI/AN Asian NHOPI SCR TOMR Hispanic White All HH Anaheim 39,335 48,750 52,343 53,750 39,272 41,675 39,430 53,056 47,122 Buena Park 41,418 45,625 56,171 79,355 43,750 45,114 43,984 52,048 50,336 Fountain Valley 39,432 66,705 66,066 51,563 56,033 51,734 62,026 72,056 69,734 Fullerton 36,000 49,167 50,817 85,643 39,991 40,030 41,587 54,359 50,269 Garden Grove 45,966 38,819 44,111 41,111 44,169 45,338 44,080 52,260 47,754 Huntington Beach 57,656 65,852 66,077 43,594 50,979 53,113 53,111 66,377 64,824 Irvine 52,443 69,125 67,246 54,444 51,163 53,156 62,616 76,742 72,057 La Habra 40,595 45,750 67,171 30,833 42,120 49,236 44,157 49,293 47,652 Lake Forest 64,732 46,618 71,094 85,124 68,438 57,656 59,633 68,949 67,967 Newport Beach 55,729 60,469 72,578 61,518 72,159 65,500 61,766 85,549 83,455 Orange 61,875 46,563 65,678 58,036 43,321 56,068 43,486 63,927 58,994 Rancho Santa Margarita 80,776 100,470 85,935 32,083 52,917 64,286 65,431 80,716 78,475 Santa Ana 47,083 39,718 47,993 44,708 41,891 42,156 41,558 48,658 43,412 Westminster 37,750 56,875 44,395 47,750 45,849 52,000 45,933 53,614 49,450 Sources: Census 2000 Summary File 3, Median Household Income (by Race /Ethnicity), Tables P152 A, B, C, D, E, F, G, H and L Table P53 Median Household Income in 1999 (Dollars) Table construction by Castaneda & Associates Notes: BAA Black or African American Alone Householder AI /AN American Indian and Alaska Native Alone Householder Asian Asian Alone Householder NHOPI Native Hawaiian and Other Pacific Islander Alone Householder SOR Some Other Race Alone Householder TOMR Two or More Races Householder Hispanic Hispanic or Latino Householder White White Alone, Not Hispanic or Latino Householder All HH All Households I: Table 4 -13 Regional Analysis of Fair Housing Impediments Median Household Income in 1999 Dollars by Race /Ethnicity of Householder Urban County - 2000 Urban County city BAA AI /AN Asian NHOPI SOR TOMR Hispanic White All HH AlisoVieo 53,125 71,983 76,610 72,250 61,250 61,447 72,170 78,915 76,409 Brea 54,375 30,682 62,760 66,250 49,653 50,391 52,118 61,453 59,759 Cypress 65,948 85,917 66,635 29,167 52,188 54,063 55,465 65,762 64,377 Dana Point 51,083 49,519 65,278 46,810 41,042 48,594 48,368 66,584 63,043 Laguna Beach 81,947 96,916 87,409 44,792 20,924 37,969 66,923 76,239 75,808 Laguna Hills 111,382 28,125 86,682 97,467 46,450 50,978 61,055 70,630 70,234 Laguna Woods 6,250 38,750 21,359 0 49,500 22,321 37,689 30,582 30,493 La Palma 71,250 42,000 68,750 57,969 63,884 70,446 64,183 71,172 68,438 Los Alamitos 65,500 63,205 47,440 0 49,135 55,903 60,966 54,344 55,286 Placentia 41,389 42,375 72,375 11,250 43,922 63,750 48,364 69,100 62,803 Seal Beach 50,781 51,528 95,556 36,250 51,538 46,964 44,219 40,676 42,079 Stanton 44,274 12,100 45,052 60,278 37,450 33,750 36,823 40,422 39,127 Villa Park 200,000+ 0 114,850 200,000+ 26,250 101,435 68,092 120,361 116,203 Yorba Linda 107,474 100,827 88,532 69,453 70,156 70,833 74,728 91,303 89,593 Sources: Census 2000 Summary File 3, Median Household Income (by Race /Ethnicity), Tables P152 A, B, C, D, E, F, G, H and I. Table P53 Median Household Income in 1999 (Dollars) Table construction by Castaneda & Associates Notes: BAA Black or African American Alone Householder AI /AN American Indian and Alaska Native Alone Householder AA Asian Alone Householder NHOPI Native Hawaiian and Other Pacific Islander Alone Householder SORA Some Other Race Alone Householder TOMR Two or More Races Householder Hispanic Hispanic or Latino Householder White White Alone, Not Hispanic or Latino Householder All HH All Households tog Table 4 -13 shows that the Laguna Woods' Black or African American householders had a median household income of $6,250. Although this figure seems low, Census 2000 does report that median household income for Black or African American householders living in Laguna Woods. The last column in Tables 4 -12 and 4 -13 shows the median household income for all householders. The median household incomes of each racial /ethnic group can be compared to that of all householders to determine a relative ranking of each group to all households in each jurisdiction. 2. Areas of Low /Moderate Income Concentration Census 2010 and 2008 American Community Survey data are unavailable at the census tract level. Thus, Technical Appendix C presents the low- and moderate - income population residing in the Entitlement Cities and Urban County's census tracts and block groups based on Census 2000 data. The census tracts /block groups were grouped according to five intervals: • 0 % -25% • 25.1%-50% • 50.1%-65.0% • 65.1%-80.0% • 80.1%-100.0% Table 4 -14 shows that within the area included in the Regional Al, there are 112 block groups with more than 80% of the population in the low /mod income category. Sixty percent of these block groups are located in Santa Ana (41) and in Anaheim (26). There are 227 block groups where 65.1% to 80% of the population has low /mod incomes. Six cities have 15 or more block groups where the percentage of the population having low /mod incomes is between 65.1% and 80.0 %. Again, both Santa Ana and Anaheim have the highest numbers of block groups with 56 and 44 respectively. Technical Appendix C contains the detailed low /mod income population by census tract and block group. The income data are presented in rank order from highest to lowest percentage of low /mod income population. For example, Block Group 2 of Census Tract 746.01 ranks as the 14`h highest block group with 97.7% of the population having low /moderate incomes. 110 Table 4 -14 Regional Analysis of Fair Housing Impediments Number of Census Tract Block Groups by City /Location and Percent Low /Mod -2000 City/Area # of Block Groups and Percent Low /Mod 80.1%-100.0% 65.1%-80.0% Anaheim 26 44 Buena Park 3 7 Fullerton 10 17 Garden Grove 9 18 La Habra 1 15 Laguna Woods 2 9 Orange 3 8 Santa Ana 41 56 Stanton 3 7 Westminster 4 11 Other Cities /Areas 9 27 Unincorporated 1 8 Total 112 227 Source: Technical Appendix C Table construction by Castaneda & Associates 111 Attachment A Definitions of Housing and Population Characteristics And Census Boundaries Housing Characteristics Housing Structure: A structure is a separate building that either has open spaces on all sides or is separated from other structures by dividing walls that extend from ground to roof. In determining the number of units in a structure, all housing units, both occupied and vacant, are counted. Stores and office space are excluded. The statistics are presented for the number of housing units in structures of specified type and size, not for the number of residential buildings. 1 -unit, detached: This is a 1 -unit structure detached from any other house; that is, with open space on all four sides. Such structures are considered detached even if they have an adjoining shed or garage. A 1 -unit structure that contains a business is considered detached as long as the building has open space on all four sides. Mobile homes to which one or more permanent rooms have been added or built are also included. 1 -unit, attached: This is a 1 -unit structure that has one or more walls extending from ground to roof separating it from adjoining structures. In row houses (sometimes called townhouses), double houses, or houses attached to nonresidential structures, each house is a separate, attached structure if the dividing or common wall goes from ground to roof. 2 or more units: These are units in structures containing 2 or more housing units, further categorized as units in structures with 2, 3 or 4, 5 to 9, 10 to 19, 20 to 49, and 50 or more units. Mobile Home: Both occupied and vacant mobile homes to which no permanent rooms have been added are counted in this category. Mobile homes used only for business purposes or for extra sleeping space and mobile homes for sale on a dealer's lot, at the factory, or in storage are not counted in the housing inventory. Boat, RV, Van, etc.: This category is for any living quarters occupied as a housing unit that does not fit in the previous categories. Examples that fit in this category are houseboats, railroad cars, campers, and vans. Population Group Quarters: The group quarters population includes all people not living in households. Two general categories of people in group quarters are recognized: (1) the institutionalized population and (2) the non institutionalized population. Institutionalized Population: The institutionalized population includes people under formally authorized, supervised care or custody in institutions at the time of enumeration, such as correctional institutions, nursing homes, and juvenile institutions. 112 Noninstitutionalized Population: The noninstitutionalized population includes all people who live in group quarters other than institutions, such as college dormitories, military quarters, and group homes. Also included is staff residing at institutional group quarters. Household: A household includes all of the people who occupy a housing unit. (People not living in households are classified as living in group quarters.) A housing unit is a house, an apartment, a mobile home, a group of rooms, or a single room occupied (or if vacant, intended for occupancy) as separate living quarters. Separate living quarters are those in which the occupants live separately from any other people in the building and that have direct access from the outside of the building or through a common hall. The occupants may be a single family, one person living alone, two or more families living together, or any other group of related or unrelated people who share living quarters. In 100 - percent tabulations, the count of households or householders always equals the count of occupied housing units. In sample tabulations, the numbers may differ as a result of the weighting process. Census Boundaries Census Tract: Designed to be relatively homogeneous units with respect to population characteristics, economic status, and living conditions at the time of establishment, census tracts average about 4,000 inhabitants. Census tract boundaries follow visible features, but may follow governmental unit boundaries and other non - visible features in some instances; they always nest within counties. For example, the area generally bounded by Pine Street, Main Street, Edinger Avenue, and Flower Street is census tract 746.01 in Santa Ana. Block Group: A subdivision of a census tract, a block group is the smallest geographic unit for which the Census Bureau tabulates sample data. A block group consists of all the blocks within a census tract with the same beginning number. For example, in Census Tract 746.01, the area bounded by West Pine Street, South Cypress Avenue, West Bishop Street, and South Birch Street is Block Group 2. Block Group 2 is comprised of all the individual blocks with a beginning numbering in the 2000 range. 113 This Page Intentionally Left Blank 114 Section 5 Regional Private Sector Fair Housing Analysis 115 SECTION 5 REGIONAL PRIVATE SECTOR FAIR HOUSING ANALYSIS Pursuant to a Scope of Work approved by HUD -LA, the Regional Al examines the following private sector impediments: • Housing Discrimination • Discriminatory Advertising • Blockbusting • Denial of Reasonable Accommodation • Hate Crimes • Unfair Lending A. HOUSING DISCRIMINATION 1. Prohibited Housing Discriminatory Practices Sections 804 (a), (b) and (d) of the 1968 Fair Housing Act describe several prohibited housing discriminatory practices such as the following: (a) To refuse to sell or rent after the making of a bona fide offer, or to refuse to negotiate for the sale or rental of, or otherwise make unavailable or deny, a dwelling to any person because of race, color, religion, sex, familial status, or national origin. (b) To discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of race, color, religion, sex, familial status, or national origin. (d) To represent to any person because of race, color, religion, sex, handicap, familial status, or national origin that any dwelling is not available for inspection, sale, or rental when such dwelling is in fact so available. Sections 804(f)(1), (2) and (3) prohibit the following practices because of a handicap: (1) To discriminate in the sale or rental, or to otherwise make unavailable or deny, a dwelling to any buyer or renter because of a handicap. (2) To discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection with such dwelling, because of a handicap. (3)(A) a refusal to permit, at the expense of the handicapped person, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises. (3)(B) a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling. 110 (3)(C) failure to comply with accessible design and construction requirements The California Fair Employment and Housing Act (FEHA) prohibits unlawful practices similar to those that are described in the Federal Fair Housing Act. For example, Article 2 — Housing Discrimination - Section 12955 of FEHA states the following are unlawful practices: (a) For the owner of any housing accommodation to discriminate against or harass any person because of the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or disability of that person. (b) For the owner of any housing accommodation to make or to cause to be made any written or oral inquiry concerning the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, or disability of any person seeking to purchase, rent or lease any housing accommodation. (f) For any owner of housing accommodations to harass, evict, or otherwise discriminate against any person in the sale or rental of housing accommodations when the owner's dominant purpose is retaliation against a person who has opposed practices unlawful under this section, informed law enforcement agencies of practices believed unlawful under this section, has testified or assisted in any proceeding under this part, or has aided or encouraged a person to exercise or enjoy the rights secured by this part. Nothing herein is intended to cause or permit the delay of an unlawful detainer action. (k) To otherwise make unavailable or deny a dwelling based on discrimination because of race, color, religion, sex, sexual orientation, familial status, source of income, disability, or national origin. HUD, the State Department of Fair Employment and Housing (DFEH) and FHCOC handle housing discrimination complaints. However, it is not known whether the number of complaints is a true measure of the incidents of housing discrimination. Housing discrimination may be underreported; therefore, the number of complaints may not accurately measure the extent of this private sector fair housing impediment. Evidence on underreporting is supported by a HUD - sponsored study conducted by The Urban Institute. That research study concluded: "Another finding with implications for fair housing programs involves the fact that so few people who believed they had been discriminated against took any action, with most seeing little point in doing so." The Urban Institute, How Much Do We Know: Public Awareness of the Nation's Fair Housing Laws, prepared for the U.S. Department of Housing and Urban Development, Office of Policy Development and Research, April 2002, pg. 7 A follow -up study finds that between 2001 and 2005 knowledge of fair housing laws has increased in two areas — discrimination against families with children and steering of prospective homebuyers by race — but declined in one area — discrimination based on religion. On a composite index of overall knowledge, there was no change between 2001 and 2005. There was, however, a significant increase in overall support for fair housing laws. 117 The study also explores whether people know what to do to address perceived discrimination and why so few people who perceive they have been discriminated against do anything about it. "Four of every five persons who believed they had experienced housing discrimination plausibly covered by the federal Act profess not ... to have done anything at all in response. Many alleged victims maintain they did not take action because they presumed doing so would not have been worth it or would not have helped. Some, however, did not know where or how to complain, supposed it would cost too much money or take too much time, were too busy, or feared retaliation. The minority who did respond mainly complained to the person thought to be discriminating or to someone else, but a small proportion also talked to or hired a lawyer or sought help from or filed a complaint with a fair housing or other group or government agency." The Urban Institute, Do We Know More Now? Trends in Public Knowledge. Support and Use of Fair Housing Law, prepared for the U.S. Department of Housing and Urban Development, Office of Policy Development and Research, February 2006, pg. iii 2. Discrimination Complaints a. Background With respect to housing discrimination complaints, the 2006 HUD study found: "About 17 percent of the adult public claims to have suffered discrimination at some point when trying to buy or rent a house or apartment. If, however, the explanations given about the nature of the perceived discrimination are taken into account, about eight percent of the public had experiences that might plausibly have been protected by the Act. While the frequency, actions, and bases for the alleged discrimination are diverse, majorities of this group believe they were discriminated against more than one time, were looking to rent more frequently than to buy, and identified race more so than any other attribute or characteristic as the basis of the discrimination." b. Number of Housing Discrimination Complaints The California Department of Fair Employment and Housing (DFEH) provided data to the FHCOC on housing discrimination complaints. The FHCOC compiled the statistics for this Regional Al. In the five -year period since the prior AI, about 300 housing discrimination complaints have been filed with DFEH. Table 5 -1 shows the number of housing discrimination cases by Entitlement Cities and Urban County Cities. The number of housing discrimination complaints averaged 60 per year. The number of cases ranged from a low of 46 in 2005 to a high of 78 in 2006. The vast majority — 244 of 302 housing discrimination complaints — have been filed in the Entitlement Cities. Irvine (58) and Anaheim (40) accounted for the highest number of complaints. Table 5 -2 shows the number of closed housing discrimination cases by entitlement and urban county cities. Once again, the Irvine (61) and Anaheim accounted for the highest number of closed cases (37). Closed cases refer to cases that have been completely investigated and resolved. 118 Table 5 -1 Regional Analysis of Fair Housing Impediments Housing Discrimination Cases Filed by Year Jurisdiction 2005 1 2006 2007 2008 2009 Total Entitlement Cities Anaheim 3 8 8 14 7 40 Buena Park 2 1 5 4 2 14 Fountain Valley 1 1 3 1 2 8 Fullerton 0 5 3 2 0 10 Garden Grove 5 2 0 0 6 13 Huntington Beach 2 8 5 2 1 18 Irvine 9 14 12 10 13 58 La Habra 0 2 0 0 1 3 Lake Forest 0 3 1 1 2 7 Newport Beach 4 8 3 5 3 23 Orange 2 3 3 3 4 15 Rancho Santa Margarita 0 1 0 1 0 2 Santa Ana 3 5 5 8 1 22 Westminster 0 2 4 1 4 11 Subtotal 31 63 52 52 46 244 Urban C unty Cities and Unincorporated Areas Aliso Viejo 1 1 2 0 1 5 Brea 0 0 0 3 0 3 Cypress 2 0 1 0 2 5 Dana Point 0 2 1 0 0 2 Foothill Ranch 1 0 0 0 0 1 La Palma 0 0 1 0 0 1 Ladera Ranch 1 2 0 0 0 3 Laguna Beach 1 1 2 1 0 5 Laguna Hills 2 3 1 1 0 7 Laguna Woods 1 0 1 0 0 2 Los Alamitos 0 0 1 0 0 1 Placentia 0 4 2 0 0 6 Seal Beach 0 1 3 0 0 4 Stanton 4 0 0 0 0 4 Villa Park 0 0 0 0 0 0 Yorba Linda 2 1 2 3 0 8 Subtotal 15 15 17 8 3 58 TOTAL 46 78 69 60 49 302 Unincorporated area Source: California Department of Fair Employment and Housing Table construction by Castaneda & Associates 119 Table 5 -2 Regional Analysis of Fair Housing Impediments Housing Discrimination Cases Closed by Year Jurisdiction 2005 2006 2007 2008 2009 Total Entitlement Cities Anaheim 4 2 7 13 11 37 Buena Park 3 0 4 2 5 14 Fountain Valley 0 1 2 3 2 8 Fullerton 1 3 2 5 0 11 Garden Grove 3 2 2 0 5 12 Huntington Beach 2 5 4 4 3 18 Irvine 9 14 7 13 18 61 La Habra 0 1 1 0 1 3 Lake Forest 2 2 1 1 1 7 Newport Beach 7 6 1 5 6 25 Orange 3 2 3 4 5 17 Rancho Santa Margarita 0 0 1 0 1 2 Santa Ana 1 6 7 7 3 24 Westminster 1 1 2 3 2 9 Subtotal 36 45 44 60 63 248 Urban County Cities and Unincorporated Areas Aliso Viejo 1 1 1 1 1 5 Brea 0 0 0 0 3 3 Cypress 2 1 0 1 0 4 Dana Point 0 0 2 1 0 3 Foothill Ranch 1 0 0 0 0 1 La Palma 0 0 0 1 0 1 Ladera Ranch 0 1 2 0 0 3 Laguna Beach 1 0 1 0 3 5 Laguna Hills 2 1 3 0 1 7 Laguna Woods 1 0 0 1 0 2 Los Alamitos 0 0 0 1 0 1 Placentia 0 0 3 2 1 6 Seal Beach 0 1 3 0 0 4 Stanton 0 2 0 9 0 11 Villa Park 0 0 0 0 0 0 Yorba Linda 1 1 1 2 3 8 Subtotal 9 8 16 19 12 64 TOTAL 45 53 60 79 75 312 Unincorporated area Source: California Department of Fair Employment and Housing Table construction by Castaneda & Associates 120 c. Bases for Housing Discrimination Complaints Tables 5 -3 and 5 -4 show the bases for the housing discrimination complaints for the Entitlement Cities and Urban County Cities. A housing discrimination complaint can have more than one basis. The bases include: • Physical Disability • Mental Disability • Race /Color • National Origin • Familial Status • Sex • Marital Status • Other - Retaliation; Religion; Source of Income; Association and Age About 35% of the housing discrimination complaints were based on a physical or mental disability. Since the prior Regional Al was completed, disability has been increasing as a basis for a housing discrimination complaint. Race and color (20 %) and national origin (14 %) rank second and third as a basis for making a housing discrimination complaint. Although Individual cities vary in terms of the basis for a housing discrimination complaint, disability, race /color and national origin also comprise the basis for the highest number of complaints. The bases for housing discrimination complaints in Orange County vary considerably from those found in the HUD studies. HUD's 2006 study found that 58% of those who believe they experienced discrimination think it was due to their race, followed by familial status (27 %) and ethnicity (17 %). According to the HUD study: "Surprisingly, less than one percent of the HUD survey respondents indicated disability as a reason for the perceived discrimination, whereas discrimination based on disability is among the most common complaints received by HUD." However, it should be noted that the Orange County findings are based on actual complaints filed, whereas the HUD study refers to persons who perceived housing discrimination but may not have filed a complaint. 121 Table 5 -3 Regional Analysis of Fair Housing Impediments Housing Discrimination Cases Filed by Bases 2005 -2009 For Entitlement Cities Jurisdiction Physical Disability Mental Disability Race/ Color Nat. Origin Familial Status Sex Marital Status Other' Total Anaheim 14 3 5 5 7 3 5 4 46 Buena Park 4 0 7 1 3 0 0 2 17 Fountain Valley 1 2 3 1 3 0 0 0 10 Fullerton 8 0 1 1 1 0 0 1 12 Garden Grove 1 2 1 5 5 2 0 0 16 Huntington Beach 9 0 1 5 6 1 1 3 26 Irvine 18 5 18 16 1 2 4 8 72 La Habra 0 1 1 1 0 0 0 0 3 Lake Forest 3 1 1 2 0 0 0 0 7 Newport Beach 9 3 7 2 4 0 1 3 29 Oran e 3 0 5 2 5 0 1 0 16 Rancho Santa Mar g. 2 0 0 0 0 0 0 0 2 Santa Ana 9 1 9 2 1 3 0 0 25 Westminster 1 2 1 4 1 3 0 3 15 Subtotal 82 20 60 47 37 14 12 24 296 Note: The number of bases exceeds the number of cases because a housing discrimination complaint can have more than one basis. Source: California Department of Fair Employment and Housing Other included Retaliation (9); Religion (8); Source of Income (3); Association (3) and Age (1) Table construction by Castaneda & Associates 122 Table 5 -4 Regional Analysis of Fair Housing Impediments Housing Discrimination Cases Filed by Bases 2005 -2009 For Urban County Cities Jurisdiction Physical Disability Mental Disability Race/ Color Nat. Origin Familial Status Sex Marital Status Other' Total Aliso Viejo 4 0 0 1 0 0 0 1 6 Brea 0 0 3 0 0 0 0 0 3 Cypress 3 1 2 0 0 2 0 2 10 Dana Point 1 0 0 0 1 2 1 0 5 Foothill Ranch 0 0 1 0 0 0 0 0 1 La Palma 0 0 0 0 0 1 1 1 3 Ladera Ranch 2 0 1 0 0 0 0 0 3 Laguna Beach 1 0 2 1 0 0 1 2 7 Laguna Hills 3 0 3 2 3 0 0 1 12 Laguna Woods 2 0 0 0 0 0 0 0 2 Los Alamitos 0 0 0 0 0 1 0 0 1 Placentia 1 3 0 2 0 0 0 0 6 Seal Beach 1 0 3 0 0 0 0 0 4 Stanton 2 0 1 0 2 0 0 0 5 Villa Park 0 0 0 0 0 0 0 0 0 Yorba Linda 3 0 0 0 2 0 0 3 8 Subtotal 23 4 16 6 8 6 3 10 76 TOTAL 105 24 76 53 45 1 20 15 1 341 372 Note: The number of bases exceeds the number of cases because a housing discrimination complaint can have more than one basis. Source: California Department of Fair Employment and Housing 'Other includes Retaliation (3); Religion (2); Source of Income (3); Association (2) Table construction by Castaneda & Associates 12S d. Alleged Acts The DFEH compiles data on number of housing discrimination cases according to nine types of alleged acts: • Refusal to Rent • Eviction • Refusal to Show • Refusal to Sell • Loan Withheld • Unequal Terms • Harassment • Unequal Access to Facilities • Denied Reasonable Modification /Accommodation Table 5 -5 shows the number of housing cases filed by alleged acts between 2005 and 2009. A summary of the highest number and percentage of alleged acts is presented below: • About 22% (101) of the housing discrimination complaints occurred during the eviction process. • About 19% each of the alleged acts pertained to unequal terms (88) and to denial of a reasonable modification and /or accommodation (87). • About 15% each of the housing cases were filed because of harassment (72) and the refusal to rent (68). It appears that most of the alleged acts affect renters or persons seeking rental housing. This mirrors HUD's national study which found that about 70% of persons who thought they were victims of discrimination were looking to rent at the time. In summary, progress on reducing housing discrimination probably cannot be measured by a reduction in the number of complaints because so few people who believe they have been victims of discrimination actually file a complaint. Therefore, progress — at least in the short run — could be measured by an increase in complaints as more people: • Become aware that they can file a complaint • Know where to file a complaint • Believe that their complaint will produce tangible results W0119 Table 5 -5 Regional Analysis of Fair Housing Impediments Housing Cases Filed By Alleged Act — 2005 -2009 Alleged Act 2005 2006 2007 2008 2009 Total Percent Refusal to Rent 8 16 20 15 9 68 14.7% Eviction 20 28 19 19 15 101 21.9% Refusal to Show 1 2 0 0 0 3 0.7% Refusal to Sell 5 4 1 0 1 11 2.4% Loan Withheld 0 3 1 1 1 6 1.3% Unequal Terms 13 27 23 12 13 88 19.1% Harassment 13 23 18 8 10 72 15.6% Unequal Access to Facilities 3 4 8 4 6 25 5.4% Denied Reasonable Modification /Accommodations 10 14 25 18 20 87 18.9% Total 73 121 115 77 75 461 100.0% Source: California Department of Fair Employment and Housing Note: includes alleged acts occurring in the cities participating in the Regional Al Total acts reported exceed the total number of cases filed because some cases are filed under more than one act Table construction by Castaneda & Associates 3. Housing Discrimination Complaint Services The Fair Housing Council of Orange County is a private non - profit organization formed in 1965 in the wake of the civil rights movement that resulted in the Civil Rights Act of 1964. The Council incorporated in 1968, the same year that Congress extended civil rights protections to cover housing with the adoption of the Fair Housing Act. Under the direction of a volunteer board of directors and with a paid staff of 14, the agency works to fulfill a mission of protecting the quality of life in Orange County by ensuring equal access to housing opportunities, fostering diversity and preserving dignity and human rights. Contracting to serve 15 Entitlement Cities and the Urban County Program for the provision of fair housing services for their residents, the Fair Housing Council handles more than 100 cases of alleged housing discrimination in the county each year. 4. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: • Continue to process housing discrimination complaints filed by city and county residents. Conduct testing of housing provider practices to determine whether there are differences in treatment based on a protected class. The 2005 -2009 housing discrimination complaint data and the fair housing community profile can be used to identify the protected classes and locations of housing providers that should be tested. 125 • Revise its website to provide direct access to a housing discrimination complaint form and provide a diagram or brief explanation of the process for investigating and resolving a complaint. • Revise its website to add more information on how residents can detect whether they have been victims of unlawful housing discrimination. Publish a quarterly report on the FHCOC website summarizing the remedies pertaining to filed housing discrimination complaints. • Ensure that all jurisdictions provide a link to the FHCOC website. Compile an Annual Report on housing discrimination complaints filed with the FHCOC, the State Department of Fair Employment and Housing (DFEH) and HUD. The report will include housing discrimination complaints unique to each participating jurisdiction as well as those of the entire County. The Annual Report will describe emerging trends within the City and County. • Transmit the Annual Report to the participating jurisdictions by August of each calendar year. This schedule allows the jurisdictions to include a summary of the report findings in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. B. DISCRIMINATORY ADVERTISING 1. Background Section 804 (c) of the 1968 Fair Housing Act prohibits discriminatory advertising; it is unlawful: To make, print, or publish, or cause to be made, printed, or published any notice, statement, or advertisement, with respect to the sale or rental of a dwelling that indicates any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. The California Fair Employment and Housing Act contains similar language prohibiting discriminatory advertising. To demonstrate whether discriminatory advertising meets the threshold for being considered a regional impediment to fair housing choice, print and online advertising was reviewed during the month of January 2010. Classified ads printed in the Los Angeles Times and Orange County Register were reviewed for words and phrases that might be viewed as discriminatory. During this period, however, few for -rent ads were published in either newspaper. Because of limited newspaper print advertising, an online search of apartment ads was conducted via Apartments. com, which is provided by the Los Angeles Times. Each ad was reviewed to determine if it might discrimination." Advertisements which describe the available at the property are generally considered any indicate a "preference, limitation or property being advertised or the services acceptable. The review, then, focused on 120 words and phrases that deviated from physical descriptions of the property and available services. Guidance on specific words and phrases that are or could be interpreted as discriminatory was obtained from the following: • Roberta Achtenberg, Assistant Secretary for Fair Housing and Equal Opportunity, HUD, "Guidance Regarding Advertisements under Section 804 (c) of the Fair Housing Act," January 9, 1995 • Bryan Green, Deputy Assistant Secretary for Enforcement, Fair Housing Act Application to Internet Advertising, September 20, 2006 [memorandum to FHEO Regional Directors] • California Newspaper Publishers Association, Fair Housing Advertising Manual, Fourth Edition, Copyright, 2001 • 24 CFR 109.30 Appendix I to Part 109 — Fair Housing Advertising. Part 109 is no longer officially part of the Code of Regulations having been withdrawn effective May 1, 1996. However, it is still published on HUD's website • State Department of Fair Employment and Housing, Guidance Memorandum These sources provide guidance on the specific words and phrases that are or could be considered discriminatory with respect the following: • Race /Color /National Origin /Ancestry • Sex • Disability • Familial /Marital Status • Religion • Source of Income • Sexual Orientation • Senior Housing Attachment A is a summary of the California Newspaper Publishers Association guidance on advertising words and phrases. 2. Review of Print Ads and Online Advertising The newspaper print and online ads were reviewed and organized by Entitlement City and Urban County jurisdiction and a data base was developed — by city — of the number of ads, the number that contained "questionable language" and the frequency of the ads. Questionable language refers to words and phrases that deviated from the physical description of the for -rent unit and services available. Table 5 -6 shows the number of ads placed by apartment complexes located in each city. A total of 177 apartment complexes were advertised online at Apartments.com for Entitlement Cites. There were 44 online ads for complexes in Urban County Cities. 127 Table 5 -6 Regional Analysis of Fair Housing Impediments Number of Apartment Complexes Publishing For Rent Ads by Jurisdiction and Unincorporated Area ( Apartment.com) — January 2010 Entitlement Cities Number of Complexes Anaheim 43 Buena Park 8 Fountain Valley 6 Fullerton 13 Garden Grove 9 Huntington Beach 14 Irvine 10 Lake Forest 8 La Habra 10 Newport Beach 6 Orange 9 Rancho Santa Margarita 8 Santa Ana 14 Tustin 13 Westminster 6 Urban County Cities /Area Aliso Viejo 11 Brea 6 Cypress 4 Dana Point/Ca istrano Beach 2 Foothill Ranch 2 una Beach 1 -Lag Hills 4 -Laguna Los Alamitos N/A La Palma 2 Ladera Ranch 3 Woods N/A -Laguna Midway City' 0 Placentia 4 Seal Beach 1 Stanton 1 Trabuco Canyon' N/A Villa Park N/A Yorba Linda 3 'Unincorporated area Source: Apartment.com website search conducted on January 4, 2010 Note: 0 denotes no listings available from Apartments.com. N/A denotes no information available from Apartments.com Table construction by Castaheda & Associates 122 The overwhelming number of ads in the Entitlement Cities conveyed information that was limited to the location of the apartment, number of bedrooms and bathrooms, and monthly rent. Very few ads — about 8% - contained language that did not pertain to the physical description of the property. The most frequent words or phrases included: "Section 8 Vouchers Accepted" • "No pets allowed" In the Urban County Cities, only three ads had questionable language. Two ads stated income restrictions and one noted its proximity to "places of worship ". Table 5 -7 provides an analysis of the print ads with respect to the city in which the apartment complex is located; number of ads placed; ads with non - property related words and phrases; and the number of ads published with those words and phrases. There was a total of 427 unique print ads published in The Orange County Register in the four January Sunday editions for apartments (223) and homes for rent (204) in Entitlement Cities. (January 3, January 10, January 17 and January 24, 2010) The number of unique print ads corresponds to the number of apartment complexes or homes publishing an ad. Forty seven of the 223 apartment ads contained non - property related words or phrases. The overwhelming majority of the non - property related words or phrases was "No Pets" which occurred in 38 (17 %) of the 223 apartment ads. There were also references to rental assistance such as "Section 8 ok" and "HUD ok ". Some ads were published multiple times during the four week period. Twenty -eight of the 204 homes for rent ads contained non - property related words or phrases. Once again, the "no pets' was the most frequent non - property related word or phrase, having occurred in 26 (12.7 %) of the 204 ads. Table 5 -8 shows the same analysis for the Urban County Cities. There were 62 unique ads for apartments and homes for rent. Ten ads had words and phrases that did not pertain to the physical description of the property: seven stated "no pets' two were "Section 8" related and one ad stated "Senior Citizen ". 3. Examples of Possible Advertising Impediments a. Source of Income Source of income is a protected class under California's fair housing law, effective January 1, 2000. Thus, it is unlawful to print or publish an advertisement that prefers, limits or discriminates on the basis of the source of the tenant's income. However, according to the California Newspaper Publishers Association, an ad referring to a government program in which an agency makes payments directly to landlords, e.g. the federal government's Section 8 housing program, would probably not be unlawful so long as the tenant's benefit or "income" is not paid directly to the "tenant or the tenant's representative ". Thus, unless an ad taker knows the term is being used as a code word for unlawful discrimination, an ad that says "Section 8 ok ", or "No Section 8" would probably not expose the newspaper to liability under the law's definition. 129 Table 5 -7 Analysis of Rental Ads in Entitlement Cities Orange County Register January 2010 Table construction by Castaneda & Associates ISO Apartment Ads Homes /Condos/Town Home Ads City Total # of Ads Ads With Non - Property Related Words /Phrases # of Ads Total # of Ads Ads With Non - Property Related Words /Phrases # of Ads Anaheim 38 No Pets /Sect. 8 ok 1 25 No Pets 3 No Pets 4 HUD OK 1 Section 8 Housing Accepted 1 Section 8 welcome 1 HUD ok 1 Total Ads 8 4 Buena Park 10 Sec. 8 welcome /Income Qualification Apply 1 3 Section 8 ok 1 No Pets 1 Total Ads 2 1 Fountain Valley 2 No Pets 2 8 No Pets 1 Total Ads 2 1 Fullerton 23 Section 8 Housing ok/No Pets 1 11 None N/A No Dos 1 No Pets 2 Total Ads 4 0 Garden Grove 24 No Pets 1 8 No Pet 3 Section 8 welcome 1 Total Ads 2 3 Huntington Beach 64 No Do 3 60 No Pets 10 No Pets 13 Total Ads 16 10 Irvine 2 None N/A 24 No Pets 4 Total Ads 0 4 La Habra 3 No Pets 1 3 None N/A Sect. 8 ok 1 Total Ads 2 0 Lake Forest 0 N/A N/A 4 No Pets 1 Total Ads 0 1 Newport Beach 12 HUD OK 1 17 No Pets 1 No Pets 1 Total Ads 2 1 Orange 27 No Pets 3 23 No Pets 2 Good Residents Wanted /No Pets 1 Total Ads 4 2 Rancho St. Margarita 2 None NIA 0 N/A N/A Total Ads 0 0 Santa Ana 8 Near Church /School 1 7 None N/A No Pets 1 Total Ads 2 0 Westminster 8 No Pets 2 11 No Pets 1 HUD OK 1 Total Ads 3 1 ALL ADS 223 47 204 28 Table construction by Castaneda & Associates ISO Table 5 -8 Analysis of Rental Ads in Urban County Cities Orange County Register January 2010 Source: Print ads in the four Sunday editions of the Orange County Register on January 3, January 10, January 17 and January 24, 2010 Table construction by Castaneda & Associates 'The ad appeared twice, once without the No Pets comment 2The ad appears four times, once with the No Dogs comment 2S2 Apartment Ads Homes /Condos/Town Home Ads Total # of Ads Ads With Non Property Related Language # of Ads Total # of Ads Ads With Non Property Related Language # of Ads Aliso Viejo 0 N/A N/A 4 None N/A Total Ads 0 0 Brea 3 No Pet 1 7 No Pets 2 Total Ads 1 2 C press 1 None N/A 3 None N/A Total Ads 0 0 Dana Point 1 Section 8 welcome 1 4 None N/A Total Ads 1 0 Foothill Ranch D N/A N/A 1 None N/A Total Ads 0 0 Laguna Beach 0 N/A N/A 1 None N/A Total Ads 0 0 Laguna Hills 0 N/A N/A 4 No Pets 1 Total Ads 0 1 Laguna Woods 0 N-/A N/A 4 No Pets 1 Total Ads 0 1 La Palma 0 N/A N/A 2 None N/A Total Ads 0 0 Los Alamitos 0 N/A N/A 0 N/A N/A Total Ads 0 0 Midway City 17N-one N/A 2 None N/A Total Ads 0 0 Placentia 6 Section 8 ok 1 4 No Dogs 1 Total Ads 1 1 Seal Beach 0 N/A N/A 0 N/A N/A Total Ads 0 0 Stanton 1 None N/A 2 None N/A Total Ads 0 0 Villa Park 0 N/A N/A 1 None N/A Total Ads 0 0 Yorba Linda 6 SR. CITIZEN 1 4 None N/A No Pets 1 Total Ads 2 0 ALL ADS 19 5 43 5 Source: Print ads in the four Sunday editions of the Orange County Register on January 3, January 10, January 17 and January 24, 2010 Table construction by Castaneda & Associates 'The ad appeared twice, once without the No Pets comment 2The ad appears four times, once with the No Dogs comment 2S2 The rental housing market is accepting tenants that receive Section 8 rental assistance. Most of the ads contained phrases such as "Section 8 OK "; "HUD OK "; "Section 8 Welcome "; and "Section 8 Accepted ". When the rental housing market vacancy rates become significantly lower, landlords may not have an incentive to attract tenants receiving Section 8 assistance. Under these conditions, "No Section 8" ads may become an impediment to fair housing choice because, in part, it could make such housing unavailable disproportionately to a protected class such as persons with disabilities. However, an ad stating "No Section 8" would not be illegal because under the California Fair Employment and Housing Act, "source of income" refers to income paid directly to a tenant or tenant's representative. A landlord that receives a Section 8 rental payment on behalf of a tenant from a housing authority is not considered a representative of the tenant. b. No Pets Persons with a disability are one of the classes protected from discrimination in housing. Apartments must allow, under certain conditions, "service animals' and "companion animals ". A service animal is one trained to do work or perform tasks for the benefit of a person with a disability. A service animal can be of varying species, breed or size. It might wear specialized equipment such as a backpack, harness, special collar or leash, but this is not a legal requirement. Companion animals, also referred to as assistive or therapeutic animals, can assist individuals with disabilities in their daily living and as with service animals, help disabled persons overcome the limitations of their disabilities and the barriers in their environment. They are typically for individuals with mental disabilities and can assist the person with depression, anxiety or provide emotional support. Under Federal and State fair housing laws, individuals with disabilities may ask their housing provider to make reasonable accommodations in the "no pets" policy to allow for their use of a companion /service animal. The housing provider may ask the disabled applicant/tenant to provide verification of the need for the animal from a qualified professional. Once that need is verified, the housing provider must generally allow the accommodation. Some disabled persons are unaware of their fair housing rights and, as a consequence, may not consider as available to them apartments with ads that state "no pets." Therefore, an action to affirmatively further fair housing is to persuade the Los Angeles Times, Orange County Register and Apartments.com to publish a concise "no pets" notice that indicates rental housing owners must provide reasonable accommodations, including "service animals' and "companion animals" for disabled persons. c. Acme Federal regulations specify that unless the housing being offered meets government requirements for "senior" or "senior only" housing, advertisers may not express a preference or limitation on the basis of age. A few ads contained phrases indicating a preference for seniors. One ad stated "senior citizen ". It appears that this ad was placed by an individual owner of a condominium. However, it is not known if the condominium complex met the requirements of a senior only complex. Two apartment complexes placed ads stating that a 5% discount was given to seniors. The complexes are located in Orange and Westminster and are managed by the same company. I32 4. Fair Housing Notices The Los Angeles Times and Apartments.com publish fair housing notices. The Los Angeles Times notice is published on the same page as the rental ads and states that it is illegal to indicate any preference, limitation or discrimination because a person belongs to one of the protected classes. It also refers readers to the Housing Rights Center and the Fair Housing Council of Orange County. Apartments.com states in its disclaimer that it and all home sellers and landlords must adhere to fair housing laws such as the Civil Rights Act of 1964, the American with Disabilities Act, and the Equal Credit Opportunity Act. It also states that those seeking to rent an apartment "have the right to expect... reasonable accommodation in rules, policies and procedures for persons with disabilities." However, the fair housing notice is difficult to find on the website and persons placing an ad are not required to read the notice before an ad is placed. In a review of the rental ads in both print and online editions of The Orange County Register, a fair housing disclaimer was not located. Typically, such a disclaimer is located at the beginning of the real estate classified ads section. S. Internet Advertising The National Fair Housing Alliance (NFHA) completed a study in 2009 of discriminatory ads placed by housing providers on various websites. The most common Fair Housing Act violation that NFHA and its members found on the Internet was advertising discriminating against families with children. NFHA found ads stating preferences for tenants who were "single' or "a couple of individuals." Phrases such as "perfect for young couple" or "three adults" were found in ads for houses or apartments with multiple bedrooms. These ads indicate an illegal preference or limitation and discourage families with children from even considering contacting a landlord. The investigation also found discriminatory ads stating preferences based on national origin, religion and sex. In California, the following are examples of ads that were placed on websites: • .quiet complex of responsibles without kids" • "no kids" • "no pets, no children According to the NFHA study, Craigslist, the source of the overwhelming majority of housing advertising in today's market, and other Internet sites provide a convenient forum for illegal housing discrimination. Under current court decisions, these websites are not considered to be publishers and thus can neither be held liable under the Fair Housing Act nor be required to screen out illegal housing advertisements. Only the individual landlords who create and post discriminatory ads online can be held responsible. The Communications Decency Act (CDA) is Title V of the Telecommunications Act of 1996 and was intended to protect families from online pornography and other forms of indecency. It states that operators of Internet services are not to be construed as publishers, and thus are not legally liable for the words of third parties who use their services. The CDA makes exceptions to i33 this rule as it relates to federal criminal statutes and intellectual property law, but does not make explicit exceptions for civil rights laws like the Fair Housing Act. Private fair housing organizations, according to the NFHA study, have brought two lawsuits against online housing advertisers for publishing discriminatory housing advertisements. In each instance, the Court accepted the website's argument that the CDA protected it from liability under the Fair Housing Act to the extent that users provided content. In reaching these decisions, the Courts relied upon Section 230(c) of the CDA to find that operators of interactive websites are not to be construed as "publishers' of the words posted by users of their websites. This section, entitled Protection for 'Good Samaritan' Blocking and Screening of Offensive Material, "aim[s] to protect interactive computer service providers 'who take (steps to screen indecent) and offensive material for their customers. "' Ironically, in refusing to take responsibility for discriminatory advertisements, these websites have screened nothing, opting instead to facilitate widespread distribution of discriminatory ads. The NFHA states that the most effective way to stop discrimination in online housing ads is to hold all housing advertisers and publishers to the same standard. In order to hold accountable websites advertising housing, just as newspapers are currently held accountable, the Communications Decency Act of 1996 must be amended. Specifically, Section 230(c)(1) is the section of the CDA that provides immunity to websites for third party content. 47 U.S.C. § 230(c)(1) currently reads: "TREATMENT OF PUBLISHER OR SPEAKER- 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." The NFHA recommends that this section of the CDA should be amended to accommodate the requirements of the Fair Housing Act. An exemption could be made specifically for Fair Housing Act claims and amend 47 U.S.C. § 230(c)(1) as follows: "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, 42 U.S.C. § 3601 et seq." If the CDA is amended, websites will be responsible for the discriminatory advertisements they publish on the Internet and, therefore, will have an incentive to implement filtering systems to prevent discriminatory advertisements from ever reaching the public. 9=r 6. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: • 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. • 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. • 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, 42 U.S.C. § 3601 at seq. • Periodically review for rent and for sale ads published in the print media. • Prepare a summary of the accomplishments each year and transmit to the Entitlement Cities and Urban County in August of each year. This schedule allows the Entitlement Cities and Urban County to include a summary of the accomplishments in the Consolidated Plan Annual Performance and Evaluation Report. That Report is published in September of each year. C. BLOCKBUSTING 1. Background Section 804(e) of the 1968 Fair Housing Act makes the following act, commonly referred to as blockbusting, unlawful: For profit, to induce or attempt to induce any person to sell or rent any dwelling by representations regarding the entry or prospective entry into the neighborhood of a person or persons of a particular race, color, religion, sex, handicap, familial status, or national origin. Blockbusting and panic selling can occur when an individual, possibly a real estate licensee, claims that an impending change in the demographic composition of a neighborhood will cause property values to fall, crime to increase or schools to decline in quality. Section 10177(1)(1) of the Business and Professions Code states that the Real Estate Commissioner may revoke or suspend the license of a real estate licensee if he /she has done the following: i35 Solicited or induced the sale, lease, or listing for sale or lease of residential property on the ground, wholly or in part, of loss of value, increase in crime, or decline of the quality of the schools due to the present or prospective entry into the neighborhood of a person or persons having a characteristic listed in subdivision (a) or (d) of Section 12955 of the Government Code, as those characteristics are defined in Sections 12926 and 12926.1, subdivision (m) and paragraph (1) of subdivision (p) of Section 12955, and Section 12955.2 of the Government Code. Government Code Section 12955 states it shall be unlawful: (a) For the owner of any housing accommodation to discriminate against or harass any person because of the race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or disability of that person. (d) For any person subject to the provisions of Section 51 of the Civil Code, as that Section applies to housing accommodations, to discriminate against any person on the basis of sex, sexual orientation, color, race, religion, ancestry, national origin, familial status, marital status, disability, source of income, or on any other basis prohibited by that section. With respect to blockbusting, the California law has more protected classes than the Federal Fair Housing Act. There is no local or county agency that maintains records on actual or potential blockbusting incidents. Such incidents would take place primarily as real estate agents attempt to solicit or induce homeowners to sell their homes. As previously noted, the California Real Estate Commissioner is authorized to take disciplinary action against licensees who have committed the prohibited discriminatory practice of blockbusting and panic selling. The Department of Real Estate stated in June 2010 that no Orange County licensee has had their license suspended or revoked because of the illegal practice of blockbusting. 2. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: • Provide information on the FHCOC website on the unlawful practice of blockbusting including examples of this illegal practice. • Work with the California Department of Real Estate to determine if any Orange County licensees have had their licenses suspended or revoked because of the illegal practice of blockbusting. • In the event, a licensee has been found to have committed blockbusting, provide education and information on this practice to the responsible broker and all related salespersons. ISO D. DENIAL OF REASONABLE MODIFICATION /ACCOMMODATION 1. Background It is unlawful to refuse to make reasonable accommodations for disabled persons. Section 804 (3) of the 1968 Fair Housing Act states that discrimination includes -- (A) a refusal to permit, at the expense of the handicapped person, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises, except that, in the case of a rental, the landlord may where it is reasonable to do so condition permission for a modification on the renter agreeing to restore the interior of the premises to the condition that existed before the modification, reasonable wear and tear excepted. (B) a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling. The DFEH compiles data on the number of housing discrimination cases according to nine types of alleged acts. During the 2005 -2009 period, 461 alleged discriminatory acts were committed in the cases processed by the DFEH. Of this total, 87 or 18.9% involved denial of a reasonable modification /reasonable accommodation. About 17 -18 denials of reasonable modification /reasonable accommodation occurred per year during the five -year period. 2. Actions to be Taken During the five -year period of the Fair Housing Action Plan, the FHCOC will take the following actions: • Provide education and information on why this practice is unlawful to the owners and managers of apartment complexes and homeowner associations. • Provide information on the unlawful practice of denying reasonable modifications /reasonable accommodations at fair housing seminars conducted by the Apartment Association of Orange County. E. HATE CRIMES 1. Background Hate crime means — ,.a criminal act committed, in whole or in part, because of one or more of the following actual or perceived characteristics of the victim: (1) disability, (2) gender, (3) nationality, (4) race or ethnicity, (5) religion, (6) sexual orientation, (7) association with a person or group with one or more of these actual or perceived characteristics." [Source: California Penal Code section 422.55] 137 According to the California Department of Justice (DOJ), hate crimes are not separate distinct crimes but rather traditional offenses motivated by the offender's bias. A bias is — A preformed negative opinion or attitude toward a group of persons based on their race, ethnicity, national origin, religion, gender, sexual orientation and /or physical /mental disability. Police and Sheriff Department's report to the DOJ hate crime events which are - An occurrence where a hate crime is involved. In the DOJ report, the information about the event is a crime report or source document that meets the criteria for a hate crime. There may be one or more suspects involved, one or more victims targeted, and one or more offenses involved for each event. A hate crime victim — May be an individual, a business or financial institution, a religious organization, government, or other. For example, if a church or synagogue is vandalized and /or desecrated, the victim would be a religious organization. According to HUD, Regional Als should analyze housing related hate crimes; that is; where an event takes place at a residence, home or driveway. When hate crimes occur at a home, the victims can feel unwelcome and threatened. The victims may feel that they have no choice other than to move from the dwelling and neighborhood of their choice. It is under these circumstances that hate crimes create a lack of fair housing choice. 2. Hate Crime Events Hate crime events were reviewed for the 5 -year period from 2004 to 2008 as reported by Criminal Justice Statistics Center of the California Department of Justice. Table 5 -9 shows the number of hate crime events by city during the five -year period. The annual average of events was 73 and, during the five -years there was a narrow low (69) to high (79) range. Except for the City of Huntington Beach, on a city -by -city basis, the number of hate crime events is low. In 2008, according to the Orange County Human Rights Commission (OCHRC), there were 79 cases of hate crimes in Orange County, essentially unchanged from the 80 cases in 2007. Despite the fact that the African American population makes up less than 2% of Orange County's population, this group continues to be the most frequent target for hate crimes. Hate crimes against Latinos continues to increase. In fact, since 2006 there has been almost a 100% increase in the number of cases reported. After a four -year downward trend, hate crimes against Jews increased. Additionally, while there was a slight decrease in hate crimes reported against Gays and Lesbian, this group frequently underreports. Table 5 -10 shows the number of hate crime events by bias motivation for the period from 2004 to 2008. Almost two - thirds of all hate crime events in California had race /ethnicity /national origin as the bias motivation. Just over one -third of all hate crime events in the State have a anti -Black bias motivation. Sexual orientation and anti - religion were the bias motivation of 18.9% and 16 %, respectively, of all hate crime events in California. 138 Table 5 -9 Regional Analysis of Fair Housing Impediments Number of Hate Crime Events by Jurisdiction /City -2004 to 2008 City/Jurisdiction 2004 2005 2006 2007 2008 Average Percent Sheriffs Department 9 2 0 5 6 4.4 6.0% Aliso Viejo 0 1 1 1 0 0.6 0.8% Anaheim 6 3 6 4 3 4.4 6.0% Brea 0 3 3 1 1 1.6 2.2% Buena Park 0 1 0 1 1 0.6 0.8% Costa Mesa 1 0 3 0 2 1.2 1.6% Cypress 1 1 0 2 2 1.2 1.6% Dana Point 0 0 0 1 0 0.2 0.3% Fountain Valley 3 0 8 2 1 2.8 3.8% Fullerton 2 2 4 2 1 2.2 3.0% Garden Grove 6 6 9 9 4 6.8 9.3% Huntington Beach 11 27 11 9 9 13.4 18.3% Irvine 3 2 5 2 9 4.2 5.7% La Habra 3 2 0 3 4 2.4 3.3% Laguna Beach 2 0 1 0 1 0.8 1.1% Laguna Hills 1 3 1 1 1 1.4 1.9% Laguna Niguel 0 0 1 0 0 0.2 0.3% Lake Forest 3 0 1 0 0 0.8 1.1% Los Alamitos 0 1 2 5 1 1.8 2.5% Mission Viejo 1 1 2 0 3 1.4 1.9% Newport Beach 4 5 2 7 7 5.0 6.8% Orange 0 2 5 4 3 2.8 3.8% Placentia 0 1 2 0 0 0.6 0.8% Rancho Santa Margarita 2 2 2 1 0 1.4 1.9% San Clemente 1 2 1 2 1 1.4 1.9% San Juan Capistrano 0 0 0 2 0 0.4 0.5% Santa Ana 2 4 3 0 1 2.0 2.7% Stanton 0 0 0 3 1 0.8 1.1% Tustin 0 0 0 1 4 1.0 1.4% Villa Park 1 1 0 0 0 0.4 0.5% Westminster 6 4 4 0 2 3.2 4.4% Yorba Linda 3 2 0 1 0 1.2 1.6% CSU Fullerton 0 0 1 1 1 0.6 0.8% UC Irvine 0 1 0 0 0 0.2 0.3% Total 71 79 78 70 69 73 100.0% Source: California Department of Justice, Division of California Justice Information Services, Bureau of Criminal Information and Analysis, Criminal Justice Statistics Center "Hate Crimes in California, 2004, 2005, 2006, 2007 and 2008" Table construction by Castaneda & Associates 139 Table 5 -10 State of California Hate Crimes Events and Bias Motivation Bias Motivation 2004 2005 2006 2007 2008 Average Percent Total 1,409 1,397 1,306 1,426 1,397 1,387 100.0% Race/Ethnicity/National Origin 921 916 844 932 800 883 63.7% Anti -White 61 77 64 73 42 63 4.5% Anti -Black 500 490 462 498 457 481 34.6% Anti - Hispanic 138 147 153 160 147 149 10.7% Anti - American Indian /Alaska Native 3 2 4 1 1 2 0.1% Anti - Asian /Pacific Islander 69 50 52 53 37 52 3.7% Anti-Multiple Race Groups 45 61 45 51 47 50 3.6% Anti -Other Ethnicity/National Origin 105 89 94 96 69 91 6.5% Religion 205 205 205 203 294 222 16.0% Anti - Jewish 142 141 129 134 184 146 10.5% Anti - Catholic 9 10 11 10 12 10 0.7% Anti - Protestant 3 10 13 11 8 9 0.6% Anti - Islamic Muslim 29 12 14 13 11 16 1.2% Anti -Other Religion 19 25 23 24 63 31 2.2% Anti-Multiple Religious, Group 3 6 14 9 15 9 0.7% Anti-Atheism/Agnosticism/etc. 0 1 1 2 1 1 0.1% Sexual Orientation 263 255 246 263 283 262 18.9% Anti-Gay 188 161 163 132 154 160 11.5% Anti - Lesbian 37 40 23 26 22 30 2.1% Anti-Gay and Lesbian 36 49 57 101 102 69 5.0% Anti - Heterosexual 1 1 0 2 3 1 0.1% Anti - Bisexual 1 4 3 2 2 2 0.2% Physical/Mental Disability 4 3 3 3 4 3 0.2% Anti-Physical Disability 2 3 1 2 2 2 0.1% Anti - Mental Disability 2 1 0 21 1 1 2 1 1 0.1% Gender 16 18 8 25 16 17 1.2% Anti -Male 1 1 0 0 0 0 0.0% Anti - Female 0 4 0 2 3 2 0.2% Anti -Trans ender 15 13 8 23 13 14 1.0% Source: California Department of Justice, Division of California Justice Information Services, Bureau of Criminal Information and Analysis, Criminal Justice Statistics Center "Hate Crimes in California, 2007 and 2008" Table construction by Castaneda & Associates 140 Table 5 -11 shows the hate crime bias motivation in 2007 and 2008, according to the Orange County Human Relations Commission. Table 5 -11 Hate Crimes in Orange County 2007 and 2008 Basis of Bias 2007 Percent 2008 Percent African American 18 22.4% 23 29.5% Latino 12 15.0% 15 19.5% Gay/Lesbian 14 17.4% 11 13.9% Jewish 7 8.8% 10 12.7% Muslim /Middle Eastern 4 5.0% 4 5.1% Christian 1 71 8.8% 1 1 1 1.3% Asian 2 2.5% 2 2.5% White 3 3.8% 0 0.0% Multiple 13 16.3%1 13 16.5% Total 80 100.0% 1 79 100.0% Source: Orange County Human Relations Commission, 2008 Orange County Hate Crime Report Table construction by Castaneda & Associates According to the OCHRC, there was an increase in crimes occurring at residential locations, the majority of which involved vandalism. One -third of the hate crimes reported in 2007 were at a residential location. That number increased to 40% in 2008. There was a significant increase in the number of hate crimes taking place on school campuses. Again the majority of these were acts of vandalism. More than one half of all hate crimes reported in both 2007 and 2008 involved acts of destruction or vandalism. The vandalism most frequently involved graffiti. The California DOJ reports the location of hate crime events for the entire state by 25 categories (e.g., church, park, college, etc). Table 5 -12 indicates the location of hate crimes for the period from 2004 to 2008. During the past five years two locations are predominant, accounting for about 60% of all hate crime locations: Highway /Road /Alley /Street (29.1 %) and Residence /Home /Driveway (29.7 %). The application of the statewide housing location average of 29.7% to the annual Orange County average of hate crime events of 73 yields at estimate of 22 annual events occurring at a residence, home or driveway. The application of the 40% factor cited by the OCHRC yields an estimate of 29 events occurring at a housing location. On an individual city basis, the number of hate crime events occurring at a housing location is small. However, the number at the countywide level is significant and, as a result, the resources to monitor and alleviate this impediment are best handled at the regional level. The agencies best equipped to assist cities to ameliorate and reduce the impact of hate crimes on families already living in their neighborhood of choice include: • Fair Housing Council of Orange County • Orange County Human Relations Commission • Center OC • Orange County Victim Assistance Partnership 141 Table 5 -12 State of California Location of Hate Crimes- 2004 to 2008 Location 2004 2005 2006 2007 2008 Average Percent Total 1,770 1,691 1,702 1931 1,397 1,698 100.0% Air /Bus/Train Terminal 31 17 6 16 14 17 1.0% Bank/Savings and Loan 3 4 2 3 2 3 0.2% Bar/Night Club 27 24 21 41 25 28 1.6% Church /Synagogue /Temple 74 84 84 72 107 84 5.0% Commercial /Office Building 48 38 30 38 32 37 2.2% Construction Site 3 1 3 3 2 2 0.1% Convenience Store 27 27 12 7 9 16 1.0% Department/Discount Store 10 9 4 10 7 8 0.5% Drug Store /Dr.'s Office/Hospital 11 6 5 5 5 6 0.4% FieldNVoods /Park 31 38 38 83 41 46 2.7 % Government/Public Building 10 17 25 29 29 22 1.3% Grocery/Supermarket 11 14 11 18 8 12 0.7% Highway/Road/Alley/Street 536 456 545 569 363 494 29.1% Hotel /Motel /etc 13 8 9 10 7 9 0.6% Jail /Prison 18 14 10 33 17 18 1.1% Lake/Waterway/Beach— 12 15 9 11 4 10 0.6% Liquor Store 4 7 5 11 1 6 0.3% Parkin Lot/Garage 86 138 135 117 110 117 6.9% Rental Storage Facility 3 0 0 0 0 1 0.0% Residence/Home/Driveway 551 511 504 571 388 505 29.7% Restaurant 49 48 40 48 42 45 2.7% School/College 155 176 152 182 148 163 9.6% Service /Gas Station 11 11 7 13 13 11 0.6% Special Store TV, Furn, etc. 38 19 12 13 4 17 1.0% Other /Unknown 8 9 33 28 19 19 1.1% Source: California Department of Justice, Division of California Justice Information Services, Bureau of Criminal Information and Analysis, Criminal Justice Statistics Center "Hate Crimes in California, 2007 and 2008" Table construction by Castaneda & Associates 3. Actions to be Taken During the five -year of the Fair Housing Action Plan, the FHCOC will take the following actions: • Coordinate with the Orange County Human Relations Commission, Center OC and the Orange County Victim Assistance Partnership. • Provide affected residents — when needed - with referrals to hate crime victim resources. (Attachment B provides definitions of key hate crime terms such as bias, event, physical and mental disability bias, and victim.) 142 F. UNFAIR LENDING 1. Fair Housing Act, Equal Credit Opportunity Act and the California Holden Act In cases involving discrimination in mortgage loans or home improvement loans, the United States Department of Justice may file suit under both the Fair Housing Act and the Equal Credit Opportunity Act. Section 805 of the Fair Housing Act (42 U.S.C. 3605) states that it is "unlawful for any person or other entity whose business includes ... the making or purchasing of loans or providing other financial assistance for purchasing, constructing, improving, repairing, or maintaining a dwelling... to discriminate against any person... because of race, color, religion, sex, handicap, familial status, or national origin." The Equal Credit Opportunity Act (ECOA) 15 U.S.C. 1691 et seq. prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age, because an applicant receives income from a public assistance program, or because an applicant has in good faith exercised any right under the Consumer Credit Protection Act. To supplement federal legislation, state laws have been enacted to forbid the discriminatory practice known as `redlining," a practice that results in blanket refusals by some lenders to make loans in whole neighborhoods or geographic areas. Redlining is illegal in California pursuant to the Housing Financial Discrimination Act of 1977 (Holden Act). (Health & Safety Code Section 35800 - 35833) The Holden Act prohibits the consideration of race, color, religion, sex, marital status, national origin, or ancestry in lending for the purchase, construction, improvement, or rehabilitation of housing. Further, lenders cannot deny loan applications because of ethnic composition, conditions, characteristics, or expected trends in the neighborhood or geographic area surrounding the property. The Holden Act places restrictions on redlining by making it illegal for lenders to consider the racial, ethnic, religious, or national origin composition of a neighborhood or geographic area surrounding a housing accommodation. To ensure that prospective borrowers are aware of their rights under this law, lenders must notify all applicants of the provisions of the Holden Act at the time of the loan application. The notice must include the address where complaints may be filed and where information may be obtained. The notice must be in at least 10 -point type and also must be posted in a conspicuous location in the lender's place of business. A notice would state the following: IT IS ILLEGAL TO DISCRIMINATE IN THE PROVISION OF OR IN THE AVAILABILITY OF FINANCIAL ASSISTANCE BECAUSE OF THE CONSIDERATION OF: 1. TRENDS, CHARACTERISTICS OR CONDITIONS IN THE NEIGHBORHOOD OR GEOGRAPHIC AREA SURROUNDING A HOUSING ACCOMMODATION UNLESS THE FINANCIAL INSTITUTION CAN DEMONSTRATE IN THE PARTICULAR CASE THAT SUCH CONSIDERATION IS REQUIRED TO AVOID UNSAFE AND UNSOUND BUSINESS: OR 143 2. RACE, COLOR, RELIGION, SEX, MARITAL STATUS, NATIONAL ORIGIN OR ANCESTRY IT IS ILLEGAL TO CONSIDER THE RACIAL, ETHNIC, RELIGIOUS, OR NATIONAL ORIGIN COMPOSITION OF A NEIGHBORHOOD OR GEOGRPAHIC AREA SURROUNDING A HOUSING ACCOMMODATION OR WHETHER OR NOT SUCH COMPOSITION IS UNDERGOING CHANGE, OR IS EXPECTED TO UNDERGO CHANGE, IN APPRAISING A HOUSING ACCOMMODATION OR IN DETERMINING WHETHER OR NOT, OR UNDER WHAT TERMS AND CONDITIONS, TO PROVIDE FINANCIAL ASSISTANCE. THESE PROVISIONS GOVERN FINANCIAL ASSISTANCE FOR THE PURPOSE OF THE PURCHASE, CONSTRUCTION, REHABILITATION, OR REFINANCING OF ONE - TO- FOUR -UNIT RESIDENCE. 2. Underwriting, Marketing and Pricing Discrimination Unfair lending refers to underwriting, marketing, and pricing discrimination. Underwriting discrimination refers to the process of evaluating home purchase loan applicants and is measured by the outcome of that process — i.e., the approval /denial decision. Marketing discrimination is more commonly known as redlining where a lender is alleged to provide unequal access to credit because of the income, race or ethnicity of the residents in the area where the property is located. Pricing discrimination means that loans are approved but with higher fees and interest rates. The Regional Al examines underwriting and marketing discrimination through the use of 2008 Home Mortgage Disclosure Act (HMDA) data. HMDA grew out of public concern over credit shortages in certain urban neighborhoods. Congress believed that some financial institutions had contributed to the decline of some geographic areas by their failure to provide adequate home financing to qualified applicants on reasonable terms and conditions. Thus, one purpose of HMDA is to provide the public with information that will help show whether financial institutions are serving the housing credit needs of the neighborhoods and communities in which they are located. The 1989 amendments to HMDA require the collection and disclosure of data about applicant and borrower characteristics to assist in identifying possible discriminatory lending patterns and enforcing antidiscrimination statutes. Underwriting discrimination refers principally to loan denials because of the non - economic characteristics of the applicant (i.e., gender and race /ethnicity). HMDA requires lenders to report on the income of home purchase loan applicants. Income means the gross income used by the lenders to make a loan decision. Lenders also must report the race of the borrower according to five categories: American Indian /Alaskan Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, and White. Two ethnic categories must be noted: Hispanic or Latino and Not Hispanic or Latino. Marketing discrimination refers to loan denials because of the characteristics of the area in which the property is located. The following property location information is reported by lenders: Metropolitan Statistical Area, State, County and 2000 census tract. Lenders only report the location of the property and not, for example, the housing and population characteristics of the census tract in which the property is located. 1K' =9 Notably, sometimes both forms of discrimination - underwriting and marketing - are linked because a borrower's loan application could be denied because of both their characteristics and those of the neighborhood. 3. Home Mortgage Disclosure Act HMDA requires lenders to report on the action taken on each loan application, as follows: • Loan Originated • Application Approved, Not Accepted • Application Denied • Application Withdrawn • Filed Closed for Incompleteness Many determinants of a loan decision — such as borrower credit history, debt -to- income -ratio and loan -to -value ratio - are not included in the HMDA data. Although the loan denial rates do not support definitive conclusions regarding discrimination on the bases of race or ethnicity, they are a useful screen to identify disparities in loan approval rates by the race and ethnicity of applicants and geographic markets where differences in denial rates warrant further investigation. Additionally, identifying census tracts /neighborhoods with high loan denial rates helps to target credit counseling and homebuyer education programs. Underwriting discrimination is examined in the Regional Al by the loan denial rates experienced by home purchase loan applicants in Orange County and its cities. Marketing discrimination is examined by reviewing the denial rates at the census tract level and determining whether there is a correlation between high census tract denial rates and minority populations residing in those census tracts. It should be reiterated that HMDA data alone cannot be used to prove unlawful discrimination. 4. Analysis of 2008 HMDA Data Three Technical Appendices contain the detailed HMDA data: • Technical Appendix D — 2008 Home Mortgage Disclosure Act Data for Orange County • Technical Appendix E — Loan Denial Rates for Census Tracts with a High Number of Loan Applications • Technical Appendix F — FHA and Conventional Loan Denial Rates by City and Census Tract a. Sources for the Analysis of the HMDA Data The key sources for the analysis of the HMDA data include: • Robert B. Avery, et.al., The 2008 HMDA Data: The Mortgage Market during a Turbulent Year, Federal Reserve Bulletin, October 2009 • Federal Reserve Board, Frequently Asked Questions About the New HMDA Data, April 3, 2006, 9 pages -1 4.5 Paul Huck, Federal Reserve Bank of Chicago, Home Mortgage Lending by Applicant Race: Do HMDA Data Figures Provide a Distorted Picture, Housing Policy Debate, 2001, Volume 12, Issue 4, pages 719 -736 Mortgage Bankers Association, Fair Lending and Home Mortgage Disclosure Act Guide, Handbook 2008 -1, 35 pages The Urban Institute, Kathryn L.S. Pettit and Audrey E. Droesch, A Guide to Home Mortgage Disclosure Act Data, December 2008, 35 pages b. Loan Denial Rates by Race /Ethnicit Data on home purchase loan applications by the race /ethnicity of the applicant were calculated for the entire Orange County area. In order to determine the denial rate, only applications where a final determination was made were used. The loan denial rate is based on the number of loans denied as a percentage of loans originated + applications approved but not accepted + applications denied. Withdrawn or incomplete applications are not included in the denominator. Of the 4,540 FHA loan applications, 47.4% (2,153) were made by White, Non - Hispanic applicants and 27.3% (1,239) were made by Hispanic borrowers. The White, Non Hispanic and Hispanic denial rates were 15.4% and 27.4 %, respectively. Race was unavailable for 459 applicants. The balance of the 689 loan applications were made by borrowers belonging to seven racial groups. Black or African borrowers represented 2% of all FHA loan applicants. This racial group had a loan denial rate of 20.6 %. Detailed data are presented in Tables D -1 and D -2 in Technical Appendix D 2008 HMDA data are available for almost 29,400 conventional loan applications. The racial /ethnic composition of the applicants was 45.3% White Non - Hispanic, 24.1% Asian, and almost 13% Hispanic. Almost one -third of Hispanic borrowers were denied compared to 17.9% of the Asian and 18.8% of the White, Non- Hispanic loan applicants. Black or African borrowers represented 0.7% of all conventional loan applicants. This racial group had a loan denial rate of 27.6 %. Detailed data are presented in Table D -3 in Technical Appendix D. c. Loan Denials by Income and Race /Ethnicity 1. FHA Loan Applications: Table 5 -13 on the next page shows the four income categories reported in the HMDA data. The four income categories are expressed in terms of a percentage of the median income for Orange County. //10 Table 5 -13 HMDA Census Tract Income Categories — 2008 Census Tract Income Categories Percent of Median MSA Income Very Low <50% Low >50% - <80% Moderate >80% - <120% Above Moderate 120 %+ Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act Table construction by Castaneda & Associates Loan denial rates decrease as incomes increase. White, Non - Hispanic borrowers have lower loan denial rates than those experienced by other racial /ethnic groups. Table 5 -14 shows the disparities in loan denial rates by income and race /ethnicity. Almost one half (49 %) of the 4,540 FHA loan applications were made by above moderate income borrowers. Within this income group, the majority of applications were made by White, Non - Hispanic borrowers who had a denial rate of 14.8 %. Hispanic, Asian and Black/African American applicants all had loan denial rates of more than 20 %. About one -third of FHA applications were made by moderate income borrowers. Within this income group, White, Non - Hispanic and Hispanic borrowers had almost the same volume of loan applications. The Hispanic loan denial rate of 27.1% was considerably higher than the White Non - Hispanic denial rate of 13.6 %. The Asian loan denial rate was 17.6 %. The volume of loan applications by each of the other race /ethnicity groups was small. About one -sixth of all FHA loan applications were made by low income borrowers. Within this income group, White, Non - Hispanic and Hispanic borrowers had almost the same volume of loan applications. The Hispanic loan denial rate of 32.2% was considerably higher than the White Non - Hispanic denial rate of 16.7 %. The Asian loan denial rate was 33.3 %. However, the number of loan applications made by Asians and each of the other race /ethnicity groups was small. Very few (2.5 %) applications were made by very low income borrowers. Detailed data are presented in Table D-4 in Technical Appendix D. 147 Table 5 -14 Orange County Disparities in FHA Loan Denial Rates By Income Group and Race /Ethnicity - 2008 Income Group All' White Non - Hispanic Hispanic Asian Black /African American Very Low 33.9% 20.0% 32.8% NA NA Low 27.5% 16.7% 32.2% 33.3% 18.2% Moderate 20.2% 13.6% 27.1% 17.6% 25.9% Above Moderate 17.5% 14.8% 21.4% 22.5% 20.5% 'All includes these other groups: Joint Hispanic, American Indian /Alaska Native, Native Hawaiian /Other Pacific Islander, 2 or More Minority Races, Joint White /Minority, and Race Not Available Note: very few loans in the NA cells Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Table construction by Castaneda & Associates 2. Conventional Loan Applications: Conventional loan denial rates also decrease as incomes increase. However, Asian borrowers (with the exception of the very-low income category) have lower denial rates than White, Non - Hispanic borrowers. Hispanic borrowers have the highest loan denial rates experienced by the other racial /ethnic groups. In general, Black/African American borrowers had lower denial rates than Hispanic loan applicants. However, this population group comprised less than one percent of all loan applicants. Table 5 -15 shows the disparities in loan denial rates by income and race /ethnicity. Table 5 -15 Orange County Disparities in Conventional Loan Denial Rates By Income Group and Race /Ethnicity- 2008 Income Group All' White Non - Hispanic Hispanic Asian Black/African American Very Low 36.4% 24.8% 44.9% 33.0% NA Low 21.7% 18.5% 30.0% 14.9% 47.2% Moderate 20.4% 16.4% 32.9% 16.1% 19.4% Above Moderate 20.3% 19.1% 31.5% 18.7% 23.9% 'All includes these other groups: Joint Hispanic, American Indian /Alaska Native, Native Hawaiian /Other Pacific Islander, 2 or More Minority Races, Joint White /Minority, and Race Not Available Note: very few loans in the N/A cell Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Table construction by Castaneda & Associates 142 Almost 60% of the 29,000 conventional loan applications were made by above moderate income borrowers. Within this income group, about one -half of applications were made by White, Non - Hispanic borrowers who had a denial rate of 19.1 %. Within this income group, 21.4% of the conventional loan applications were made by Asian borrowers, who had a loan denial rate of 18.7 %. Hispanic borrowers experienced a loan dental rate of 31.5% and comprised 7.4% of all above moderate income loan applicants About one -fourth of conventional loan applications were made by moderate income borrowers. Within this income group, the largest numbers of applicants were White, Non - Hispanic (39 %); Asian (28 %); and Hispanic (18 %). The Hispanic loan denial rate of 32.9% was considerably higher than Asian denial rate of 16.1% and the White Non - Hispanic denial rate of 16.4 %. The volume of loan applications by each of the other race /ethnicity groups was small. About 13% of conventional loan applications were made by low income borrowers. Within this income group, the largest numbers of applicants were White, Non - Hispanic (34 %); Asian (28 %); and Hispanic (23 %). The Hispanic loan denial rate of 30% was considerably higher than Asian denial rate of 14.9% and the White Non - Hispanic denial rate of 18.5 %. The volume of loan applications by each of the other race /ethnicity groups was small. Very few (3 %) applications were made by very low income borrowers. Within this income group, the largest numbers of applications were made, in order, by White, Non - Hispanic, Hispanic and Asian borrowers. All racial /ethnic groups experience loan denial rates of more than 25 %. Detailed data are presented in Table D -5 in Technical Appendix D. d. Loan Denials by Census Tract Characteristics of Income and Minority Concentration HMDA data are available on the loan denials by two census tract characteristics - income categories and minority population concentration levels. The census tract characteristics are based on demographic information from Census 2000 and they are not based on the applicant characteristics. Minority means all races other than White and Whites of Hispanic or Latino Origin. Table 5 -13 shows census tract income categories. For FHA loans, the data reveal that very low income borrowers reside in census tracts where the minority population exceeds 80% of the population. In these very low income /high minority census tracts, 39% of the loan applications were denied. In low income neighborhoods, the loan denial rate increases as the minority population increases. In moderate and above moderate income neighborhoods, they do not always increase as the percentage of the minority population increases. Detailed FHA loan data are presented in Table D -6 in Technical Appendix D. For conventional loans, the data also reveal that very low income borrowers reside in census tracts where the minority population exceeds 80% of the population. In these neighborhoods, 36.2% of the loan applications were denied. In low income neighborhoods, the loan denial rates increase as the percentage of the minority population increases. For instance, in low income / <10% minority population neighborhoods, 2.6% of the loan applications are denied. In contrast, in low income / >80% minority population neighborhoods, 31.2% of the loan applications are denied. These numbers and percentages, though, need to be interpreted with caution 1-" because the number of applications for home purchases in <10% minority neighborhoods is very small. In moderate income neighborhoods, denial rates generally increase as the percentage of the minority population increases. For example, in moderate income / <10% minority population neighborhoods, 13.7% of the loan applications are denied. By comparison, in moderate income / >80% minority population neighborhoods, 24.7% of the loan applications are denied. These numbers and percentages again need to be interpreted with caution because the number of applications for home purchases in <10% and > 80% minority neighborhoods is very small. Detailed conventional loan data are presented in Table D -7 in Technical Appendix D. Perhaps, more representative of Orange County is the loan applications for homes located in census tracts where the minority population ranges from 20 % -79 %. In fact, 73% of the 29,400 conventional loan applications were made in these census tracts. Table 5 -16 shows that the denial rates in neighborhoods with 20 % -79% minority populations are about the same for low and moderate income neighborhoods and somewhat lower for above moderate income neighborhoods. Table 5 -16 Orange County Denial Rates for Neighborhoods with 20 % -79% Minority Populations by Income Level of Census Tracts - 2008 Census Tract Income Level Number of Applications Number Denied Percent Denied Low 4,911 1,080 22.0% Moderate 8,321 1,729 20.8% Above Moderate 8,133 1,432 17.6% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 7 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Characteristics of Census Tract in Which Property is Located, 2008. Table 7 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Characteristics of Census Tract in Which Property is Located, 2008 Table construction by Castaneda & Associates e. Reasons for Loan Denial Reasons for loan denial are summarized on a county -wide basis in Table D -8 in Technical Appendix D. There are eight "known" reasons for a loan denial and one "other' category. With respect to FHA loans, the most frequent reason for a loan denial was "debt -to- income ratio ". The percentage of loans denied for this reason ranged from 27.3% for Black or African American applicants to 57.1 % for Native Hawaiian /Other Pacific Islander applicants. It must be noted, however, that there were few applications for these two groups. White and Hispanic /Latino applicants were denied because of debt to income ratio at nearly the same percentages - 37.9% and 40.2% respectively. 150 The second most frequent known reason for denial of FHA loan applications was credit history. These denials ranged from a low of 7.1% for joint applicants to 22.7% for Black/African American applicants. Again there were few applications for these groups. Credit history was the reason for denial for 13.3% of White applicants and 16.0% of Hispanic applicants. Similar to FHA loans, conventional loans were most frequently denied due to "debt -to- income" ratio as the known reason. These denials ranged from 20.9% for Asian applicants to 40.0% for applicants of two or more races. There were, however, only five applications denied for the group two or more races. Nearly 4,100 White applicants were denied conventional loans with 23.1 % denied due to "debt -to- income ratio'. Hispanic applicants were slightly lower at 21.1 %. Unlike FHA loans however, the second most frequent known reason for denial in most instances is "collateral'. Nearly 20% of the joint applicants, 15.4% of Asian applicants and 10.3% of the Hispanic applicants were denied due to "collateral'. It is unclear exactly what "collateral' encompasses; however, it could refer to declining home values and the inability for homes to meet appraisal requirements. About 9,250 refinance loans were denied for White applicants. About one half of the loans were denied because of "debt -to- income" or "collateral' reasons. More than half of the refinance applications for Asian and Hispanic applicants were denied for these two reasons. For seven out of the 10 groups, "collateral' was more frequently the reason for denial rather than "debt -to- income". Again this may be due to homes not meeting appraisal requirements. County -wide there are relatively few home improvement loan applications. The two most frequent reasons for loan denial for most groups was "debt -to- income" and "credit history". f. Association of High Denial Rates and Minority Population Concentrations As previously noted, HMDA was designed so that the public and regulators could better determine whether or not individuals or specific neighborhoods were being unfairly denied access to credit. A fair housing issue is whether there is an association between neighborhoods with high minority population concentrations and high denial rates. That is, do applicants for home purchases in minority neighborhoods experience high loan denial rates compared to applicants in non - minority neighborhoods? This issue was examined for the following: • Entitlement and Urban County census tracts with 15 or more FHA loan applications • Entitlement and Urban County census tracts with 50 or more conventional loan applications • Percent minority population for each census was determined • Census tracts were ranked ordered in terms of denial rates (high to low) A preliminary analysis was completed to determine if race /ethnicity is associated with the denial of loan applications. The percent minority, percent of the median county income, and the loan denial rates were determined for each census tract in Orange County where there was loan activity in 2008. The initial analysis indicated that there was no relationship between the percent minority in a census tract and the percent of loans that were denied in that census tract. However, inspection of the data suggested that there were some confounding factors in that there were -151 high denial rates in very high income areas. Often these areas have loan applications for very large sums of money to finance the purchase of very expensive homes. Although the loan amount was not in the data set, there was a "proxy' variable in the income of the census tract. It was assumed that higher income areas were more likely to have more expensive homes. A second regression analysis was conducted only on those areas where the median income was at or below 100% of the median income. Focusing on this sub - sample of the data did reveal a relationship between denial rates and percent minority. The R2 value was .2 which is statistically significant. Another regression analysis was performed on a subset of the data where the income was at 80% or below the median income. The resulting R2 was .33. [The value r is a fraction between 0.0 and 1.0, and has no units. An r2 value of 0.0 means that knowing X does not help you predict Y. There is no linear relationship between X and Y, and the best -fit line is a horizontal line going through the mean of all Y values. When r2 equals 1.0, all points lie exactly on a straight line with no scatter. Knowing X lets you predict Y perfectly.] The results suggested that further analysis was warranted. Each record in the HMDA Loan Application Register includes the Census Tract Minority Population Percentage and the Census Tract Percentage of the Metropolitan Statistical Area Median Family Income, as well as the loan amount. An analysis was completed to determine if race /ethnicity is associated with the denial of loan applications. Two types of loans applications were considered in the analysis: (1) home purchases with conventional loans and (2) home purchases with FHA loan. A logit regression was used to "predict' if a loan was denied based on the minority population and income ratio of the census tract, as well as the loan amount. These variables were chosen because the results of a preliminary analysis utilizing census tract level data suggested each of these variables were influencing denials. Each of the three variables was significant predictors of loan denials for conventional loan applications, while the percent minority and the income ratio of a census tract were significant predictors of denials for FHA loan applications. The key to Iogit regression is the analysis of maximum likelihood estimates. It estimates the log odds of an event occurring (loan denial) given a one unit increase in a variable. The statistical significance of these log odds are measured using a Wald chi - square, which would be zero or near zero if the two events and the predictor variable were independent. The chi - square values are presented in Table 5 -17. Table 5 -17 Analysis of Maximum Likelihood Estimates Parameter Conventional Loans FHA Loans Wald Chi- Square Pr >Chi- Square Wald Chi- Square Pr >Chi- Square Percent Minority Population 39.99 <.0001 24.05 <.0001 Tract to MSA Median Family Income 8.83 0.003 4.05 0.0441 Loan Amount 114.57 <.0001 0.73 0.3935 1152 By way of elaboration, the logit regression is based on the probability of an event occurring, i.e. loan denial. It measures the likelihood that the probability of the event increases as the independent variables increase. For conventional loans, the probability of a loan being denied increased as the percentage minority population in the census tract increased, as the income increased the probability of a denial decreased, and as the amount of the loan increased the probability of a loan denial increased. It should be noted that the association analysis suffers because the data sets are from two different points in time: loan activity in 2008 and minority population characteristics per Census 2000. Since 2000, the census tract income, racial and ethnic characteristics are likely to have changed since the time the census data was collected. With more current data, a more robust analysis of the relationship between the probability of a denial and the independent variables can be developed. Consequently, a more definitive analysis should be conducted when the 2010 census tract information is available on income, racial and ethnic characteristics. HMDA data for 2010 will be available in September 2011. 5. Actions to be Taken A summary of the examination of the 2008 HMDA data is given below • Disparities exist in loan approval /denial rates among the racial and ethnic borrowers. In particular, Hispanic applicants have higher loan denial rates than White, Non - Hispanic borrowers. • Black /African American borrowers also have high loan denial rates compared to White alone loan applicants. • Loan denial rates in neighborhoods with 20 % -79% minority populations are about the same regardless of census tract income level (low, moderate and above moderate). • Unfair lending is manifested more in the loan denial disparities experienced by different racial /ethnic borrowers than by the denial rate disparities experienced in neighborhoods with 20 % -79% minority populations, regardless of income. Unfair lending is a fair housing issue best addressed at the regional level rather on a city -by -city basis. The FHCOC will undertake the following actions during the 2010 -2015 period: • Monitor the HMDA data annually using the 2008 HMDA analysis as a benchmark. • Complete a HMDA analysis of the top 10 lenders in Orange County to compare and contrast loan denial rates. • 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. 1153 • Conduct outreach to cultural, ethnic and minority organizations to potentially increase interest and readiness in home purchases. 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. •iJi Attachment A California Newspaper Publishers Association Guidance on Advertising Words and Phrases The Civil Rights Act of 1968 is a federal law that prohibits discrimination in many different sectors, including housing and employment. Title VIII of the Civil Rights Act of 1968 is the section that is popularly referred to as the Fair Housing Act, and applies to everyone in the United States. Title VIII [42 U.S.C. Section 3604 9(c)] as amended, makes it unlawful to: Make, print, or publish, or cause to be made, printed or published any notice, statement or advertisement, with respect to the sale or rental of a dwelling that indicated any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination. California has enacted a similar anti - discrimination provision. California Government Code Section 12955 (a), part of the Fair Employment and Housing Act, makes it unlawful: For the owner of any housing accommodation to discriminate against any person because of the race, color, religion, sex, marital status, national origin, ancestry, familial status, sexual orientation, source of income, or disability of that person. California Government Code Section 12955 (c) further makes it unlawful: For any person to make, print, or publish, or cause to be made, printed or published any notice, statement or advertisement, with respect to the sale or rental of housing that indicates any preference, limitation, or discrimination based on race, color, religion, sex, marital status, national origin, ancestry, familial status, disability, sexual orientation, source of income, or an intention to make any such preference, limitation, or discrimination. California's Unruh Civil Rights Act (Civil Code Section 51 et. seq.) further prohibits discrimination in housing based on age. The Act has also been interpreted by the courts in California to protect individuals based on sexual orientation. More broadly, the Unruh law prohibits discrimination based on any of the characteristics listed above as well as any other arbitrary basis. The FEHA expressly incorporates the anti - discrimination housing provisions (Government code Section 12955[d]). 1. Race/ Color/ National Origin/ Ancestry These four classes are generally discussed together. Race and color refer to a person's skin color and to ethnological (e.g. Asian, African American) as well as unscientific distinctions (e.g. "Middle Eastern "). National origin and ancestry refer to one's country of origin and ethnic heritage. The following are some words and terms that state and federal regulators discourage because they discriminate based on race, color, ancestry, or national origin: white, black, asian, 155 integrated, restricted, private, board approval, ethnic landmarks, executive, exclusive, membership approval, a specific nationality such as Chinese and any specific race. Federal and state regulations and guidelines discourage words and terms such as "membership approval," "restricted," "integrated," and "exclusive." These and other words and phrases may be discriminatory, according to regulators, because someone reading the advertisement is likely to believe that people of a certain race or national origin will be preferred over others in the sale or rental of the advertised housing. 2. Sex Discrimination on the basis of sex protects both men and women. It is illegal to specify either "male "preferred" or "female preferred." No preference on the basis of sex should be stated in an advertisement. DFEH stated that terms such as "bachelor pad," "granny flat," "mother -in -law suite" and others are commonly used as physical descriptions of housing units do not violate the Act. 3. Disability The following are a few of the words and phrases that federal regulations state convey an overt or tacit discriminatory preference and should be avoided: crippled, blind, deaf, mentally ill, retarded, impaired, alcoholic, handicapped, able- bodied, and physically fit. Physical descriptions of property (e.g. "great view," "walk -in closet" and second floor walk -up ") or descriptions of services or facilities (e.g. "jogging trails') are not facially discriminatory 4. Marital Status /Familial Status Marital status, as the term suggests, protects people from discrimination based on whether or not they are married. Familial status refers to whether or not an individual has minor children living with them. Words and phrases that, according to state and federal regulators, bring up the issue of discrimination on the basis of marital or familial status: retired, one child, one person, number of people, family, (`great for family," etc.) family park, adult, adults only, children, single, single person, student, two people, seniors, senior discount, couples (e.g. "ideal for couples'), and older person. Advertisements which describe the property being advertised or the services or facilities available at the property are generally considered to be acceptable. Examples include "family room" and "playground" It may be unlawful to limit the number of persons who can live in a housing unit if it would have the effect of discriminating on the basis of familial or marital status. CNPA recommends rejecting any advertisement that limits the number of occupants, even where the owner specifies that the limitation is required by local law. The reason is that a newspaper publisher cannot investigate the facts surrounding every proposed advertisement to determine if the advertiser's claim is correct. 150 5. Religion Discrimination in housing on the basis of religion is prohibited under both state and federal law. According to the state Guidance Memorandum, "advertisements should not contain an explicit preference, limitation or discrimination on account of religion (i.e. "no Jews," "Christian home ")." Some of the words and phrases that regulators say may draw a complaint based on religious discrimination include Jewish, Mormon Temple, Catholic Church, Christian home, religious name, any religious landmark. 6. Sexual Orientation Any reference to an individual's sexual orientation, e.g. lesbian, gay, and straight, etc. should be eliminated from housing ads. Publishing an ad that says, "lesbian, vegetarian seeking roommate," would expressly indicate a preference for a person on the basis of her sexual orientation. 7. Age Federal regulations specify that unless the housing being offered meets government requirements for "senior" or "senior only" housing, advertisers may not express a preference or limitation on the basis of age. Federal and state guidance memorandums specifying that if an advertiser represents to the newspaper that the housing meets the requirements of "senior housing," the newspaper is allowed to rely on the representation. 157 Attachment B Hate Crimes Glossary Bias — A preformed negative opinion or attitude toward a group of persons based on their race, ethnicity, national origin, religion, gender, sexual orientation and /or physical /mental disability. Ethnic Bias — A preformed negative opinion or attitude toward a group of persons of the same race or national origin that share common or similar traits in language, custom, and tradition, such as Arabs or Hispanics. Event — An event is an occurrence where a hate crime is involved. (In this DOJ report, the information about the event is a crime report or source document that meets the criteria for a hate crime.) There may be one or more suspects involved, one or more victims targeted, and one or more offenses involved for each event. Known Suspect(s) — A suspect can be any person alleged to have committed a criminal act(s) or attempted criminal act(s) to cause physical injury, emotional suffering, or property damage. The known suspect category contains the number of suspects that have been identified and /or alleged to have committed hate crimes as stated in the crime report. For example, witnesses observe three suspects fleeing the scene of a crime. The word "known" does not necessarily refer to specific identities. Offenses — Offenses that are recorded are as follows; murder, forcible rape, robbery, aggravated assault, burglary, larceny -theft, motor vehicle theft, arson, simple assault, intimidation, and destruction /vandalism as defined in the national UCR and the national Hate Crimes Statistics Report. Physical /Mental Disability Bias — A preformed negative opinion or attitude toward a group of persons based on physical or mental impediments /challenges, whether such disabilities are congenital or acquired by heredity, accident, injury, advanced age, or illness. Racial Bias — A preformed negative opinion or attitude toward a group of persons such as Asians, blacks, or whites, based on common physical characteristics. Religious Bias — A preformed negative opinion or attitude toward a group of persons that share the same religious beliefs regarding the origin and purpose of the universe and the existence or nonexistence of a supreme being, such as Catholics, Jews, Protestants, or Atheists. Sexual- Orientation Bias — A preformed negative opinion or attitude toward a group of persons based on sexual preferences and /or attractions toward and responsiveness to members of their own or opposite sexes. Victim — A victim may be an individual, a business or financial institution, a religious organization, government, or other. For example, if a church or synagogue is vandalized and /or desecrated, the victim would be a religious organization. 152 Section 6 Public Sector Fair Housing Analysis 2�9 SECTION 6 PUBLIC SECTOR FAIR HOUSING ANALYSIS A. INTRODUCTION The United States Department of Justice has indicated a major focus of its efforts is on public sector impediments that may restrict housing opportunities for disabled persons. The Department has stated: The Division's enforcement of the Fair Housing Act's protections for persons with disabilities has concentrated on two major areas. One is insuring that zoning and other regulations concerning land use are not employed to hinder the residential choices of these individuals, including unnecessarily restricting communal, or congregate, residential arrangements, such as group homes. The second area is insuring that newly constructed multifamily housing is built in accordance with the Fair Housing Act's accessibility requirements so that it is accessible to and usable by people with disabilities, and, in particular, those who use wheelchairs. Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, page 4 California's Fair Employment and Housing Act states that it is unlawful: To discriminate through public or private land use practices, decisions, and authorizations because of race, color, religion, sex, sexual orientation, familial status, marital status, disability, national origin, source of income, or ancestry. Discrimination includes, but is not limited to, restrictive covenants, zoning laws, denials of use permits, and other actions authorized under the Planning and Zoning Law (Title 7 (commencing with Section 65000)), that make housing opportunities unavailable. [emphasis added] The analysis of public sector impediments involves following: • A description of the actions taken by the County's four housing authorities to affirmatively further fair housing • A description of the housing authorities policies on reasonable physical modifications and reasonable accommodations • A discussion on the most frequent land use and zoning impediments identified by the Entitlement Cities and the County of Orange • An identification of the land use and zoning impediments identified by each participating Entitlement City and the County of Orange • A description of the actions to be taken by the FHCOC and the participating jurisdictions to ameliorate or eliminate public sector impediments 100 B. DESCRIPTION OF HOUSING AUTHORITY FAIR HOUSING POLICIES Orange County's four housing authorities provide rental assistance through the Housing Choice Voucher Program (HCVP) to an estimated 21,000 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 FHCOC. 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 Eight 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% or greater. The Orange County Housing Authority has consistently received five bonus points in SEMAP for de- concentration. 1. Fair Housing Policies of Housing Authorities The paragraphs below summarize key fair housing policies of the housing authorities a. Anaheim Housina Authoritv (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. 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 101 • 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 b. Garden Grove Housina Authoritv (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. 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. c. 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. 102 • 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. d. Oranoe County Housino 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: 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 1('03 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 it 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. • 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. 7 N 2. Section 8 Housing Policies on Reasonable Physical Modifications and Reasonable Accommodations Question #8 of the Zoning and Planning Survey (Attachment A) asks: If the jurisdiction supplies or manages housing, is there a clear policy to allow disabled persons residing in or seeking to reside in the housing to make or request reasonable physical modifications or to request reasonable accommodations? As previously noted, four housing authorities administer the Section 8 Housing Choice Voucher Program: • Anaheim Housing Authority • Garden Grove Housing Authority • Santa Ana Housing Authority • Orange County Housing Authority The Anaheim Housing Authority administers about 6,300 Section 8 Housing Choice Voucher units. As a consequence, this rental assistance program represents a significant segment of the rental housing market. The Garden Grove Housing Authority administers about 2,500 Section 8 Housing Choice Voucher units. Of this total, 2,026 Section 8 families reside in rental housing located in Garden Grove, a number that represents 10% of the City's rental housing stock. The Santa Ana Housing Authority administers about 2,600 Section 8 Housing Choice Voucher units. The Orange County Housing Authority administers about 9,600 Section 8 Housing Choice Vouchers. The housing units are located in the unincorporated area and 31 participating cities in Orange County. HUD stipulates a number of reasonable accommodations that can be made available to persons with disabilities who are recipients of Housing Choice Vouchers. Examples of the types of accommodations include: • Approval to perform annual reexaminations of household income by telephone • Approval to add a live -in aide /care provider • Approval to rent a unit owned by a relative • Approval of an extra bedroom for large, intrusive medical equipment • Approval to use a voucher in special housing types such as shared housing, group homes, congregate housing and assisted living Each housing authority has adopted policies - as part of their Administrative Plans - related to persons with disabilities, including reasonable accommodation. For example, the Anaheim Housing Authority has the following policy: If you or anyone in your family is a person with disabilities, and you require specific accommodation in order to fully utilize our programs and services, please contact the housing authority. 105 Another example is the Garden Grove Housing Authority policy which states: The GGHA shall make reasonable adjustments to their rules, policies, practices and procedures in order to enable an applicant or participant with a disability to have an equal opportunity to access the HCVP. If providing the accommodations would result in a fundamental alteration in the nature of the HCVP or an undue financial or administrative burden, then the GGHA need not provide the accommodation, however it may present an alternate accommodation that will still meet the need of the person. An undue administrative burden is one that requires a fundamental alteration of the essential functions of the GGHA (i.e., waiving a family obligation). An undue financial burden is one that when considering the available resources of the agency as a whole, the requested accommodation would pose a severe financial hardship on the GGHA. A participant with a disability must request a change to a policy or practice as an accommodation of his or her disability before the GGHA will treat a person differently than anyone else. The GGHA's policies and practices will be designed to provide assurances that persons with disabilities will be given reasonable accommodations, upon request, so that they may fully access and utilize the housing program and related services. This policy is intended to afford persons with disabilities an equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement as those who do not have disabilities. 3. Fair Housing and Lead -Based Paint The issue of lead based paint in housing is recognized as a fair housing concern because of the overconcentration of housing containing lead based paint in very low and low income neighborhoods coupled with the over concentration of protected classes residing in these neighborhoods. Lead based paint also is a fair housing issue because it relates especially to rental housing for children. Under the Fair Housing Act, it is illegal to not rent to families unless the housing is exempt because it is housing for older persons. The Orange County Childhood Lead Poisoning Prevention Program ( CLPPP) explains that high blood lead levels are a concern because they may cause harmful effects to a child's developing organ systems such as the kidneys, brain, liver, and blood- forming tissues. This may affect a child's ability to learn. Very high blood levels can cause devastating health consequences, including seizures, coma, and even death. Children are much more vulnerable to lead poisoning than adults because they put many kinds of items into their mouths. Their bodies absorb up to 40% of the lead with which they come into contact as opposed to only 10% absorbed by adults. Lead enters the body through breathing or ingestion. Some possible sources of lead include • Living in an older home painted with lead -based paint • Ceramic pottery • Lead -based paint dust from a household contact's work clothing • A home remedy • A crib painted with lead -based paint The CLPPP follows children with abnormal or high blood lead levels. CLPPP receives reports of abnormal lead results from the State, laboratories, or physicians /clinics who have ordered the test. 100 In order to better protect children and families against lead poisoning; in 1999 HUD instituted revised lead -based paint regulations focused on the following five activities: • Notification — disclosure, distribution of pamphlet, notice of lead hazard evaluation or presumption, and notice of lead hazard reduction activity • Lead Hazard Evaluation — visual assessment, paint testing, and risk assessment or lead hazard screen • Lead Hazard Reduction — paint stabilization, interim controls, and abatement • Ongoing Maintenance — inspect and maintain lead hazard reduction work • Response to Children with Environmental Intervention Blood Lead Level — sharing and comparing information, risk assessment, interim controls or abatement, and notices of disclosure On April 22, 2008, EPA issued a rule requiring the use of lead -safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead -based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination. Starting on April 22, 2010, the rule affected paid renovators who work in pre -1978 housing and child- occupied facilities, including: • Renovation contractors Maintenance workers in multi - family housing Painters and other specialty trades Under the rule, child- occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule does not apply to minor maintenance or repair activities where less than six square feet of lead -based paint is disturbed in a room or where less than 20 square feet of lead -based paint is disturbed on the exterior. Window replacement is not minor maintenance or repair. HUD has indicated that lead -based paint in assisted housing occupied by families with children is a fair housing concern. The County's four housing authorities provide rental assistance to a combined total of about 21,000 households /housing units. Many of the assisted households are families with children. Efforts to reduce lead based paint hazards are integrated into the County's four housing authority's administrative procedures. For example, as of May, 2010 the Orange County Housing Authority was assisting 1,226 families that include one or more children under the age of six. The Housing Authority developed a report listing the address of the assisted units with children under the age of six. The County's Health Care Agency (HCA) then compared the assisted unit addresses with the address of any children in their records that had an elevated blood level. HCA completed a check of current, open State - defined cases against OCHA's list. These are children with one blood lead level (BLL) of 20 mcg /dL or greater or two BLLs of 15 -19 mcg /dL) There have been no matches at this time. HCA is continuing to compare the addresses for other identified elevated blood lead levels for those addresses. 2O7 C. DESCRIPTION OF CITY AND COUNTY PUBLIC SECTOR IMPEDIMENTS As part of the preparation of an Analysis of Impediments to Fair Housing Choice participating cities responded to a 24- question survey 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. The survey 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. 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. Attachment A is the complete Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice. The survey provides background information that explains the fair housing issues and concerns posed by each question. Three examples of background information are provided below: • The City of Santa Barbara v Adamson case explains why cities should not have a definition of "family" that restricts housing opportunities for disabled persons living in a group home. The U.S. ex re. Anti - Discrimination Center v. Westchester County indicates that in appropriate circumstances affordable housing can be a tool to address a lack of fair housing choice in highly segregated communities. The Housing for Older Persons Act explains the conditions under which senior housing is exempt from the prohibition against familial discrimination. Chart 6 -1 on the next page lists the 24 topics /questions included in the Survey of Zoning and Planning Codes, Policies and Practices. The results of the Zoning and Planning Survey are presented in the following pages. The analysis is presented in two parts: • First, a summary is presented of public sector impediments that are common to most participating jurisdictions. • Second, the public sector impediments unique to each participating jurisdiction are identified. m Chart 6 -1 Orange County Regional Analysis of Impediments to Fair Housing Choice Topics Included in the Survey of Zoning and Planning Codes, Policies and Practices That May Pose an Impediment to Fair Housing Choice 1. Lack of a Family Definition Consistent with Fair Housing Laws 2. Mischaracterize Housing for the Disabled as 'Boarding or Rooming house' 3. Lack of a Definition of Disability Consistent with Fair Housing Laws 4. Treating Housing for Disabled Persons Differently than Other Housing 5. Restrict On -Site Supportive Services for Housing for Disabled Persons 6. Occupancy Limits on Housing for Disabled Persons 7. Lack of a Reasonable Accommodation Procedure 8. Lack of Reasonable Modifications /Accommodations in Section 8 Housing 9. Public Hearing Requirements on Requests for Exceptions to Zoning Rules 10. CUP Requirement for Housing for Disabled Persons 11. Lack of Disabled - Accessible Parking for Multiple - Family Projects 12. Lack of Development Standards for Making Housing Accessible to Disabled Persons 13. Plan Check for Accessibility Compliance of Covered Multi - Family New Construction 14. Zoning Ordinance or Policy for Inclusionary Housing 15. Zoning Ordinance or Policy for Mixed Use Development 16. Development Incentives for the Provision of Affordable Housing 17. Ordinance or Policy Limiting Housing to Fair Housing Protected Classes 18. Zoning Development Standards for Senior Housing /Compliance with Unruh Civil Rights Act 19. CUP Requirements for Senior Housing Developments 20. Zoning and Policies for Special Needs Housing 21. Occupancy Standards More Restrictive than State Law 22. Policy on Admission Preference to Persons Already Residing in the Jurisdiction 23. Impact of Redevelopment Activities on Fair Housing Choice 24. Zoning Ordinance or Policies that Discuss Fair Housing log 1. Public Sector Impediments Common to Most Participating Jurisdictions 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 Disabilit 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. Jurisdictions planning to define disability in either or both the zoning regulations and a reasonable accommodation procedure need to be aware of what the Fair Housing Act (FHA) and American with Disabilities Act (ADA) cover. The ADA covers the activities of state and local governments, their buildings as well as public accommodations in movie theaters, restaurants, hotels, etc. The FHA applies to residential dwellings. Because of this difference, at one time both builders and developers believed that they were meeting the guidelines of the ADA and, therefore, believed that they were fulfilling all of their responsibilities in regards to accessibility, which was not necessarily true. Also, the protections for persons with disabilities are very different from protections provided for other protected cases under the FHA in that the provisions actually call for affirmative actions to be taken by housing providers, municipalities and others in removing barriers to fair housing choice for people with disabilities. That is why some cities have adopted an ordinance incorporating provisions to provide people with disabilities reasonable accommodations in rules, policies, practices and procedures that may be necessary to ensure equal access to housing. 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. 170 Government Code Section 65582(f) states: "'Supportive housing' has the same meaning as defined in subdivision (b) of Section 50675.14 of the Health and Safety Code." Health and Safety Code Section 50675.14(b) states: "For purposes of this section, 'supportive housing' means housing with no limit on length of stay, that is occupied by the target population as defined in subdivision (d) of Section 53260, and that is linked to onsite or offsite services that assist 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." Health and Safety Code Section 53260(d) states: "'Target population' means adults with low incomes having one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Act (Division 4.5 (commencing with Section 4500) of the Welfare and Institutions Code) and may, among other populations, include families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, or homeless people." [emphasis added] Government Code Section 65582(g) states: "'Transitional housing' has the same meaning as defined in subdivision (h) of Section 50675.2 of the Health and Safety Code." Health and Safety Code Section 50675.2(h) states: "'Transitional housing' and `transitional housing development' means buildings configured as rental housing developments, but operated under program requirements that call for the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months." Health and Safety Code Section 50801(i) states: "'Transitional housing' means housing with supportive services for up to 24 months that is exclusively designated and targeted for recently homeless persons. Transitional housing includes self- sufficiency development services, with the ultimate goal of moving recently homeless persons to permanent housing as quickly as possible, and limits rents and service fees to an ability -to -pay formula reasonably consistent with the United States Department of Housing and Urban Development's requirements for subsidized housing for low- income persons. Rents and service fees paid for transitional housing may be reserved, in whole or in part, to assist residents to move to permanent housing." 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. 171 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. The federal Departments of Justice (DOJ) and Housing and Urban Development (HUD) as well as the California Attorney General have encouraged local governments to adopt a reasonable accommodation procedure. The DOJ and HUD have stated: "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 the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 5. On May 15, 2001 the State Attorney General transmitted a letter to all local governments advising the localities to consider adoption of a reasonable accommodation procedure. In that letter, the Attorney General stated: "Both the federal Fair Housing Act ('FHA') and the California Fair Employment and Housing Act ('FEHA') impose an affirmative duty on local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning laws and other land use regulations and practices when such accommodations 'may be necessary to afford' disabled persons 'an equal opportunity to use and enjoy a dwelling. "' Many jurisdictions currently handle requests for relief from the zoning ordinance through variance or conditional use permits. The Attorney General remarked that: " ...the criteria for determining whether to grant a variance or conditional use permit typically differ from those which govern the determination whether a requested accommodation is reasonable within the meaning of fair housing laws. "Thus, municipalities relying upon these alternative procedures have found themselves in the position of having refused to approve a project as a result of considerations which, while sufficient to justify the refusal under the criteria applicable to grant of a variance or conditional use permit, were insufficient to justify the denial when judged in light of the fair housing laws' reasonable accommodations mandate." The Attorney General also stated that the variance and conditional use permit procedures — with their different governing criteria — serve to encourage community opposition to projects housing the disabled. The Attorney General wrote: "Yet this is the very type of opposition that, for example, the typical conditional use permit procedure, with its general health, safety and welfare standard, would seem rather 272 predictably to invite, whereas a procedure conducted pursuant to the more focused criteria applicable to the reasonable accommodation determination would not." The advice of the Attorney General is to establish a reasonable accommodation procedure instead of relying on the conditional use permit and variance procedures to process a request for disabled persons seeking specific exceptions to zoning and land -use rules (variances) necessary for them to be able to fully use and enjoy housing. A public hearing is not required for approval of a reasonable accommodation request. 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. Attachment B on page 6 -34 is an example of a reasonable accommodation procedure (City of La Habra). d. Special Needs Zoning Question #20 asks: Does the zoning code or other planning document address housing for "special needs" populations. 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. There is a high incidence of disability in the homeless population, domestic violence overwhelmingly impacts women, and people with HIV /AIDS are considered disabled under fair housing law. While age is not a characteristic protected under federal fair housing law, it is covered under state law, and the higher incidence of disability in the frail elderly introduces possible fair housing implications for that population as well. Entitlement cities and the Urban County should consider enacting special needs housing zoning regulations. Attachment C on page 6 -37 is an example of such zoning regulations (City of La Habra). e. Fair Housing Discussion Question 24 asks: Does the zoning ordinance or other planning or policy document include a discussion of fair 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. Attachment D on page 6 -47 is an example of such zoning regulations (City of San Francisco Fair Housing Implementation Ordinance). 1�3 2. City Identified Public Sector Impediments Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the City of Newport Beach did not identify any public sector impediments. Reference: Technical Appendix G: Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice 174 D. ACTIONS TO BE TAKEN BY THE FHCOC AND CITY TO AMELIORATE OR ELIMINATE PUBLIC SECTOR IMPEDIMENTS 1. 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 consistent of providing background information on the above impediments and model ordinances or regulations that adequately address the fair housing concerns posed by the impediments. 2. Actions to be Taken by the City Based on an evaluation of City Zoning and Planning Codes as well as policies and practices that may pose an impediment to Fair Housing Choice, the City of Newport Beach did not identify any public sector impediments. Therefore, there are no actions to be taken at this time by the City with respect to public sector impediments. Reference: Technical Appendix G: Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice ij 5 /_[ice IT i -- iiw_1 SURVEY OF ZONING AND PLANNING CODES, POLICIES AND PRACTICES THAT MAY POSE AN IMPEDIMENT TO FAIR HOUSING CHOICE 170 FAIR HOUSING COUNCIL OF ORANGE COUNTY 201 S. Broadway • Sams Ana, CA 92701 7141569 -0823 • Fax 714/835 -0281 • www.fairhousingoc.org SURVEY OF ZONING AND PLANNING CODES, POLICIES AND PRACTICES THAT MAY POSE AN IMPEDIMENT TO FAIR HOUSING CHOICE Name of Jurisdiction: Completing Department: Completed By: Date Completed: 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 24 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 and local developers of housing. 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. QUESTIONS [NOTE: For document automation please enable macros and then double click check boxes to check or uncheck ] 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 0 No O Background 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 situating of group homes for individuals with disabilities (but not families similarly sized and 2�� situated). Such definitions are prohibited because they could have the effect 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. 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 who were allowed to do so to five. Under the invalidated 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. For example, a city may have a definition of `family' as follows: "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. [emphasis added] A definition of family should look to whether the household functions as a cohesive unit instead of distinguishing between related and unrelated persons. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 2. Does the code definition of "dwelling unit" or "residential unit" have the effect of discriminating against unrelated individuals with disabilities who reside together in a congregate or group living arrangement? Yes ❑ No ❑ Background The definition of a "dwelling unit" or "residential unit" may exclude or restrict housing opportunities for individuals with disabilities by mischaracterizing congregate or group living arrangements as "boarding or rooming house' a "hotel' or a "residential care facility ". Both State and Federal fair housing laws prohibit definitions of dwelling that either intentionally discriminate against people with disabilities or have the effect of excluding such individuals from housing. Generally, all dwellings are covered by fair housing laws, with a "dwelling" being defined as "a temporary or permanent dwelling place, abode or habitation to which one intends to return as distinguished from the place of temporary sojourn or transient visit." Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 172 3. Does the code or any policy document define "disability ", if at all; at least as broadly as the federal Fair Housing Act? Yes ❑ No ❑ Background The federal Fair Housing Act (FHA) defines disability /handicap as follows: "Handicap" means, with respect to a person- - (1) a physical or mental impairment which substantially limits one or more of such person's major life activities, (2) a record of having such an impairment, or (3) being regarded as having such an impairment, but such term does not include current, illegal use of or addiction to a controlled substance (as defined in section 102 of the Controlled Substances Act (21 U.S.C. 802)). The term "physical or mental impairment" 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. The California Fair Employment and Housing Act (FEHA) definition is somewhat broader, in that removes the word "substantially ". The FEHA definition is: (1) A physical or mental impairment that limits one or more of a person's major life activities (2) A record of having, or being perceived as having, a physical or mental impairment. It does not include current illegal use of, or addiction to, a controlled substance (as defined by Section 102 of the Federal Controlled Substance Act, 21 U.S.C. Sec. 802). Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 4. Are personal characteristics of residents, including, but not necessarily limited to, disability, considered? Yes ❑ No ❑ 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 people, 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 conditional use permit or variance requirement on family -like facilities of a certain size and not similarly sized housing for people without disabilities, violates fair housing laws. 179 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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 2 and 3. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 5. Does the code limit housing opportunities for disabled individuals through restrictions on the provision of on -site supportive services? Yes ❑ No ❑ Background Housing for disabled persons, to be sustainable, successful and to allow them to fully use and enjoy the housing, 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." Joint Statement of the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 2. m Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 6. Does the jurisdiction policy have more restrictive limits for occupancies involving disabled residents than for other occupancies of unrelated, non - disabled persons? Yes ❑ No ❑ 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." Joint Statement of the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 3. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 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? Yes ❑ No ❑ 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 121 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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 4 and 5. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: B. If the jurisdiction supplies or manages housing, is there a clear policy to allow disabled persons residing in or seeking to reside in the housing to make or request reasonable physical modifications or to request reasonable accommodations? Yes ❑ No ❑ N/A ❑ If 'Yes', is the policy communicated to applicants or residents? Yes ❑ No ❑ Explanation of Answer Given Above Please provide a brief description of the policy, its dissemination and its process: 182 9. Does the jurisdiction require a public hearing for disabled persons seeking specific exceptions to zoning and land -use rules (variances) necessary for them to be able fully use and enjoy housing? Yes ❑ No ❑ If `Yes', is the process the same as for other applications for variances, or does it impose added requirements? 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. In acting consistently with "affirmatively furthering fair housing," it is considered preferable to have a reasonable accommodation procedure intended to facilitate a disabled applicant's request for exceptions to zoning and land use rules, that does not require a public hearing process. As previously explained in the joint statement by DOJ and HUD: "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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 5. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer, and an explanation of any differences for persons with disabilities: 10. Does the zoning code distinguish housing for persons with disabilities from other residential uses by requiring an application for a conditional use permit (CUP)? Yes ❑ No ❑ Background See the Background section for questions 7 and 9 above. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and what aspects of use trigger the need for a permit: 11. Describe the development standards, if any, for the provision of disabled - accessible parking for multiple - family projects. 122 12. Does the code contain any development standards or special provisions for making housing accessible to persons with disabilities? Yes O No O Does it specifically reference the accessibility requirements contained in the Fair Housing Amendments Act of 1988? Yes ❑ No ❑ Background Generally, under the federal Fair Housing Amendments Act of 1988, both privately owned and publicly assisted single -story, multi - family housing units built for first occupancy on or after March 13, 1991— including both 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, or 2) are ground floor units in non - elevator buildings containing four or more units. These standards, encompassing seven basic provisions, are codified at Code of Federal Regulations Title 24, Part 100.205. Additionally, under Section 504 of the Rehabilitation Act of 1973, it is unlawful to discriminate based on disability in federally assisted programs. This section provides that no otherwise qualified individual shall, solely by reason of his or her disability, be excluded from participation (including employment), denied program benefits, or be subjected to discrimination on account of disability under any program or activity receiving federal funding assistance. Section 504 also contains accessibility provisions for dwellings developed or substantially rehabilitated with federal funds. For the purposes of compliance with Section 504, "accessible" means ensuring that programs and activities, when viewed in their entirety, are accessible to and usable by individuals with disabilities. For housing purposes, the Section 504 regulations define an accessible dwelling unit as a unit that is located on an accessible route and can be approached, entered, and used by individuals with physical disabilities. A unit that is on an accessible route and is adaptable and otherwise in compliance with the standards set forth in Code of Federal Regulations Title 24, Part 8.32 is accessible. In addition, the Section 504 regulations impose specific accessibility requirements for new construction and alteration of housing and non - housing facilities in HUD assisted programs. Section 8.32 of the regulations states that compliance with the appropriate technical criteria in the Uniform Federal Accessibility Standards (UFAS), or a standard that is equivalent to or stricter than the UFAS, is an acceptable means of meeting the technical accessibility requirements in Sections 8.21, 8.22, 8.23 and 8.25 of the Section 504 regulations. However, meeting Section 504 accessibility requirements does not exempt housing from other accessibility requirements that may be required under fair housing laws. The following Section 504 requirements apply to all federally assisted newly constructed housing and to substantial rehabilitation of housing with 15 or more units: A minimum of five percent of total dwelling units (but not less than one unit) accessible for individuals with mobility impairments; An additional two percent of dwelling units (but not less than one) accessible for persons with hearing or vision impairments; and All units made adaptable that are on the ground level or can be reached by an elevator. r Fair housing laws do not impose a duty on local jurisdictions to include accessibility provisions in their codes, or to enforce the accessibility provisions of fair housing laws. However, the inclusions of accessibility standards and /or plan checking for accessibility compliance are significant ways that jurisdictions can affirmatively further fair housing choice for persons with disabilities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and of the standards, if any: 13. Does the jurisdiction conduct plan checking for accessibility compliance of covered multi - family new construction? Yes ❑ No ❑ Background See the final paragraph of the Background section of question 12. If `Yes', please give a brief description of process and what items are checked. 14. Is there a zoning ordinance or other development policy that encourages or requires the inclusion of housing units affordable to low and/or moderate income households (so- called `inclusionary housing')? Yes ❑ No ❑ Background An analysis of impediments to fair housing choice must be careful to not substitute or conflate housing affordability policy with policies intended to affirmatively further fair housing. While household income is not a characteristic addressed by fair housing laws, it is appropriate to recognize that a lack of affordable housing can have a disparate impact on housing choice, on the basis of characteristics protected by fair housing laws. As demonstrated in the outcome in the recent court case of U.S, ex reL Anti - Discrimination Center v. Westchester County, which involved failures to affirmatively further fair housing by Westchester County, New York, in appropriate circumstances the provision and situation of affordable housing can be a tool to address a lack of fair housing choice in highly segregated communities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: ig5 15. Does the zoning ordinance allow for mixed uses? Yes ❑ No ❑ If 'Yes', does the ordinance or other planning policy document consider the ability of mixed -use development to enhance housing affordability? Also, do development standards for mixed -uses take into consideration the challenges of providing housing accessible to persons with disabilities in such mixed uses? Background The purpose of this inquiry relates to housing affordability and fair housing choice as discussed in the Background section of question 14. Also, 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 CFR Title 24, Part 100.205 and CCR Title 24 accessibility requirements. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief overview of the development standards: 16. Does the zoning ordinance provide for any of the following: 1) development incentives for the provision of affordable housing beyond those provided by state law; 2) development by right of affordable housing; or, 3) a zoning overlay to allow for affordable housing development? Yes ❑ No ❑ Background The purpose of this inquiry relates to housing affordability and fair housing choice as discussed in the Background section of the question 14. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief overview of the development standards: 17. Does the zoning ordinance describe any areas in this jurisdiction as exclusive? Yes ❑ No ❑ Are there exclusions or discussions in the ordinance or any planning policy document of limiting housing on the basis of any of the following characteristics covered by fair housing laws? Yes ❑ No ❑ If `Yes', check all of the following that apply: Race ❑ Color ❑ Sex ❑ Religion ❑ Age ❑ Disability ❑ Familial Status ❑ National Origin ❑ 120 Explanation of Answer Given Above Please provide a brief explanation of the how you arrived at the answer: 18. Are there any standards for Senior Housing in the zoning ordinance? Yes ❑ No ❑ If `Yes', do the standards comply with state or federal law on housing for older persons (i.e., solely occupied by persons 62 years of age or older, or occupied by at least one person 55 years of age, or other qualified permanent resident pursuant to Civil Code §51.3)? Yes ❑ No ❑ Is the location of Senior Housing treated differently than that other rental or for -sale housing? Yes ❑ No ❑ If `Yes', explain. Background Under federal law housing discrimination against families with children is permitted only in housing in which all the residents are 62 years of age or older or where at least 80% of the occupied units have one person who is 55 years of age or older. Generally, California law states that a housing provider using the lower age limitation of 55 years must have at least 35 units to use the familial status discrimination exemption. Also, California law, with narrow exceptions, requires all residents to be "senior citizens' or "qualified permanent residents ", pursuant to Civil Code §51.3. The 1988 amendments to the federal Fair Housing Act exempt "housing for older persons" from the prohibitions against familial discrimination. This means that housing communities and facilities that meet the criteria for the federal Housing for Older Persons Act (HOPA) may legally exclude families with children. Such housing is still bound by all other aspects of fair housing law (such as prohibition of discrimination based on race, national origin or disability). Section 3607(b)(2) defines "housing for older persons" as housing: (A) provided under any State or Federal program that the Secretary determines is specifically designed and operated to assist elderly persons (as defined in the State of Federal program); or (B) intended for, and solely occupied by, persons 62 years of age or older; or (C) intended and operated for occupancy by persons 55 years of age or older and — (i) at least 80 percent of the occupied units are occupied by at least one person who is 55 years of age or older; (ii) the housing facility or community publishes and adheres to policies and procedures that demonstrate the intent required under this subparagraph; and (iii) the housing facility or community complies with rules issued by the Secretary for verification of occupancy, which shall — 187 (1) provide for verification by reliable surveys and affidavits, and (II) include examples of the types of policies and procedures relevant to a determination of compliance with the requirement of clause (ii). Such surveys and affidavits shall be admissible in administrative and judicial proceedings for the purposes of such verification. Subsection (C) was changed by the Housing for Older Persons Act of 1995 (HOPA) to remove some of the uncertainties created by a provision in the 1988 Amendments that required the "existence of significant facilities and services specifically designed to meet the physical and social needs of older persons." The HOPA also provides for a good faith defense in an action for monetary damages under this subsection. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief overview of the development standards, if any: 19. Does the zoning code distinguish senior citizen housing from other residential uses by the application of a conditional use permit (CUP)? Yes ❑ No ❑ Background Senior housing is an important component of the community's housing stock. Demographic projections show that many communities will experience a growth in the elderly population. As a population ages, seniors need a variety of housing opportunities. Also, there is a higher prevalence of persons with disabilities within the senior population. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and what aspects of use trigger the need for a permit: 20. Does the zoning code or other planning policy document address housing for "special needs" populations? Yes ❑ No ❑ Background Special needs populations typically are considered to be homeless people, victims of domestic violence, people with disabilities (including those recovering from substance abuse), youth in crisis, people living with HIV /AIDS and the frail elderly. Of these groups, homeless people, victims of domestic violence, people with disabilities, and people living with HIV /AIDS have direct fair housing implications. There is a high incidence of disability in the homeless population, domestic violence overwhelming impacts women; and people living with HIV /AIDS are considered disabled under fair housing laws. While age is not a characteristic protected under federal fair housing law, it is covered under state law, and the higher incidence of disability in the frail elderly introduces possible fair housing implication for that population as well. :: These populations often rely on group homes or service - enriched multi - family settings for housing opportunities. To the extent that zoning and other planning policy documents fail to provide for, or impose barriers to, these types of housing an impediment to fair housing choice might exist. As previously noted, according to the DOJ and HUD, the term 'group home' does not have a specific legal meaning. While it often implies a living situation for people with disabilities, it also applies to any group of unrelated persons, often sharing common characteristics, who live together in a dwelling. This broader use of the term encompasses 'special needs' individuals. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief explanation of 'special needs' provisions, if any: 21. Does the zoning ordinance establish occupancy standards or maximum occupancy limits that are more restrictive than state law, which incorporates the Uniform Housing Code(UHC)? Yes 0 No O Background Occupancy standards sometimes can impede housing choice for families with children or for disabled persons. For example, some jurisdiction's zoning regulations have attempted to limit occupancy to five related persons occupying a single family home, or to strictly establish an occupancy standard of no more than two persons per bedroom. Such regulations can limit housing availability for some families with children, or prevent the development of housing for disabled persons. The federal Fair Housing Act (FHA) also 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." [Section 807(b)(1)] HUD implements section 589 of the Quality Housing and Work Responsibility Act (QHWRA) of 1988 by adopting as its policy on occupancy standards for purposes of enforcement actions under the FHA, the standards provided in the Memorandum of General Counsel Frank Keating to Regional Counsel dated March 20, 1991. The purpose of that Memorandum was "to articulate more fully the Department's position on reasonable occupancy policies and to describe the approach that the Department takes on its review of occupancy cases." The Memorandum states the following: "Specifically, the Department believes that an occupancy policy of two persons in a bedroom, as a general rule, is reasonable under the Fair Housing Act. [. .] However, the reasonableness of any occupancy policy is rebuttable, and neither the February 21 [1991] memorandum nor this memorandum implies that Department will determine compliance with the Fair Housing Act based solely on the number of people permitted in each bedroom." [emphasis added] The memorandum goes on to reiterate statements taken from the final rule implementing the Fair Housing Amendments Act of 1988 as follows: "[T]here is nothing in the legislative history that indicates any intent on the part of Congress to provide for the development of a national occupancy code ...." "Thus, the Department 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 that, in connection with a complaint alleging discrimination on the basis of familial status, the Department will carefully examine any such nongovernmental restriction to determine whether it operates unreasonably to limit or exclude families with children. " *U.S. Department of Housing and Urban Development, Memorandum to All Regional Counsel from Frank Keating on the subject of Fair Housing Enforcement Policy: Occupancy Cases, March 20, 1991. Essentially, HUD has established a starting point for assessing the reasonableness of occupancy restrictions, but has stated that the specific facts of each living situation must inform the final determination of reasonableness. While the above discussion relates to matters of discrimination affecting families with children, a similar analysis applies to standards that may limit housing choice for persons with disabilities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and the standards, if any: 22. Does the jurisdiction encourage or require affordable housing developments to give an admission preference to individuals already residing within the jurisdiction? Yes ❑ No ❑ If `Yes', is it a requirement? Yes ❑ No ❑ Background This practice may have fair housing implications if the population of the jurisdiction lacks diversity or does not reflect the demographic makeup of the larger region in which it is located. There may be a barrier to fair housing choice, in that the policy can have a discriminatory affect on the basis of characteristics considered by fair housing laws. For example if a jurisdiction already lacks housing suitable to people with mobility - related disabilities, the local population may have an under representation of such individuals, when compared to the population generally. Newly developed accessible housing that could meet the needs of such individuals, but which has a local resident admission preference, would be less likely to improve the ability of people with mobility - related disabilities to live in the jurisdiction. Likewise, a jurisdiction with an under representation of minority residents is likely to perpetuate that situation if a local resident admission preference is implemented for new affordable housing development. ;19L-) Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 23. Does the jurisdiction have any redevelopment areas? Yes ❑ No ❑ If `Yes', does the jurisdiction analyze possible impacts on fair housing choice resulting from its redevelopment activities? Yes ❑ No ❑ Background Redevelopment activities can result in the permanent displacement of residents. If the housing opportunities created by the redevelopment activity could result in a different demographic mix of residents, consideration needs to be given as to whether this difference represents an impediment, an enhancement or is neutral with respect to fair housing choice. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 24. Does the zoning ordinance or other planning or policy document include a discussion of fair housing? Yes ❑ No ❑ If 'Yes', how does the jurisdiction propose to further fair housing? Background Affirmatively furthering fair housing is an important responsibility of local government. In order to receive certain federal funds a jurisdiction must certify that it is taking actions to "affirmatively further fair housing" (AFFH). Although a jurisdiction may have numerous plans, policies, and standards, fair housing is rarely discussed in a zoning ordinance. Other documents of a jurisdiction may discuss the need to affirmatively further fair housing and the policies and actions that are in place to do so. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer, a description of where AFFH discussions, if any, may be found, and a brief summary of how AFFH is accomplished: X91 IDENTIFIED IMPEDIMENTS AND PROPOSED CORRECTIVE ACTIONS Based on your responses to questions 1 -24, please: a) provide a concise list of the zoning and planning impediments to fair housing choice that you have identified b) describe the actions that will be taken over the next five years to remove or ameliorate the identified impediments. ACKNOWLEDGMENTS: Thanks go to David A. Acevedo and Jesus Velo, of the HUD Los Angeles Fair Housing and Equal Opportunity Office, and Ralph Castaneda, Jr., of Castaneda & Associates, for providing substantial content that went into the preparation of this survey. PLEASE RETURN COMPLETED SURVEY VIA E -MAIL TO DAVID LEVY AT: dlevy(a)fairhousingoc.org 192 Attachment B City of La Habra Chapter 18.09 Reasonable Accommodations in Housing to Disabled Individuals 18.09.010 Purpose. It is the purpose of this chapter, pursuant to Fair Housing Laws, to provide individuals with disabilities reasonable accommodation in the application of the city's rules, policies, practices and procedures, as necessary to ensure equal access to housing. The purpose of this chapter is to provide a process for individuals with disabilities to make requests for, and be provided, reasonable accommodation from the various land use, zoning, or building laws, rules, policies, practices and /or procedures of the city, where warranted. (Ord. 1684 § 22 (part), 2007) 18.09.020 Definitions. A. Applicant. A person, business, or organization making a written request to city for reasonable accommodation in the strict application of land use or zoning provisions of this title. B. City. The city of La Habra. C. Code. The La Habra Municipal Code. D. Department. The community development department of city. E. Director. The community development director of city. F. Disabled or Handicapped Person. An individual who has a physical or mental impairment that substantially limits one or more of that person's major life activities; anyone who is regarded as having such impairment; or anyone who has a record of having such an impairment, but not including an individual's current, illegal use of a controlled substance. G. Fair Housing Laws. The "Fair Housing Amendments Act of 1988" (42 U.S.C. § 3601, et seq.), including reasonable accommodation required by 42 U.S.C. § 3604(f)(3)(B), and the "California Fair Employment and Housing Act" (California Government Code Section 12900, et seq.), including reasonable accommodation required specifically by California Government Code Sections 12927(c)(1) and 12955(1), as any of these statutory provisions now exist or may be amended from time to time. (Ord. 1684 § 22 (part), 2007) 18.09.030 Notice to the public of availability of accommodation process. The department shall prominently display in the public areas of the planning and building and safety department at city hall a notice advising those with disabilities or their representatives that they may request a reasonable accommodation in accordance with the procedures established in this chapter. City employees shall direct individuals to the display whenever they are requested to do so or reasonably believe that individuals with disabilities or their representatives may be entitled to a reasonable accommodation. (Ord. 1684 § 22 (part), 2007) 18.09.040 Requesting reasonable accommodation. A. In order to make specific housing available to an individual with a disability, a disabled person or representative may request reasonable accommodation, pursuant to this chapter, relating to the application of various land use, zoning, or building laws, rules, policies, practices and /or procedures of the city. B. If an individual or representative needs assistance in making a request for reasonable accommodation, or appealing a determination regarding reasonable accommodation, 4J°3 the department will endeavor to provide the assistance necessary to ensure that the process is accessible to the applicant or representative. The applicant may be represented at all stages of the proceeding by a person designated by the applicant as his or her representative. C. A request for reasonable accommodation in laws, rules, policies, practices and /or procedures must be filed on an application form provided by the department and shall include the following information: 1. A description of how the property will be used by the disabled individual(s); 2. The basis for the claim that the Fair Housing Laws apply to the individual(s) and evidence supporting the claim, which may be in the form of a letter from a medical doctor or other licensed healthcare professional, a handicapped license, or other appropriate evidence; and 3. The specific reason the requested accommodation is necessary to make particular housing available to the disabled individual(s). D. A filing fee in an amount as determined from time to time by resolution of the city council, but not to exceed the reasonable estimated costs to the city in processing the application. (Ord. 1684 § 22 (part), 2007) 18.09.050 Decision on application. A. The director shall have the authority to consider and act on requests for reasonable accommodation. The director shall issue a written determination within thirty days of the date of receipt of a completed application and may (1) grant the accommodation request, (2) grant the accommodation request subject to specified nondiscriminatory conditions, (3) deny the request, or (4) may refer the matter to the planning commission, which shall render a decision on the application in the same manner as it considers an appeal. All written determinations shall give notice of the right to appeal and the right to request reasonable accommodation on the appeals process, if necessary. The notice of determination shall be sent to the applicant by first class mail. B. If necessary to reach a determination on the request for reasonable accommodation, the director may request further information from the applicant consistent with this chapter, specifying in detail what information is required. In the event a request for further information is made, the thirty -day period to issue a written determination shall be stayed until the applicant reasonably responds to the request. (Ord. 1684 § 22 (part), 2007) 18.09.060 Required findings. The following findings must be made in order to approve a request for reasonable accommodation: A. The housing, which is the subject of the request for reasonable accommodation, will be used by an individual protected under the Fair Housing Laws. B. The request for reasonable accommodation is necessary to make specific housing available to one or more individuals protected under the Fair Housing Laws. C. The requested reasonable accommodation will not impose an undue financial or administrative burden on the city. D. The requested accommodation will not require a fundamental alteration of the zoning or building laws, policies and /or procedures of the city. If, based upon all of the evidence presented to the director, the above findings may reasonably be made, the director shall grant the requested reasonable accommodation. (Ord. 1684 § 22 (part), 2007) 294 18.09.070 Appeals. A. Within thirty days of the date the director issues a written determination, any person aggrieved or affected by a decision on an application requesting the accommodation may appeal such determination in writing to the planning commission or to the city council, as applicable. B. All appeals shall contain a statement of the grounds for the appeal. C. No such appeal shall be accepted unless there is, paid contemporaneously with the filing of such letter, a filing and processing fee in a sum to be set by resolution of the city council. Upon receipt of a timely filed appeal, together with the filing and processing fee, the secretary of the planning commission or the city clerk shall set the matter for a de novo hearing before the planning commission or city council, as applicable, at its next most convenient meeting. D. Appeals shall be to the planning commission, or the city council as applicable, which shall hear the matter and render a determination as soon as reasonably practicable, but in no event later than sixty days after an appeal has been filed, or after an application has been referred to it by the director. All determinations shall address and be based upon the same findings required to be made in the original determination from which the appeal is taken. E. An applicant may request reasonable accommodation in the procedure by which an appeal will be conducted. F. Any determination by the planning commission or city council on an application or appeal shall be by a de novo hearing. G. An applicant requesting the accommodation may appeal an adverse determination or any conditions or limitations imposed by the director to the planning commission and the planning commission's decision to the city council, in accordance with this section. In the case of an appeal of the director's decision to the planning commission or the planning commission's decision to the city council, the planning commission and city council decisions shall be final. (Ord. 1684 § 22 (part), 2007) 18.09.080 Waiver of time periods. Notwithstanding any provisions in this chapter regarding the occurrence of any action within a specified period of time, the applicant may request additional time beyond that provided for in this chapter or may request a continuance regarding any decision or consideration by the city of the pending appeal. Extensions of time sought by applicants shall not be considered delay on the part of the city, shall not constitute failure by the city to provide for prompt decisions on applications and shall not be a violation of any required time period set forth in this chapter. (Ord. 1684 § 22 (part), 2007) 195 Attachment C City of La Habra Chapter 18.21 Special Needs Housing 18.21.010 Puroose. The purpose of this chapter is to establish uniform standards, land use regulations and permit processes for the development of congregate housing, domestic violence shelters, homeless shelters, senior hotel, single -room occupancy housing (SROs), and transitional housing; and to implement general plan policies regarding special needs households. (Ord. 1460 § 1 (part), 1993) 18.21.020 Definitions. "Congregate housing" means a residential facility with shared common living areas, restricted by an agreement approved by the city for occupancy by low and very low income households, providing services which may include meals, housekeeping, child care, and other services as well as common areas for residents of the facility. "Domestic violence shelter" means a residential facility which provides temporary accommodations to persons and /or families who have been the victims of domestic violence. Such a facility may provide meals, child care, counseling, and other services. The term "temporary accommodations" means that a person or family will be allowed to reside at the shelter for a time period not to exceed six months. "Homeless shelter" means a residential facility which provides temporary accommodations to homeless persons and /or families and which meet standards for shelters contained in Title 25 California Administrative Code, Part 1, Chapter F, Subchapter 12, Section 7972. The facility may provide, or contract with recognized community organizations to provide, emergency or temporary shelter, and may also provide meals, child care, counseling, and other services. Such facility may have individual rooms, but is not developed with individual dwelling units, with the exception of manager units. The term "temporary accommodations" means that a person or family will be allowed to reside at the shelter for a time period not to exceed six months. "Low income family" means any household whose income exceeds fifty percent but does not exceed eighty percent of median income adjusted for household size as defined by the U.S. Department of Housing and Urban Development for the Anaheim -Santa Ana Primary Metropolitan Statistical Area. "Senior hotel" means a cluster of guest units with shared common living areas, restricted for occupancy by persons who are sixty -two years of age or older, providing services which may provide meals, housekeeping and other services. "Single -room occupancy housing" means a cluster of guest units within a residential hotel providing sleeping and living facilities restricted by an agreement approved by the city for occupancy by low and very low income individuals, designed for occupancy for periods of one month or longer. ?90 "Transitional housing" means a residential facility that provides accommodations to low and very low income persons and families for periods of up to two years, and which also may provide meals, child care, counseling, and other services, as well as common areas for residents of the facility. The intent of this type of facility is to provide a stable environment for the homeless and to facilitate self - sufficiency. This type of facility typically involves a situation wherein the resident is accountable to the owner /operator for his location and conduct among other factors. "Very low income" means any household whose income does not exceed fifty percent of median income adjusted for household size as defined by the U.S. Department of Housing and Urban Development for the Anaheim -Santa Ana Primary Metropolitan Statistical Area. (Ord. 1684 § 13, 2007; Ord. 1460 § 1 (part), 1993) 18.21.030 Applicability, A. The specific requirements of this chapter are applicable to the development of congregate housing, domestic violence shelters, homeless shelters, senior hotels, single -room occupancy housing (SROs), and transitional housing as defined in Section 18.21.020. B. Congregate housing, domestic violence shelters, homeless shelters, senior hotels, single - room occupancy (SROs), and transitional housing projects are permitted within commercial, industrial, and high density land use designated areas within multiple family zone with an approved conditional use permit pursuant to the procedures established in Chapter 18.58. (Ord. 1460 § 1 (part), 1993) 18.21.040 General provisions. A. All facilities shall maintain a scale, character, and design consistent with the area and compatible with the surrounding developments. B. All congregate housing, domestic violence shelter, homeless shelter, senior hotel, single room occupancy (SROs) and transitional housing projects within permitted commercial, industrial, and residential zones shall be subject to the special development standards established in Section 18.18.070. C. Site Access. A single controlled entryway for routine ingress to the site shall be situated adjacent to and in full view of the manager's office. D. Laundry Facilities. Washer and dryer shall be provided in a separate room in a location accessible to all the residents of the facility. Washers and dryers may be coin - operated. E. Child Care Area. All facilities providing child care on -site shall provide yard area in compliance with all state regulations. The yard area required for child care shall be provided in addition to the required usable yard area for the facility. F. Pay Telephone. A minimum of two pay telephones shall be provided in the facility. G. On -site Manager. Each congregate housing, domestic violence shelter, homeless shelter, single room occupancy (SROs), senior citizen hotel and transitional housing project shall have a twenty -four hour on -site manager. 197 H. Management Plan. A management plan the conditional use permit application. The information, as applicable: shall be submitted for review and approval with management plan shall contain the following 1. Child care; 2. Emergency procedures; 3. Maintenance plans; 4. Management policies; 5. Operation of the facility; 6. Rental procedures and policies; 7. Residency rules; 8. Screening of residents to insure compatibility with services provided at the facility; 9. Security programs; 10. Services, training, counseling, and treatment programs for residents to be provided by the facility, including services to assist resident to obtain permanent income and shelter; 11. Staffing needs; 12. Staff training; 13. Tenants responsibility. Project Review. 1. Annual Review. Each project shall be subject to annual review by the city which includes the review of management services. The project owner shall be responsible for filing an annual report to the city which includes the range of monthly rents, average length of tenancy, range of monthly income of residents, occupancy rates, number of family served, the number of vehicles owned by the residents, and services provided at the facility; 2. Management Plan Revisions. Management plan revisions shall be reviewed and approved by the chief planner, before implementation of changes. Substantive changes or revisions as determined by the chief planner shall be approved by the planning commission. (Ord. 1460 § 1 (part), 1993) 18.21.050 Congregate housing, domestic violence shelter and transitional housing. Congregate housing, domestic violence shelter and transitional housing shall conform to all standards of development of the zoning in which it is located except as provided in this section. A. Density. 1. In high density residential land use designated areas within multiple family residential zones, the number of families shall not exceed the number of families permitted pursuant to the appropriate zoning designation provided for in Table 18.18.060.1 -C, plus twenty -five percent. 2. In all commercial and industrial zones, the number of families shall not exceed that pursuant to the zoning designation provided in Table 18.21.050A, plus twenty -five percent. The maximum floor area ratio (FAR), shall not exceed that established within the appropriate land use designation of the general plan land use element. Table 18.21.050A Total Area Of Parcel Being Developed Minimum Area Per Family Within: CP; C -1; C -2; C -3; PC -I; M -1 Under 10,000 square feet 1,980 10,001 through 20,000 square feet 1,742 20,001 square feet and over 1,555 B. Building Design. 1. Each facility within the high density residential, commercial, and industrial land use designated areas shall contain common kitchen, dining and living room areas adequate for the number of residents serviced. a. Bathrooms shall contain lavatory, toilet, and shower or bathtub adequate for the number of residents serviced, b. Each bedroom shall have access to a bathroom, C. Each bedroom shall have a minimum of eighteen square feet of closet/storage space, d. Bedroom occupancy shall be determined in accordance with the Uniform Building Code or as limited by the planning commission; 2. Each facility shall provide private sleeping areas per families serviced in accordance with the requirements of the building code. C. Recreational and Usable Yard Area. 1. Minimum Area Per Parcel. Such usable yard area shall have no dimension of less than fifteen feet. This area may be provided at any location on the lot except in the required front yard or in a required side yard abutting a street. This area may be divided into not more than two separate subareas. a. Within the multiple family zone, no parcel of land shall have less than one thousand square feet of usable yard area plus one hundred square feet per bedroom, b. Within commercial and industrial zones, no parcel of land shall have less than eight hundred square feet of usable yard area plus eighty square feet per bedroom. D. Parking. 1. Automobiles. For each facility located within an allowed designation, a minimum of two parking spaces shall be provided per the standards established in Chapter 18.56. (Ord. 1693 § 2(b), 2008; Ord. 1460 § 1 (part), 1993) 18.21.060 Homeless shelter. Homeless shelters shall conform to all standards of development of the zoning in which it is located except as provided in this section. 199 A. Density 1. In high density residential land use designated areas within a multiple family zone, the number of beds shall be limited to three times the maximum units permitted within the zoning designation in which the facility is located as established in Table 18.18.060.1 -C; 2. In all commercial and industrial zones, the number of beds shall be limited to three times the maximum number of units allowed within the commercial /industrial zone as provided in Table 18.21.050A. The proposed development shall not exceed the maximum floor area ratio (FAR) established within the general plan land use element for the appropriate land use designation. B. Building Design. 1. Each facility shall provide common kitchen and dining room area adequate for the number of residents serviced; 2. Each facility shall provide bathroom with lavatory, toilet, and showers adequate for the number of residents serviced. C. Recreational and Usable Yard Area. 1. Minimum Area Per Parcel. Such usable yard area shall have no dimension of less than fifteen feet. This area may be provided at any location on the lot except in the required front yard or in a required side yard abutting a street. Subareas may be divided into not more than two separate subareas. a. Within multiple family zones, no parcel of land shall have less than one thousand square feet of usable yard area plus sixty -two square feet per bed, b. Within the commercial and industrial zones, no parcel of land shall have less than five hundred square feet of usable yard area plus ten square feet of additional usable yard area per each additional bed over twenty -five. D. Parking. (See Chapter 18.56.) E. Operating and Location Requirements. 1. No more than one federal, state or youth authority parolee shall be allowed to live in a homeless shelter at any one time. 2. The conditional use application submitted for any homeless shelter shall provide information, including identifying information such as the full name and age of the parolee and the proposed time of residency at the facility, regarding any proposed residents who will be, at the time of proposed residency in the homeless shelter, federal, state or youth authority parolees. Such information shall be updated with the city by the owner or landlord of the facility as to each lessee, renter, resident or occupant upon the signing, entering into, or otherwise commencing any rental or lease agreement, arrangement or accommodation within three business days. 3. All homeless shelters shall require residents or occupants to sign an agreement that provides that a conviction for any criminal violation, not including infractions and minor traffic 200 violations, during residency or occupancy in the transitional shelter /house, is grounds for termination of the residency, tenancy, occupancy or accommodations of that resident or occupant, whether the rental, lease, or sublease agreement is written or oral. 4. Homeless shelters shall be in compliance with all requirements of the city's zoning code at all times, as well as any other applicable provisions of this code, including obtaining any other permits or licenses, such as building permits or a business license, required before establishing, expanding or maintaining the use. 5. No homeless shelter shall be maintained as a nuisance. The conduct of any homeless shelter within the city in violation of any of the terms of this chapter or other applicable provisions of this code found and declared to be a public nuisance, and the city attorney or the district attorney may, in addition or in lieu of prosecuting a criminal action hereunder, commence an action or proceeding for the abatement, removal and enjoinment thereof, in the manner provided by law; and shall take other steps and shall apply to such courts as may have jurisdiction to grant such relief as will abate or remove such homeless shelter and restrain and enjoin any person from conducting, operating or maintaining a homeless shelter contrary to the provisions of this chapter or code. 6. Any violation of any local, state or federal laws by residents or occupants of homeless shelters while on the premises shall be grounds for revocation of the homeless shelter's conditional use permit, including but not limited to any violations of this section, California Penal Code Section 3003.5 or Chapter 9.66 of this code, where the property owner contributed to or did not take all reasonable steps to protect against or prevent the violation. 7. Any owner, operator, manager, employee or independent contractor of a homeless shelter violating or permitting, counseling, or assisting the violation of any of the provisions of this chapter or applicable provisions of this code regulating homeless shelters shall be subject to any and all civil remedies, including conditional permit revocation, criminal penalties pursuant to Chapter 1.08 of this code, and /or administrative citations pursuant to Chapter 1.09. All remedies provided herein shall be cumulative and not exclusive. Any violation of these provisions shall constitute a separate violation for each and every day during which such violation is committed or continued. (Ord. 1693 § 2(c), 2008; Ord. 1684 § 14, 2007; Ord. 1460 § 1 (part), 1993) 18.21.070 Senior hotel. Senior hotels shall conform with all local state and federal requirements for senior housing. Each facility shall conform to all property development standards of the zoning in which it is located except as provided in this section. A. Density. 1. In high density residential land use designated areas within multiple family residential zoned areas, the number of units shall not exceed that pursuant to the zoning designation provided in Table 18.18.060.1 -C, plus twenty -five percent; 2. In all commercial and industrial zones, the number of units shall be limited by the maximum floor area ratio (FAR) as established within the general plan land use element for the appropriate land use designation. 201 B. Building Design. Each guest unit shall contain a bathroom. 1. Bathrooms shall contain a lavatory, toilet, and shower or bathtub; 2. Each unit shall have a minimum forty -eight cubic feet of closet/storage space. C. Recreational and Usable Yard Area. 1. Minimum Area Per Parcel. Such usable yard area shall have no dimension of less than fifteen feet. This area may be provided at any location on the lot except in the required front yard or in a required side yard abutting a street. a. Within multiple family zones, no parcel of land shall have less than one thousand square feet of usable yard area plus one hundred square feet per bedroom. b. Within the commercial and industrial zones, no parcel of land shall have less than one thousand square feet of common usable yard area plus fifteen square feet of common recreational area per guest unit for projects over twenty -five units. 2. Common recreational space may be indoor or outdoor provided there is at least forty percent allotted towards outdoor space; the balance may be indoors or outdoors. D. Parking. (See Chapter 18.56.) E. Common Facilities. The development may provide one or more of the following common facilities for the exclusive use of the senior citizen residents: 1. Central cooking and dining room; 2. Recreation room; 3. Library; 4. Beauty salon and barber shop; 5. Small pharmacy; 6. Laundry facilities or laundry services. F. Occupancy. 1. No more than one person shall be permitted to reside in any unit which is less than two hundred twenty square feet in size. No more than two persons shall be permitted to reside in any unit. 2. Residential occupancy shall be limited to single persons sixty -two years of age or older, or to couples in which one person is sixty -two years of age or older. (Ord. 1693 § 2(d), 2008; Ord. 1460 § 1 (part), 1993) 202 18.21.080 Sinale -room occuoancv housina (SROs). SRO projects shall conform to all standards of development of the zoning in which it is located except as provided below. A. Density. 1. In high density residential land use designated areas with multiple family residential zones, the number of units shall not exceed that pursuant to the zoning designation provided in Table 18.18.060.1 -C, plus twenty -five percent; 2. In all commercial and industrial zones, the number of units shall be limited by the maximum floor area ratio (FAR), as established within the appropriate land use designation of the general plan land use element. B. Building Design. 1. Unit Size. Minimum unit size for all SROs shall be one hundred seventy square feet and maximum unit size for all SROs shall be four hundred square feet; 2. Each unit shall contain a kitchen and bathroom. a. Kitchens shall contain a sink with garbage disposal, counter top minimum sixteen by twenty -four inch, refrigerator, and stove or microwave oven, b. If stoves are not provided in each unit, then stoves shall be provided in a common C. Bathrooms shall contain a lavatory, toilet, and shower or bathtub, d. Each unit shall have a minimum forty -eight cubic feet of closet/storage space. C. Recreational and Usable Yard Area 1. Minimum Area Per Parcel a. Within multiple - family zones, no parcel of land shall have less than one thousand square feet of usable yard area plus one hundred square feet per unit, b. Within the commercial and industrial zones, no parcel of land shall have less than five hundred square feet of common usable yard area plus fifteen square feet of common recreational area per unit for projects over twenty -five units. Such usable yard area shall have no dimension of less than fifteen feet. This area may be provided at any location on the lot except in the required front yard or in a required side yard abutting a street; 2. Common recreational space may be indoor or outdoor provided there is at least forty percent allotted towards outdoor space; the balance may be indoors or outdoors. D. Parking. (See Chapter 18.56.) E. Occupancy. No more than one person shall be permitted to reside in any unit which is less than two hundred twenty square feet in size. No more than two persons shall be permitted to reside in any unit. (Ord. 1693 § 2(e), 2008; Ord. 1460 § 1 (part), 1993) 203 18.21.090 Transitional housing project. Transitional housing projects shall also comply with the following operating and location requirements: A. No more than one federal, state or youth authority parolee shall be allowed to live in a transitional housing project at any one time. B. No transitional housing project shall be within five hundred feet of any other transitional housing project. The distance requirement herein shall be measured from property line to property line, along a straight line extended between the two points. C. The conditional use application submitted for any transitional housing project shall provide information, including identifying information such as the full name and age of the parolee and the proposed time of residency at the facility, regarding any proposed residents who will be, at the time of proposed residency in the transitional housing project, federal, state or youth authority parolees. Such information shall be updated with the city by the owner or landlord of the facility as to each lessee, renter, resident or occupant upon the signing, entering into, or otherwise commencing any rental or lease agreement, arrangement or accommodation within three business days. D. All transitional housing projects shall require residents or occupants to sign an agreement that provides that a conviction for any criminal violation, not including infractions and minor traffic violations, during residency or occupancy at the transitional housing project, is grounds for termination of the residency, tenancy, occupancy or accommodations of that resident or occupant, whether the rental, lease, or sublease agreement is written or oral. E. Transitional housing projects shall be in compliance with all requirements of the city's zoning code at all times. F. No transitional housing project shall be maintained as a nuisance. The conduct of any transitional housing project within the city in violation of any of the terms of this chapter or other applicable provisions of this code found and declared to be a public nuisance, and the city attorney or the district attorney may, in addition or in lieu of prosecuting a criminal action hereunder, commence an action or proceeding for the abatement, removal and enjoinment thereof, in the manner provided by law, and shall take other steps and shall apply to such courts as may have jurisdiction to grant such relief as will abate or remove such transitional housing project and restrain and enjoin any person from conducting, operating or maintaining a transitional housing project contrary to the provisions of this chapter or code. G. Any violation of any local, state or federal laws by residents or occupants of transitional housing projects while on the premises shall be grounds for revocation of the transitional housing project's conditional use permit, including but not limited to any violations of this section, California Penal Code Section 3003.5 or Chapter 9.66 of this code, where the property owner contributed to or did not take all reasonable steps to protect against or prevent the violation. H. Any owner, operator, manager, employee or independent contractor of a transitional housing project violating or permitting, counseling, or assisting the violation of any of the provisions of this chapter or applicable provisions of this code regulating transitional housing projects shall be subject to any and all civil remedies, including conditional permit revocation, i�ZJr criminal penalties pursuant to Chapter 1.08 of this code, and /or administrative citations pursuant to Chapter 1.09. All remedies provided herein shall be cumulative and not exclusive. Any violation of these provisions shall constitute a separate violation for each and every day during which such violation is committed or continued. (Ord. 1684 § 15, 2007) 205 Attachment D City of San Francisco Chapter 87 Fair Housing Implementation Ordinance SEC. 87.1. - SHORT TITLE. This ordinance shall be entitled the "Fair Housing Implementation Ordinance." (Added by Ord. 303 -99, File No. 990494, App. 12(3199) SEC. 87.2. - FINDINGS. The Board of Supervisors finds that: (a) Federal, state and local fair housing laws protect certain classes of individuals from housing discrimination that may occur through zoning laws, land use authorizations, funding decisions and other activities of local government. These laws include, but are not limited to: (1) The federal Fair Housing Act, 42 U.S.C. §§ 3601 et seq. This law prohibits, among other things, local government from making dwellings unavailable because of the race, color, religion, sex, familial status, national origin, or handicap of the individual(s) seeking such dwellings. (2) California Government Code Section 12955 (the "California Fair Employment and Housing Act'). This law prohibits local government from (i) making housing unavailable, and (ii) discriminating through land use practices, decisions, and authorizations, because of race, color, religion, sex, familial status, marital status, disability, national origin, or ancestry. Prohibited practices include, but are not limited to, zoning laws, denials of use permits, and other actions under the Planning and Zoning Law, Government Code § 65000 et seq., that make housing opportunities unavailable because of protected class status. (3) California Government Code Section 12955.8(a) (the "California Fair Employment and Housing Act'). This law establishes that a local government engages in unlawful housing discrimination if race, color, religion, sex, familial status, marital status, disability, national origin, or ancestry is a motivating factor when a land use practice, decision, authorization, or other local action makes housing unavailable to members of a protected class. (4) California Government Code Section 12955.8(b) (the "California Fair Employment and Housing Act'). This law establishes that a local government engages in unlawful housing discrimination if a land use practice, decision, authorization, or other local action has an unjustified discriminatory effect, regardless of intent, on the basis of race, color, religion, sex, familial status, marital status, disability, national origin, or ancestry. (5) California Government Code Section 65008 (the "California Planning and Zoning Law "). This law prohibits, among other things, local government, in the enactment or administration of zoning laws, from discriminating against a residential development because the development is intended for occupancy by low and moderate income persons. This Act also prohibits local government from imposing different requirements on residential developments because of race, sex, color, religion, ethnicity, national origin, ancestry, lawful occupation or age of the intended occupants of the development, or because of the income 200 level of the intended occupants of the development, unless the local government imposes those requirements on developments generally or the requirements promote the availability of the residential development for lower income persons. (6) California Government Code Section 65589.5 (the "California Planning and Zoning Law "). This law prohibits a local government agency from disapproving a housing development for low- and moderate - income households or conditioning approval in a manner which renders the project infeasible for development for use by low- and moderate- income households unless the local agency makes one of six findings justifying such disapproval or conditions. (7) Section 3604(f)(B)(3) of Title 42 of the United State Code (the "Fair Housing Act ") and Section 12927(c)(1) of the California Government Code (the "California Fair Employment and Housing Act'). These laws prohibit local government from refusing to make reasonable accommodations in policies and practices when these accommodations are necessary to afford persons with disabilities equal opportunity to use and enjoy a dwelling. (8) Section 3304 of Article 33 of the San Francisco Police Code. This ordinance establishes, among other things, that local government engages in unlawful housing discrimination if the inclusion of restrictions, terms or conditions on real property transactions, the imposition of different conditions on financing for the construction, rehabilitation, or maintenance of real property, or the restriction of facilities for any tenant or lessee is based wholly or partially on race, religion, color, ancestry, age, sex, sexual orientation, gender identity, disability or place of birth. (b) Federal, state and local fair housing laws require that departments, agencies, commissions, officers, and employees of the City and County of San Francisco shall not base any decision about housing development on evidence that discriminates against the classes protected by these laws. (c) Federal, state and local fair housing laws require that departments, agencies, commissions, officers and employees of the City and County of San Francisco shall not impose, when approving a housing development, any conditions that discriminate against the classes protected by these laws. (d) This ordinance will facilitate compliance with federal, state and local fair housing laws, and promote housing opportunities for residents of San Francisco. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.3. - DEFINITIONS. (a) Protected Class. 'Protected class" means those groups that receive protection from housing discrimination under the Fair Housing Act, 42 U.S.C. §§ 3601 et seq., the California Fair Employment and Housing Act, Government Code §§ 12900 et seq., Sections 65008 and 65589.5 of the Government Code, and Section 3304 of Article 33 of the San Francisco Police Code. (b) City Entity. "City entity" includes the Board of Supervisors, the Executive Branch as described in Articles III, IV, and V of the Charter of the City and County of San Francisco, and any department, agency, commission, officer, employee, or advisory group of the City and County of San Francisco. (c) Dwelling. "Dwelling" shall have the same meaning as the definition of "dwelling" in Section 3602 of Title 42 of the United States Code (the "Fair Housing Act'). 20 j (d) Fair Housing Laws. "Fair housing laws" shall mean those laws described in Section 87.2, above, together with any other federal, State or local laws related to housing discrimination. (e) Family. "Family" shall have the same meaning as in Section 401 of the San Francisco Housing Code. (f) Supportive Services. "Supportive services" means services that are provided to residents of a housing development and that are based on their particular needs and circumstances. These services include, but are not limited to, counseling, vocational training, case management, medical services, peer -based services, rehabilitative services, skills development, and recreational activities. The use of a portion of a residential building to provide supportive services for the building's residents shall be a permissible accessory use to the building. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.4. - COMPLIANCE WITH FAIR HOUSING LAWS. When any City entity considers an application or proposal for the development, use, or funding of dwellings in which protected class members are likely to reside, or when any City entity applies existing City codes, regulations, or other standards to such dwellings, the City entity shall comply with all applicable fair housing laws and administer local policies, procedures, and practices in a manner that affirmatively furthers those laws. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.5. - NO DECISIONS BASED ON DISCRIMINATORY INFORMATION With respect to applications or proposals for the development, use, or funding of dwellings in which protected class members are likely to reside, a City entity shall not base any decision regarding the development, use, or funding of the dwellings on information which may be discriminatory to any member of a protected class. This discriminatory information includes, but is not limited to, the following: (a) That the dwellings will lower the property values of surrounding parcels of land because members of a protected class will reside in the dwellings; (b) That the dwellings will increase crime in the neighborhood because members of a protected class will reside in the dwellings; (c) That the dwellings will generate an increased demand for parking or generate more traffic because members of a protected class will reside in the dwellings; (d) That the dwellings will not be compatible with a neighborhood or community because members of a protected class will reside in the dwellings; (e) That the dwellings will increase the concentration of dwellings or services for members of a protected class in a particular neighborhood or area of the city; (f) That the dwellings will be detrimental to, or have a specific, adverse impact upon, the health, safety, convenience or general welfare of persons residing or working in the vicinity because members of a protected class will reside in the dwellings; (g) That the dwellings will be injurious to property, improvements or potential development in the vicinity because members of a protected class will reside in the dwellings; (h) That the dwellings will generate an increased demand for city services because members of a protected class will reside in the dwellings. I: (i) That the dwellings will not be appropriate for the neighborhood because supportive services will be provided to members of a protected class residing in the dwellings. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.6. - NONDISCRIMINATORY CONDITIONS OF APPROVAL. With respect to applications or proposals for the development, use, or funding of dwellings in which protected class members are likely to reside, a City entity shall not impose on the approval of the dwellings (a) any condition that it does not impose on other dwellings of similar scale and size in the use district or zoning classification specified in the San Francisco Planning Code, or (b) any conditions of approval which are based on the fact that protected class members are likely to reside in the dwellings, including but not limited to restrictions on the activities of residents in or around the dwellings, restrictions on visitors to the dwellings, requirements for additional off - street parking, special review or monitoring of the dwellings by a City entity or neighborhood group, restrictions on services provided to residents, special design or maintenance requirements for the dwellings, and restrictions on future development on or near the site. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.7. - REASONABLE ACCOMMODATIONS. With respect to applications or proposals for the development, use, or funding of dwellings in which protected class members are likely to reside, a City entity shall make reasonable accommodations in its rules, policies, practices, or services when those accommodations may be necessary to afford persons with disabilities equal opportunities to use and enjoy the dwellings. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.8. - NONDISCRIMINATORY APPLICATION OF STANDARDS. Nothing in this Chapter shall be construed to prohibit a City entity from applying building and planning standards, design review, health and safety standards, environmental standards, or any other standards within the jurisdiction of the City entity as long as those standards are identical to those applied to other dwellings of similar scale and size in the use district or zoning classification specified in the San Francisco Planning Code, unless the City entity is required to make a reasonable accommodation under Section 87.7 of this Chapter. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.9. - APPLICABILITY. This Chapter shall, among other things, apply to all actions, practices, and other decisions of any City entity having discretionary authority over permits, funding, conditions of approval, or other matters related to the development of dwellings. These actions, practices, and decisions include, but are not limited to, conditional use authorizations under Section 303 of the San Francisco Planning Code, variances under Section 305 of the San Francisco Planning Code, permits under Article 1 of Part III of the San Francisco Municipal Code, discretionary review of permits under Section 26 of Article 1 of Part III of the San Francisco Municipal Code, subdivision approvals under the San Francisco 209 Subdivision Code, permit approvals under the San Francisco Public Works Code, and any actions authorized under law by the Board of Appeals, the Building Inspection Commission, the Health Commission, and other city entities, regardless of whether the laws or regulations describing such discretionary authority specifically refer to the City entity's obligations under this Chapter. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.10. - COMPLIANCE BY STATE - AUTHORIZED AGENCIES. Upon the effective date of this ordinance, the Mayor shall request, in writing, compliance with this ordinance by any state - authorized agency operating solely within the City and County of San Francisco and having authority over permits, funding, conditions of approval, or other matters related to the development of dwellings. (Added by Ord. 303 -99, File No. 990494, App. 1213199) SEC. 87.11. - SEVERABILITY. If any part or provision of this Chapter, or the application thereof to any person or circumstance, is held invalid, the remainder of the Chapter, including the application of such part or provision to other persons or circumstances, shall not be affected thereby and shall continue in full force and effect. To this end, provisions of this Chapter are severable. (Added by Ord. 303 -99, File No. 990494, App. 1213199) 210 Section 7 AFFH Through the Location of Affordable Housing 211 SECTION 7 AFFH THROUGH THE LOCATION OF AFFORDABLE HOUSING A. BACKGROUND A lack of affordable housing in and of itself, HUD has pointed out, is not an impediment to fair housing choice, unless it creates an impediment to housing choice because of membership in a protected class. However, recent court cases and recent events have demonstrated that the location of affordable housing is regarded as a means of AFFH. As a result of a court settlement, Westchester County (New York) must adopt a policy statement providing that "the location of affordable housing is central to fulfilling the commitment to AFFH because it determines whether such housing will reduce or perpetuate residential segregation." (United States of America ex rel. Anti - Discrimination Center of Metro New York, Inc. v. County of Westchester, New York) In order to meet the requirements of the settlement agreement, Westchester County must develop an implementation plan that includes, but is not limited, to: • A model ordinance that the County will promote to municipalities to advance fair housing that shall include: ✓ A model inclusionary housing ordinance that requires new development projects to include a certain percentage of affordable units, including criteria and standards for the affordable housing units and definitions of who is eligible for affordable housing; ✓ Standards for affirmative marketing of new housing developments to ensure outreach to racially and ethnically diverse households; • Standards for expedited review of proposals for affordable housing that AFFH including procedures for streamlining the approval process for the design, permitting, and development of these units; and • Standards for legal mechanisms to ensure the continued affordability of new affordable units. Housing developed pursuant to the plan: • Must be located predominantly in municipalities where the African American and Hispanic population comprise less than 3% and 7% of the population, respectively. • Not be developed in any census block which has an African American population of more than 10% and a total population of 20 or more. • Not be developed in any census block which has a Hispanic population of more than 10% and total population of 20 or more. The Westchester County settlement agreement demonstrates that a means to AFFH is by the development of affordable housing outside of areas with concentrations of minority populations. 212 Another example is the State of North Carolina which added "affordable housing" to the group of protected classes. The State passed an act providing that it is a violation of the State's fair housing act to discriminate in land use decisions or the permitting of development based on the fact that a development contains affordable housing units. The Act states: It is an unlawful discriminatory housing practice to discriminate in land -use decisions or in the permitting of development based on race, color, religion, sex, national origin, handicapping condition, familial status, or, except as otherwise provided by law, the fact that a development or proposed development contains affordable housing units for families or individuals with incomes below eighty percent (80 %) of area median income. It is not a violation of this Chapter if land -use decisions or permitting of development is based on considerations of limiting high concentrations of affordable housing. In 2000, Florida's Affordable Housing Study Commission adopted a proposal made by 1000 Friends of Florida to amend the Florida Fair Housing Act by extending protection to affordable housing developments. Florida Statute 760.26 reads: It is unlawful to discriminate in land use decisions or in the permitting of development based on race, color, national origin, sex, disability, familial status, religion, or, except as otherwise provided by law, the source of financing of a development or proposed development. The decision to not specifically use the term "affordable housing" in statutory language has not diminished the intended application of Fair Housing Act protection, according to its advocates. Since enactment, county and city attorneys have regularly advised their commissions that affordable housing developments cannot be treated differently from market -rate developments in land use or permitting decisions. In California, Government Code Section 65008 expressly prohibits localities from discriminating against residential development or emergency shelters if the intended occupants are low - income or if the development is subsidized (i.e., the method of financing). B. DATA SOURCES The purpose of the analysis was to determine whether affordable housing developments are concentrated in neighborhoods with a high concentration of minority populations and low income populations. Neighborhoods with "high concentrations" were determined as follows: • Census tracts with 80% or more minority population • Census tracts with 80% or more of the population having low incomes (that is, incomes less than 80% of the County's median income) Census 2000 is the data source for the minority population data. The low income population is based on HUD calculations, which are based on the Census 2000 data. The statistical information used by HUD in the calculation of the estimates comes from three tables in Summary File (SF) 3: P9 — Household Type (Including Living Alone) by Relationship; P76 — Family Income in 1999; and P79 — Non - family Household Income in 1999. 213 The inventory of affordable housing was determined primarily from two data sources: County of Orange, Orange County Community Services, 2009 County of Orange Affordable Rental Housing List California Tax Credit Allocation Committee, Active Projects Receiving Tax Credits 1987- 2010 Year to Date, May 2010 The affordable housing developments from these two sources were merged and duplicates were eliminated. The overall inventory was further refined by consulting the affordable housing lists maintained by the cities of Anaheim, Garden Grove and Santa Ana. Consulting these lists resulted in adding projects and eliminating a few in cases of duplicates due to different project names with same address. Field surveys were necessary in a few cases because more than one project was located within in the same address range. Lastly, phone calls became necessary to confirm the city location of a project and the number of housing units. The census tract location of each affordable housing development is identified in the CTAC list. The census tract location of all other projects was identified by using American Factfinder: U.S. Census Bureau, American Factfinder Website, Advanced Geography Search, Census Program Year, Address Search. An analysis also was completed on the extent to which Section 8 assisted housing (families) is located in census tracts /neighborhoods with a high percentage (80 %) of minority populations. Housing authorities encourage Section 8 voucher holders to find housing located outside areas of poverty and minority concentration. The Los Angeles Area Office of the U.S. Department of Housing and Urban Development reviewed the Draft Regional Al and requested the analysis of the location of Section 8 housing. Data on the census tract location of Section 8 voucher holders was provided by: • Garden Grove Housing Authority (GGHA) • Santa Ana Housing Authority (SAHA) • Orange County Housing Authority (OCHA) Data was unavailable from the Anaheim Housing Authority (AHA). C. ANALYSIS OF THE LOCATION OF THE AFFORDABLE HOUSING INVENTORY 1. Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Minority Populations Altogether there are 64 census tracts with a minority population of 80% or more. Attachment A on page 7 -29 describes the population composition of the 64 census tracts. Table 7 -1 (pages 7- 5 and 7 -6) shows the number of affordable housing units located in these "high concentration" census tracts as well as the percentage of affordable housing units located in those tracts and each tract's percentage of all affordable housing units. 2-14 The merged database has a total of 20,379 affordable housing units located within the geographic area covered by the Regional Al. Attachment B (page 7 -32) shows the affordable housing stock arranged by census tract. Within this Regional Al area, the affordable housing stock is not concentrated in neighborhoods with a high percentage (80 % +) of minority populations for the reasons cited below: • Forty -two of the high concentration census tracts have no affordable housing units • Almost 16% (3,200) of all affordable housing units (20,379) are located in 22 of 64 high concentration census tracts. • 84% of the affordable housing stock is located in census tracts with less than 80% minority population. • About 8% of the affordable housing stock is located in three census tracts: 744.03 (Santa Ana); 751.02 (Santa Ana); and Anaheim (866.01). There are five census tracts where affordable housing units represent a high percentage of tract's total housing stock: • Santa Ana 744.03 38.2 %, 500 of 1,310 • Santa Ana 745.01 23.4 %, 326 of 1,391 • Santa Ana 750.02 21.1 %, 496 of 2,348 • Anaheim 866.01 24.5 %, 576 of 2,348 • Stanton /Anaheim 878.03 21.6 %, 298 of 1,379 Table 7 -2 on page 7 -7 lists the individual developments which are located in these five census tracts. The three developments located in census tracts 744.03 and 745.01 are located in close proximity. Refer to Map 1 on page 7 -8. The rear property line of Minnie Street is essentially the boundary between the two census tracts. 21 5 Table 7 -1 Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a High Percentage ( >80 %) of Minority Populations -2010 Census Tract City Percent Minority Total Housing Units 2008' Number of Affordable Housing Units2 Percent of Units in Census Tract Percent of All Affordable Units 12.01 La Habra/County 81.55% 1,461 0 0.0% 0.0% 116.02 Fullerton /Anaheim 82.82% 1,647 16 1.0% 0.1% 117.14 Anaheim 80.79% 82 0 0.0% 0.0% 117.2 Anaheim /Placentia 92.54% 1,518 54 3.6% 0.3% 740.03 Santa Ana 94.97% 810 6 0.7% 0.0% 740.05 Santa Ana 86.27% 1,478 0 0.0% 0.0% 741.02 Santa Ana 92.95% 1,301 0 0.0% 0.0% 741.03 Santa Ana 92.59% 918 0 0.0% 0.0% 741.08 Santa Ana 94.08% 887 0 0.0% 0.0% 741.09 Santa Ana 95.04% 663 0 0.0% 0.0% 741.11 Santa Ana 80.83% 1,370 0 0.0% 0.0% 742 Santa Ana 94.76% 1,747 0 0.0% 0.0% 743 Santa Ana 96.67% 797 0 0.0% 0.0% 744.03 Santa Ana 95.32% 1,310 500 38.2% 2.5% 744.05 Santa Ana 94.67% 1,468 24 1.6% 0.1% 744.06 Santa Ana 91.90% 847 0 0.0% 0.0% 744.07 Santa Ana/Tustin 92.55% 1,866 0 0.0% 0.0% 745.01 Santa Ana 99.00% 1,391 326 23.4% 1.6% 745.02 Santa Ana 97.17% 1,010 0 0.0% 0.0% 746.01 Santa Ana 92.94% 1,675 3 0.2% 0.0% 746.02 Santa Ana 97.06% 1,691 0 0.0% 0.0% 747.01 Santa Ana 97.82% 1,410 0 0.0% 0.0% 747.02 Santa Ana 95.96% 1,096 0 0.0% 0.0% 748.01 Santa Ana 98.29% 986 8 0.8% 0.0% 748.02 Santa Ana 93.79% 1,109 60 5.4% 0.3% 748.03 Santa Ana 92.24% 1,781 0 0.0% 0.0% 748.05 Santa Ana 97.68% 1,123 112 10.0% 0.5% 748.06 Santa Ana 98.70% 910 0 0.0% 0.0% 749.01 Santa Ana 98.17% 1,924 204 10.6% 1.0% 749.02 Santa Ana 98.60% 1,184 12 1.0% 0.1% 750.02 Santa Ana 95.57% 2,348 496 21.1% 2.4% 750.03 Santa Ana 96.37% 1,729 48 2.8% 0.2% 750.04 Santa Ana 95.73% 1,316 4 0.3% 0.0% 752.01 Santa Ana 97.28% 1,107 0 0.0% 0.0% 752.02 Santa Ana 94.75% 1,186 0 0.0% 0.0% 753.02 Santa Ana 81.51% 1,125 0 0.0% 0.0% 864.04 Anaheim 81.97% 1,503 0 0.0 % 0.0% 210 Table 7 -1 continued Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a High Percentage ( >80 %) of Minority Populations -2010 Census Tract City Percent Minority Total Housing Units 2008' Number of Affordable Housing Units2 Percent of Units in Census Tract Percent of All Affordable Units 864.05 Anaheim 82.83% 1,658 0 0.0% 0.0% 865.01 Anaheim 84.58% 1,172 0 0.0% 0.0% 865.02 Anaheim 92.36% 1,3891 0 0.0% 0.0% 866.01 Anaheim 87.29% 2,348 576 24.5% 2.8% 873 Anaheim 85.04% 2,839 151 5.3% 0.7% 874.03 Anaheim 85.78% 813 0 0.0% 0.0% 874.04 Anaheim 91.47% 786 0 0.0% 0.0% 874.05 Anaheim 89.23% 1,609 0 0.0% 0.0% 875.04 Anaheim 87.42% 1,937 0 0.0% 0.0% 878.03 Stanton /Anaheim 86.62% 1,379 298 21.6% 1.5% 879.02 Stanton 82.08% 1,311 0 0.0% 0.0% 888.01 Garden Grove 81.15% 2,604 0 0.0% 0.0% 889.02 Garden Grove 81.33% 1,199 80 6.7% 0.4% 889.03 Garden Grove /Santa Ana 85.75% 1,942 0 0.0% 0.0% 889.04 Westminster /Garden Grove 82.05% 1,418 0 0.0% 0.0% 890.01 Santa Ana 89.52% 1,668 0 0.0% 0.0% 890.03 Garden Grove 88.55% 862 0 0.0% 0.0% 890.04 Santa Ana 89.08% 1,791 60 3.4% 0.3% 891.02 Garden Grove /Santa Ana 81.56% 1,607 0 0.0% 0.0% 891.04 Santa Ana /Garden Grove 92.61% 1,358 194 14.3% 1.0% 891.05 Santa Ana 96.72% 1,132 12 1.1% 0.1% 891.06 Garden Grove 81.79% 930 0 0.0% 0.0% 992.02 Santa Ana /Fountain Valley 82.73% 1,832 0 0.0% 0.0% 992.47 Santa Ana 88.88% 798 0 0.0% 0.0% 992.48 Santa Ana 88.67% 1,420 0 0.0% 0.0% 992.49 Santa Ana 97.28% 820 0 0.0% 0.0% 1106.1 Buena Park 83.52% 1,303 0 0.0% 0.0% Total 87,6991 3,232 3.7% 15.9% Note: The merged database has a total of 20,379 affordable units in the area covered by the Regional Al 'California State University, Fullerton, Center for Demographic Research, Orange County Population & Dwelling Unit Estimates by Census Tract, January 1, 2008 2Number of affordable housing units per census tract is obtained from Attachment B on page 7 -32. Table construction by Castaneda & Associates 217 Table 7 -2 Regional Analysis of Fair Housing Impediments Census Tracts with a High Percentage of Affordable Housing Units City/Location Census Tract Project (s) Number of Affordable Units Santa Ana 744.03 Warwick Square 500 Santa Ana 745.01 Wakeham Grant Apartments 126 Cornerstone Village 200 Santa Ana 750.02 Henin er Village Apartments 58 Santa Ana Towers 198 Rosswood Villas 198 Garden Court 42 Anaheim 866.01 Park Vista Apartments 390 Paseo Village 174 Casa Delia 12 Stanton /Anaheim 878.03 Continental Garden Apartments 298 Although near one another, Warwick Square is physically separated from the Minnie Street developments by physical barriers (Metrolink and the Santa Ana -Santa Fe Channel). More importantly, all three complexes were constructed before State law required localities to conduct housing policy planning (i.e., the housing element of the general plan). Warwick Square was built in 1969. The Wakeman Grant Apartments were built in 1961. The Cornerstone Village dwellings were constructed in 1959 and rehabilitated in 2000. In effect, at least for the last two developments, the housing complexes probably accommodated the population already residing in the developments at the time of rehabilitation or the population living near the developments. 212 Map 1 Santa Ana: Warwick Square and Minnie Street Developments Census Tracts 744.03 and 745.01 2 9 Map 2 below shows the locations of the four affordable housing developments located in downtown Santa Ana. Three developments contain a total of 454 senior (62 +) housing units. Two developments (Santa Ana Towers and Rosswood Villas) were built in the mid- 1970s. The third senior housing complex (Heninger Village) was constructed in 1988 and rehabilitated in 2001. Built in 1986, the Garden Court complex has 42 of the 84 family housing units rent restricted. Map 2 Santa Ana: Downtown Santa Ana Affordable Housing Developments Census Tract 750.02 220 Census tract 866.01, which is located in Anaheim, contains three family projects having a total of 576 housing units. Map 3 below shows the locations of the three developments. The construction dates for these developments are: Park Vista, 1958; Paseo Village, 1957; and Casa Delia, 1961. These developments, like many others located in high concentrations areas, were built before local housing policy planning was required and probably became affordable as a result of acquisition /rehabilitation programs. As a result, the housing complexes probably accommodated the population already residing in the developments at the time of rehabilitation or the population living near the developments. Map 3 Anaheim: Park Vista, Paseo Village and Casa Delia Census Tract 866.01 221- 2. Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Minority Populations This part examines the existence of affordable housing opportunities in neighborhoods (census tracts) with a low percentage ( <20 %) of minority populations. Altogether there are 74 census tracts that meet the definition of a neighborhood with a low percentage of minority populations. Thirteen of the 74 census tracts have affordable housing units. In sum, there are 1,108 affordable housing units located in the 13 census tracts, which represents 5.4% of all the affordable housing located within the area covered by the Regional Al. Consequently, it can be stated that affordable housing opportunities exist in neighborhoods with a low percentage of minority populations. The affordable housing units are located in the following cities and communities: • Newport Beach 442 • Huntington Beach 185 • Laguna Beach 135 • Irvine 118 • Yorba Linda 100 • Dana Point 84 • Ladera Ranch 44 Table 7 -3 on the next two pages lists the number of affordable housing units located in these "low concentration" census tracts as well as the percentage of affordable housing units located in those tracts and each tract's percentage of all affordable housing units. 222 Table 7 -3 Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage ( <20 %) of Minority Populations -2010 Census Tract City/Area Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Tract Percent of All Affordable Housing Units 993.10 Huntington Beach 19.79% 2,227 0 0.0% 0.0% 994.07 Huntington Beach 19.75% 968 11 1.1% 0.1% 423.25 Laguna Beach 19.75% 1,550 0 0.0% 0.0% 992.20 Huntington Beach 19.68% 2,407 68 2.8% 0.3% 993.06 Huntington Beach 19.63% 2,836 0 0.0% 0.0% 219.12 Orange/Unincorporated 19.46% 1,379 0 0.0% 0.0% 524.15 Lake Forest 19.32% 1,315 0 0.0% 0.0% 114.02 Fullerton 19.24% 874 0 0.0% 0.0% 992.43 Huntington Beach 19.17% 1,844 0 0.0% 0.0% 320.42 Rancho Santa Mar arita /Uninc. 19.14% 1,778 0 0.0% 0.0% 631.02 Unincorporated 19.11% 2,803 0 0.0% 0.0% 993.07 Huntington Beach 18.38% 1,457 0 0.0% 0.0% 993.11 Huntington Beach 18.10% 2,230 0 0.0% 0.0% 995.12 Seal Beach 18.08% 1,776 0 0.0% 0.0% 218.09 Yorba Linda 18.04% 881 100 11.4% 0.5% 757.03 Unincorporated 17.94% 1,384 0 0.0% 0.0% 219.17 Orange/Unincorporated 17.71% 1,195 0 0.0% 0.0% 1100.06 Unincorporated 17.56% 1,102 0 0.0% 0.0% 626.45 Newport Beach /Uninc. 17.35% 2,692 0 0.0% 0.0% 218.16 Yorba Linda /Uninc. 17.26% 1,770 0 0.0% 0.0% 1100.08 Seal Beach 17.19% 1,731 0 0.0% 0.0% 995.14 Huntington Beach 17.09% 2,455 0 0.0% 0.0% 992.17 Huntington Beach 16.67% 891 0 0.0% 0.0% 320.23 Unincorporated 16.45% 4,345 0 0.0% 0.0% 626.05 Laguna Beach 16.31% 2,183 65 3.0% 0.3% 421.03 Unincorporated 15.74% 3,430 0 0.0% 0.0% 423.28 Laguna Hills 15.17% 843 0 0.0% 0.0% 1100.07 Los Alamitos 14.72% 1,686 0 0.0% 0.0% 320.43 Rancho Santa Margarita 14.65% 1,249 0 0.0% 0.0% 993.09 Huntington Beach 14.64% 1,702 106 6.2% 0.5% 636.03 Newport Beach 14.39% 3,293 91 2.8% 0.4% 995.13 Huntington Beach /Uninc. 14.35% 1,337 0 0.0% 0.0% 995.11 Seal Beach 14.26% 2,032 0 0.0% 0.0% 423.38 Dana Point 13.86% 2,050 0 0.0% 0.0% 320.46 Coto de Caza 13.68% 1,878 0 0.0% 0.0% 421.13 Dana Point 13.56% 1,851 0 0.0% 0.0% 633.02 Newport Beach 13.40% 1,727 0 0.0% 0.0% 630.10 Newport Beach 13.29% 3,372 0 0.0% 0.0% 223 Table 7 -3 continued Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage ( <20 %) of Minority Populations -2010 Census Tract City/Area Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Tract Percent of All Affordable Housing Units 995.06 Seal Beach /Uninc. 12.71% 863 0 0.0% 0.0% 320.52 Ladera Ranch 12.67% 8,124 44 0.5% 0.2% 320.44 Coto de Caza 12.60% 2,013 0 0.0% 0.0% 626.44 Newport Beach 12.52% 3,479 99 2.8% 0.5% 995.04 Seal Beach 12.47% 999 0 0.0% 0.0% 626.32 Laguna Beach 12.40% 2,191 70 3.2% 0.3% 630.09 Newport Beach 12.27% 752 0 0.0% 0.0% 992.44 Huntington Beach 12.19% 1,928 0 0.0% 0.0% 630.07 Newport Beach 12.04% 3,326 133 4.0% 0.7% 631.03 Newport Beach /Uninc. 11.64% 1,097 0 0.0% 0.0% 423.23 Dana Point 11.64% 2,717 0 0.0% 0.0% 423.24 Dana Point 11.51% 2,282 84 3.7% 0.4% 635.00 Newport Beach 11.48% 3,586 0 0.0% 0.0% 626.42 Newport Beach 11.32% 1,611 0 0.0% 0.0% 630.08 Newport Beach 11.29% 658 0 0.0% 0.0% 626.20 Laguna Beach 11.26% 2,663 0 0.0% 0.0% 626.22 Laguna Hills/Laguna Woods 10.75% 2,992 0 0.0% 0.0% 422.06 Dana Point 10.65% 1,459 0 0.0% 0.0% 626.04 Irvine 10.53% 6,267 118 1.9% 0.6% 320.11 Unincorporated 10.33% 826 0 0.0% 0.0% 630.04 Newport Beach 10.23% 3,491 119 3.4% 0.6% 628.00 Newport Beach 9.78% 3,031 0 0.0% 0.0% 320.37 Unincorporated 9.30% 2,437 0 0.0% 0.0% 423.05 Laguna Beach /Dana Point 8.59% 1,991 0 0.0% 0.0% 626.19 Laguna Beach 8.56% 2,063 0 0.0% 0.0% 627.02 Newport Beach 8.35% 2,702 0 0.0% 0.0% 995.10 Seal Beach 8.13% 3,644 0 0.0% 0.0% 630.05 Newport Beach 8.13% 1,023 0 0.0% 0.0% 626.23 Laguna Beach /Laguna Hills/Laguna Woods 8.07% 4,584 0 0.0% 0.0% 627.01 Newport Beach 7.86% 1,651 0 0.0% 0.0% 421.06 Dana Point/Uninc. 7.49% 738 0 0.0% 0.0% 634.00 Newport Beach 7.37% 2,207 0 0.0% 0.0% 626.46 Laguna Woods 6.84% 2,979 0 0.0% 0.0% 630.06 Newport Beach 6.83% 2,148 0 0.0% 0.0% 995.09 Seal Beach 6.48% 2,950 0 0.0% 0.0% 629.00 Newport Beach 5.33% 944 0 0.0% 0.0% Total 1 160,939 1 1,1081 0.7% 1 5.4% M0,19 3. Affordable Housing Units Located in Neighborhoods with a High Percentage ( >80 %) of Low Income Populations Table 7 -4 on the next page shows the number of affordable housing units located in 18 census tracts with a high percentage (80 % +) of low income population. As previously indicated, the merged database has a total of 20,379 affordable housing units located within the geographic area covered by the Regional Al. Within this geographic area, the affordable housing stock is not concentrated in neighborhoods with a high percentage (80 % +) of low income population for the reasons cited below: • Nine of the 18 high percentage census tracts have zero or less than 12 affordable housing units. • Only about 10% (2,055) of all affordable housing units (20,379) are located in census tracts with a high percentage of low income population. • About 90% of all affordable housing units are located outside census tracts with a high percentage of low income population. There are three census tracts that have high percentages of both minority and low income populations and a large percentage of affordable housing units located within the tracts: 744.03, 745.01 and 750.02. These tracts are located in Santa Ana and Maps 1 and 2 show the locations of the affordable housing developments. 4. Affordable Housing Units Located in Neighborhoods with a Low Percentage ( <20 %) of Low Income Populations Table 7 -5 (on pages 7 -16 to 7 -18) shows that affordable housing opportunities exist in census tracts with a low percentage of low income populations. Fourteen of the 101 census tracts with a low percentage of low income populations have affordable housing units. Almost 6% of all the affordable housing units are located in neighborhoods having 20% or less of its population with low incomes. However, the number of affordable housing units (1,205) represents a very small percentage (0.6 %) of the housing stock (186,329) located in these census tracts. The affordable housing opportunities are located in the following cities and communities • Aliso Viejo 174 • Anaheim 157 • Cypress 13 • Dana Point 84 • Fullerton 24 • Irvine 183 • Ladera Ranch 44 • Laguna Beach 70 • Newport Beach 232 • Yorba Linda 224 225 Table 7-4 Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a High Percentage ( >80 %) of Low Income Populations -2010 City Census Tract # Low /Mod Total Pop. Percent Low /Mod Total Housing Units 2008' Number of Affordable Housing UnitS2 Percent of Units in Census Tract Percent of All Affordable Units Anaheim/ Placentia 117.20 6,097 7,535 80.9% 1,518 54 3.6% 0.3% Santa Ana 744.03 5,556 6,374 87.2% 1,310 500 38.2% 2.5% Santa Ana 744.05 6,024 6,766 89.0% 1,468 24 1.6% 0.1% Santa Ana 744.06 3,132 3,706 84.5% 847 0 0.0% 0.0% Santa Ana/ Tustin 744.07 6,651 7,687 86.5% 1,866 0 0.0% 0.0 % Santa Ana 745.01 10,197 12,055 84.6% 1,391 326 23.4% 1.6% Santa Ana 748.05 5,577 6,710 83.1% 1,123 112 10.0% 0.5% Santa Ana 748.06 5,080 6,136 82.8% 910 0 0.0% 0.0% Santa Ana 749.01 8,512 10,102 84.3% 1,924 204 10.6% 1.0% Santa Ana 749.02 6,122 7,243 84.5% 1,184 12 1.0% 0.1% Santa Ana 750.02 8,000 9,466 84.5% 2,348 496 21.1% 2.8% Santa Ana 750.03 7,198 8,200 87.8% 1,729 48 2.8% 0.2% Santa Ana 750.04 4,865 5,713 85.2% 1,316 4 0.3% 0.0% Orange/ Villa Park* 758.11 1,354 1,569 86.3% 828 0 0.0% 0.0% Anaheim 865.02 5,488 6,669 82.3% 1,389 0 0.0% 0.0% Anaheim 874.05 5,489 6,580 83.4% 1,609 0 0.0% 0.0% Santa Ana/ Garden Grove 891.04 4,303 5,085 84.6% 1,358 194 14.3% 1.0% Santa Ana 891.05 5,935 6,991 84.9% 1,132 12 1.1% 0.1% Total 105,580 1 124,5871 84.7% 1 25,2501 2,055 1 8.1% 1 10.1% *All of the Low /Mod population is located within the City of Orange, 1,354 of 1,490 (90.9 %). Note: The merged database has a total of 20,379 affordable units in Orange County. 'California State University, Fullerton, Center for Demographic Research, Orange County Population & Dwelling Unit Estimates by Census Tract, January 1, 2008 2Number of affordable housing units per census tract is obtained from Attachment B on page 7 -28. Table construction by Castaneda & Associates 220 Table 7 -5 Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage (<20 %) of Low Income Populations -2010 Census Tract City Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Census Tract Percent of All Affordable Units 16.02 Fullerton 13.8% 1,858 0 0.0% 0.0% 17.06 Fullerton 19.1% 1,373 24 1.7% 0.1% 114.02 Fullerton 16.4% 874 0 0.0% 0.0% 117.15 Placentia /Unincorporated 14.6% 2,058 0 0.0% 0.0% 117.18 Placentia/Unincorporated 17.8% 1,110 0 0.0% 0.0% 218.09 Yorba Linda 19.8% 881 100 11.4% 0.5% 218.10 Yorba Linda /Placentia 19.8% 1,226 0 0.0% 0.0% 218.20 Yorba Linda /Placentia 19.2% 1,380 0 0.0% 0.0% 218.23 Yorba Linda 17.5% 1,057 0 0.0% 0.0% 218.24 Yorba Linda 11.0% 867 0 0.0% 0.0% 218.25 Yorba Linda 16.3% 1,158 124 10.7% 0.6% 218.27 Yorba Linda 11.7% 1,079 0 0.0% 0.0% 218.28 Yorba Linda 5.4% 1,331 0 0.0% 0.0% 218.29 Yorba Linda 11.4% 1,812 0 0.0% 0.0% 218.30 Yorba Linda 12.1% 2,037 0 0.0% 0.0% 219.05 Anaheim 19.5% 1,803 27 1.5% 0.1% 219.12 Orange 10.3% 1,379 0 0.0% 0.0% 219.15 Anaheim/Orange 19.7% 1,501 0 0.0% 0.0% 219.17 Oran a /Unincor orated 13.7% 1,195 0 0.0% 0.0% 219.20 Anaheim 12.9% 2,326 0 0.0% 0.0% 219.21 Anaheim 11.7% 1,427 0 0.0% 0.0% 219.22 Anaheim 15.1% 2,266 130 5.7% 0.6% 219.23 Anaheim 13.2% 2,322 0 0.0% 0.0% 219.24 Anaheim/Unincorporated 15.3% 1,532 0 0.0% 0.0% 320.11 Unincorporated 15.4% 826 0 0.0% 0.0% 320.34 Rancho Santa Margarita 14.5% 1,852 0 0.0% 0.0% 320.41 Unincorporated 12.1% 411 0 0.0% 0.0% 320.42 Rancho Santa Margarita 13.6% 1,778 0 0.0% 0.0% 320.43 Rancho Santa Margarita 6.9% 1,249 0 0.0% 0.0% 320.44 Coto de Caza 9.0% 2,013 0 0.0% 0.0% 320.45 Coto de Caza 11.3% 922 0 0.0% 0.0% 320.46 Coto de Caza 5.5% 1,878 0 0.0% 0.0% 320.48 Rancho Santa Margarita 11.5% 2,255 0 0.0% 0.0% 320.49 Rancho Santa Mar arita /Unincor orated 11.9% 3,106 0 0.0% 0.0% 320.50 Rancho Santa Margarita 16.6% 1,740 0 0.0% 0.0% 320.52 Ladera Ranch 19.2% 8,124 44 0.5% 0.2% 227 Table 7 -5 continued Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage (<20 %) of Low Income Populations -2010 Census Tract city Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Census Tract Percent of All Affordable Units 320.53 Rancho Santa Mar arita /Unincor orated 18.5% 3,095 0 0.0% 0.0% 320.56 Rancho Santa Margarita/Unincorporated 6.5% 2,002 0 0.0% 0.0% 423.05 Laguna Beach /Dana Point 18.6% 1,991 0 0.0% 0.0% 423.07 Laguna Hills 19.0% 2,316 0 0.0% 0.0% 423.24 Dana Point 14.3% 2,282 84 3.7% 0.4% 423.27 Laguna Hills 15.7% 1,735 0 0.0% 0.0% 423.28 Laguna Hills 14.7% 843 0 0.0% 0.0% 423.33 Laguna Hills 5.4% 1,332 0 0.0% 0.0% 423.35 Unincorporated 17.0% 2,300 0 0.0% 0.0% 524.04 Unincorporated 0.0% 979 0 0.0% 0.0% 524.08 Lake Forest 15.8% 2,153 0 0.0% 0.0% 524.15 Lake Forest 12.5% 1,315 0 0.0% 0.0% 524.17 Irvine 18.7% 2,302 0 0.0% 0.0% 524.20 Irvine 6.1% 6,304 0 0.0% 0.0% 524.21 Irvine 13.3% 1,964 0 0.0% 0.0% 524.22 Lake Forest 18.9% 1,491 0 0.0% 0.0% 524.26 Lake Forest/Unincorporated 8.9% 2,217 0 0.0% 0.0% 524.27 Lake Forest 12.4% 1,741 0 0.0% 0.0% 524.28 Lake Forest/Unincorporated 12.8% 2,181 0 0.0% 0.0% 525.06 Irvine 16.0% 828 0 0.0% 0.0% 525.22 Irvine 12.9% 1,446 59 4.1% 0.3% 525.23 Irvine 15.1% 1,544 0 0.0% 0.0% 525.26 Irvine 19.5% 1,366 0 0.0% 0.0% 525.27 Irvine 19.2% 2,713 124 4.6% 0.6% 626.20 Laguna Beach 18.3% 2,663 0 0.0% 0.0% 626.30 Irvine 16.7% 801 0 0.0% 0.0% 626.31 Irvine 7.9% 1,275 0 0.0% 0.0% 626.32 Laguna Beach 19.8% 2,191 70 3.2% 0.3% 626.33 Aliso Viejo 7.0% 1,742 0 0.0% 0.0% 626.34 Aliso Viejo 16.8% 2,066 0 0.0% 0.0% 626.35 Aliso Viejo/Laguna Woods 15.1% 1,713 0 0.0% 0.0% 626.38 Aliso Viejo 13.3% 2,432 0 0.0% 0.0% 626.39 Aliso Vie'o 17.6% 2,504 174 6.9% 0.9% 626.43 New ort Beach 10.0% 2,017 0 0.0% 0.0% 626.44 New ort Beach 17.6% 3,479 99 2.8% 0.5% 626.45 Newport Beach 9.3% 2,692 0 0.0% 0.0% 222 Table 7 -5 continued Regional Analysis of Fair Housing Impediments Affordable Housing Units Located in Neighborhoods With a Low Percentage (<20 %) of Low Income Populations -2010 Census Tract city Percent Minority Total Housing Units 2008 Number of Affordable Housing Units Percent of Units in Census Tract Percent of All Affordable Units 627.01 Newport Beach 16.1% 1,651 0 0.0% 0.0% 627.02 Newport Beach 17.3% 2,702 0 0.0% 0.0% 629.00 Newport Beach 19.6% 944 0 0.0% 0.0% 630.05 Newport Beach 15.0% 1,023 0 0.0% 0.0% 630.07 Newport Beach 18.6% 3,326 133 4.0% 0.7% 630.08 Newport Beach 12.5% 658 0 0.0% 0.0% 630.09 Newport Beach /Unincorporated 18.4% 752 0 0.0% 0.0% 630.10 Newport Beach 19.4% 3,372 0 0.0% 0.0% 636.01 Newport Beach 12.8% 1,393 0 0.0% 0.0% 756.04 Ora ng a /Unincorporated 12.6% 2,726 0 0.0% 0.0% 756.05 Ora ng a /Unincorporated 12.7% 2,198 0 0.0% 0.0% 756.06 Unincorporated 8.8% 2,270 0 0.0% 0.0% 757.03 Unincorporated 18.9% 1,384 0 0.0% 0.0% 758.09 Villa Park/Orange 13.7% 1,092 0 0.0% 0.0% 758.10 Villa Park/Orange 15.9% 1,033 0 0.0% 0.0% 758.14 Orange/Villa Park 14.0% 1,184 0 0.0% 0.0% 992.38 Huntington Beach 18.4% 1,396 0 0.0% 0.0% 992.39 Huntington Beach 19.3% 1,379 0 0.0% 0.0% 992.40 Huntington Beach 18.8% 2,166 0 0.0% 0.0% 992.43 Huntington Beach 19.8% 1,844 0 0.0% 0.0% 992.46 Huntington Beach 12.6% 1,241 0 0.0% 0.0% 993.08 Huntington Beach 10.3% 2,256 0 0.0% 0.0% 994.15 Huntington Beach 11.2% 2,095 0 0.0% 0.0% 995.04 Seal Beach 19.7% 999 0 0.0% 0.0% 995.13 Huntington Beach /Unincorporated 18.5% 1,337 0 0.0% 0.0% 995.14 Huntington Beach 9.8% 2,455 0 0.0% 0.0% 1100.07 Unincorporated/Seal Beach 15.7% 1,686 0 0.0% 0.0% 1100.11 Cypress 12.2% 1,112 13 1.2% 0.1% 1100.12 Seal Beach /Los Alamitos 14.6% 1,867 0 0.0% 0.0% 1101.18 Cypress 16.9% 767 0 0.0% 0.0% Total 186,329 1,205 0.6% 5.9% 2:�9 D. ANALYSIS OF THE LOCATION OF THE SECTION 8 HOUSING INVENTORY 1. Garden Grove Housing Authority (GGHA) The GGHA administers 2,504 Section 8 Housing Choice Vouchers. Of this total, 2,489 voucher holders reside in Garden Grove and other cities participating in the Regional Al. Table 7 -6 below lists the city residence of the Section 8 voucher holders. About 80.5% of the voucher holders live in Garden Grove (2,003 of 2,489). This table also lists the four census tracts having 5% or more of the Garden Grove's Section 8 voucher holders. Table 7 -6 Garden Grove Housing Authority Section 8 Assisted Families by City City Number of Families Anaheim 89 Buena Park 4 Cypress 0 Fountain Valley 13 Garden Grove Census Tract 881.07 137 Garden Grove Census Tract 887.01 156 Garden Grove Census Tract 889.01 135 Garden Grove Census Tract 891.04 265 Garden Grove - Balance of City 1,310 Huntington Beach 29 Irvine 19 La Habra 1 Laguna Woods 1 Newport Beach 3 Orange 14 Stanton 21 Westminster 160 Yorba Linda 2 Split Tracts* 130 Total 2,489 Source: Garden Grove Housing Authority *The data was provided by Census Tract and these tracts were split between two or more cities. Note: Census tracts listed have 5% (125) or more of the total (2,489) Section 8 assisted households. Tabulation by Castaneda & Associates 23O Table 7 -7 below identifies the number of Section 8 voucher holders residing in census tracts with a high percentage (80 % +) of minority populations. Only about one -fourth (660 of 2,489) of the GGHA voucher holders live in census tracts with a high percentage of minority populations. Within these census tracts Section 8 assisted housing — for the most part - comprises a small percentage of all the housing units. Only in census tract 891.04 does Section 8 housing comprise a "high" percentage (23.4 %) of all the housing units located in a census tract. Consequently, the vast majority (75 %) of Section 8 assisted housing is located in census tracts that do not have a high percentage of minority populations. Table 7 -7 Garden Grove Housing Authority Number of Section 8 Housing Units Located in Census Tracts With a High Percentage ( >80 %) of Minority Populations Census Tract City Total Population' Percent Minority # of Section 8 Assisted Units 891.04 Santa Ana /Garden Grove 6,074 92.61% 265 874.05 Anaheim 6,649 89.23% 1 890.03 Garden Grove 3,808 88.55% 63 875.04 Anaheim 8,248 87.42% 4 866.01 Anaheim 9,872 87.29% 1 874.03 Anaheim 3,735 85.78% 2 889.03 Garden Grove /Santa Ana 8,594 85.75% 84 873.00 Anaheim 10,041 85.04% 1 116.02 Anaheim 5,762 82.82% 1 891.06 Garden Grove 3,784 81.79% 96 891.02 Garden Grove 6,954 81.56% 20 12.01 La Habra/County 5,371 81.55% 1 888.01 Garden Grove 8,206 81.15% 121 Total 660 '2000 population Source: Garden Grove Housing Authority Tabulation by Castaneda & Associates 2S2 2. Santa Ana Housing Authority (SAHA) The SAHA administers Section 8 Housing Choice Vouchers predominately within the City of Santa Ana. Data on the census tract location of the voucher holders was provided by the SAHA. However, the census tract location is not available for all Section 8 voucher holders. (In some cases the census tract is unknown or an incorrect census tract was assigned to the voucher holder.) Table 7 -8 below and on the next page shows the census tract location of 653 Section 8 voucher holders. As noted by this table, the vast majority of Section 8 assisted families reside in Santa Ana. Table 7 -8 Santa Ana Housing Authority Section 8 Assisted Families by Census Tract Census Tract City Number of Section 8 Vouchers 740.03 Santa Ana 4 740.04 Santa Ana 10 740.05 Santa Ana 16 740.06 Santa Ana 9 741.02 Santa Ana 9 741.03 Santa Ana 1 741.06 Santa Ana/Unincorporated' 19 741.07 Santa Ana 8 741.08 Santa Ana/Unincorporated' 6 741.09 Santa Ana 5 741.10 Santa Ana 9 741.11 Santa Ana 1 742.00 Santa Ana 5 744.03 Santa Ana 9 744.05 Santa Ana 4 744.06 Santa Ana 5 744.07 Santa Ana 7 745.01 Santa Ana 1 745.02 Santa Ana 5 746.01 Santa Ana 5 746.02 Santa Ana 11 747.01 Santa Ana 6 747.02 Santa Ana 2 748.01 Santa Ana 10 748.02 Santa Ana 3 748.03 Santa Ana/Unincorporated' 11 748.05 Santa Ana 5 748.06 Santa Ana 3 749.01 Santa Ana 4 232 Table 7 -8 - continued Santa Ana Housing Authority Section 8 Assisted Families by Census Tract Census Tract city Number of Section 8 Vouchers 749.02 Santa Ana 5 750.02 Santa Ana 8 750.03 Santa Ana 1 750.04 Santa Ana 2 751.00 Santa Ana 5 752.01 Santa Ana 7 752.02 Santa Ana 10 753.01 Santa Ana /Orange 11 753.02 Santa Ana 31 753.03 Santa Ana 2 754.01 Santa Ana 3 754.03 Santa Ana 15 754.04 Santa Ana 9 754.05 Santa Ana 4 755.04 Santa Ana 5 757.01 Santa Ana 9 889.03 Santa Ana /Garden GroveMestminster 8 890.01 Santa Ana /Garden Grove 64 890.04 Santa Ana 27 891.02 Santa Ana /Garden Grove 9 891.04 Santa Ana /Garden Grove 13 891.05 Santa Ana 41 891.07 Santa Ana /Garden Grove 2 992.02 Santa Ana /Fountain Valley 38 992.03 Santa Ana /Fountain Valley/ Garden Grove/Westminster 22 992.47 Santa Ana 46 992.48 Santa Ana 40 992.49 Santa Ana 23 Total 653 Although this tract is split with Orange, all the population is located within the City of Santa Ana. 2There was no population within the City of Westminster. Source: Santa Ana Housing Authority Tabulation by Castaneda & Associates Table 7 -9 on the next page indicates the number of Section 8 voucher holders residing in census tracts with a high percentage (80 % +) of minority populations. Only about 28% (184 of 653) of the SAHA voucher holders live in census tracts with a high percentage of minority 233 populations. Within these census tracts Section 8 assisted housing — for the most part - comprises a small percentage of all the housing units. Consequently, the vast majority (72 %) of Section 8 assisted housing is located in census tracts that do not have a high percentage of minority populations. Table 7 -9 Santa Ana Housing Authority Number of Section 8 Housing Units Located in Census Tracts With a High Percentage ( >80 %) of Minority Populations Census Tract City Total Population' Minority Population Percent Minority Number of Section 8 Vouchers 749.02 Santa Ana 7,261 7,080 97.51% 5 744.07 Santa Ana 3,822 3,701 96.83% 7 746.02 Santa Ana 9,649 9,222 95.57% 11 747.02 Santa Ana 6,680 6,328 94.73% 2 747.01 Santa Ana 9,075 8,588 94.63% 6 750.03 Santa Ana 8,232 7,773 94.42% 1 748.06 Santa Ana 6,154 5,801 94.26% 3 750.04 Santa Ana 5,779 5,444 94.20% 2 749.01 Santa Ana 10,129 9,533 94.12% 4 748.05 Santa Ana 6,710 6,298 93.86% 5 744.05 Santa Ana 6,965 6,450 92.61% 4 742.00 Santa Ana 9,611 8,899 92.59% 5 744.03 Santa Ana 6,374 5,861 91.95% 9 748.01 Santa Ana 6,267 5,722 91.30% 10 752.01 Santa Ana 5,948 5,426 91.22% 7 740.03 Santa Ana 2,484 2,266 91.22% 4 746.01 Santa Ana 8,861 7,998 90.26% 5 752.02 Santa Ana 6,137 5,519 89.93% 10 750.02 Santa Ana 9,610 8,639 89.90% 8 745.02 Santa Ana 6,280 5,637 89.76% 5 741.03 Santa Ana 5,196 4,646 89.41% 1 744.06 Santa Ana 3,838 3,402 88.64% 5 891.05 Santa Ana 7,081 6,133 86.61% 41 741.09 Santa Ana 4,032 3,486 86.46% 5 745.01 Santa Ana 8,233 7,115 86.42% 1 748.02 Santa Ana 6,041 5,218 86.38% 3 741.08 Santa Ana/Unincorporated 2 5,287 4,515 85.40% 6 741.02 Santa Ana 7,428 5,996 80.72% 9 Total 184 12000 population 2Although this tract is split with an unincorporated area of the County, all the population is within the City of Santa Ana Source: Santa Ana Housing Authority Tabulation by Castaneda & Associates 234 3. Anaheim Housing Authority (AHA) Data are not available from the AHA. 4. Orange County Housing Authority (OCHA) OCHA administers 8,089 Section 8 Housing Choice Vouchers within the cities participating in the Regional Al. Data was available on the census tract location of 6,832 voucher holders. (The census tract location was not available for 989 recipients and another 268 had discrepancies with respect to a census tract number.) The geographic area covered by the OCHA spans from the City of La Habra in the north down to Dana Point in the south. Of the 6,832 voucher holders, 3,153 reside in census tracts entirely within an entitlement city as shown in Table 7 -10 on the next page. With respect to Urban County cities, 762 voucher holders reside in census tracts entirely within these jurisdictions as shown in Table 7 -11 on the next page. Almost 3,000 voucher holders reside in census tracts split between two or more jurisdictions. These shared jurisdictions include entitlement cities with entitlement cities and entitlement cities with urban county cities. Nearly 1,700 of these "shared" locations were with the City of Westminster. The geographic distribution of all Section 8 voucher holders is as follows: • Entitlement Cities 3,153 • Urban County Cities 762 • Split Tract Locations 2,917 Total 6,832 Table 7 -12 on page 7 -26 identifies the number of Section 8 voucher holders residing in census tracts with a high percentage (80 % +) of minority populations. Only about 5.3% (363 of 6,832) of the OCHA voucher holders live in census tracts with a high percentage of minority populations. Within these census tracts Section 8 assisted housing — for the most part - comprises a small percentage of all the housing units. Only in census tract 525.18 does Section 8 housing comprise a "high" percentage (67 %) of all housing in a census tract. However, the population in the tract is extremely low. Consequently, the vast majority (95 %) of Section 8 assisted housing is located in census tracts that do not have a high percentage of minority populations. An analysis also was completed to determine the number of Section 8 voucher holders residing in census tracts with a low ( <20 %) minority population. Some 258 (almost 4 %) OCHA Section 8 voucher holders reside in 34 low minority population neighborhoods /census tracts. Consequently, the number (258) of voucher holders residing in low minority population neighborhoods is about 100 less than the number (363) living in high minority population census tracts. Table 7 -13 on page 7 -27 presents the data analysis. 235 Table 7 -10 Orange County Housing Authority Section 8 Assisted Families by Entitlement City Entitlement Cities Number of Section 8 Vouchers Anaheim 92 Buena Park 117 Fountain Valley 193 Fullerton 251 Garden Grove 156 Huntington Beach 498 Irvine 538 La Habra 108 Lake Forest 169 Newport Beach 110 Orange 447 Rancho Santa Margarita 42 Santa Ana 2 Westminster 430 Total 3,153 Source: Orange County Housing Authority Table 7 -11 Orange County Housing Authority Section 8 Assisted Families by Urban County City Urban County Number of Section 8 Vouchers Aliso Viejo 13 Brea 129 Cypress 74 Dana Point 37 Laguna Beach 13 Laguna Hills 8 Laguna Woods 1 La Palma 46 Los Alamitos 11 Placentia 121 Seal Beach 3 Stanton 220 Villa Park 0 Yorba Linda 76 Unincorporated 10 Total 762 Source: Orange County Housing Authority 23 o Table 7 -12 Orange County Housing Authority Number of Section 8 Housing Units Located in Census Tracts With a High Percentage ( >80 %) of Minority Populations Census Tract City Total Population' Minority Population Percent Minority Number of Section 8 Vouchers 525.18 Irvine 3 3 100.00% 2 992.49 Orange 4,443 4,322 97.28 % 1 741.02 Santa Ana 7,428 6,904 92.95% 1 891.04 Garden Grove 6,074 5,625 92.61% 13 117.20 Placentia 7,535 6,973 92.54% 17 865.02 Anaheim 6,678 6,168 92.36% 1 874.05 Anaheim 6,649 5,933 89.23% 1 992.48 Santa Ana 5,365 4,757 88.67% 1 890.03 Garden Grove 3,808 3,372 88.55% 9 875.04 Anaheim 8,248 7,210 87.42% 1 878.03 Stanton 6,442 5,580 86.62% 87 874.03 Anaheim 3,735 3,204 85.78% 1 889.03 Garden Grove/Westminster 8,594 7,369 85.75% 21 873.00 Anaheim 10,041 8,539 85.04% 1 1106.06 Buena Park 4,841 4,043 83.52% 41 864.05 Anaheim 6,699 5,549 82.83% 1 116.02 Fullerton 5,762 4,772 82.82% 6 992.02 Fountain Valley 8,117 6,715 82.73% 2 744.08 Orange 5,239 4,323 82.52% 1 879.02 Anaheim /Stanton 5,983 4,911 82.08% 22 889.04 Garden Grove/Westminster 5,809 4,766 82.05% 72 891.06 Garden Grove 3,784 3,095 81.79% 2 891.02 Garden Grove/Orange 6,954 5,672 81.56% 3 12.01 La Habra 5,371 4,380 81.55% 13 889.02 Garden Grove/Westminster 5,136 4,177 81.33 % 16 888.01 Garden Grove 8,206 6,659 81.15% 27 Total 363 '2000 population Source: Orange County Housing Authority Tabulation by Castaneda & Associates 237 Table 7 -13 Orange County Housing Authority Number of Section 8 Housing Units Located in Census Tracts With a Low Percentage (<20 %) of Minority Populations Census Tract City Total Population' Minority Population Percent Minority Number of Section 8 Vouchers 994.07 Huntington Beach/Westminster 2,491 492 19.75% 44 992.20 Huntington Beach 5,421 1,067 19.68% 1 993.06 Huntington Beach 5,931 1,164 19.63% 11 632.01 Orange 3,611 701 19.41% 1 320.42 Trabuco Canyon 6,135 1,174 19.14% 1 993.07 Huntington Beach 2,377 437 18.38% 14 993.11 Huntington Beach 3,818 691 18.10% 2 995.12 Seal Beach 2,766 500 18.08% 3 218.09 Yorba Linda 2,616 472 18.04% 6 219.17 Orange 3,366 596 17.71% 4 218.16 Yorba Linda 4,943 853 17.26% 3 1100.08 Los Alamitos /Seal Beach 4,304 740 17.19% 2 626.05 La gun Beach 3,396 554 16.31% 10 320.13 Ladera Ranch 3,528 569 16.13% 1 993.09 Huntington Beach 3,565 522 14.64% 4 636.03 Newport Beach 6,263 901 14.39% 41 423.38 Dana Point 4,814 667 13.86% 2 630.10 Newport Beach 6,495 863 13.29% 4 995.06 Sunset Beach 1,267 161 12.71% 1 320.52 Ladera Ranch 3,330 422 12.67% 1 626.44 Corona del Mar /Newport Beach 6,558 821 12.52% 9 626.32 Laguna Beach 4,058 503 12.40% 1 992.44 Huntington Beach 3,846 469 12.19% 3 630.07 Newport Beach 5,928 714 12.04% 18 423.23 Dana Point 4,717 549 11.64% 2 635.00 Newport Beach 6,191 711 11.48% 4 630.08 Irvine 868 98 11.29% 2 626.22 Irvine/Laguna Hills/Laguna Woods 4,231 455 10.75% 26 630.04 Newport Beach 5,602 573 10.23% 18 628.00 Newport Beach 4,732 463 9.78% 3 423.05 Laguna Beach 3,782 325 8.59% 1 626.23 Laguna Hills/Laguna Woods 6,435 519 8.07% 11 634.00 Newport Beach 4,995 368 7.37% 3 626.46 Laguna Woods 3,643 249 6.84% 1 Total 258 12000 population Source: Orange County Housing Authority E. ACTIONS TO BE TAKEN As explained on page one, the location of affordable housing is central to fulfilling the commitment to AFFH because it determines whether such housing will reduce or perpetuate residential segregation. The data analysis shows that affordable housing is predominantly located outside areas of high minority and high low income population concentrations. Many of the developments were constructed before localities were required to develop policies to guide the location of affordable housing. During the 2010 -2015 period, the FHCOC will take the following actions: • Provide technical assistance to participating jurisdictions on how the location of affordable housing contributes to AFFH. • Aggregate - for each census tract - the number of voucher holders assisted by all four housing authorities. • Conduct an analysis of the location of affordable housing in census tracts with a low concentration of minority and low income populations for purposes of determining whether they offer sufficient affordable housing opportunities. • Extend the analysis to include census tracts with minority populations in the range of 60 to 80 %. • Suggest policies that the Housing Authorities and /or entitlement cities and the Urban County Program can implement to promote affordable housing opportunities outside of census tracts with high percentages of poverty and minority populations. 239 Attachment A Census Tracts With 80 %+ Minority Populations Census Tract city White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Pop. of two or more races 2000 Total Pop. Minority Percent Minority 2008 Total Pop. Pop. Change 2000 - 2008 745.01 Santa Ana 82 7,115 5 21 842 13 7 148 8,233 8,151 99.00% 8,547 314 748.06 Santa Ana 80 5,801 161 2 74 14 13 9 6,154 6,074 98.70% 6,395 241 749.02 Santa Ana 102 7,080 15 4 43 2 0 15 7,261 7,159 98.60% 7,539 278 748.01 Santa Ana 107 5,722 244 30 130 20 1 13 6,267 6,160 98.29% 6,448 181 749.01 Santa Ana 185 9,533 50 30 272 22 8 29 10,129 9,944 98.17% 10,520 391 747.01 Santa Ana 198 8,588 72 6 135 34 0 42 9,075 8,877 97.82% 9,419 344 748.05 Santa Ana 156 6,298 76 15 100 27 14 24 6,710 6,554 97.68% 6,966 256 992.49 Santa Ana 121 3,472 26 8 770 21 0 25 4,443 4,322 97.28% 4,612 169 752.01 Santa Ana 162 5,426 71 16 240 1 2 30 5,948 5,786 97.28% 6,206 258 745.02 Santa Ana 178 5,637 7 19 361 32 0 46 6,280 6,102 97.17% 6,527 247 746.02 Santa Ana 284 9,222 27 5 76 14 3 18 9,649 9,365 97.06% 10,008 359 891.05 Santa Ana 232 6,133 18 22 635 11 5 25 7,081 6,849 96.72% 7,144 63 743.00 Santa Ana 147 4,204 5 19 15 3 0 22 4,415 4,268 96.67% 4,584 169 750.03 Santa Ana 299 7,773 49 42 25 0 16 28 8,232 7,933 96.37% 8,531 299 747.02 Santa Ana 270 6,328 9 19 18 15 4 17 6,680 6,410 95.96% 6,953 273 750.04 Santa Ana 247 5,444 29 0 44 4 2 9 5,779 5,532 95.73% 6,018 239 750.02 Santa Ana 426 8,639 86 20 395 2 3 39 9,610 9,184 95.57% 10,145 535 744.03 Santa Ana 298 5,861 18 19 153 4 0 21 6,374 6,076 95.32% 6,617 243 741.09 Santa Ana 200 3,486 13 25 270 15 1 22 4,032 3,832 95.04% 4,198 166 740.03 Santa Ana 125 2,266 25 8 39 4 1 16 2,484 2,359 94.97% 3,462 978 742.00 Santa Ana 504 8,899 23 16 118 16 8 27 9,611 9,107 94.76% 9,976 365 752.02 Santa Ana 322 5,519 98 25 139 0 11 23 6,137 5,815 94.75% 6,366 229 744.05 Santa Ana 371 6,450 32 5 64 3 11 29 6,965 6,594 94.67% 7,429 464 741.08 Santa Ana 313 4,515 40 13 331 37 0 38 5,287 4,974 94.08% 5,496 209 748.02 Santa Ana 375 5,218 163 22 180 22 3 58 6,041 5,666 93.79% 6,278 237 741.02 Santa Ana 524 5,996 110 19 696 30 9 44 7,428 6,904 92.95% 1 7,709 281 ME Census Tract city White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Pop. of two or more races 2000 Total Pop. Minority Percent Minority 2008 Total Pop. Pop. Change 2000 - 2008 746.01 Santa Ana 626 7,998 29 29 110 23 4 42 8,861 8,235 92.94% 9,208 347 891.04 Santa Ana /Garden Grove 449 4,384 37 10 1,130 19 0 45 6,074 5,625 92.61% 6,293 219 741.03 Santa Ana 385 4,646 13 21 79 21 1 30 5,196 4,811 92.59% 5,394 198 744.07 Santa Ana/Tustin 573 6,765 100 6 161 8 6 68 7,687 7,114 92.55% 8,005 318 117.20 Anaheim /Placentia 562 6,612 93 24 158 11 10 65 7,535 6,973 92.54% 8,008 473 865.02 Anaheim 510 5,995 34 24 77 1 1 36 6,678 6,168 92.36% 6,916 238 748.03 Santa Ana 702 6,623 177 26 1,409 33 4 78 9,052 8,350 92.24% 9,416 364 744.06 Santa Ana 311 3,402 31 14 55 8 1 16 3,838 3,527 91.90% 3,994 156 874.04 Anaheim 323 3,338 34 14 53 9 0 14 3,785 3,462 91.47% 3,926 141 890.01 Santa Ana 794 3,704 54 30 2,835 46 1 110 7,574 6,780 89.52% 7,900 326 874.05 Anaheim 716 5,504 101 20 235 16 4 53 6,649 5,933 89.23% 6,977 328 890.04 Santa Ana 812 4,865 68 5 1,596 34 6 53 7,439 6,627 89.08% 7,823 384 992.47 Santa Ana 380 1,765 24 14 1,176 31 1 27 3,418 3,038 88.88% 3,558 140 992.48 Santa Ana 608 3,297 73 3 1,300 44 1 39 5,365 4,757 88.67% 5,595 230 890.03 Garden Grove 436 2,009 84 4 1,155 37 1 82 3,808 3,372 88.55% 3,973 165 875.04 Anaheim 1,038 6,342 106 35 587 22 0 118 8,248 7,210 87.42% 8,542 294 866.01 Anaheim 1,255 7,746 247 26 455 29 13 101 9,872 8,617 87.29% 10,343 471 878.03 Stanton /Anaheim 862 4,415 135 16 808 89 12 105 6,442 5,580 86.62% 6,671 229 740.05 Santa Ana 1,051 5,238 103 21 1,110 26 20 85 7,654 6,603 86.27% 7,947 293 874.03 Anaheim 531 3,059 21 9 92 2 0 21 3,735 3,204 85.78% 3,861 126 889.03 Garden Grove /Santa Ana 1,225 2,289 45 16 4,776 59 12 172 8,594 7,369 85.75% 9,001 407 873.00 Anaheim 1,502 7,428 216 23 716 16 3 137 10,041 8,539 85.04% 10,933 892 865.01 Anaheim 732 3,843 36 16 79 1 2 39 4,748 4,016 84.58% 4,929 181 1106.06 Buena Park 798 2,805 249 18 860 10 6 95 4,841 4,043 83.52% 5,215 374 864.05 Anaheim 1,150 5,067 100 8 288 10 17 59 6,699 5,549 82.83% 6,961 262 116.02 Fullerton /Anaheim 990 4,460 113 19 123 3 1 53 5,762 4,772 82.82% 5,990 228 2'4'1 242 Native American Hawaiian Pop. Indian and of Black or and Other Some two Pop. Hispanic African Alaska Pacific other or 2000 2008 Change Census White or American Native Asian Islander race more Total Percent Total 2000 - Tract city alone Latino alone alone alone alone alone races Pop. Minority Minority Pop. 2008 992.02 Santa Ana /Fountain Valley 1,402 4,206 88 54 2,194 49 10 114 8,117 6,715 82.73% 8,402 285 879.02 Stanton 1,072 3,586 81 11 1,019 86 1 127 5,983 4,911 82.08% 6,143 160 889.04 Westminster /Garden Grove 1,043 682 20 3 3,927 26 7 101 5,809 4,766 82.05% 6,072 263 864.04 Anaheim 1,121 4,347 57 24 585 5 6 72 6,217 5,096 81.97% 6,451 234 891.06 Garden Grove 689 2,317 32 7 680 12 3 44 3,784 3,095 81.79% 3,933 149 891.02 Garden Grove /Santa Ana 1,282 4,232 69 23 1,182 57 4 105 6,954 5,672 81.56% 7,234 280 12.01 La Habra/County 991 3,991 59 18 213 3 0 96 5,371 4,380 81.55% 5,586 215 753.02 Santa Ana 852 3,440 86 3 181 6 6 34 4,608 3,756 81.51% 4,782 174 889.02 Garden Grove 959 1,363 34 14 2,601 82 4 79 5,136 4,177 81.33% 5,387 251 888.01 Garden Grove 1,547 1,593 108 17 4,701 53 8 179 8,206 6,659 81.15% 8,633 427 741.11 Santa Ana 1,135 3,579 153 12 938 15 6 84 5,922 4,787 80.83% 6,148 226 117.14 Anaheim 58 227 1 0 3 9 0 0 5 302 244 80.79% 311 9 242 Attachment B Affordable Housing Inventory Arranged by Census Tract City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units La Habra Casa Nicolina 1510 W. La Habra Blvd. 90631 11.03 Family 562 22 La Habra La Habra Inn Senior Apartments 700 N. Beach Blvd. 90631 11.03 Senior SRO 55+ 70 70 La Habra Casa El Centro 101 N. Cypress St. 90631 12.02 Senior /Disabled 62+ 55 55 La Habra Las Lomas Gardens 900 S. Las Lomas Dr. 90631 13.03 Family 112 93 La Habra Cypress Villa Apartments 900 North Cypress Street 90631 14.01 Non Targeted 72 71 Brea Vintage Creek Sr. Apartments 855 North Brea Blvd. 92821 15.02 Senior 105 105 Brea Birch Street Loft Apartments 260 & 330 W. Birch St. 92821 15.03 1 Bedroom Lofts 30 25 Brea Imperial Terrace Apartments 430 W. Imperial Hwy. 92821 15.03 Family 36 18 Brea Loft Apartments 215 S. Brea Blvd. 92821 15.03 Artist's Lofts 32 8 Brea South Walnut Bungalows 302 -314 S. Walnut Ave. 92821 15.03 Family 9 9 Brea Walnut Village Apartments 620 Walnut Ave 92821 15.03 Large Family 46 46 Brea Birch Terrace Apartments 601 E. Birch St. 92821 15.04 Family 36 18 Brea BREAL Senior Apartments 111 N. Orange Ave. 92821 15.04 Senior 65+ 30 30 Brea Civic Center Apartments 651 E. Birch St. 92821 15.04 Family 30 16 Brea Orange Villa Senior Apartments 137 N. Orange Ave. 92821 15.04 Senior 62+ 36 9 Brea Williams Senior Apartments 212 S. Orange Ave. 92821 15.04 Senior 62+ 28 28 Brea Town and Country Apartments 800 S. Brea Blvd. 92821 15.05 Family 122 50 Brea Brea Woods Senior Apartments 195 W. Central Ave. 92821 15.06 Senior 55+ 151 36 Brea Tamarack Pointe Villas 330 W. Central Ave. 92821 15.07 Family 48 5 Fullerton North Hills Apartments 570 East Imperial Highway 92835 16.01 Non Targeted 204 203 24S City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Fullerton Harborview Terrace Apartments 2305 N. Harbor Blvd. 92835 17.06 Physical Disability 25 24 Fullerton Courtyard Apartments 4127 West Valencia 92633 18.01 Large Family 108 108 Fullerton Franklin Garden Apartment Homes 3828 Franklin Ave. 92833 18.01 Family 15 11 Fullerton Fullerton Residential Manor 2441 W. Orangethorpe Ave. 92632 18.02 Senior 62+ (Board & Care 97 97 Fullerton Ameri a Villa Apartments 343 W. Ameri e Ave. 92832 112.00 Senior 62+ or Disabled 101 100 Fullerton Fullerton City Lights 224 E. Commonwealth Ave. 92832 113.00 1 or 2 person 137 136 Fullerton Klim el Manor 229 E Amerig a Ave. 92832 113.00 Senior 59 59 Fullerton Casa Maria Del Rio 2130 E. Chapman Ave. 92831 115.02 Mobility Impaired 24 24 Fullerton East Fullerton Villas 2140 -2190 East Chapman Avenue 92821 115.02 Large Family 27 27 Fullerton Palm Garden Apartments 400 West Orangethorpe Avenue 92832 116.01 Non Targeted 223 223 Fullerton Richman Park 1 436 -442 W. Valencia Dr. 92832 116.01 Family 8 8 Fullerton Richman Park II 461 West Ave. 92832 116.01 Family 4 4 Fullerton Truslow Village 220 W. Truslow Ave. 92832 116.01 Family 12 1 Fullerton Allen Hotel Apartments 410 S. Harbor Blvd. 92832 116.02 Family 16 16 Fullerton Las Palmas Apartments 2598 N. Associated Rd. 92835 117.07 Family 259 52 Fullerton Garnet Housing 3012 -3024 Garnet Ln. 1512 & 1518 Placentia 92831 117.11 Family 20 20 Fullerton Garnet Lane Apartments 3125 -3149 Garnet Ln. 92631 117.11 Family 18 17 Placentia Imperial Villas 1050 E. Imperial Hwy. 92870 117.17 Family 58 58 Placentia Villa La Jolla 734 W. La Jolla Blvd. 92870 117.20 At -Risk 55 54 Placentia No Name Provided 219 Melrose St. 92870 117.21 Family 2 2 Placentia No Name Provided 307 Santa Fe Ave. 92870 117.21 Family 2 2 MEN City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Placentia No Name Provided 338 Santa Fe Ave. 92870 117.21 Family 4 4 Placentia Ramona Gardens 415 & 421 Ramona St. 92670 117.21 Family 6 6 Yorba Linda Evergreen Villas 5100 Avocado Circle 92886 218.02 Senior 55+ 52 25 Yorba Linda Yorba Linda Family Apartments 18542 Yorba Linda Blvd. 92886 218.02 Large Family 44 43 Yorba Linda Parkwood Apartments 4075 Prospect Avenue 92885 218.09 Senior 101 100 Placentia Arbor Lane East 1621 & 1931 Cherry St. 92870 218.21 Family 2 2 Placentia Highland Orchard Apartments 140 S. Highland Ave. 92870 218.21 Family 104 10 Yorba Linda Victoria Woods Yorba Linda 5303 Stonehaven Drive 92887 218.25 Senior 124 124 Yorba Linda Riverbend (Archstone Yorba Linda) 25550 River Bend Dr. 92887 218.26 Family 400 100 Anaheim Palacio Villas 435 S. Anaheim Hills Rd. 92807 219.05 Senior 62+ 117 27 Orange Villa Modena 4431 E. Marmon Ave. 92869 219.13 Family 5 5 Anaheim Fountain Glen 225 S. Festival Dr. 92808 219.22 Senior 55+ 259 130 Trabuco Canyon Trabuco Highlands 31872 Joshua Dr. 92679 320.04 Family 184 37 Rancho Santa Margarita Villa Aliento 114 Aliento St. 92688 320.51 Family 225 23 Ladera Ranch Laurel Glen 70 Sklar St. 92694 320.52 Family 220 44 Rancho Santa Margarita Fountain Glen Senior Apartments 30751 El Corazon 92688 320.54 Senior 55+ 166 34 Rancho Santa Margarita Villa La Paz 2 Via Amistosa 92688 320.55 Family 500 100 Dana Point OC Community Housing Corp. 25942 Domingo 92624 422.01 Family 24 24 Dana Point Monarch Coast 32400 Crown Valley Pkwy. 92629 423.24 Family 418 84 Irvine Northwood Affordable Apartments Jeffrey and Trabuco Road 92620 524.18 Large Family 96 94 245 city Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Irvine Northwood Place 1300 Hayes St. 92620 524.18 Family 604 186 Irvine Woodbury NE Apartments North of Talisman, South of Mission Park, East of Pink Sage, West of Hallmark in Planning Area 9A 92620 524.18 Large Family 150 148 Irvine Woodbury Apts. — Phase I Sand Can on /Trabuco 92620 524.18 Family 90 90 Lake Forest Alexan Bellecour 21041 Osterman Rd. 92630 524.23 Family 131 6 Lake Forest Arbors 26356 Vintage Woods Rd. 92630 524.23 Family 328 22 Lake Forest Emerald Court 21141 Canada Rd. 92630 524.23 Family 288 58 Lake Forest Westrid e 26571 Normadale Dr. 92630 524.23 Family & Senior 390 78 Lake Forest Trabuco Woods 22159 Rimhurst Dr. 92630 524.24 Family 72 15 Lake Forest Spring Lakes 21641 Canada Rd. 92630 524.25 Famii 180 36 Irvine Woodbridge Manor 27 Lake Road 92604 525.11 Senior 165 164 Irvine The Inn At Woodbridge 3 Osborne 92714 525.13 Senior 116 116 Irvine Cedar Creek 5051 Alton Pkwy. 92604 525.14 Family 176 36 Irvine Woodbridge Oaks 1 Knoll glen 92604 525.14 Family 120 120 Irvine Woodbridge Willows 344 Knoll glen 92614 525.14 Family 200 40 Irvine Santa Alicia Apartments 100 Santorini 92606 525.15 Family 84 82 Irvine Orchard Park 50 Tarocco 92618 525.17 Large Family 60 60 Irvine Woodbridge Villas 10 Thunder Run #30 92614 525.19 Family 258 60 Irvine Cross Creek 22 Creek Rd. 92604 525.20 Family 136 45 Irvine Woodbridge Cross Creek Apartments 22 Creek Rd., #1 92604 525.20 Family 136 45 Irvine San Leon Villa Apartments 1 San Leon 92606 525.21 Family 247 72 Irvine San Marco Apartments 101 Veneto 92614 525.21 Family 426 361 Irvine San Paulo Apartments 100 Duranzo Aisle 92606 525.21 Family 382 203 Irvine San Remo Villa 1011 San Remo 92606 525.21 Family 248 76 V2 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Irvine San Marino Villa Apartments 403 San Marino 92614 525.22 Family 199 59 Irvine Montecito Vista Apartment Homes 4000 El Camino Real 92602 525.25 Large Family 162 161 Irvine Northwood Park 146 Roosevelt St. 92620 525.25 Family 168 34 Irvine The Parklands 1 Monroe, #11 92620 525.25 Family 120 120 Irvine Windrow Apartments 5300 Trabuco Rd. 92620 525.25 Family 96 96 Irvine Abilityfirst Apartments 14501 Harvard Ave. 92606 525.27 Disabled 24 24 Irvine Windwood Glen 97 Hearthstone 92606 525.27 Family 196 40 Irvine Windwood Knoll 2 Flagstone 92606 525.27 Family 188 60 Irvine Deerfield Apartments 3 Bear Paw 92604 525.28 Family 288 20 Irvine Laguna Canyon Apartments 400 Limestone Way 92618 626.04 Large Family 120 118 Laguna Beach Glenne re Apartments 450 Glenne re Street 92651 626.05 Single Room 27 26 Laguna Beach Hagan Place 383 3rd St. 92651 626.05 1 Bedroom Disabled /HIV 24 24 Laguna Beach Harbor Cove Apartments 310 -312 Broadway St. 92651 626.05 Senior 62+ 15 15 Irvine Mariposa Co -Op 3773 University Dr. 92612 626.10 Disabled /Physically Challenged/Senior 40 39 Irvine Toscana Apartments 35 Via Lucca 92612 626.10 Family 563 84 Irvine Villa Sienna 25 Palatine #100 92612 626.10 Family 1442 216 Irvine Harvard Manor 21 California Ave. 92715 626.14 Senior 62+ 50 35 Laguna Hills Rancho Niguel Apartments 25952 Via Lomas 92653 626.25 Non Targeted 51 51 Irvine Berkeley Court 307 Berkeley 92612 626.26 Family 118 32 Irvine Columbia Court 307 Berkeley 92612 626.26 Family 58 12 Irvine Dartmouth Court 1100 Stanford 92612 626.26 Family 294 89 Irvine Stanford Court 400 Stanford 92612 626.26 Family 320 96 Irvine Harvard Court 146 Berkeley 92612 626.27 Family 112 34 Irvine Harvard Manor 50 Cornell Dr. 92712 626.27 Family 161 100 247 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Irvine Turtle Rock Canyon Apartments 100 Stone Cliff Aisle 92612 626.28 Family 217 66 Laguna Beach Vista Aliso Apartments 21544 Wesley Drive 92651 626.32 Senior 71 70 Aliso Viejo Wood Canyon Villas 28520 Wood Canyon Dr. 92656 626.39 Family 230 46 Aliso Viejo Wood ark Apartments 22702 Pacific Park Dr 92656 626.39 Large Family 128 128 Newport Beach Corona del Mar Seaview Lutheran Plaza 2800 Pacific View Dr. 92625 626.44 Senior 62+ & Mobility Impaired 100 99 Newport Beach Ba view Landing 1121 Back Bay Drive 92660 630.04 Senior 120 119 Newport Beach Newport North 2 Milano Dr. 92660 630.07 Family 570 133 Newport Beach SA Hei hts Lange Drive Family 1621 Mesa Drive 92707 631.01 Large Family 74 74 Newport Beach Newport Seacrest Apartments 843 W. 15th St. 92663 636.03 Family 65 65 Newport Beach Newport Seaside Apts. 1544 Placentia Avenue -0- 636.03 Large Family 26 26 Santa Ana La Gema Del Barrio 638 -642 East Adams 92707 740.03 Large Family 6 6 Santa Ana Warwick Square Apartments 780 South Lyon Street 92705 744.03 Large Family 500 500 Santa Ana 901 E. 6th St. 901 E. 6th St. 744.05 Family 24 24 Santa Ana Wakeham Grant Apartments 816 Minnie Street 92701 745.01 Non Targeted 127 126 Santa Ana Cornerstone Village 923 -1117 S. Minnie 745.01 Family 200 200 Santa Ana 415 -417 Birch 415 -417 Birch St. 92701 746.01 Family 3 3 Santa Ana Raitt Street Apartments 201, 271 North Raitt Street 92703 748.01 Large Family 6 2 Santa Ana Santa Ana Civic Center 405 & 411 S. Raitt St. 92703 748.01 Family 12 6 Santa Ana Santa Ana Civic Center 2009 W. Myrtle St. 92703 748.02 Family 6 6 Santa Ana Sullivan Manor 2516 W. 1st St. 92703 748.02 Family 54 54 Santa Ana Villa Del Sol Apartments 811 S. Fairview St. 92704 748.05 Family 562 112 Santa Ana 1060 W. Third 1060 W. Third St. 92701 749.01 Family/Senior 6 6 Santa Ana Flower Park Plaza 901 West First Street 92703 749.01 Senior 199 198 Santa Ana Highland Manor Apartments 1128 W. Highland St. 92703 749.02 Family 12 12 Santa Ana Henin er Village Apartments 200 S. Sycamore Street 92701 750.02 Senior 58 58 242 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Santa Ana Santa Ana Towers 401 W. First Street 92701 750.02 Senior 199 198 Santa Ana Rosswood Villas 100 N. Ross 750.02 Senior 199 198 Santa Ana Garden Court 300 E. Santa Ana BI. 750.02 Family 84 42 Santa Ana Ross & Durant Apartments 1411 N. Durant Street & 1501 N. Ross Street 92706 750.03 Large Family 49 48 Santa Ana 1025 N. Spurgeon 1025 N. Spurgeon St. 92701 750.04 Family 4 4 Santa Ana Wycliffe Plaza 1401 N. Flower St. 92706 751.00 Senior 62+ /Disabled 199 140 Santa Ana City Gardens Apartments 2901 N Bristol St 92706 753.01 Non Targeted 274 55 Santa Ana Santiago Villas 939 E. 17th St. 754.01 Senior 89 89 Irvine Alta Court Apartments 2552 Kelvin Ave. 92614 755.15 Family 132 27 Irvine Granite Court 17421 Murphy Ave. 92612 755.15 Family 71 71 Irvine Irvine Inn 2810 Warner Avenue 92606 755.15 Single Room 192 192 Irvine The Camden Apts. 2801 Main St. 92614 755.15 Family 290 58 Orange Stonegate Senior Apartments 170 N. Prospect Street 92869 758.04 Senior 20 19 Orange Rose Avenue Apartments 1743 E. Rose Ave. 92867 758.05 Family 6 6 Orange Casas Del Rio 1740 E. La Veta Ave. 92866 758.06 Disabled Only 40 40 Orange Chestnut Place 1745 E. Fairway Dr. 92866 758.06 Senior 62+ 50 49 Orange Harmony Creek Sr. Apartments 1616 E. Rock Creek Dr. 92866 758.06 Senior 62+ 83 82 Orange Esplanade St. Apartments 280 S. Esplanade St. 92869 758.07 Family 27 27 Orange Adams Triplexes 1741 -1745, 1837 -1841, & 1915 -1919 E. Adams Ave. 92867 758.12 Family 9 9 Orange Orange Garden Apartments (see Plaza Garden) 928 N. Highland St., #2 92867 758.12 Family 24 24 2 —" City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Orange Plaza Garden Apartments 928 N. Highland St., #2 92867 758.12 Family 56 56 Orange Wilson Avenue Apartment 1 1924 & 1934 E. Wilson Ave. 92867 758.12 Family 20 20 Orange Wilson Avenue Apartments 11 1844 E. Wilson Ave. 92867 758.12 Family 10 10 Orange Wilson Avenue Apartments III 1944 E. Wilson Ave. 92867 758.12 Family 10 10 Orange The Knolls Apartments 206 Prospect Avenue 92669 758.16 Non Targeted 260 260 Orange Casa Ramon Apartments 840 West Walnut Avenue 92868 759.01 Large Family 75 74 Orange Friendly Center 451 -453 N. Lemon St. 92866 759.01 Family 8 8 Orange Parker Street Apartments 161 N. Parker St. 92868 759.01 Family 3 3 Orange OHDC /Orange Rotary Senior Plaza 235 W. La Veta Avenue 92866 759.02 Senior 6 6 Orange Triangle Terrace 555 S. Shaffer St. 92866 759.02 Senior 62+ 75 75 Orange Pixley Arms 537 W. Almond Ave. 92868 760.00 Senior 62+ 15 15 Orange Citrus Village 501 N. Citrus St. 92868 761.01 Family 47 22 Orange Community Garden Tower East 3919 W. Garden Grove Blvd. 92868 761.02 Senior 62+ 333 332 Garden Grove Arroyo Vista 12242 Haster St. 92840 761.03 Family 148 10 Garden Grove Crystal View Apartments 12091 Bayport St. 92840 761.03 Family 402 80 Orange Hoover Avenue 108 -118, 218 -228 W. Hoover Ave. 92867 762.04 Family 40 40 Orange Orangevale Apartments 1300 North Shaffer Avenue 92867 762.05 Non Targeted 64 64 Orange Orchid Gardens 1051 N. Glassell St. 92867 762.05 Senior 62+ 33 17 Orange Walnut - Pixley 1519 E Walnut and 537 W Almond Ave 92867 762.06 Large Family 22 22 Anaheim Broadway Village 1245 E. Broadway 92805 863.01 Large Family 46 45 2150 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Anaheim Tyrol Plaza Senior Apartments 891 S. State College Blvd. 92806 863.01 Senior 60 59 Anaheim Carbon Creek Shores 3060 E. Frontera St. 92806 864.07 Families, Mobility & Sensory Impaired 40 40 Anaheim Park Vista Apartments 1200 N. Robin Street 92801 866.01 Family 392 390 Anaheim Paseo Village 1115 N. Citron Ln. 92801 866.01 Family 176 174 Anaheim Casa Delia 1105 N. Citron St. 92801 866.01 Family 12 12 Anaheim Sae Park Apts. 810 N. Loara 92801 866.02 Senior 62+ 100 25 Anaheim Villa Catalpa Apts. 1680 Catalpa 92801 866.02 Senior 62+ 18 6 Anaheim Fairhaven Apts. 535 Fairhaven 92801 867.02 Senior 62+ 17 6 Anaheim Monarch Pointe Apartment Homes 1830 W. Crescent Avenue (Crescent and Chippewa Avenue at the I -5 Freeway) 92801 867.02 Large Family 63 62 Anaheim Sea Wind Apartments 1924 Glenoaks & 1925 Greenleaf Avenue 92801 867.02 Non Targeted 91 18 Anaheim Greenleaf Family Apartments 2048 Greenleaf 867.02 Family 53 53 Buena Park Dorado Senior Apartments 8622 Stanton Ave. 90620 868.03 Senior 55+ 150 150 Anaheim Miracle Terrace 225 S. Western Ave. 92804 869.01 Senior 62+ 179 177 Anaheim Palm West Apartments 644 South Knott Avenue 92804 869.01 Non Targeted 58 23 Anaheim Renaissance Park Apartments 3433 West Del Monte 92804 869.01 Non Targeted 127 51 Anaheim Westchester Apartments 125 S. Westchester Dr. 92804 869.01 Family 65 64 Anaheim New porter Apts. 3424 W. Orange 869.01 Family 22 4 Anaheim Cobblestone Apartments 870 South Beach Blvd. 92804 869.03 Non Targeted 64 13 Anaheim Casa Alegre 2761 West Ball Road 92804 870.01 Disabled Persons — AIDS /HIV 23 22 Anaheim Magnolia Acres 640 S. Magnolia Avenue 92807 870.01 1 Senior 40 10 251 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Anaheim Harbor Village 2736 W. Lincoln 870.01 Family 111 9 Anaheim Sunset Plaza Apartments 2771 W. Ball Rd. 870.01 Family 106 9 Anaheim Gilbert Park Apts. 925 S. Gilbert 92804 870.02 Senior 62+ 24 8 Anaheim California Villas 935 S. Gilbert Street 92804 870.02 Senior 34 33 Anaheim Linbrook Court 2240 W. Lincoln Avenue 92801 871.01 Senior 81 80 Anaheim Bel-Age Manor 1660 W. Broadway 92802 871.05 Senior 55+ 180 179 Anaheim Acaciawood Village 1415 W. Ball Rd. 92802 871.06 Seniors 62+ 123 31 Anaheim Heritage Village Apts. 707 W. Santa Ana St. 92805 872.00 Senior 62+ 196 49 Anaheim Vintage Apartments 200 S. Citron 872.00 Senior 55+ 82 21 Anaheim Diamond Asile 1232 Diamond St. 872.00 Special Needs 26 25 Anaheim Anaheim Family Housing 415 South Vine Street 92805 873.00 Large Family 60 59 Anaheim Anaheim Memorial Manor 275 E. Center St. 92805 873.00 Senior 62+ 75 75 Anaheim Elm Street Commons 111 -125 West Elm Street 92805 873.00 Large Family 52 51 Anaheim Village Center Apartments 200 E. Lincoln Ave. 92805 873.00 Senior 62+ 100 100 Anaheim Hermosa Village Apartments 1515 S. Calle Del Mar Dr. 92802 875.01 Large Families 517 517 Anaheim Nutwood Park Apartments 1668 S. Nutwood St. 92802 876.02 Family 30 2 Anaheim Cornerstone Apartments 9541 W. Ball Road 92804 877.01 Family 49 48 Anaheim New Horizons Apts. 835 S. Brookhurst 92804 877.01 Senior 62+ 80 32 Anaheim Heritage Park Apartments 950 S. Gilbert 877.01 Senior 60+ 94 29 Stanton Casa de Esperanza 10572 Knott Ave. 90680 878.01 Special Needs 10 9 Stanton Continental Gardens Apartments 8101 Cerritos Avenue 90680 878.03 Non Targeted 298 298 Anaheim Pebble Cove Apartments 2555 W. Winston Rd. 95242 878.06 Family 112 45 Garden Grove Malabar Apartments 9777 Bixby Avenue 92841 882.03 Large Family 126 126 Garden Grove Aslam 11211 Steele St. 92840 883.01 Family 10 10 Garden Grove Pat Stein -Palma Vista 10772 -10862 Palma Vista 883.01 24 24 2152 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Garden Grove Tamerlane 12131,12141,12161,12171 Tamerlane; 12112,12222,12132,12182 Tamerlane 884.02 43 28 Anaheim Harborcliffe 2170 S. Harbor BI. 884.03 Family 130 26 Garden Grove Briar Crest and Rose Crest Briar: 11701 Stewart St. Rose: 11762 Stewart St. 92843 885.01 Briar - 32 Rose —10 42 Garden Grove Stuart Drive Apartments 11632 Stuart Dr. #3 92843 885.01 Family 95 95 Garden Grove Arbor Glen Apartments 12680 Buaro St. 92840 885.02 Family 136 68 Garden Grove Garden Grove Senior Apartments 12739 Garden Grove Blvd. 92843 885.02 Senior 85 85 Garden Grove Sun rove Senior Apartments 12811 Garden Grove Blvd. 92843 885.02 Senior 82 82 Garden Grove Acacia Villa Apartments 10931 Acacia Pkwy. 92840 886.01 Senior 62+ 161 161 Garden Grove Jordan Manor 11441 Acacia Pkwy. 92840 886.02 Senior 62+ 64 64 Garden Grove Rose Garden Apartment 8551 Westminster Ave. 92844 889.01 Family 144 144 Garden Grove Orange Tree Apartments 13902 Taft 889.02 80 80 Santa Ana Harbor Pointe Apartments 1500 N. Harbor Blvd. 92703 890.04 Family 130 26 Santa Ana Vintage Wood Apartments 3900 W. 5th St. 92703 890.04 Family 170 34 Garden Grove Tudor Grove 12631 Sunswept Avenue #1 92843 891.04 144 144 Garden Grove Thomas House 12591 -12601 Mornin side 891.04 16 14 Garden Grove La Esperanza I and II 14024,14021,14041,14061 Buena St. 891.04 28 28 Garden Grove OCCHC /Emergency Shelter for the Homeless 12602 Keel St. 891.04 8 8 Santa Ana Jackson Park 300 -304 N. Jackson St. 92701 891.05 Family 7 4 Santa Ana Santa Ana Civic Center 3524 W. Washington Ave. 92703 891.05 Family 8 8 253 254 Low Zip Census Total Income City Name Address Code Tract Housing Type Units Units Anaheim CHOC Site Lincoln Ave. /East St. 894.05 Family 150 150 Stanton Park Stanton Senior 7622 Katella Ave. 90680 897.01 Senior 55+ 335 334 Apartments (Formerly Park Place Apartments) Stanton Plaza Court 11380 -11480 Court Street 90680 897.01 Large Family 103 103 Orange Alice Clark Orange Blossom 141 E. Walnut Ave. 92866 962.05 Senior 62+ 4 4 Sr. Apartments Garden Grove Garden Grove Manor 10642 Bolsa Ave. 92843 992.03 Family 78 31 Westminster Summerville at Brookhurst 15302 Brookhurst St. 92683 992.04 Senior 62+ 117 24 Huntington Beach Huntington Breakers 21270 Beach Blvd. 92648 992.20 Family/Senior/Disabled 342 68 Fountain Valley Club 42 17230 Newho a 92708 992.29 Family 7 7 Fountain Valley Guadalupe Manor 17103 Magnolia St. 92708 992.33 Senior 62+ & Mobility 71 69 Impaired Fountain Valley Fountain Valley Senior (The 17911 Bushard Street 92708 992.34 Senior 156 154 Jasmine Huntington Beach Beachview Villa 8102 Ellis Avenue 92648 992.35 Single Room 107 86 Huntington Beach Huntington Villa Yorba 16000 Villa Yorba 92647 992.41 Family 198 192 Huntington Beach Sea Air Apartments 725, 729 & 733 Utica Ave. 92648 993.05 Family 36 36 Huntington Beach Bowen Court 1970, 1974, 1978, 1982 & 92648 993.05 Senior 20 20 1990 Lake Street Huntington Beach Fountain Glen @ Seacliff 7200 Garden Glen Dr 92648 993.09 Senior 55+ 271 80 (North of Main & Yorktown Huntington Beach Main Place Apartments 7311 Luna (N/W corner 92648 993.09 Family 26 26 Cla /Gothard /Main Huntington Beach Oceanaire Garden 7811 Talbert Ave. 92648 994.02 Family 65 65 Apartments Huntington Beach Shelter For the Homeless 7802 Barton Dr. 7812 92647 994.02 Family 8 8 Barton Dr. 254 City Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Huntington Beach Shelter for the Homeless Keelson 17382 Keelson Ln. 92647 994.02 Family 4 4 Huntington Beach Huntington Village Senior Apartments 16171 Springdale St. 92649 994.07 Senior 62+ 114 11 Huntington Beach Sher Lane Apartments 16112 Sher Ln. 92647 994.10 Family/Senior 66 66 Huntington Beach Bridges Apartments 16851 Nichols St. 92647 994.11 Family 80 80 Huntington Beach 5 Points Senior Apartments 18561 Florida St. 92648 994.13 Senior 55+ 166 50 Huntington Beach Emerald Cove 18191 Parktree Cir. 92648 994.13 Senior 60+ 164 164 Huntington Beach Wycliffe Gardens 18765 Florida St. 92648 994.13 Senior 62+ & disabled 185 185 Huntington Beach Huntington Pointe (Quo Vadis Apartments) 18992 Florida Street 92648 994.13 Non Targeted 104 102 Huntington Beach Hermosa Vista Apartments 15353 & 15425 Goldenwest Street 92647 996.05 Non Targeted 88 87 Midway City Jackson Aisle Apartments 15432 Jackson Street 92655 997.02 Special Needs 30 29 Midway City Pacific Terrace Apartments 15000 Pacific St. 92655 997.02 Seniors 62+ 97 97 Westminster Cambridge Heights Senior Apartments 7541 Wyoming Street 92683- 3922 998.02 Senior 22 21 Westminster Coventry Heights 7521 Wyoming Street 92683 998.02 Senior 76 75 Westminster Westminster Senior Apartments 7632 21st Street 92683 998.02 Senior 92 91 Westminster The Rose Gardens" 8190 13th Street 92683 998.03 Large Family or Senior? 132 132 Westminster Windsor Court & Stratford Place 8140 - 8156 13th Street 92683 998.03 Large Family 86 85 Garden Grove Valley View Senior Villas 12200 Valley View St. 92845 1100.03 Senior 55+ 36 36 Cypress Cypress Park Senior Community 9021 Grindlay St. 90630 1101.04 Active Senior 55+ 124 31 Cypress Cypress Pointe Senior Community 5120 Lincoln Ave. 90630 1101.04 Senior 55+ 110 11 2155 city Name Address Zip Code Census Tract Housing Type Total Units Low Income Units Cypress Cypress Sunrise Apartments 9151 Grindlay Street 90630 1101.04 Senior 75 74 Cypress Tara Village Apartments 5201 Lincoln Avenue 90630 1101.04 Large Family 170 168 Cypress OC Community Housing Corp. 8702 & 8692 LaSalle 90630 1101.11 Family 8 8 Cypress Sumner Place 8542 -8552 Sumner PI. 90630 1101.11 Family 5 5 Los Alamitos Laurel Park Manor 4121 Katella Ave. 90720 1101.13 Senior 62+ and Mobility Impaired 71 70 La Palma Seasons La Palma 7051 -7061 Walker St. 90623 1101.15 Senior 62+ 60 60 La Palma Camden Place Apartments 4500 Montecito Drive 90623 1101.16 Senior 35 35 La Palma Casa La Palma Apartments 7799 Valley View Street 90623 1101.16 Non Targeted 269 269 Anaheim Solara Court 3335 West Lincoln Avenue 92801 1102.01 Senior 132 132 Anaheim Villa Anaheim 3305 W. Lincoln Avenue 92626 1102.01 Senior 135 47 Buena Park Emerald Garden Apartments 8720 Valley View St. 90620 1102.01 Family 110 109 Buena Park Casa Santa Maria 7551 Oran ethorpe Ave. 90621 1105.00 Senior 62+ 100 98 Buena Park Harmony Park Apartments 7252 Melrose St. 90622 1105.00 Senior 62+ 59 58 Buena Park OC Community Housing Corp. Palm Village) 7602 -7638 W. 9th St. 90621 1105.00 Family 38 38 Buena Park Walden Glen Apartments 6570 -6680 Knott Avenue 90621 1105.00 Non Targeted 186 185 Anaheim OC Community Housing Corp. Various Locations 92801 92802, 92804 Family 17 17 Garden Grove OC Community Housing Corp. Various Locations 92843 Family 44 44 Huntington Beach OC Community Housing Corp. Various Location 92647, 92648 Family 64 64 Irvine OC Community Housing Corp. Various locations 92604, 92618, 92620 Family 6 6 2150 257 Low Zip Census Total Income City Name Address Code Tract Housing Type Units Units Orange Lemon Street Apartments 481 -491 Lemon Street 92866 Family 6 6 Placentia OC Community Housing Various Locations 92870 Family 14 14 Corp. Santa Ana OC Community Housing Various Locations 92703, Family 10 10 Corp. 92704 92707 Santa Ana Orange Housing Various Locations 92701 Family 352 313 Development Corp. TOTAL 34,834 20,379 257 This Page Intentionally Left Blank 252 TECHNICAL APPENDICES 259 This Page Intentionally Left Blank 200 Technical Appendix A Orange County Fair Housing Community Profile 201 Table A -1 Regional Analysis of Fair Housing Impediments Entitlement Cities: Year 2010 Population Estimates by City city Total Population Household Population Group Quarters Persons Per Household Anaheim 353,643 349,847 3,796 3.485 Buena Park 84,141 83,207 934 3.465 Fountain Valley 58,741 58,229 512 3.130 Fullerton 138,610 135,395 3,215 2.945 Garden Grove 175,618 173,384 2,234 3.714 Huntington Beach 203,484 202,692 792 2.667 Irvine 217,686 209,482 8,204 2.708 La Habra 63,184 62,589 595 3.215 Lake Forest 78,720 77,876 844 3.029 Newport Beach 86,738 85,798 940 2.212 Orange 142,708 137,240 5,468 3.148 Rancho Santa Margarita 49,945 49,931 14 3.022 Santa Ana 357,754 352,107 5,647 4.737 Westminster 94,294 93,742 552 3.462 Total 2,105,266 2,071,519 33,747 3.265 Source: State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 202 Table A -2 Regional Analysis of Fair Housing Impediments Urban County: Year 2010 Population Estimates by City city Total Population Household Population Group Quarters Persons Per Household Aliso Viejo 46,123 45,963 160 2.596 Brea 40,377 40,249 128 2.813 Cypress 49,981 49,660 321 3.054 Dana Point 37,326 37,084 242 2.517 Laguna Beach 25,354 25,232 122 2.140 Laguna Hills 33,593 33,169 424 3.069 Laguna Woods 18,747 18,673 74 1.469 La Palma 16,304 16,273 31 3.223 Los Alamitos 12,270 11,864 406 2.735 Placentia 52,305 52,002 303 3.199 Seal Beach 26,010 25,752 258 1.928 Stanton 39,799 39,281 518 3.575 Villa Park 6,307 6,286 21 3.199 Yorba Linda 69,273 69,138 135 3.179 Unincorporated 120,088 118,621 1,467 3.178 Total 593,857 589,247 4,610 2.815 Source: State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2009 Table construction by Castaneda & Associates 203 Table A -3 Regional Analysis of Fair Housing Impediments Entitlement Cities: Population Growth April 1, 1990, April 1, 2000 and January 1, 2010 City 1990 2000 2010 Numerical Change 1990 -2000 Percentage Change 1990 -2000 Numerical Change 2000 -2010 Percentage Change 2000 -2010 Anaheim 266,406 328,014 353,643 61,608 23.1% 25,629 7.8% Buena Park 68,784 77,962 84,141 9,178 13.3% 6,179 7.9% Fountain Valley 53,691 54,978 58,741 1,287 2.4% 3,763 6.8% Fullerton 114,144 126,003 138,610 11,859 10.4% 12,607 10.0% Garden Grove 142,965 165,196 175,618 22,231 15.5% 10,422 6.3% Huntington Beach 181,519 189,627 203,484 8,108 4.5% 13,857 7.3% Irvine 110,330 143,072 217,686 32,742 29.7% 74,614 52.2% La Habra 51,266 58,974 63,184 7,708 15.0% 4,210 7.1% Lake Forest NA 58,707 78,720 NA NA 20,013 34.1% Newport Beach 66,643 70,032 86,738 3,389 5.1% 16,706 23.9% Orange 110,658 128,868 142,708 18,210 16.5% 13,840 10.7% Rancho Santa Margarita* 11,390 47,214 49,945 35,824 314.5% 2,731 5.8% Santa Ana 293,827 337,977 357,754 44,150 15.0% 19,777 5.9% Westminster 78,293 88,207 94,294 9,914 12.7% 6,087 6.9% Total NA 1,874,831 2,105,266 NA NA 230,435 12.3% 'Lake Forest was unincorporated in 1990 2Rancho Santa Margarita was a Census Division Place (CDP) and not an incorporated city in 1990 Source: 1990 Census Summary Tape File 1 (STF1) Table P001 Persons State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2000 State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates WON Table A -4 Regional Analysis of Fair Housing Impediments Urban County: Population Growth April 1, 1990, April 1, 2000 and January 1, 2010 Cities 1990 2000 2010 Numerical Change 1990 -2000 Percentage Change 1990 -2000 Numerical Change 2000 -2010 Percentage Change 2000 -2010 Aliso Viejo* NA NA 46,123 NA NA NA NA Brea 32,873 35,410 40,377 2,537 7.7% 4,967 14.0% Cypress 42,655 46,549 49,981 3,894 9.1% 3,432 7.4% Dana Point 31,896 35,110 37,326 3,214 10.1% 2,216 6.3% Laguna Beach 23,170 23,727 25,354 557 2.4% 1,627 6.9% Laguna Hills* NA 29,891 33,593 NA NA 3,702 12.4% Laguna Woods* NA 17,794 18,747 NA NA 953 5.4% La Palma 15,392 15,408 16,304 16 0.1% 896 5.8% Los Alamitos 11,788 11,536 12,270 -252 -2.1% 734 6.4% Placentia 41,259 46,488 52,305 5,229 12.7% 5,817 12.5% Seal Beach 25,098 24,157 26,010 -941 -3.7% 1,853 7.7% Stanton 30,491 37,403 39,799 6,912 22.7% 2,396 6.4% Villa Park 6,299 5,952 6,307 -347 -5.5% 355 6.0% Yorba Linda 52,422 58,918 69,273 6,496 12.4% 10,355 17.6% Unincorporated 226,927 168,132 120,088 - 58,795 -25.9% - 48,044 -28.6% Total NA 556,475 593,857 NA NA NA NA *Denotes that the city was not incorporated in 1990 Source: 1990 Census Summary Tape File 1 (STF1) Table P001 Persons State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2000 State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 205 Table A -5 Regional Analysis of Fair Housing Impediments Entitlement Cities: Year 2010 Housing Supply Estimate by City City_ Single Detached Single Attached 2 to 4 Units 5 Plus Units Mobile Homes Total Percent Vacant Anaheim 43,733 9,064 10,436 35,624 4,385 103,242 2.76 Buena Park 14,351 2,024 1,462 6,395 291 24,523 2.07 Fountain Valley 12,486 2,247 672 3,122 398 18,925 1.69 Fullerton 23,958 4,101 3,711 14,518 921 47,209 2.60 Garden Grove 26,811 4,538 3,426 11,014 1,828 47,617 1.95 Huntington Beach 38,619 9,467 9,909 16,924 3,141 78,060 2.65 Irvine 28,138 14,605 5,091 32,155 1,022 81,011 4.52 La Habra 10,619 1,750 1,362 5,508 734 19,973 2.54 Lake Forest 14,165 3,923 1,276 5,734 1,286 26,384 2.55 Newport Beach 19,467 7,166 5,599 10,420 863 43,515 10.87 Orange 25,254 5,374 4,726 7,934 1,339 44,627 2.32 Rancho Santa Margarita 9,117 3,883 598 3,194 0 16,792 1.59 Santa Ana 33,746 7,223 7,473 23,592 3,909 75,943 2.13 Westminster 14,932 2,550 2,106 4,972 3,068 27,628 1.98 Total 315,396 77,915 57,847 181,106 23,185 655,449 3.19 Source: State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 200 Table A -6 Regional Analysis of Fair Housing Impediments Urban County: Year 2010 Housing Supply Estimate by City City Single Detached Single Attached 2 to 4 Units 5 Plus Units Mobile Homes Total Percent Vacant Aliso Viejo 6,549 4,991 753 5,899 15 18,207 2.76 Brea 8,510 1,095 569 3,548 869 14,591 1.93 Cypress 10,195 2,717 529 2,842 364 16,647 2.34 Dana Point 7,958 2,273 2,831 2,622 299 15,983 7.80 Laguna Beach 8,336 762 1,760 2,100 324 13,282 11.23 Laguna Hills 5,873 2,183 608 2,272 217 11,153 3.10 Laguna Woods 727 4,146 2,474 6,390 26 13,763 7.61 La Palma 3,643 376 102 989 27 5,137 1.71 Los Alamitos 1,940 269 1,061 1,023 129 4,422 1.90 Placentia 9,798 2,113 1,117 2,954 587 16,569 1.89 Seal Beach 4,711 2,121 1,160 6,390 164 14,546 8.17 Stanton 3,062 1,915 988 4,009 1,262 11,236 2.22 Villa Park 1,994 18 0 6 5 2,023 2.87 Yorba Linda 17,399 2,395 662 1,336 311 22,103 1.62 Unincorporated 30,529 2,188 2,213 3,260 306 38,496 3.04 Total 121,224 29,562 16,827 45,640 4,905 218,158 3.97 Source: State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 20 Table A -7 Regional Analysis of Fair Housing Impediments Entitlement Cities: Housing Supply Growth April 1, 1990, April 1, 2000 and January 1, 2010 city 1990 2000 2010 Numerical Change 1990 -2000 Percentage Change 1990 -2000 Numerical Change 2000 -2010 Percentage Change 2000 -2010 Anaheim 93,177 99,719 103,242 6,542 7.0% 3,523 3.4% Buena Park 23,200 23,690 24,523 490 2.1% 833 3.4% Fountain Valley 18,019 18,473 18,925 454 2.5% 452 2.4% Fullerton 42,956 44,771 47,209 1,815 4.2% 2,438 5.2% Garden Grove 45,957 46,703 47,617 746 1.6% 914 1.9% Huntington Beach 72,736 75,679 78,060 2,943 4.0% 2,381 3.1% Irvine 42,221 53,711 81,011 11,490 27.2% 27,300 33.7% Lake Forest' NA 20,486 26,384 NA NA 5,898 22.4% La Habra 18,670 19,441 19,973 771 4.1% 532 2.7% Newport Beach 34,861 37,288 43,515 2,427 7.0% 6,227 14.3% Orange 38,018 41,920 44,627 3,902 10.3% 2,707 6.1% Rancho Santa Margarita 2 4,951 16,515 16,792 11,564 233.6% 277 1.6% Santa Ana 75,000 74,588 75,943 -412 -0.5% 1,355 1.8% Westminster 25,892 26,940 27,628 1,048 4.0% 688 2.5% Total NA 599,924 655,449 NA NA 55,525 8.5% 'Lake Forest was unincorporated in 1990 2Rancho Santa Margarita was a Census Division Place (CDP) and not an incorporated city in 1990 Source: 1990 Census Summary Tape File 1 (STF1) Table H001 Housing Units State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing - Report E -5, January 1, 2000 State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates is Table A -8 Regional Analysis of Fair Housing Impediments Urban County: Housing Supply Growth April 1, 1990, April 1, 2000 and January 1, 2010 city 1990 2000 2010 Numerical Change 1990 -2000 Percentage Change 1990 -2000 Numerical Change 2000 -2010 Percentage Change 2000 -2010 Aliso Viejo* NA NA 18,207 NA NA NA NA Brea 12,648 13,327 14,591 679 5.4% 1,264 8.7% Cypress 14,715 16,164 16,647 1,449 9.8% 483 2.9% Dana Point 14,666 15,682 15,983 1,016 6.9% 301 1.9% Laguna Beach 12,846 12,965 13,282 119 0.9% 317 2.4% Laguna Hills' NA 10,324 11,153 NA NA 829 7.4% Laguna Woods" NA 13,629 13,763 NA NA 134 1.0% La Palma 4,935 5,066 5,137 131 2.7% 71 1.4% Los Alamitos 4,312 4,329 4,422 17 0.4% 93 2.1% Placentia 13,733 15,326 16,569 1,593 11.6% 1,243 7.5% Seal Beach 14,407 14,267 14,546 -140 -1.0% 279 1.9% Stanton 10,755 11,011 11,236 256 2.4% 225 2.0% Villa Park 1,966 1,992 2,023 26 1.3% 31 1.5% Yorba Linda 17,341 19,567 22,103 2,226 12.8% 2,536 11.5% Unincorporated 89,440 61,161 38,496 - 28,279 -31.6% - 22,665 - 58.9% Total NA NA 218,158 NA NA NA NA 'Denotes that the city was not incorporated in 1990 Source: 1990 Census Summary Tape File 1 (STF1) Table H001 Housing Units State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2000 State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2010 Table construction by Castaneda & Associates 2o9 Table A -9 Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities city, Year/Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Anaheim Number 2000 117,607 153,374 7,939 1,049 38,919 1,263 457 7,406 328,014 Percent 2000 35.9% 46.8% 2.4% 0.3% 11.9% 0.4% 0.1% 2.3% 100.0% Number 2008 97,373 187,122 10,049 693 46,087 1,040 347 3,812 346,522 Percent 2008 28.1% 54.0% 2.9% 0.2% 13.3% 0.3% 0.1% 1.1% 100.0% # Change - 20,234 33,748 2,110 -356 7,168 -223 -110 -3,594 18,508 % Change - 17.2% 22.0% 26.6% -33.9% 18.4% -17.7% - 24.2% -48.5% 5.6% Buena Park Number 2000 29,885 26,221 2,826 315 16,338 358 154 2,185 78,282 Percent 2000 38.2% 33.5% 3.6% 0.4% 20.9% 0.5% 0.2% 2.8% 100.0% Number 2008 29,396 31,632 1,573 662 17,969 248 331 994 82,807 Percent 2008 35.5% 38.2% 1.9% 0.8% 21.7% 0.3% 0.4% 1.2% 100.0% # Change -489 5,411 -1,253 347 1,631 -110 177 -1,191 4,525 % Change -1.6% 20.6% 44.3% 110.3% 10.0% - 30.6% 115.1% -54.5% 5.8% Fountain Valley` Number 2000 32,144 5,870 584 171 14,100 202 129 1,778 54,978 Percent 2000 58.5% 10.7% 1.1% 0.3% 25.6% 0.4% 0.2% 3.2% 100.0% Number 2008 31,166 6,720 521 463 17,437 116 116 1,390 57,929 Percent 2008 53.8% 11.6% 0.9% 0.8% 30.1% 0.2% 0.2% 2.4 % 100.0% # Change -978 1 850 1 -63 1 2921 3,337 1 -86 1 -13 1 -388 1 2,951 % Change -3.0% 1 14.5% 1 - 10.7% 1 171.0% 1 23.7% 1 - 42.6% 1 - 10.2% 1 - 21.8% 1 5.4% 270 Table A -9 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Fullerton Number 2000 61,420 38,014 2,675 404 20,130 251 237 2,872 126,003 Percent 2000 48.7% 30.2% 2.1% 0.3% 16.0% 0.2% 0.2% 2.3% 100.0% Number 2008 52,943 44,988 5,486 686 29,489 137 137 3,292 137,158 Percent 2008 38.6% 32.8% 4.0% 0.5% 21.5% 0.1% 0.1% 2.4% 100.0% # Change -8,477 6,974 2,811 282 9,359 -114 -100 420 11,155 %Change - 13.8% 18.3% 105.1% 69.8% 46.5% - 45.4% -42.1% 14.6% 8.9% Garden Grove Number 2000 53,735 53,608 1,873 523 50,803 995 210 3,449 165,196 Percent 2000 32.5% 32.5% 1.1% 0.3% 30.8% 0.6% 0.1% 2.1% 100.0% Number 2008 41,582 69,476 2,080 173 58,215 69 347 1,387 173,329 Percent 2008 24.0% 40.1 % 1.2% 0.1 % 33.6% 0.0% 0.2% 0.8% 100.0% # Change - 12,153 15,868 207 -350 7,412 -926 137 -2,062 8,133 % Change - 22.6% 29.6% 11.0% - 66.9% 14.6% - 93.0% 65.1% - 59.8% 4.906 Huntington Beach Number 2000 136,237 27,798 1,383 777 17,544 432 314 5,109 189,594 Percent 2000 71.9% 14.7% 0.7% 0.4% 9.3% 0.2% 0.2% 2.7% 100.0% Number 2008 140,297 31,244 1,008 403 22,375 1,613 403 4,233 201,576 Percent 2008 69.6% 15.5% 0.5% 0.2% 11.1% 0.8% 0.2% 2.1% 100.0% # Change 4,060 3,446 -375 -374 4,831 1,181 89 -876 11,982 %Change 3.0% 12.4% -27.1% -48.1% 27.5% 273.3% 28.4% -17.1% 6.3% Irvine Number 2000 81,613 10,539 1,977 162 42,506 180 359 5,736 143,072 Percent 2000 57.0% 7.4% 1.4% 0.1% 29.7% 0.1% 0.3% 4.0% 100.0% Number 2008 105,467 18,698 2,311 420 75,844 420 840 6,093 210,094 Percent 2008 50.2% 8.9% 1.1% 0.2% 36.1 % 0.2% 0.4% 2.9% 100.0% # Change 23,854 8,159 334 258 33,338 240 481 357 67,022 % Change 29.2% 77.4% 16.9% 159.4% 78.4% 133.4% 134.1% 6.2% 46.8% 271 Table A -9 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total La Habra" Number 2000 24,399 28,922 808 188 3,432 89 95 1041 58,974 Percent 2000 41.4% 49.0% 1.4% 0.3% 5.8% 0.2% 0.2% 1.8% 100.0% Number 2008 19,634 35,641 1,188 125 4,940 125 125 750 62,528 Percent 2008 31.4% 57.0% 1.9% 0.2% 7.9% 0.2% 0.2% 1.2% 100.0% # Change -4,765 6,719 380 -63 1,508 36 30 -291 3,554 % Change - 19.5% 23.2% 47.0% - 33.5% 43.9% 40.5% 31.6% - 27.9% 6.0% Lake Forest Number 2000 39,161 10,913 998 143 5,647 113 102 1,630 58,707 Percent 2000 66.7% 18.6% 1.7% 0.2% 9.6% 0.2% 0.2% 2.8% 100.0% Number 2008 44,895 18,817 1,327 78 11,087 156 156 1,562 78,078 Percent 2008 57.5% 24.1 % 1.7% 0.1 % 14.2% 0.2% 0.2% 2.0% 100.0% # Change 5,734 1 7,904 329 -651 5,440 43 1 54 -68 1 19,371 % Change 14.6% 72.4% 33.0% - 45.4% 96.3% 38.2% 53.1% -4.2% 33.006 Newport Beach Number 2000 62,342 3,301 354 137 2,763 81 93 961 70,032 Percent 2000 89.0% 4.7% 0.5% 0.2% 3.9% 0.1% 0.1% 1.4% 100.0% Number 2008 NA NA NA NA NA NA NA NA 85,145 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 15,113 % Change NA NA NA NA NA NA NA NA 21.6% Orange Number 2000 70,292 41,434 1,798 393 11,898 268 162 2,576 128,821 Percent 2000 54.6% 32.2% 1.4% 0.3% 9.2% 0.2% 0.1% 2.0% 100.0% Number 2008 64,344 56,037 1,549 282 15,347 282 141 2,816 140,796 Percent 2008 45.7% 39.8% 1.1% 0.2% 10.9% 0.2% 0.1% 2.0% 100.0% # Change -5,948 14,603 -249 -111 3,449 14 -21 240 11,975 %Change -8.5% 35.2% - 13.9% - 28.3% 29.0% 5.1% -13.1% 9.3% 9.3% 272 Table A -9 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Entitlement Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Rancho Santa Margarita* Number 2000 35,132 6,139 787 131 3,440 90 91 1,404 47,214 Percent 2000 74.4% 13.0% 1.7% 0.3% 7.3% 02% 0.2% 3.0% 100.0% Number 2008 35,989 7,386 744 149 4,263 0 0 1,041 49,572 Percent 2008 72.6% 14.9% 1.5% 0.3% 8.6% 0.0% 0.0% 2.1% 100.0% # Change 857 1,247 -43 18 823 -90 -91 -363 2,358 % Change 2.4% 20.3% -5.5% 13.5% 23.9% - 100.0% - 100.0% - 25.9% 5.0% Santa Ana Number 2000 41,984 257,097 4,309 886 29,412 993 273 3,023 337,977 Percent 2000 12.4% 76.1% 1.3% 0.3% 8.7% 0.3% 0.1% 0.9% 100.0% Number 2008 33,543 284,234 3,885 353 29,306 106 353 1,413 353,193 Percent 2008 9.5% 80.5% 1.1 % 0.1 % 8.3% 0.0% 0.1% 0.4% 100.0% # Change -8,441 27,137 -424 -533 -106 -887 80 -1,610 15,216 %Change -20.1% 10.6% -9.8% -60.1% -0.4% -89.3% 29.4% - 53.3% 4.5% Westminster Number 2000 31,962 19,138 764 293 33,511 393 101 2,045 88,207 Percent 2000 36.2% 21.7% 0.9% 0.3% 38.0% 0.4% 0.1% 2.3% 100.0% Number 2008 NA NA NA NA NA NA NA NA 92,854 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 4,647 % Change NA NA NA NA NA NA NA NA 5.3% * Denotes 2006 -2008 ACS 3 -Year Estimate Data Source: Census 2000, Summary File 1, Table P4 Hispanic or Latino by Race, Not Hispanic or Latino. 2008 American Community Survey (ACS) 1 Year Estimates, Select Demographic Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates Note: The ACS data was used for determining the percent breakdown for the population, which was then applied to a mid year -2008 estimate of DOF population estimates. 273 Table A -10 Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban County Cities city Year/Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Aliso Viejo Number 2000 28,599 4,680 790 107 4,367 78 102 1,443 40,166 Percent 2000 71.2% 11.7% 2.0% 0.3% 10.9% 0.2% 0.3% 3.6% 100.0% Number 2008 27,833 8,718 1,544 91 6,039 0 136 1,044 45,404 Percent 2008 61.3% 19.2% 3.4% 0.2% 13.3% 0.0% 0.3% 2.3% 100.0% # Change -766 4,038 754 -16 1,672 -78 34 -399 5,238 % Change -2.7% 86.3% 95.4% -15.1% 38.3% - 100.0% 33.5% -27.6% 13.0% Brea Number 2000 23,541 7,205 409 111 3,184 71 57 832 35,410 Percent 2000 66.5% 20.3% 1.2% 0.3% 9.0% 0.2% 0.2% 2.3% 100.0% Number 2008 23,319 8,320 640 80 6,440 40 160 1,000 39,998 Percent 2008 58.3% 20.8% 1.6% 0.2% 16.1% 0.1% 0.4% 2.5% 100.0% # Change -222 1,115 231 -31 3,256 -31 103 168 4,588 % Change -0.9% 15.5% 56.5% -27.9% 102.3% - 43.7% 180.7% 20.2% 13.0% Cypress Number 2000 26,400 7,235 1,251 176 9,564 164 112 1,327 46,229 Percent 2000 57.1% 15.7% 2.7% 0.4% 20.7% 0.4% 0.2% 2.9% 100.0% Number 2008 1 24,2721 8,305 1 1,137 1 198 1 13,842 1 346 1 99 1 1,236 1 49,434 Percent 2008 1 49.1% 1 16.8% 1 2.3% 1 0.4% 1 28.0% 1 0.7% 1 0.2% 1 2.5% 1 100.0% # Change 1 -2,1281 1,070 1 -114 1 22 1 4,278 1 182 1 -13 1 -91 1 3,205 % Change 1 -8.1% 1 14.8% 1 -9.1% 1 12.4% 1 44.7% 1 111.0% 1 -11.7% 1 -6.9% 1 6.9% 27.4. Table A -10 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban Count I Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Dana Point Number 2000 27,658 5,440 252 123 874 31 76 656 35,110 Percent 2000 78.8% 15.5% 0.7% 0.4% 2.5% 0.1% 0.2% 1.9% 100.0% Number 2008 28,940 5,131 406 111 923 37 664 701 36,913 Percent 2008 78.4% 13.9% 1.1% 0.3% 2.5% 0.1% 1.8% 1.9% 100.0% # Change 1,282 -309 154 -12 49 6 588 45 1,803 % Change 4.6% -5.7% 61.1% - 10.0% 5.6% 19.1% 774.3% 6.9% 5.1% Laguna Beach Number 2000 20,921 1,570 183 59 486 19 36 453 23,727 Percent 2000 88.2% 6.6% 0.8% 0.2% 2.0% 0.1% 0.2% 1.9% 100.0% Number 2008 NA NA NA NA NA NA NA NA 25,087 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 1,360 % Change NA NA NA NA NA NA NA NA 5.7% Laguna Hills Number 2000 21,471 5,113 404 77 3,153 45 73 842 31,178 Percent 2000 68.9% 16.4% 1.3% 0.2% 10.1% 0.1% 0.2% 2.7% 100.0% Number 2008 21,391 7,230 700 33 2,899 100 133 833 33,319 Percent 2008 64.2% 21.7% 2.1% 0.1% 8.7% 0.3% 0.4% 2.5% 100.0% # Change -80 2,117 296 -44 -254 55 60 -9 2,141 % Change -0.4% 41.4% 73.2% - 56.7% -8.1% 122.1% 82.6% -1.1% 6.9% Los Alamitos Number 2000 7,836 1,848 358 31 1,090 35 18 320 11,536 Percent 2000 67.9% 16.0% 3.1% 0.3% 9.4% 0.3% 0.2% 2.8% 100.0% Number 2008 NA NA NA NA NA NA NA NA 12,165 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 629 % Change NA NA NA NA NA NA NA NA 5.5% 275 Table A -10 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban Count I Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total La Palma Number 2000 5,592 1,736 696 37 6,874 43 35 395 15,408 Percent 2000 36.3% 11.3% 4.5% 0.2% 44.6% 0.3% 0.2% 2.6% 100.0% Number 2008 NA NA NA NA NA NA NA NA 16,139 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 731 % Change NA NA NA NA NA NA NA NA 4.7% Laguna Woods Number 2000 15,580 340 41 18 412 4 7 105 16,507 Percent 2000 94.4% 2.1% 0.2% 0.1% 2.5% 0.0% 0.0% 0.6% 100.0% Number 2008 NA NA NA NA NA NA NA NA 18,399 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 1,892 % Change NA NA NA NA NA NA NA NA 11.5% Placentia Number 2000 24,967 14,460 746 177 5,121 65 61 891 46,488 Percent 2000 53.7% 31.1% 1.6% 0.4% 11.0% 0.1% 0.1% 1.9% 100.0% Number 2008 23,225 19,664 671 103 6,813 361 103 671 51,612 Percent 2008 45.0% 38.1% 1.3% 0.2% 13.2% 0.7% 0.2% 1.3% 100.0% # Change -1,742 5,204 -75 -74 1,692 296 42 -220 5,124 % Change -7.0% 36.0% -10.1% 41.7% 33.0% 455.8% 69.2% -24.7% 11.0% Seal Beach Number 2000 20,372 1,554 329 54 1,363 37 21 427 24,157 Percent 2000 84.3% 6.4% 1.4% 0.2% 5.6% 0.2% 0.1% 1.8% 100.0% Number 2008 21,210 1,811 259 207 1,733 0 129 517 25,866 Percent 2008 82.0% 7.0% 1.0% 0.8% 6.7% 0.0% 0.5% 2.0% 100.0% # Change 838 257 -70 153 370 -37 108 90 1,709 % Change 4.1% 16.5% -21.4% 283.2% 27.1% - 100.0% 515.9% 21.2% 7.1% 270 Table A -10 continued Regional Analysis of Fair Housing Impediments Population by Race and Hispanic or Latino Growth Trends 2000 -2008 for Urban County Cities City Year /Change White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Two or more races Total Stanton Number 2000 11,295 18,285 721 155 5,721 322 57 847 37,403 Percent 2000 30.2% 48.9% 1.9% 0.4% 15.3% 0.9% 0.2% 2.3% 100.0% Number 2008 9,459 19,743 1,021 157 8,007 236 196 432 39,251 Percent 2008 24.1% 50.3% 2.6% 0.4% 20.4% 0.6% 0.5% 1.1% 100.0% # Change -1,836 1,458 300 2 2,286 -86 139 -415 1,848 % Change -16.3% 8.0% 41.5% 1.3% 40.0% -26.9% 244.3% -49.0% 4.9% Villa Park Number 2000 4,691 354 41 22 769 2 4 116 5,999 Percent 2000 78.2% 5.9% 0.7% 0.4% 12.8% 0.0% 0.1% 1.9% 100.0% Number 2008 NA NA NA NA NA NA NA NA 6,248 Percent 2008 NA NA NA NA NA NA NA NA 100.0% # Change NA NA NA NA NA NA NA NA 249 % Change NA NA NA NA NA NA NA NA 4.2% Yorba Linda Number 2000 44,071 6,044 638 139 6,502 50 138 1,336 58,918 Percent 2000 74.8% 10.3% 1.1% 0.2% 11.0% 0.1% 0.2% 2.3% 100.0% Number 2008 46,676 8,301 1,361 613 9,390 14 476 1,225 68,056 Percent 2008 68.6% 12.2% 2.0% 0.9% 13.8% 0.0% 0.7% 1.8% 100.0% # Change 2,605 2,257 723 474 2,888 -36 338 -111 9,138 % Change 5.9% 37.3% 113.3% 340.7% 44.4% -72.8% 245.2% -8.3% 15.5% Source: Census 2000, Summary File 1, Table P4 Hispanic or Latino by Race, Not Hispanic or Latino. 2008 American Community Survey (ACS) 3 -Year Estimates, Select Demographic Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates Note: The ACS data was used for determining the percent breakdown for the population, which was then applied to a mid year -2008 estimate of DOF population estimates. 277 Table A -11 Regional Analysis of Fair Housing Impediments Household Type for Entitlement Cities - 2008 City Married Couple Families Percent Male Householder, No Wife Present Percent Female Householder, No Husband Present Percent Non - Family Households Percent Total Households Anaheim 54,620 55.1% 4,758 4.8% 16,059 16.2% 23,692 23.9% 99,129 Buena Park 13,353 56.0% 1,478 6.2% 4,220 17.7% 4,793 20.1% 23,844 Fountain Valley* 11,571 62.5% 926 5.0% 1,463 7.9% 4,554 24.6% 18,514 Fullerton 23,485 51.2% 1,743 3.8% 5,045 11.0% 15,595 34.0% 45,868 Garden Grove 25,337 54.5% 4,463 9.6% 6,787 14.6% 9,902 21.3% 46,489 Huntington Beach 39,044 51.4% 3,950 5.2% 7,900 10.4% 25,067 33.0% 75,961 Irvine 38,977 52.1% 3,666 4.9% 6,509 8.7% 25,661 34.3% 74,813 Lake Forest 14,604 56.8% 1,800 7.0% 1,491 5.8% 7,816 30.4% 25,711 La Habra* 10,009 51.5% 1,458 7.5% 2,974 15.3% 4,995 25.7% 19,436 Newport Beach 18,244 47.5% 922 2.4% 2,612 6.8% 16,631 43.3% 38,409 Orange 24,767 57.1% 2,429 5.6% 4,337 10.0% 11,841 27.3% 43,374 Rancho Santa Margarita 10,279 62.2% 793 4.8% 1,405 8.5% 4,049 24.5% 16,526 Santa Ana 39,089 52.8% 8,292 11.2% 12,659 17.1% 13,992 18.9% 74,032 Westminster 15,542 57.8% 1,775 6.6% 3,092 11.5% 6,480 24.1% 26,889 Total 338,921 53.9% 38,453 6.1% 76,553 12.2% 175,068 27.8% 628,995 *Denotes data from the 2006 -2008 ACS estimate Source: 2008 American Community Survey (ACS) 1 -Year Estimates, Select Demographic Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates 272 Table A -12 Regional Analysis of Fair Housing Impediments Household Type for Urban County Cites - 2008 City Married Couple Families Percent Male Householder, No Wife Present Percent Female Householder, No Husband Present Percent Non - Family Households Percent Total Households Aliso Viejo 8,810 50.1% 545 3.1% 1,460 8.3% 6,770 38.5% 17,585 Brea 7,867 55.0% 544 3.8% 1,545 10.8% 4,348 30.4% 14,303 Cypress 9,849 60.7% 681 4.2% 2,369 14.6% 3,326 20.5% 16,225 Dana Point 7,690 52.3% 573 3.9% 1,338 9.1% 5,102 34.7% 14,704 Laguna Beach 5,038 42.8% 530 4.5% 612 5.2% 5,592 47.5% 11,772 Laguna Hills 6,873 63.6% 378 3.5% 1,092 10.1% 2,464 22.8% 10,807 Laguna Woods NA NA NA NA NA NA NA NA 12,591 La Palma NA NA NA NA NA NA NA NA 5,043 Los Alamitos NA NA NA NA NA NA NA NA 4,339 Placentia 9,274 57.3% 906 5.6% 2,023 12.5% 3,982 24.6% 16,185 Seal Beach 4,930 36.8% 121 0.9% 710 5.3% 7,636 57.0% 13,397 Stanton 5,543 50.7% 492 4.5% 1,727 15.8% 3,171 29.0% 10,933 Villa Park NA NA NA NA NA NA NA NA 1,964 Yorba Linda 15,349 71.2% 884 4.1% 1,660 7.7% 3,665 17.0% 21,558 Total' 81,224 55.1% 5,654 3.8% 14,535 9.9% 46,056 31.2% 147,469 'Totals are only for the cities that have ACS data and exclude the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park all of which have populations of less than 20,000. The ACS 3 -Year estimates are available for cities having populations between 20,000 and 65,000 persons. The percentages are based on the total for the known cities (147,469). Source: 2006 -2008 American Community Survey (ACS) 3 -Year Estimates, Select Social Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda 8 Associates Table A -13 Regional Analysis of Fair Housing Impediments Households with Children under 18 Years of Age by Type of Household Entitlement Cities - 2008 City Married Couple Families Percent of All Households Male Householder, No Wife Present Percent of All Households Female Householder, No Husband Present Percent of All Households Total Percent of All Households Total Households Anaheim 31,226 31.5% 1,883 1.9% 8,723 8.8% 41,832 42.2% 99,129 Buena Park 9,347 39.2% 501 2.1% 1,836 7.7% 11,684 49.0% 23,844 Fountain Vale y* 4,684 25.3% 296 1.6% 574 3.1% 5,554 30.0% 18,514 Fullerton 10,962 23.9% 871 1.9% 2,477 5.4% 14,311 31.2% 45,868 Garden Grove 14,179 30.5% 1,162 2.5% 3,115 6.7% 18,456 39.7% 46,489 Huntington Beach 16,256 21.4% 1,367 1.8% 3,874 5.1% 21,497 28.3% 75,961 Irvine 19,751 26.4% 2,020 2.7% 2,693 3.6% 24,464 32.7% 74,813 Lake Forest 7,251 28.2% 823 3.2% 694 2.7% 8,767 34.1% 25,711 La Habra* 5,073 26.1% 603 3.1% 1,769 9.1% 7,444 38.3% 19,436 Newport Beach 8,143 21.2% 346 0.9% 1,383 3.6% 9,871 25.7% 38,409 Orange 11,537 26.6% 954 2.2% 2,472 5.7% 14,964 34.5% 43,374 Rancho Santa Margarita* 6,363 38.5% 331 2.0% 826 5.0% 7,520 45.5% 16,526 Santa Ana 25,467 34.4% 5,108 6.9% 7,403 10.0% 37,978 51.3% 74,032 Westminster 7,529 28.0% 323 1.2% 1,533 5.7% 9,384 34.9% 26,889 Total 177,768 28.0% 16,588 2.7% 39,372 6.3% 233,726 36.9% 628,995 *Denotes data from 3 -Year 2006 -2008 estimate Source: 2008 American Community Survey (ACS) 1 -Year Estimates, Select Demographic Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1. 2009 Table construction by Castaneda & Associates v� Table A -14 Regional Analysis of Fair Housing Impediments Households with Children under 18 Years of Age by Type of Household Urban County Cities - 2008 city Married Couple Families Percent of All Households Male Householder, No Wife Present Percent of All Households Female Householder, No Husband Present Percent of All Households Total Percent of All Households Total Households Aliso Viejo 4,977 28.3% 264 1.5% 844 4.8% 6,084 34.6% 17,585 Brea 3,561 24.9% 200 1.4% 744 5.2% 4,505 31.5% 14,303 Cypress 4,738 29.2% 373 2.3% 925 5.7% 6,036 37.2% 16,225 Dana Point 2,603 17.7% 221 1.5% 779 5.3% 3,602 24.5% 14,704 Laguna Beach 1,460 12.4% 224 1.9% 341 2.9% 2,025 17.2% 11,772 Laguna Hills 2,885 26.7% 195 1.8% 659 6.1% 3,739 34.6% 10,807 Laguna Woods NA NA NA NA NA NA NA NA 12,591 La Palma NA NA NA NA NA NA NA NA 5,043 Los Alamitos NA NA NA NA NA NA NA NA 4,339 Placentia 4,645 28.7% 469 2.9% 939 5.8% 6,053 37.4% 16,185 Seal Beach 1,233 9.2% 67 0.5% 281 2.1% 1,581 11.8% 13,397 Stanton 3,160 28.9% 219 2.0% 951 8.7% 4,329 39.6% 10,933 Villa Park NA NA NA NA NA NA NA NA 1,964 Yorba Linda 7,114 33.0% 366 1.7% 755 3.5% 8,235 38.2% 21,558 Total 36,375 24.7% 2,597 1.8% 7,218 4.9% 46,191 31.3% 147,469 'Totals are only for the cities that have ACS data and exclude the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park all of which have populations of less than 20,000. The ACS 3 -Year estimates are available for cities having populations between 20,000 and 65,000 persons. The percentages are based on the total for the known cities (147,469). Source: 2006 -2008 American Community Survey (ACS) 3 -Year Estimates, Select Social Characteristics. State of California, Department of Finance, Demographic Research Unit, City and County Summary Report of Population and Housing -- Report E -5, January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates 2g2 Table A -15 Regional Analysis of Fair Housing Impediments Poverty Rates for Female Householders And Presence of Children for Entitlement Cities - 2008 City With Related Children <5 Years With Related Children <18 Years All Female Householder Families Anaheim 20.6% 27.0% 19.8% Buena Park 0.0% 15.1% 10.2% Fountain Valley* 0.0% 13.3% 8.0% Fullerton 16.1% 317% 23.1% Garden Grove 36.2% 28.7% 22.5% Huntington Beach 15.1% 8.5% 10.2% Irvine 11.6% 9.9% 6.8% La Habra* 52.0% 27.9% 21.3% Lake Forest N/A N/A N/A Newport Beach N/A 5.3% 13.7% Orange 14.4% 14.5% 11.4% Rancho Santa Margarita* 44.1% 7.0% 4.6% Santa Ana 25.7% 31.4% 23.8% Westminster 0.0% 17.8% 10.6% *Denotes data from 3 -Year 2006 -2008 ACS estimate Source: 2008 American Community Survey (ACS) 1 -Year Estimates, Select Income Characteristics Table construction by Castaneda & Associates 222 Table A -16 Regional Analysis of Fair Housing Impediments Poverty Rates for Female Householders And Presence of Children for Urban County Cities — 2008 City With Related Children <5 Years With Related Children <18 Years All Female Householder Families Aliso Viejo 12.3% 18.6% 12.8% Brea 100.0% 18.7% 9.6% Cypress 0.0% 9.2% 6.1% Dana Point 23.6% 10.2% 6.8% Laguna Beach N/A 15.3% 12.2% Laguna Hills 0.0% 30.6% 20.4% Laguna Woods N/A N/A N/A La Palma N/A N/A N/A Los Alamitos N/A N/A N/A Placentia 59.3% 32.4% 21.0% Seal Beach N/A N/A N/A Stanton 28.7% 51.7% 33.3% Villa Park N/A N/A N/A Yorba Linda 20.7% 22.2% 12.5% Source: 2008 American Community Survey (ACS) 3 -Year Estimates, Select Income Characteristics Table construction by Castaneda & Associates 22S Table A -17 Regional Analysis of Fair Housing Impediments Marital Status for Entitlement Cities - 2008 City Married Households Percent Not Married Households Percent Total Households Anaheim 54,620 55.1% 44,509 44.9% 99,129 Buena Park 13,353 56.0% 10,491 44.0% 23,844 Fountain Valley* 11,553 62.4% 6,961 37.6% 18,514 Fullerton 23,439 51.1% 22,429 48.9% 45,868 Garden Grove 25,337 54.5% 21,152 45.5% 46,489 Huntington Beach 39,044 51.4% 36,917 48.6% 75,961 Irvine 39,052 52.2% 35,761 47.8% 74,813 La Habra* 10,010 51.5% 9,426 48.5% 19,436 Lake Forest 14,578 56.7% 11,133 43.3% 25,711 Newport Beach 18,244 47.5% 20,165 52.5% 38,409 Orange 24,810 57.2% 18,564 42.8% 43,374 Rancho Santa Margarita* 10,296 62.3% 6,230 37.7% 16,526 Santa Ana 39,089 52.8% 34,943 47.2% 74,032 Westminster 15,542 57.8% 11,347 42.2% 26,889 Total 338,965 53.9% 290,030 46.1% 628,995 *Denotes data from 3 -Year 2006 -2008 ACS estimate Source: 2008 American Community Survey (ACS) 1 -Year Estimates, Select Social Characteristics. California Department of Finance (DOF) Mid -Point Estimate for 2008 Occupied Housing Units (Households) for January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates r Table A -18 Regional Analysis of Fair Housing Impediments Marital Status for Urban County - 2008 city Married Households Percent Not Married Households Percent Total Households Aliso Viejo 8,810 50.1% 8,775 49.9% 17,585 Brea 7,852 54.9% 6,451 45.1% 14,303 Cypress 9,865 60.8% 6,360 39.2% 16,225 Dana Point 7,675 52.2% 7,029 47.8% 14,704 Laguna Beach 5,038 42.8% 6,734 57.2% 11,772 Laguna Hills 6,862 63.5% 3,945 36.5% 10,807 Laguna Woods N/A N/A N/A N/A 12,591 La Palma N/A N/A N/A N/A 5,043 Los Alamitos N/A N/A N/A N/A 4,339 Placentia 9,290 57.4% 6,895 42.6% 16,185 Seal Beach 4,930 36.8% 8,467 63.2% 13,397 Stanton 5,543 50.7% 5,390 49.3% 10,933 Villa Park N/A N/A N/A N/A 1,964 Yorba Linda 15,371 71.3% 6,187 28.7% 21,558 Total 1 81,238 55.1% 66,231 44.9% 147,469 'Totals are only for the cities that have ACS data and exclude the cities of Laguna Woods, La Palma, Los Alamitos and Villa Park all of which have populations of less than 20,000. The ACS 3 -Year estimates are available for cities having populations between 20,000 and 65,000 persons. The percentages are based on the total for the known cities (147,469). Source: 2008 American Community Survey (ACS) 3 -Year Estimates, Select Social Characteristics. California Department of Finance (DOF) Mid -Point Estimate for 2008 Occupied Housing Units (Households) for January 1, 2008 and January 1, 2009 Table construction by Castaneda & Associates 225 This Page Intentionally Left Blank Technical Appendix 6 Minority Population by Census Tract 22 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 525.18 0 0 0 0 0 0 0 3 3 3 100.00% 745.01 82 7,115 5 21 842 13 7 148 8,233 8,151 99.00% 748.06 80 5,801 161 2 74 14 13 9 6,154 6,074 98.70% 749.02 102 7,080 15 4 43 2 0 15 7,261 7,159 98.60% 748.01 107 5,722 244 30 130 20 1 13 6,267 6,160 98.29% 749.01 185 9,533 50 30 272 22 8 29 10,129 9,944 98.17 %° 747.01 198 8,588 72 6 135 34 0 42 9,075 8,877 97.82% 748.05 156 6,298 76 15 100 27 14 24 6,710 6,554 97.68% 992.49 121 3,472 26 8 770 21 0 25 4,443 4,322 97.28% 752.01 162 5,426 71 16 240 1 2 30 5,948 5,786 97.28% 745.02 178 5,637 7 19 361 32 0 46 6,280 6,102 97.17% 746.02 284 9,222 27 5 76 14 3 18 9,649 9,365 97.06% 891.05 232 6,133 18 22 635 11 5 25 7,081 6,849 96.72% 743.00 147 4,204 5 19 15 3 0 22 4,415 4,268 96.67% 750.03 299 7,773 49 42 25 0 16 28 8,232 7,933 96.37% 747.02 270 6,328 9 19 18 15 4 17 6,680 6,410 95.96% 750.04 247 5,444 29 0 44 4 2 9 5,779 5,532 95.73% 750.02 426 8,639 86 20 395 2 3 39 9,610 9,184 95.57% 744.03 298 5,861 18 19 153 4 0 21 6,374 6,076 95.32% 741.09 200 3,486 13 25 270 15 1 22 4,032 3,832 95.04% 740.03 125 2,266 25 8 39 4 1 16 2,484 2,359 94.97% 742.00 504 8,899 23 16 118 16 8 27 9,611 9,107 94.76% 752.02 322 5,519 98 25 139 0 11 23 6,137 5,815 94.75% 744.05 371 6,450 32 5 64 3 11 29 6,965 6,594 94.67% 741.08 313 4,515 40 13 331 37 0 38 5,287 4,974 94.08% 748.02 375 5,218 163 22 180 22 3 58 6,041 5,666 93.79% 741.02 524 5,996 110 19 696 30 9 44 7,428 6,904 92.95% 746.01 626 7,998 29 29 110 23 4 42 8,861 8,235 92.94% 891.04 449 4,384 37 10 1,130 19 0 45 6,074 5,625 92.61% 741.03 385 4,646 13 21 79 21 1 30 5,196 4,811 92.59% 744.07 573 6,765 100 6 161 8 6 68 7,687 7,114 92.55% v� Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 117.20 562 6,612 93 24 158 11 10 65 7,535 6,973 92.54% 865.02 510 5,995 34 24 77 1 1 36 6,678 6,168 92.36% 748.03 702 6,623 177 26 1,409 33 4 78 9,052 8,350 92.24% 744.06 311 3,402 31 14 55 8 1 16 3,838 3,527 91.90% 874.04 323 3,338 34 14 53 9 0 14 3,785 3,462 91.47% 890.01 794 3,704 54 30 2,835 46 1 110 7,574 6,780 89.52% 874.05 716 5,504 101 20 235 16 4 53 6,649 5,933 89.23% 890.04 812 4,865 68 5 1,596 34 6 53 7,439 6,627 89.08% 992.47 380 1,765 24 14 1,176 31 1 27 3,418 3,038 88.88% 992.48 608 3,297 73 3 1,300 44 1 39 5,365 4,757 88.67% 890.03 436 2,009 84 4 1,155 37 1 82 3,808 3,372 88.55% 875.04 1,038 6,342 106 35 587 22 0 118 8,248 7,210 87.42% 866.01 1,255 7,746 247 26 455 29 13 101 9,872 8,617 87.29% 878.03 862 4,415 135 16 808 89 12 105 6,442 5,580 86.62% 740.05 1,051 5,238 103 21 1,110 26 20 85 7,654 6,603 86.27% 874.03 531 3,059 21 9 92 2 0 21 3,735 3,204 85.78% 889.03 1,225 2,289 45 16 4,776 59 12 172 8,594 7,369 85.75% 873.00 1,502 7,428 216 23 716 16 3 137 10,041 8,539 85.04% 865.01 732 3,843 36 16 79 1 2 39 4,748 4,016 84.58% 1106.06 798 2,805 249 18 860 10 6 95 4,841 4,043 83.52% 864.05 1,150 5,067 100 8 288 10 17 59 6,699 5,549 82.83% 116.02 990 4,460 113 19 123 3 1 53 5,762 4,772 82.82 % 992.02 1,402 4,206 88 54 2,194 49 10 114 8,117 6,715 82.73 % 744.08 916 3,664 213 24 322 17 7 76 5,239 4,323 82.52% 879.02 1,072 3,586 81 11 1,019 86 1 127 5,983 4,911 82.08% 889.04 1,043 682 20 3 3,927 26 7 101 5,809 4,766 82.05% 864.04 1,121 4,347 57 24 585 5 6 72 6,217 5,096 81.97% 891.06 689 2,317 32 7 680 12 3 44 3,784 3,095 81.79% 891.02 1,282 4,232 69 23 1,182 57 4 105 6,954 5,672 81.56% 12.01 991 3,991 59 18 213 3 0 96 5,371 4,380 81.55% 753.02 852 3,440 86 3 181 6 6 34 4,608 3,756 81.51% Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 889.02 959 1,363 34 14 2,601 82 4 79 5,136 4,177 81.33% 88.01 1,547 1,593 108 17 4,701 53 8 179 8,206 6,659 81.15% 741.11 1,135 3,579 153 12 938 15 6 84 5,922 4,787 80.83% 117.14 58 227 0 3 9 0 0 5 302 244 80.79% 637.01 1,296 5,028 60 11 189 20 12 76 6,692 5,396 80.63% 875.01 1,214 4,135 79 8 442 3 4 65 5,950 4,736 79.60% 889.05 1,028 835 30 13 2,991 10 1 72 4,980 3,952 79.36% 755.14 824 2,430 127 15 424 24 5 74 3,923 3,099 79.00% 755.15 1,588 4,325 227 24 1,129 16 19 154 7,482 5,894 78.78% 1105.00 1,843 4,663 417 40 1,382 61 16 177 8,599 6,756 78.57% 762.04 1,150 3,716 28 15 393 4 1 53 5,360 4,210 78.54% 751.00 2,250 7,416 258 13 336 12 11 126 10,422 8,172 78.41% 998.03 1,165 1,397 33 13 2,671 9 6 87 5,381 4,216 7835% 871.02 1,279 2,816 311 11 1,237 44 5 159 5,862 4,583 78.18% 891.07 1,251 2,753 48 13 1,522 34 11 78 5,710 4,459 78.09% 1106.03 1,889 4,535 434 41 1,441 28 16 189 8,573 6,684 77.97% 636.05 1,246 4,149 50 11 93 1 3 68 5,621 4,375 77.83% 116.01 1,840 5,322 249 37 625 11 6 202 8,292 6,452 77.81% 741.10 849 1,255 89 4 1,549 9 1 70 3,826 2,977 77.81% 761.03 1,918 4,276 179 51 1,991 66 8 150 8,639 6,721 77.80% 878.06 1,203 3,153 92 20 733 53 8 145 5,407 4,204 77.75% 889.01 1,530 1,422 94 15 3,510 24 6 162 6,763 5,233 77.38% 887.01 1,433 1,987 61 22 2,635 41 2 133 6,314 4,881 77.30% 13.04 912 2,798 59 16 105 10 0 45 3,945 3,033 76.88% 994.02 2,055 5,973 60 39 468 3 2 126 8,726 6,671 76.45% 638.08 1,598 4,682 67 13 221 74 13 85 6,753 5,155 76.34% 888.02 1,309 1,656 72 5 2,312 28 2 110 5,494 4,185 76.17% 887.02 1,305 1,409 16 8 2,549 21 9 142 5,459 4,154 76.09% 740.06 1,354 3,142 171 22 657 20 9 147 5,522 4,168 75.48% 866.02 1,521 3,720 226 23 538 22 8 119 6,177 4,656 75.38% 867.02 1,645 3,741 289 7 663 51 13 237 6,646 5,001 75.25% 29 D Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 885.02 1,252 2,563 54 14 1,003 42 6 89 5,023 3,771 75.07% 14.04 939 2,557 40 25 122 5 4 75 3,767 2,828 75.07% 12.02 843 2,360 25 13 72 8 4 42 3,367 2,524 74.96% 998.02 1,020 1,292 30 30 1,556 5 1 123 4,057 3,037 74.86% 875.03 1,805 4,467 143 20 520 32 4 119 7,110 5,305 74.61% 992.03 1,572 1,191 47 12 3,195 37 4 112 6,170 4,598 74.52% 884.02 1,248 2,597 80 29 815 58 4 65 4,896 3,648 74.51% 884.03 1,664 3,473 178 25 992 30 5 147 6,514 4,850 74.46% 218.13 11 28 0 0 0 0 0 4 43 32 74.42% 886.01 1,468 1,889 63 14 2,163 32 4 99 5,732 4,264 74.39% 86101 1,801 4,482 68 25 458 6 8 82 6,930 5,129 74.01% 885.01 1,712 3,235 71 23 1,368 43 16 116 6,584 4,872 74.00% 881.07 1,557 1,316 39 35 2,699 9 13 198 5,866 4,309 73.46% 996.01 1,955 2,724 55 9 2,415 37 4 137 7,336 5,381 73.35% 423.12 2,256 5,919 20 68 73 2 1 76 8,415 6,159 73.19% 740.04 1,986 3,535 259 7 1,272 34 17 129 7,239 5,253 72.57% 999.04 1,871 2,069 56 28 2,604 35 10 128 6,801 4,930 72.49% 117.21 1,283 2,854 100 32 276 13 2 94 4,654 3,371 72.43% 879.01 909 1,579 54 16 632 21 3 58 3,272 2,363 72.22% 997.01 1,622 1,149 39 20 2,840 19 3 144 5,836 4,214 72.21% 874.01 859 1,999 40 11 84 12 2 51 3,058 2,199 71.91% 1101.16 1,369 468 200 2 2,677 21 12 99 4,848 3,479 71.76% 877.03 1,751 2,855 110 34 1,225 62 7 150 6,194 4,443 71.73% 871.06 1,422 2,865 83 42 515 12 2 49 4,990 3,568 71.50% 1106.05 1,952 520 62 7 4,122 2 12 110 6,787 4,835 71.24% 18.01 1,492 2,394 292 27 774 6 14 122 5,121 3,629 70.87% 219.13 2,506 4,907 61 28 834 24 12 110 8,482 5,976 70.46% 999.03 1,659 2,036 32 24 1,701 52 12 92 5,608 3,949 70.42% 753.01 1,576 3,041 145 21 405 13 4 77 5,282 3,706 70.16% 876.01 1,543 2,736 101 18 629 5 12 113 5,157 3,614 70.08% 755.12 1,070 1,477 95 4 730 14 3 117 3,510 2,440 69.52% : 92 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 17.07 1,906 604 96 6 3,437 9 3 131 6,192 4,286 69.22% 992.23 1,623 903 68 18 2,432 37 6 135 5,222 3,599 68.92% 1104.02 1,649 2,636 141 11 660 43 10 149 5,299 3,650 68.88% 878.05 2,165 3,417 131 25 819 61 10 169 6,797 4,632 68.15% 13.03 1,861 3,460 66 14 248 3 11 87 5,750 3,889 67.63% 18.02 2,398 3,825 246 27 658 34 18 194 7,400 5,002 67.59% 864.02 1,731 2,991 67 23 402 25 8 89 5,336 3,605 67.56% 117.22 1,021 1,662 67 13 334 1 0 38 3,136 2,115 67.44% 871.01 1,337 1,267 181 13 1,094 15 15 165 4,087 2,750 67.29% 998.01 1,825 1,613 65 26 1,826 66 3 140 5,564 3,739 67.20% 868.02 1,789 2,326 173 16 918 15 5 117 5,359 3,570 66.62% 870.01 1,819 2,478 207 35 715 35 3 111 5,403 3,584 66.33% 1101.18 944 203 115 1 1,441 1 8 78 2,791 1,847 66.18% 869.01 3,053 3,859 366 27 1,219 183 22 249 8,978 5,925 65.99% 111.02 1,560 2,213 109 16 512 11 7 100 4,528 2,968 65.55% 878.02 2,330 2,945 209 28 1,008 43 8 154 6,725 4,395 65.35% 992.04 1,506 405 37 4 2,280 28 8 74 4,342 2,836 65.32% 626.26 928 200 35 2 1,356 3 12 136 2,672 1,744 65.27% 867.01 2,991 3,965 183 26 1,220 14 16 183 8,598 5,607 65.21% 886.02 1,569 1,402 66 30 1,307 28 4 73 4,479 2,910 64.97% 872.00 2,605 3,874 205 33 485 8 10 151 7,371 4,766 64.66% 997.02 2,922 1,904 82 16 3,074 12 5 191 8,206 5,284 64.39 % 761.02 2,484 2,750 290 21 1,211 28 7 133 6,924 4,440 64.12 % 864.06 1,460 1,923 88 24 412 11 10 91 4,019 2,559 63.67% 1103.02 2,193 2,255 87 20 1,188 31 11 159 5,944 3,751 63.11% 1101.15 1,311 417 171 17 1,537 2 3 85 3,543 2,232 63.00% 524.04 358 500 32 12 37 7 2 19 967 609 62.98% 761.01 1,963 2,658 46 10 452 15 7 113 5,264 3,301 62.71% 869.03 2,254 2,348 185 21 930 93 5 178 6,014 3,760 62.52% 117.11 2,713 3,427 182 19 684 12 20 169 7,226 4,513 62.46% 995.02 1 2481 1391 1651 61 691 91 21 181 6561 4081 62.20% �9 � Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 871.05 1,712 1,729 117 13 776 37 5 118 4,507 2,795 62.01% 876.02 2,802 3,093 118 17 1,107 17 12 188 7,354 4,552 61.90% 754.03 2,403 3,199 163 23 364 28 6 112 6,298 3,895 61.85% 1106.07 1,315 1,074 91 21 789 15 15 114 3,434 2,119 61.71% 741.06 2,088 2,341 156 11 672 32 6 132 5,438 3,350 61.60% 755.13 1,809 1,731 205 23 744 30 9 118 4,669 2,860 61.26 % 992.27 2,362 1,265 128 10 2,082 25 15 175 6,062 3,700 61.04% 880.01 1,835 1,409 58 15 1,213 42 6 126 4,704 2,869 60.99% 754.04 2,406 3,074 164 25 313 28 10 123 6,143 3,737 60.83% 881.06 1,748 1,238 73 13 1,207 52 1 118 4,450 2,702 60.72% 881.05 1,540 1,035 38 10 1,193 13 5 82 3,916 2,376 60.67% 1102.02 3,055 2,169 353 29 1,810 54 21 266 7,757 4,702 60.62% 636.04 1,575 2,187 38 5 107 4 5 62 3,983 2,408 60.46% 117.12 1,875 2,003 95 19 580 5 11 99 4,687 2,812 60.00% 11.03 1,788 2,348 69 12 148 7 8 80 4,460 2,672 59.91% 626.14 4,648 1,199 253 10 4,929 12 69 419 11,539 6,891 59.72% 525.15 2,785 432 99 3 3,151 12 26 381 6,889 4,104 59.57% 992.22 1,908 655 25 4 1,934 16 12 117 4,671 2,763 59.15% 870.02 2,774 2,185 259 22 1,113 38 7 316 6,714 3,940 58.68% 758.11 1,383 1,674 20 6 176 4 3 45 3,311 1,928 58.23% 871.03 3,188 2,472 144 30 1,541 33 25 198 7,631 4,443 58.22% 877.04 1,983 1,580 82 16 933 15 9 116 4,734 2,751 58.11 % 884.01 2,061 1,660 37 10 1,011 31 3 90 4,903 2,842 57.96 % 882.03 1,962 1,245 125 14 1,160 16 6 120 4,648 2,686 57.79% 868.03 3,078 1,869 480 28 1,515 24 12 278 7,284 4,206 57.74% 639.04 2,125 1,840 30 21 704 186 7 96 5,009 2,884 57.58% 883.01 2,544 2,012 61 30 1,154 43 2 145 5,991 3,447 57.54% 864.07 2,530 2,445 229 8 589 18 7 131 5,957 3,427 57.53% 115.02 1,725 1,557 102 24 480 14 6 99 4,007 2,282 56.95% 755.07 2,328 1,789 252 26 733 22 21 201 5,372 3,044 56.660% 421.07 1 1,9691 2,3281 461 221 751 41 51 871 4,5361 2,5671 56.59% 293 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 637.02 2,435 2,668 59 20 263 21 6 120 5,592 3,157 56.46% 19.03 1,307 1,056 78 15 458 8 6 70 2,998 1,691 56.40% 992.26 1,716 350 32 5 1,664 22 13 123 3,925 2,209 56.28% 1103.01 2,951 1,328 306 42 1,810 28 22 238 6,725 3,774 56.12% 878.01 2,146 1,773 126 28 556 28 13 220 4,890 2,744 56.11% 1101.02 2,468 767 171 13 1,985 13 18 171 5,606 3,138 55.98% 758.16 1,581 1,322 127 9 402 9 3 124 3,577 1,996 55.80% 1106.04 3,237 983 225 16 2,493 8 9 263 7,234 3,997 55.25% 999.02 2,077 1,329 52 19 987 23 8 143 4,638 2,561 55.22% 881.04 2,072 1,286 80 30 987 24 15 119 4,613 2,541 55.08% 880.02 1,594 780 48 12 970 21 9 110 3,544 1,950 55.02% 111.01 1,796 1,700 83 11 308 4 5 65 3,972 2,176 54.78% 1103.04 2,213 880 92 18 1,465 22 4 170 4,864 2,651 54.50% 877.01 2,235 1,382 113 13 997 16 3 123 4,882 2,647 54.22% 114.03 2,589 2,530 83 27 297 12 7 110 5,655 3,066 54.22% 882.01 1,687 1,240 40 18 605 3 3 65 3,661 1,974 53.92% 117.16 1,916 885 67 11 1,172 4 4 72 4,131 2,215 53.62% 14.01 2,607 2,659 92 9 137 7 12 81 5,604 2,997 53.48% 14.02 2,426 2,342 72 13 189 13 28 112 5,195 2,769 53.30% 863.03 2,125 1,518 126 23 615 15 7 117 4,546 2,421 53.26% 1102.01 3,277 1,801 325 29 1,332 28 19 195 7,006 3,729 53.23% 863.04 2,135 1,716 96 20 448 6 1 110 4,532 2,397 52.89% 863.06 1,690 1,158 96 15 472 15 4 120 3,570 1,880 52.66% 525.27 3,646 595 123 11 2,962 3 14 327 7,681 4,035 52.53% 525.22 1,928 222 44 3 1,633 8 13 204 4,055 2,127 52.45% 758.07 2,219 1,905 44 17 364 4 5 82 4,640 2,421 52.18% 882.02 1,377 679 45 15 665 16 1 71 2,869 1,492 52.00% 19.01 1,298 1,011 43 3 272 12 8 56 2,703 1,405 51.98% 1103.03 2,339 1,020 186 14 1,125 22 5 151 4,862 2,523 51.89% 992.51 2,496 981 105 24 1,357 23 17 184 5,187 2,691 51.88% 626.11 1,810 335 76 4 1,296 11 10 197 3,739 1,929 51.59% :94 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 758.12 3,225 2,815 94 21 359 13 6 118 6,651 3,426 51.51% 525.21 2,214 491 185 8 1,373 7 7 254 4,539 2,325 51.22% 760.00 4,269 3,250 217 37 774 25 17 163 8,752 4,483 51.22% 869.02 2,409 1,197 202 18 866 63 7 159 4,921 2,512 51.05% 1101.10 2,804 1,602 194 22 857 50 15 160 5,704 2,900 50.84% 1104.01 2,294 1,434 115 20 644 22 6 99 4,634 2,340 50.50% 759.01 2,213 1,979 61 14 101 13 7 73 4,461 2,248 50.39% 868.01 1,545 847 70 5 552 19 4 72 3,114 1,569 50.39% 17.05 2,168 1,497 71 6 496 8 1 112 4,359 2,191 50.26% 19.02 1,463 944 72 13 344 12 16 63 2,927 1,464 50.02% 524.20 3,723 438 49 3 2,889 5 5 326 7,438 3,715 49.95% 525.23 2,061 273 48 4 1,510 4 18 172 4,090 2,029 49.61% 639.06 3,429 2,646 109 18 339 42 18 176 6,777 3,348 49.40% 626.27 1,599 234 23 4 1,158 7 4 124 3,153 1,554 49.29% 15.04 2,262 1,766 36 16 251 6 1 121 4,459 2,197 49.27% 115.04 2,710 943 291 25 1,114 21 14 217 5,335 2,625 49.20% 639.03 2,072 1,123 45 7 678 30 7 116 4,078 2,006 49.19% 754.01 1,803 1,549 46 15 73 3 3 46 3,538 1,735 49.04% 524.11 2,621 1,773 68 7 499 13 1 150 5,132 2,511 48.93% 17.04 1,493 252 43 7 1,018 5 6 66 2,890 1,397 48.34% 524.18 1,559 339 108 6 812 3 2 162 2,991 1,432 47.88% 758.06 3,044 2,127 81 29 398 17 3 140 5,839 2,795 47.87% 17.08 1,995 521 20 4 1,190 3 15 73 3,821 1,826 47.79% 997.03 2,421 561 54 15 1,419 9 2 133 4,614 2,193 47.53% 320.14 3,227 2,191 56 20 489 19 13 123 6,138 2,911 47.43% 883.02 2,750 1,101 72 14 1,188 18 16 71 5,230 2,480 47.42% 992.42 1,984 979 35 18 628 6 1 106 3,757 1,773 47.19% 755.05 1,856 1,161 95 21 257 20 15 88 3,513 1,657 47.17% 994.11 3,006 1,656 93 19 643 23 10 165 5,615 2,609 46.46% 1103.13 1,314 410 37 6 571 6 5 88 2,437 1,123 46.08% 762.05 3,377 2,203 77 29 347 15 5 175 6,228 2,851 45.78% 29 5 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 525.05 2,769 617 73 10 1,439 12 9 171 5,100 2,331 45.71% 218.21 2,857 1,302 138 32 775 10 12 132 5,258 2,401 45.66% 11.02 1,683 1,098 50 17 170 3 4 62 3,087 1,404 45.48% 881.01 1,190 584 48 8 261 13 12 51 2,167 977 45.09% 1101.04 3,197 900 231 26 1,236 20 10 145 5,765 2,568 44.54% 639.08 3,156 1,053 158 24 1,035 16 12 235 5,689 2,533 44.52% 753.03 1,913 1,299 55 6 108 5 3 41 3,430 1,517 44.23% 863.05 2,085 978 40 10 520 8 1 88 3,730 1,645 44.10% 525.26 2,458 478 46 3 1,259 6 3 141 4,394 1,936 44.06% 320.27 3,546 1,839 73 19 643 15 9 180 6,324 2,778 43.93% 219.14 2,376 1,456 62 9 240 3 2 78 4,226 1,850 43.78% 639.02 3,776 1,666 116 9 892 44 19 166 6,688 2,912 43.54% 759.02 3,865 2,339 147 22 287 23 13 129 6,825 2,960 4337% 13.01 3,518 2,123 105 20 300 12 11 94 6,183 2,665 43.10% 320.22 3,580 2,016 132 23 356 11 3 170 6,291 2,711 43.09% 757.01 3,671 2,088 150 18 373 3 6 133 6,442 2,771 43.01% 1101.09 2,669 668 122 21 1,032 10 27 131 4,680 2,011 42.97% 117.08 2,519 895 140 15 649 16 8 164 4,406 1,887 42.83% 219.24 2,511 491 97 4 1,123 0 6 158 4,390 1,879 42.80% 992.41 2,455 641 55 17 976 3 11 120 4,278 1,823 42.61% 741.07 2,598 1,128 122 14 498 24 7 135 4,526 1,928 42.60% 219.13 2,281 900 79 6 546 19 4 130 3,965 1,684 42.47 %° 525.25 4,383 529 70 12 2,334 5 12 272 7,617 3,234 42.46 %° 992.24 1,965 291 27 11 1,006 29 2 83 3,414 1,449 42.44% 994.10 2,438 829 80 28 646 32 7 174 4,234 1,796 42.42% 758.05 2,336 1,347 45 28 198 19 7 59 4,039 1,703 42.16% 1101.11 3,058 957 157 29 914 20 4 126 5,265 2,207 41.92% 992.12 2,952 1,122 64 26 721 19 9 148 5,061 2,109 41.67% 992.25 1,973 240 27 4 1,005 14 5 107 3,375 1,402 41.54% 1102.23 3,200 1,087 138 28 797 23 5 175 5,453 2,253 41.32% 525.17 2,838 369 100 5 1,249 7 25 224 4,817 1,979 41.08% 29 0 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 626.10 885 141 38 5 245 1 9 171 1,495 610 40.80% 992.29 3,396 721 76 24 1,260 15 9 218 5,719 2,323 40.62% 525.24 4,232 723 177 7 1,550 8 10 312 7,019 2,787 39.71% 110.00 3,926 1,596 129 23 680 14 4 130 6,502 2,576 39.62% 1101.07 3,479 785 247 11 1,019 14 14 152 5,721 2,242 39.19% 626.28 2,056 166 75 7 951 3 10 106 3,374 1,318 39.06% 626.25 2,912 1,470 56 7 248 1 2 67 4,763 1,851 38.86% 762.05 3,487 1,526 100 23 350 41 9 153 5,689 2,202 38.71% 525.28 2,087 236 46 2 887 1 1 140 3,400 1,313 38.62% 525.19 2,585 403 73 7 869 10 8 235 4,190 1,605 38.31% 992.50 1,821 312 49 19 619 4 11 115 2,950 1,129 38.27% 11.01 2,654 1,349 64 16 119 1 4 89 4,296 1,642 38.22% 626.41 2,167 935 63 11 239 2 11 75 3,503 1,336 38.14% 1100.14 2,904 816 222 15 533 25 11 147 4,673 1,769 37.86% 15.03 3,169 1,552 51 6 209 11 4 86 5,088 1,919 37.72% 423.13 4,501 2,363 52 24 138 11 7 127 7,223 2,722 37.69% 219.18 3,128 1,127 57 8 591 4 2 92 5,009 1,881 37.55% 758.14 2,188 218 27 5 957 4 7 94 3,500 1,312 37.49 % 755.04 2,553 1,027 66 17 262 7 17 122 4,071 1,518 37.29% 112.00 2,504 1,084 40 21 247 4 12 79 3,991 1,487 37.26% 524.19 1,759 161 23 6 769 7 3 74 2,802 1,043 37.22% 1100.10 2,887 512 54 12 953 18 10 148 4,594 1,707 37.16% 754.05 1,691 748 55 11 117 6 4 54 2,686 995 37.04% 219.23 3,705 635 137 5 1,174 10 12 186 5,864 2,159 36.82% 423.10 5,497 2,758 40 59 127 14 11 174 8,680 3,183 36.67% 320.55 2,680 966 64 15 343 9 13 133 4,223 1,543 36.54% 525.14 3,358 373 60 8 1,229 9 7 246 5,290 1,932 36.52% 758.13 3,269 933 31 20 762 3 1 120 5,139 1,870 36.39% 219.22 2,916 538 75 14 872 5 11 150 4,581 1,665 36.35% 992.33 2,131 259 7 8 794 9 6 133 3,347 1,216 36.33% 524.17 1 3,6861 3831 501 51 1,4691 101 161 1491 5,7681 2,0821 36.10% �9� Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 423.07 4,821 1,564 101 25 766 8 16 209 7,510 2,689 35.81% 525.02 3,738 895 92 13 907 6 11 157 5,819 2,081 35.76% 992.34 1,962 269 21 11 657 2 8 104 3,034 1,072 35.33% 320.28 2,054 646 42 7 275 7 7 128 3,166 1,112 35.12% 219.21 2,942 411 70 5 952 8 13 119 4,520 1,578 34.91% 638.07 3,439 903 177 1 570 7 7 133 5,237 1,798 34.33% 1101.14 3,179 782 74 19 582 11 9 181 4,837 1,658 34.28% 638.03 3,057 1,288 29 24 124 15 7 106 4,650 1,593 34.26% 758.15 3,228 1,168 50 9 322 4 4 125 4,910 1,682 34.26% 218.20 2,772 490 60 13 775 3 12 84 4,209 1,437 34.14% 756.07 3,747 509 75 9 1,152 10 9 172 5,683 1,936 34.07% 524.10 3,365 1,018 73 16 460 13 7 146 5,098 1,733 33.99% 1101.08 1,828 509 70 7 286 5 1 60 2,766 938 33.91% 524.23 3,337 812 140 14 555 10 11 168 5,047 1,710 33.88% 639.07 3,352 571 96 2 779 26 13 229 5,068 1,716 33.86% 993.05 4,926 1,887 42 44 350 23 10 158 7,440 2,514 33.79% 762.01 3,608 1,124 96 13 424 26 12 145 5,448 1,840 33.77% 524.16 2,701 848 56 23 327 1 2 116 4,074 1,373 33.70% 15.07 2,846 752 86 16 431 4 23 132 4,290 1,444 33.66% 996.02 2,140 495 35 13 394 11 13 110 3,211 1,071 33.35% 218.28 3,136 365 98 13 929 1 6 157 4,705 1,569 33.35% 423.20 3,703 1,008 94 15 524 13 18 170 5,545 1,842 33.22% 218.12 4,353 1,121 150 18 669 10 25 159 6,505 2,152 33.08 % 524.24 3,234 780 125 6 476 13 11 180 4,825 1,591 32.97% 219.15 2,732 383 53 10 758 3 5 130 4,074 1,342 32.94% 994.13 5,091 1,046 68 41 1,091 22 9 215 7,583 2,492 32.86% 525.13 3,922 433 55 14 1,219 10 2 174 5,829 1,907 32.72% 626.36 2,489 563 112 16 394 6 15 103 3,698 1,209 32.69% 999.05 2,208 559 40 19 344 9 2 91 3,272 1,064 32.52% 1101.06 2,440 542 58 13 414 31 13 100 3,611 1,171 32.43% 524.27 1 3,4591 5451 741 131 7801 111 71 2151 5,1041 1,645 32.23% Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 320.51 3,112 910 123 20 282 9 15 120 4,591 1,479 32.22% 113.00 2,556 787 57 19 236 4 2 98 3,759 1,203 32.00% 423.30 4,347 1,174 121 8 490 2 5 241 6,388 2,041 31.95% 524.25 3,926 743 134 15 773 4 11 149 5,755 1,829 31.78% 762.06 3,039 1,111 33 18 175 4 9 59 4,448 1,409 31.68% 636.01 2,510 875 20 24 104 21 2 106 3,662 1,152 31.46 % 626.12 4,963 427 58 1 1,473 11 17 251 7,201 2,238 31.08% 15.05 4,440 1,034 78 20 694 14 3 149 6,432 1,992 30.97% 218.14 4,833 857 123 27 973 2 12 170 6,997 2,164 30.93% 15.06 2,987 589 38 12 551 14 3 125 4,319 1,332 30.84% 1100.11 1,905 234 31 12 476 12 2 76 2,748 843 30.68% 218.27 2,431 322 74 6 571 1 7 92 3,504 1,073 30.62% 755.06 2,254 513 61 11 338 4 8 58 3,247 993 30.58% 524.26 3,247 533 73 8 630 17 8 153 4,669 1,422 30.46% 996.05 2,590 396 30 3 582 8 1 113 3,723 1,133 30.43% 218.26 1,789 323 50 5 291 4 9 98 2,569 780 30.36% 421.08 4,133 1,450 45 37 93 14 11 151 5,934 1,801 30.35% 992.15 3,805 892 39 25 500 19 12 167 5,459 1,654 30.30% 999.06 3,338 524 41 26 640 12 9 198 4,788 1,450 30.28% 525.20 2,452 190 18 3 739 3 8 104 3,517 1,065 30.28% 996.03 4,362 744 55 28 895 15 7 147 6,253 1,891 30.24% 626.39 4,369 736 142 16 701 10 7 260 6,241 1,872 30.00 % 762.08 3,347 896 62 15 333 9 6 105 4,773 1,426 29.88 % 320.29 3,267 668 91 5 439 13 20 143 4,646 1,379 29.68% 423.34 3,687 723 56 13 547 2 17 191 5,236 1,549 29.58% 992.31 4,010 392 33 10 1,080 7 2 159 5,693 1,683 29.56% 626.21 3,481 689 90 8 495 13 17 147 4,940 1,459 29.53% 320.15 4,746 967 115 12 691 10 17 172 6,730 1,984 29.48% 992.46 2,676 253 28 11 689 10 5 111 3,783 1,107 29.26% 218.29 3,820 332 64 9 1,067 2 5 93 5,392 1,572 29.15% 219.05 1 3,6961 6971 971 141 5971 41 31 1081 5,2161 1,5201 29.14% Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 626.38 3,114 447 97 15 540 11 4 161 4,389 1,275 29.05% 117.07 3,119 551 66 14 492 7 16 114 4,379 1,260 28.77% 320.39 4,944 1,038 55 9 644 15 5 226 6,936 1,992 28.72% 114.01 1,519 387 37 12 117 6 5 45 2,128 609 28.62% 992.32 3,888 390 26 11 915 17 14 181 5,442 1,554 28.56% 320.33 2,522 461 66 5 308 19 6 142 3,529 1,007 28.53% 423.35 2,698 448 65 11 356 17 11 169 3,775 1,077 28.53% 1101.01 3,250 583 64 13 496 15 5 120 4,546 1,296 28.51% 320.54 3,313 746 113 22 272 10 6 146 4,628 1,315 28.41% 218.07 2,737 682 57 16 235 3 5 87 3,822 1,085 28.39% 994.05 3,173 606 37 13 432 10 18 138 4,427 1,254 28.33% 525.11 4,218 298 44 7 1,110 1 22 178 5,878 1,660 28.24% 524.21 3,853 327 57 4 968 3 11 139 5,362 1,509 28.14% 14.03 2,354 675 10 12 124 18 4 75 3,272 918 28.06% 626.35 2,976 461 57 14 465 7 16 135 4,131 1,155 27.96% 320.56 3,892 654 88 15 545 3 7 195 5,399 1,507 27.91% 626.29 1,949 82 4 6 574 0 2 78 2,695 746 27.68% 320.38 5,048 536 98 10 1,045 19 16 204 6,976 1,928 27.64% 626.37 2,029 310 67 2 216 9 9 151 2,793 764 27.35% 117.15 4,157 620 60 17 721 9 8 119 5,711 1,554 27.21% 756.05 4,323 480 28 15 965 7 5 100 5,923 1,600 27.01% 320.50 3,758 720 74 18 361 26 16 170 5,143 1,385 26.93% 994.06 3,248 517 53 6 500 9 9 93 4,435 1,187 26.76 %° 626.40 2,606 376 54 14 353 17 7 121 3,548 942 26.55% 15.01 4,224 786 51 16 545 22 3 100 5,747 1,523 26.50% 626.34 4,104 455 76 9 723 4 9 198 5,578 1,474 26.43% 423.31 4,016 795 52 8 397 10 8 172 5,458 1,442 26.42% 219.20 3,929 422 64 14 769 6 9 125 5,338 1,409 26.40% 219.19 2,037 306 27 6 289 3 11 88 2,767 730 26.38% 320.47 2,295 435 64 16 196 4 0 106 3,116 821 26.35% 992.30 3,246 355 34 27 569 16 18 139 4,404 1,158 26.29% 300 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 218.23 2,363 351 39 5 323 4 11 109 3,205 842 26.27% 16.01 5,037 850 70 17 698 9 13 130 6,824 1,787 26.19% 524.22 3,008 406 109 3 441 8 10 88 4,073 1,065 26.15% 992.38 3,032 243 23 17 603 13 5 167 4,103 1,071 26.10% 992.35 3,465 621 34 25 398 5 4 134 4,686 1,221 26.06% 996.04 2,762 351 28 31 432 7 1 123 3,735 973 26.05% 631.01 2,094 432 49 22 171 7 1 55 2,831 737 26.03% 995.08 3,450 847 26 20 168 16 14 120 4,661 1,211 25.98% 218.25 2,495 304 38 8 436 0 13 76 3,370 875 25.96% 115.03 1,317 236 17 4 156 5 2 40 1,777 460 25.89% 1100.03 2,361 353 19 11 324 7 2 98 3,175 814 25.64% 626.33 2,715 309 63 4 420 8 12 117 3,648 933 25.58% 16.02 3,200 356 40 3 581 1 13 98 4,292 1,092 25.44% 218.02 4,878 1,119 52 19 301 5 30 134 6,538 1,660 25.39% 117.18 2,516 397 48 18 277 9 1 95 3,361 845 25.14% 525.06 1,901 136 26 4 383 7 8 73 2,538 637 25.10% 423.39 2,612 643 38 11 100 12 4 57 3,477 865 24.88% 117.10 2,654 401 43 3 358 3 4 60 3,526 872 24.73% 639.05 3,200 544 56 22 290 8 4 118 4,242 1,042 24.56% 992.16 3,076 460 28 21 360 8 2 121 4,076 1,000 24.53% 320.31 2,852 478 31 12 283 0 6 107 3,769 917 24.33% 218.24 2,199 259 14 5 385 7 11 25 2,905 706 24.30% 17.06 2,814 211 33 3 586 4 1 64 3,716 902 24.27% 756.06 4,734 404 45 16 906 4 9 125 6,243 1,509 24.17% 219.16 2,878 186 51 4 555 2 7 101 3,784 906 23.94% 423.33 3,398 240 33 9 606 4 25 151 4,466 1,068 23.91% 320.48 4,489 641 94 7 499 3 8 146 5,887 1,398 23.75% 994.16 3,502 580 44 19 296 7 2 142 4,592 1,090 23.74% 1100.12 3,726 316 65 5 648 11 9 96 4,876 1,150 23.58% 992.45 2,345 290 29 11 291 7 11 83 3,067 722 23.54% 320.49 6,175 733 167 16 737 16 21 211 8,076 1,901 23.54% 301 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 626.31 2,712 85 8 0 613 2 4 117 3,541 829 23.41% 320.53 6,004 900 135 29 518 12 6 235 7,839 1,835 23.41% 320.34 4,919 473 86 14 696 1 8 224 6,421 1,502 23.39% 423.29 3,492 602 38 17 287 6 8 108 4,558 1,066 23.39% 218.10 2,822 493 40 17 228 5 6 70 3,681 859 2134% 423.27 3,912 387 67 18 528 8 12 158 5,090 1,178 23.14% 423.36 3,507 366 33 7 476 6 22 144 4,561 1,054 23.11% 422.05 5,104 1,153 31 13 200 1 5 130 6,637 1,533 23.10% 626.30 1,272 58 8 1 278 1 5 30 1,653 381 23.05% 994.12 3,596 503 53 10 362 16 1$ 112 4,670 1,074 23.00% 320.20 4,631 745 52 11 374 8 21 167 6,009 1,378 22.93% 423.26 3,232 465 113 7 228 4 5 138 4,192 960 22.90% 992.39 3,099 243 20 16 517 11 8 99 4,013 914 22.78% 320.30 2,957 456 26 9 260 5 4 110 3,827 870 22.73% 758.10 2,379 197 26 9 419 1 8 39 3,078 699 22.71% 1100.05 2,443 313 26 10 257 5 5 100 3,159 716 22.67% 992.37 2,727 316 15 10 358 4 5 89 3,524 797 22.62% 218.17 2,845 428 53 2 235 10 13 87 3,673 828 22.54% 992.14 2,654 359 29 11 277 6 8 82 3,426 772 22.53% 1100.04 3,611 450 30 23 424 7 21 95 4,661 1,050 22.53% 632.02 2,722 595 11 16 72 7 10 77 3,510 788 22.45% 218.30 4,563 460 36 13 676 0 14 114 5,876 1,313 22.35% 626.43 2,622 134 6 4 508 0 2 93 3,369 747 22.17% 756.04 5,902 501 38 9 937 7 24 163 7,581 1,679 22.15% 626.47 3,281 510 39 7 297 1 0 71 4,206 925 21.99% 320.02 4,806 717 62 23 370 9 7 163 6,157 1,351 21.94% 423.15 4,635 657 87 18 358 7 18 153 5,933 1,298 21.88% 993.08 3,764 254 27 10 697 0 7 59 4,818 1,054 21.88% 638.02 2,261 354 16 11 147 11 10 84 2,894 633 21.87% 320.45 2,278 333 21 5 169 4 9 96 2,915 637 21.85% 524.28 4,998 641 101 14 425 8 13 191 6,391 1,393 21.80% 302 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 1100.15 2,766 409 45 9 191 5 4 107 3,536 770 21.78% 756.03 3,011 429 43 7 194 7 20 137 3,848 837 21.75% 994.08 2,494 350 18 15 211 8 5 83 3,184 690 21.67% 117.09 3,450 451 34 14 357 5 4 84 4,399 949 21.57% 524.08 5,003 537 62 10 568 5 9 180 6,374 1,371 21.51% 758.09 2,468 194 8 12 376 1 4 67 3,130 662 21.15% 638.06 2,889 411 26 17 185 18 12 98 3,656 767 20.98% 117.17 2,129 304 48 5 146 0 0 61 2,693 564 20.94% 421.14 2,953 558 31 14 121 6 1 50 3,734 781 20.92% 218.22 2,958 343 45 14 250 6 9 110 3,735 777 20.80% 320.41 855 152 11 7 34 1 3 16 1,079 224 20.76% 423.11 4,559 837 29 23 174 3 11 117 5,753 1,194 20.75% 757.02 2,576 391 15 4 191 7 2 61 3,247 671 20.67% 758.08 2,564 455 19 4 115 3 3 63 3,226 662 20.52% 423.19 2,769 190 20 6 424 0 2 71 3,482 713 20.48% 320.36 2,897 424 22 9 206 1 3 80 3,642 745 20.46% 994.17 3,155 316 34 9 338 5 3 99 3,959 804 20.31% 422.01 4,664 908 29 27 115 2 12 95 5,852 1,188 20.30% 994.15 4,380 300 9 10 619 4 2 170 5,494 1,114 20.28% 218.15 2,478 328 24 7 208 2 4 55 3,106 628 20.22% 992.40 4,127 415 26 18 395 19 12 150 5,162 1,035 20.05% 994.04 3,777 432 28 19 322 6 12 127 4,723 946 20.03 % 993.10 3,603 420 20 36 228 11 4 170 4,492 889 19.79 % 994.07 1,999 197 17 18 174 5 1 80 2,491 492 19.75% 423.25 2,901 263 31 1 320 3 6 90 3,615 714 19.75% 992.20 4,354 559 31 19 232 14 9 203 5,421 1,067 19.68% 993.06 4,767 641 24 37 255 12 24 171 5,931 1,164 19.63% 320.32 2,653 342 11 12 204 9 4 65 3,300 647 19.61% 219.12 2,706 176 15 4 379 2 0 78 3,360 654 19.46% 636.02 2,910 401 32 16 148 10 12 82 3,611 701 19.410% 524.15 1 3,3151 3241 651 71 2961 71 71 881 4,1091 7941 19.32% 303 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 114.02 1,839 239 15 2 121 2 11 48 2,277 438 19.24% 992.43 3,319 359 19 14 296 2 2 95 4,106 787 19.17% 320.42 4,961 582 57 16 327 16 9 167 6,135 1,174 19.14% 631.02 5,087 752 51 27 215 18 8 131 6,289 1,202 19.11% 423.37 3,121 241 39 4 331 4 7 88 3,835 714 18.62% 638.05 1,896 212 27 8 121 9 4 52 2,329 433 18.59% 993.07 1,940 221 27 15 116 10 3 45 2,377 437 18.38% 993.11 3,127 376 12 18 144 15 8 118 3,818 691 18,10% 995.12 2,266 260 25 6 128 7 7 67 2,766 500 18.08% 218.09 2,144 257 15 10 139 0 4 47 2,616 472 18.04% 320.12 3,032 350 43 9 184 3 11 63 3,695 663 17.94% 757.03 3,271 285 16 8 327 1 0 78 3,986 715 17.94% 421.09 4,128 462 55 17 232 12 2 118 5,026 898 17.87% 633.01 2,506 316 33 11 88 11 19 65 3,049 543 17.81% 219.17 2,770 261 18 8 252 0 5 52 3,366 596 17.71% 320.03 4,103 531 22 2 209 13 2 97 4,979 876 17.59% 1100.06 2,389 197 27 10 196 2 10 67 2,898 509 17.56% 626.45 3,987 166 19 11 546 4 8 83 4,824 837 17.35% 218.16 4,090 488 34 11 228 4 8 80 4,943 853 17.26% 1100.08 3,564 310 57 8 237 6 11 111 4,304 740 17.19% 995.14 4,826 290 23 5 538 5 22 112 5,821 995 17.09% 992.17 2,034 172 14 8 161 1 1 50 2,441 407 16.67% 320.40 2,409 205 9 5 213 1 1 47 2,890 481 16.64% 421.12 3,139 343 26 8 152 9 10 75 3,762 623 16.56% 320.23 2,285 318 7 15 58 2 7 43 2,735 450 16.45% 626.05 2,842 356 23 17 64 3 6 85 3,396 554 16.31% 320.13 2,959 293 39 9 137 14 4 73 3,528 569 16.13% 421.03 6,345 878 32 16 91 3 13 152 7,530 1,185 15.74% 320.35 2,057 138 28 10 116 3 7 68 2,427 370 15.25% 423.28 2,036 88 19 5 207 3 0 42 2,400 364 15.17% 1100.07 4,031 314 18 11 256 3 3 91 4,727 696 14.72% U001 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 320.43 3,659 174 28 2 274 0 7 143 4,287 628 14.65% 993.09 3,043 259 14 12 156 6 3 72 3,565 522 14.64% 636.03 5,362 511 69 20 191 12 5 93 6,263 901 14.39% 995.13 2,005 148 7 10 124 3 5 39 2,341 336 14.35% 423.32 4,784 302 43 5 333 5 8 102 5,582 798 14.30% 995.11 2,929 259 12 18 126 3 1 68 3,416 487 14.26% 422.03 6,374 633 45 14 207 10 4 126 7,413 1,039 14.02% 423.38 4,147 365 26 10 158 1 6 101 4,814 667 13.86% 423.17 3,125 204 23 6 191 1 16 57 3,623 498 13.75% 320.46 3,527 228 34 2 215 12 0 68 4,086 559 13.68% 421.13 3,875 340 6 20 146 7 7 82 4,483 608 13.56% 633.02 3,452 341 13 10 77 9 9 75 3,986 534 13.40% 630.10 5,632 391 32 15 309 2 24 90 6,495 863 13.29% 995.06 1,106 82 1 3 25 0 16 34 1,267 161 12.71% 320.52 2,908 231 11 6 120 5 3 46 3,330 422 12.67% 320.44 5,293 307 37 10 279 2 16 112 6,056 763 12.60% 626.44 5,737 278 39 11 398 6 6 83 6,558 821 12.52% 995.04 2,198 144 5 5 88 4 0 67 2,511 313 12.47% 626.32 3,555 262 31 10 104 3 9 84 4,058 503 12.40% 630.09 1,466 62 6 1 96 2 1 37 1,671 205 12.27% 992.44 3,377 187 12 19 178 2 3 68 3,846 469 12.19% 421.11 5,190 412 39 12 151 4 0 96 5,904 714 12.09% 630.07 5,214 234 31 4 352 4 2 87 5,928 714 12.04% 631.03 2,262 166 17 8 48 7 7 45 2,560 298 11.64% 423.23 4,168 305 40 20 74 2 25 83 4,717 549 11.64% 423.24 3,767 182 34 3 176 0 8 87 4,257 490 11.51% 635.00 5,480 373 35 10 169 11 8 105 6,191 711 11.48% 626.42 2,876 106 5 2 205 5 10 34 3,243 367 11.32% 630.08 770 25 7 1 45 1 1 18 868 98 11.29% 626.20 4,506 325 30 14 98 3 5 97 5,078 572 11.26% 626.22 3,776 249 28 7 128 1 4 38 4,231 455 10.75% 305 Census Tract White alone Hispanic or Latino Black or African American alone American Indian and Alaska Native alone Asian alone Native Hawaiian and Other Pacific Islander alone Some other race alone Population of two or more races Total Population Total Minority Population Percent Minority 422.06 2,702 189 24 8 55 1 5 40 3,024 322 10.65% 626.04 3,714 254 17 15 73 1 3 74 4,151 437 10.53% 320.11 1,580 92 9 12 16 4 6 43 1,762 182 10.33% 630.04 5,029 211 20 6 231 9 11 85 5,602 573 10.23% 628.00 4,269 266 28 13 66 12 10 68 4,732 463 9.78% 320.37 3,987 149 22 8 189 0 3 38 4,396 409 9.30% 423.05 3,457 170 23 5 60 2 4 61 3,782 325 8.59% 626.19 3,664 193 19 5 50 7 9 60 4,007 343 8.56% 627.02 4,293 203 18 8 92 3 8 59 4,684 391 8.35% 995.10 3,874 160 16 9 111 0 0 47 4,217 343 8.13% 630.05 1,356 24 15 0 63 0 0 18 1,476 120 8.13% 626.23 5,916 247 53 8 161 1 2 47 6,435 519 8.07% 627.10 2,684 104 7 7 70 7 3 31 2,913 229 7.86% 421.06 1,395 68 5 2 20 1 3 14 1,508 113 7.49% 634.00 4,627 202 13 17 77 3 1 55 4,995 368 7.37% 626.46 3,394 98 8 2 110 2 2 27 3,643 249 6.84% 630.06 2,907 99 13 6 66 2 0 27 3,120 213 6.83% 995.09 3,450 112 17 5 86 2 0 17 3,689 239 6.48% 629.00 1 1,7041 581 21 51 131 11 31 141 1,8001 96 5.33% 30% Technical Appendix C Low Income Population by Census Tract and Block Group Sol Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Brea city 021815 1 7 7 100.0 Fullerton city 011708 3 17 17 100.0 Fullerton city 086701 3 125 125 100.0 Garden Grove city 089001 1 21 21 100.0 Los Alamitos city 110113 1 141 141 100.0 Newport Beach city 063101 1 8 8 100.0 Placentia city 021813 9 20 20 100.0 Westminster city 088901 1 15 15 100.0 Westminster city 099701 3 25 25 100.0 001903 2 61 61 100.0 021924 1 33 33 100.0 Buena Park city 001801 1 295 296 99.7 Santa Ana city 074601 2 1668 1708 97.7 Santa Ana city 074501 3 996 1022 97.5 Anaheim city 088402 1 768 790 97.2 001201 3 257 269 95.5 Garden Grove city 087806 2 96 101 95.0 Anaheim city 087501 3 1294 1363 94.9 Garden Grove city 089104 2 3469 3656 94.9 Anaheim city 011720 1 1463 1556 94.0 Santa Ana city 074405 1 1517 1614 94.0 Santa Ana city 074901 1 2075 2225 93.3 Santa Ana city 074901 3 1960 2107 93.0 Santa Ana city 074902 3 2765 2983 92.7 Garden Grove city 089106 2 1435 1549 92.6 Santa Ana city 074406 3 1540 1669 92.3 Santa Ana city 075003 2 3282 3569 92.0 Irvine city 062626 2 1191 1306 91.2 Stanton city 087803 3 3319 3638 91.2 Orange city 075811 2 1354 1490 90.9 Santa Ana city 074501 2 2435 2679 90.9 Santa Ana city 075100 4 1896 2086 90.9 Irvine city 062627 2 687 758 90.6 Santa Ana city 074601 3 1347 1492 90.3 Santa Ana city 074407 1 3442 3822 90.1 Santa Ana city 074403 2 2699 3002 89.9 Fullerton city 011504 2 447 498 89.8 Santa Ana city 074805 1 4183 4670 89.6 Stanton city 087806 1 1653 1846 89.5 Santa Ana city 074405 2 1761 1973 89.3 Anaheim city 086405 2 1706 1923 88.7 Fullerton city 011601 5 814 919 88.6 Stanton city 087902 2 1126 1271 88.6 Anaheim city 087501 2 1868 2116 88.3 Westminster city 099601 3 1668 1889 88.3 Westminster city 099803 1 1743 1977 88.2 Buena Park city 001801 4 119 135 88.1 Santa Ana city 075004 2 2292 2603 88.1 Anaheim city 086601 1 2126 2424 87.7 Garden Grove city 088701 1 1201 1369 87.7 Santa Ana city 075003 3 2116 2412 87.7 308 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Santa Ana city 075002 3 4171 4777 87.3 Anaheim city 086502 4 1881 2158 87.2 Santa Ana city 074405 3 1636 1884 86.8 Garden Grove city 088501 2 1917 2213 86.6 Santa Ana city 074806 1 2843 3288 86.5 Anaheim city 087102 3 1240 1440 86.1 Fullerton city 001802 5 1159 1346 86.1 Anaheim city 087403 2 1176 1367 86.0 Anaheim city 087404 1 2349 2739 85.8 Laguna Woods city 062641 2 204 238 85.7 Santa Ana city 074405 4 1110 1295 85.7 Huntington Beach city 099402 4 2047 2395 85.5 Buena Park city 110402 3 1573 1841 85.4 Santa Ana city 089105 2 2122 2488 85.3 Huntington Beach city 099402 3 3038 3571 85.1 Anaheim city 087405 3 2895 3407 85.0 Santa Ana city 074901 4 1430 1682 85.0 Santa Ana city 089105 3 2499 2948 84.8 Santa Ana city 074403 1 2857 3372 84.7 Santa Ana city 074602 3 1948 2302 84.6 Anaheim city 087405 1 1496 1770 84.5 Fullerton city 011711 5 1934 2290 84.5 Santa Ana city 089105 1 1314 1555 84.5 Santa Ana city 099249 1 2143 2539 84.4 Anaheim city 087200 3 1117 1327 84.2 Placentia city 011720 1 1836 2184 84.1 Santa Ana city 074501 1 2257 2685 84.1 Santa Ana city 074602 1 1055 1255 84.1 Santa Ana city 076000 2 121 144 84.0 Anaheim city 087504 3 1743 2081 83.8 Orange city 075812 1 2640 3157 83.6 Santa Ana city 074802 3 2259 2703 83.6 Fullerton city 011101 3 567 682 83.1 Anaheim city 011720 3 492 593 83.0 Anaheim city 110402 2 581 700 83.0 Laguna Woods city 062622 5 44 53 83.0 Anaheim city 087503 5 1984 2397 82.8 Santa Ana city 074801 2 1625 1962 82.8 Anaheim city 086502 3 1116 1349 82.7 Anaheim city 087601 1 1604 1939 82.7 Santa Ana city 075004 1 2573 3110 82.7 Santa Ana city 074801 1 1413 1711 82.6 Westminster city 099903 2 2173 2634 82.5 Anaheim city 087102 4 488 592 82.4 Fullerton city 011601 6 1579 1916 82.4 Garden Grove city 088502 3 1480 1797 82.4 Santa Ana city 075002 2 1749 2122 82.4 Santa Ana city 074602 2 1906 2320 82.2 Santa Ana city 075100 1 2313 2825 81.9 Anaheim city 086502 1 1082 1325 81.7 Anaheim city 087300 3 926 1133 81.7 309 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 087504 2 2398 2941 81.5 Orange city 075807 3 1069 1313 81.4 Anaheim city 011602 2 385 474 81.2 Anaheim city 086601 5 1262 1556 81.1 Santa Ana city 075003 1 1800 2219 81.1 Santa Ana city 075002 1 2080 2567 81.0 Santa Ana city 099248 1 2067 2557 80.8 Garden Grove city 088203 2 1320 1643 80.3 Anaheim city 086602 2 1685 2100 80.2 Fullerton city 011200 2 631 787 80.2 Fullerton city 011403 4 687 860 79.9 Santa Ana city 074601 1 1390 1740 79.9 Santa Ana city 074902 2 1695 2122 79.9 Anaheim city 087300 1 1591 1993 79.8 Westminster city 099904 4 995 1252 79.5 Anaheim city 087504 1 1245 1568 79.4 Fullerton city 011504 5 1116 1405 79.4 Laguna Woods city 062646 2 532 670 79.4 Santa Ana city 074701 1 1989 2504 79.4 Anaheim city 087300 5 1060 1337 79.3 Santa Ana city 074406 2 879 1108 79.3 Irvine city 062614 2 2342 2966 79.0 La Habra city 001202 3 795 1008 78.9 Santa Ana city 074502 2 2546 3225 78.9 Anaheim city 086901 3 3110 3945 78.8 Buena Park city 110500 1 2120 2692 78.8 Seal Beach city 099509 1 375 476 78.8 Buena Park city 110603 3 1742 2218 78.5 Santa Ana city 074806 2 2237 2848 78.5 Buena Park city 110606 1 2289 2918 78.4 Anaheim city 087405 2 1098 1403 78.3 Fullerton city 011101 1 372 475 78.3 Santa Ana city 074003 1 1758 2253 78.0 Fullerton city 011601 1 921 1183 77.9 Santa Ana city 074901 5 1763 2265 77.8 Santa Ana city 074802 2 987 1270 77.7 Santa Ana city 074902 1 1662 2138 77.7 Anaheim city 087701 2 430 554 77.6 Anaheim city 011602 1 1454 1879 77.4 Placentia city 011720 2 1958 2531 77.4 Anaheim city 087503 1 741 959 77.3 La Habra city 001201 2 1403 1814 77.3 Placentia city 011721 4 1669 2158 77.3 Cypress city 110104 3 799 1035 77.2 Westminster city 099904 5 1357 1758 77.2 Santa Ana city 074108 1 1462 1896 77.1 Orange city 075813 2 892 1161 76.8 Stanton city 088105 1 43 56 76.8 Anaheim city 086502 2 1409 1837 76.7 Santa Ana city 074406 1 713 929 76.7 Anaheim city 086903 1 1700 2220 76.6 310 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% La Habra city 001201 3 1310 1712 76.5 Santa Ana city 074602 4 1749 2287 76.5 Laguna Woods city 062646 1 427 559 76.4 Orange city 075806 4 1799 2359 76.3 Santa Ana city 089004 2 2767 3633 76.2 Anaheim city 087403 1 524 689 76.1 Fullerton city 011601 2 890 1170 76.1 Anaheim city 087001 1 2204 2900 76.0 Laguna Woods city 062622 3 662 872 75.9 Fullerton city 001802 4 929 1226 75.8 Santa Ana city 074803 1 3064 4041 75.8 Santa Ana city 074004 2 529 700 75.6 Anaheim city 086901 4 986 1308 75.4 La Habra city 001304 3 402 533 75.4 La Habra city 001404 2 783 1039 75.4 Santa Ana city 074801 3 1865 2474 75.4 Fullerton city 011401 1 477 634 75.2 021913 4 2144 2850 75.2 Santa Ana city 074103 3 1582 2107 75.1 La Habra city 001401 4 1196 1595 75.0 Santa Ana city 074005 3 1075 1433 75.0 La Habra city 001304 2 1510 2015 74.9 Santa Ana city 089104 1 739 987 74.9 Anaheim city 086501 1 1705 2280 74.8 Garden Grove city 088601 4 846 1131 74.8 Santa Ana city 074300 1 1696 2266 74.8 Anaheim city 087401 1 339 454 74.7 Huntington Beach city 099214 4 566 758 74.7 Orange city 076204 2 1678 2253 74.5 Placentia city 011721 1 830 1116 74.4 Westminster city 099802 2 2104 2829 74.4 Anaheim city 087806 1 1050 1413 74.3 Anaheim city 110202 3 1488 2006 74.2 Lake Forest city 032014 1 1462 1970 74.2 Seal Beach city 099509 4 703 950 74.0 Anaheim city 087803 1 1094 1481 73.9 Santa Ana city 089004 3 1433 1938 73.9 Stanton city 087806 2 181 245 73.9 Anaheim city 087106 3 1174 1591 73.8 Santa Ana city 074702 1 2655 3600 73.8 Anaheim city 087601 3 989 1343 73.6 Dana Point city 042201 1 572 777 73.6 Anaheim city 011722 1 706 961 73.5 Rancho Santa Margarita city 032055 2 863 1174 73.5 Santa Ana city 075100 2 1107 1507 73.5 Fullerton city 110605 2 798 1089 73.3 Westminster city 099904 2 1435 1959 73.3 La Habra city 001404 3 854 1166 73.2 Tustin Foothills CDP 075701 4 115 157 73.2 Santa Ana city 074802 1 1396 1910 73.1 Anaheim city 086903 2 10151 1390 73.0 311 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 087200 2 1621 2225 72.9 Fullerton city 011712 2 363 498 72.9 Anaheim city 087504 4 1202 1652 72.8 Santa Ana city 075201 2 1719 2364 72.7 Anaheim city 086702 2 595 819 72.6 Irvine city 062611 1 530 730 72.6 099227 2 283 390 72.6 Garden Grove city 088601 2 1000 1382 72.4 Garden Grove city 088702 1 1023 1413 72.4 Seal Beach city 099510 3 594 821 72.4 Santa Ana city 074109 2 1445 1998 72.3 Stanton city 087803 2 793 1097 72.3 Fullerton city 011502 1 635 879 72.2 Westminster city 099203 1 281 390 72.1 Anaheim city 086601 4 1214 1687 72.0 Westminster city 099802 1 836 1161 72.0 Seal Beach city 099510 5 501 697 71.9 Orange city 075902 3 1363 1898 71.8 Seal Beach city 099502 1 483 673 71.8 Seal Beach city 099510 2 1168 1627 71.8 Cypress city 110110 1 602 840 71.7 Orange city 076102 3 1556 2171 71.7 Santa Ana city 075202 2 2359 3291 71.7 Laguna Hills city 062623 2 141 197 71.6 La Habra city 001201 1 1123 1573 71.4 Santa Ana city 074701 2 2115 2966 71.3 Anaheim city 086601 3 1576 2214 71.2 Buena Park city 110603 5 1358 1907 71.2 Santa Ana city 074200 1 849 1192 71.2 Santa Ana city 075701 2 1246 1749 71.2 032056 4 47 66 71.2 Garden Grove city 088801 2 624 878 71.1 Westminster city 088901 4 248 349 71.1 Anaheim city 087503 4 373 525 71.0 Garden Grove city 088701 2 1400 1972 71.0 Santa Ana city 089004 1 1313 1852 70.9 Fullerton city 011300 1 776 1096 70.8 Anaheim city 086405 3 1343 1899 70.7 Santa Ana city 074701 3 2539 3596 70.6 Anaheim city 086802 2 1355 1924 70.4 Santa Ana city 074901 2 1284 1823 70.4 021918 3 528 750 70.4 Buena Park city 110603 4 717 1020 70.3 Anaheim city 086702 4 302 430 70.2 Anaheim city 087103 3 970 1383 70.1 Garden Grove city 088702 2 614 876 70.1 Laguna Woods city 062646 4 568 810 70.1 Laguna Hills city 062625 4 1224 1750 69.9 Garden Grove city 089102 1 1826 2617 69.8 Stanton city 087805 3 1837 2637 69.7 0997021 21 9011 12931 69.7 312 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Fullerton city 001801 2 1052 1512 69.6 Westminster city 099601 1 1381 1985 69.6 Fullerton city 011000 4 984 1416 69.5 Santa Ana city 074006 1 867 1248 69.5 Anaheim city 086702 5 2027 2921 69.4 La Habra city 001501 1 177 255 69.4 Garden Grove city 088902 1 1105 1594 69.3 Santa Ana city 075202 1 1893 2734 69.2 Santa Ana city 075302 1 1392 2013 69.2 Stanton city 088106 3 2098 3033 69.2 La Habra city 001303 2 687 994 69.1 Laguna Woods city 062647 2 405 586 69.1 Santa Ana city 099248 2 2091 3025 69.1 086701 3 288 417 69.1 Anaheim city 086902 1 871 1262 69.0 Garden Grove city 076103 2 2598 3771 68.9 Santa Ana city 074803 2 2070 3003 68.9 Santa Ana city 075403 2 855 1241 68.9 Santa Ana city 074005 2 1679 2442 68.8 Westminster city 088904 2 953 1388 68.7 Fullerton city 001802 1 1088 1586 68.6 Anaheim city 086407 3 1417 2068 68.5 La Habra city 001202 1 912 1331 68.5 Laguna Woods city 062646 3 554 809 68.5 Laguna Woods city 062647 3 214 313 68.4 Santa Ana city 074102 1 1317 1926 68.4 Santa Ana city 074805 2 1394 2040 68.3 Santa Ana city 074102 3 649 951 68.2 Santa Ana city 088903 3 1156 1695 68.2 087701 3 135 198 68.2 Garden Grove city 088201 1 898 1318 68.1 La Habra city 001202 2 623 915 68.1 Anaheim city 087805 1 1086 1598 68.0 Orange city 076101 3 1217 1793 67.9 Placentia city 011722 2 359 529 67.9 Anaheim city 086901 1 1136 1676 67.8 Santa Ana city 099249 2 1289 1904 67.7 Santa Ana city 075302 3 635 942 67.4 Santa Ana city 089001 2 953 1413 67.4 Stanton city 087803 1 152 226 67.3 Santa Ana city 099247 2 1442 2147 67.2 Huntington Beach city 099413 4 982 1464 67.1 Santa Ana city 099202 2 2540 3783 67.1 Santa Ana city 074803 3 1341 2002 67.0 Garden Grove city 089003 1 1202 1796 66.9 Stanton city 087902 3 1583 2366 66.9 Orange city 076000 5 937 1402 66.8 Orange city 076103 1 813 1217 66.8 Los Alamitos city 110117 4 46 69 66.7 001501 3 16 24 66.7 Anaheim city 086404 2 10171 1527 66.6 313 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 087103 4 1113 1672 66.6 Buena Park city 110607 2 711 1067 66.6 Garden Grove city 088301 1 1530 2299 66.6 Santa Ana city 074005 1 1247 1872 66.6 Santa Ana city 074601 4 1281 1924 66.6 Garden Grove city 088107 2 2400 3608 66.5 Seal Beach city 099509 5 461 693 66.5 Westminster city 099223 2 902 1357 66.5 Fullerton city 011602 2 675 1016 66.4 Buena Park city 110500 2 2105 3173 66.3 Anaheim city 086803 1 1209 1827 66.2 Anaheim city 110202 2 730 1103 66.2 Fullerton city 001801 1 1090 1647 66.2 Garden Grove city 088901 3 1516 2293 66.1 Garden Grove city 089106 1 1359 2056 66.1 Laguna Woods city 062622 2 479 725 66.1 Villa Park city 075812 2 39 59 66.1 Garden Grove city 088402 2 1441 2182 66.0 La Habra city 001304 1 922 1397 66.0 Santa Ana city 089001 3 1524 2309 66.0 Irvine city 062626 1 960 1456 65.9 Laguna Woods city 062625 1 496 754 65.8 Garden Grove city 088702 3 2068 3148 65.7 Santa Ana city 074300 2 1408 2143 65.7 Anaheim city 086501 2 999 1522 65.6 Garden Grove city 088801 5 1053 1605 65.6 La Habra city 001303 1 1179 1798 65.6 Westminster city 099222 1 512 782 65.5 Fullerton city 011502 4 697 1067 65.3 Anaheim city 087300 2 2546 3908 65.1 Laguna Beach city 062605 2 385 591 65.1 Santa Ana city 075201 1 2328 3584 65.0 Orange city 021913 4 731 1126 64.9 Westminster city 099905 1 1293 1996 64.8 Anaheim city 087101 1 1356 2096 64.7 Fullerton city 011708 1 1438 2224 64.7 Garden Grove city 088801 4 1415 2190 64.6 Fullerton city 011504 3 424 658 64.4 Anaheim city 087102 1 978 1520 64.3 Garden Grove city 088801 3 1201 1869 64.3 Laguna Woods city 062647 4 615 956 64.3 Dana Point city 042313 5 1210 1886 64.2 Anaheim city 087105 1 1100 1715 64.1 Orange city 076204 1 1882 2934 64.1 Santa Ana city 074200 4 1859 2898 64.1 Anaheim city 086405 1 790 1234 64.0 Anaheim city 087002 2 1054 1646 64.0 Buena Park city 110603 2 992 1549 64.0 Rancho Santa Margarita city 032051 4 579 905 64.0 Santa Ana city 074006 3 1774 2773 64.0 Westminster city 099601 2 1622 2533 64.0 mail Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Fullerton city 011602 3 1528 2393 63.9 Anaheim city 076202 4 1072 1680 63.8 Brea city 001504 1 750 1175 63.8 Fullerton city 011504 4 572 896 63.8 Irvine city 062612 3 461 723 63.8 La Palma city 110116 3 918 1442 63.7 Los Alamitos city 110106 2 35 55 63.6 Santa Ana city 075404 3 1532 2409 63.6 Stanton city 087802 4 954 1499 63.6 075701 3 279 439 63.6 Anaheim city 087704 1 658 1036 63.5 Lake Forest city 052410 5 498 784 63.5 Santa Ana city 074103 2 934 1471 63.5 099702 3 1342 2112 63.5 Santa Ana city 074004 1 1550 2444 63.4 Anaheim city 087101 2 809 1278 63.3 Buena Park city 110500 3 1053 1664 63.3 Fullerton city 011403 2 1092 1725 63.3 Garden Grove city 088601 3 1361 2151 63.3 Garden Grove city 088104 1 84 133 63.2 Irvine city 052505 4 321 508 63.2 Anaheim city 086301 1 1635 2593 63.1 Anaheim city 086306 1 937 1486 63.1 Fullerton city 011711 2 952 1508 63.1 Anaheim city 086303 4 1228 1953 62.9 Huntington Beach city 099410 3 1466 2329 62.9 Huntington Beach city 099411 4 930 1479 62.9 Orange city 076102 1 127 202 62.9 Anaheim city 086405 4 993 1582 62.8 Anaheim city 086404 1 1873 2987 62.7 Anaheim city 086803 3 1719 2742 62.7 Orange city 076201 2 723 1155 62.6 Huntington Beach city 099402 2 1362 2180 62.5 Seal Beach city 099509 3 412 659 62.5 Santa Ana city 074109 1 1262 2022 62.4 087703 1 1190 1908 62.4 Huntington Beach city 099305 4 1418 2276 62.3 Lake Forest city 032027 1 316 507 62.3 Anaheim city 087403 3 1000 1607 62.2 Anaheim city 110202 1 804 1293 62.2 Stanton city 087805 1 834 1342 62.1 Santa Ana city 075301 1 927 1496 62.0 Stanton city 087901 1 2024 3266 62.0 Orange city 076208 4 589 952 61.9 Anaheim city 086602 3 1526 2470 61.8 Orange city 075901 3 1723 2790 61.8 Fullerton city 011711 4 836 1354 61.7 Anaheim city 086802 1 1403 2283 61.5 Garden Grove city 088602 1 1367 2230 61.3 Garden Grove city 088001 3 931 1522 61.2 Irvine city 052514 1 729 1192 61.2 SZJ5 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Seal Beach city 099510 1 312 511 61.1 Orange city 075816 1 1335 2187 61.0 Anaheim city 086402 1 1738 2856 60.9 Orange city 076101 1 1179 1938 60.8 Anaheim city 021812 4 1044 1722 60.6 Anaheim city 087002 3 1715 2831 60.6 Garden Grove city 088104 2 361 596 60.6 Santa Ana city 074200 2 1227 2026 60.6 Santa Ana city 074702 2 1865 3077 60.6 Laguna Woods city 062623 1 403 666 60.5 Seal Beach city 099509 2 437 722 60.5 Cypress city 110111 3 1079 1786 60.4 Anaheim city 110201 1 359 595 60.3 Anaheim city 086406 1 562 934 60.2 Laguna Hills city 042307 4 701 1165 60.2 087902 1 950 1582 60.1 Anaheim city 086406 2 767 1279 60.0 Garden Grove city 089003 2 1208 2012 60.0 076204 1 42 70 60.0 Anaheim city 087602 3 2067 3456 59.8 Anaheim city 087701 3 921 1540 59.8 Fullerton city 011708 2 781 1306 59.8 La Habra city 001301 5 1060 1774 59.8 Westminster city 099204 1 834 1394 59.8 Orange city 075902 2 1261 2112 59.7 099701 3 818 1370 59.7 Santa Ana city 074106 1 1310 2197 59.6 Buena Park city 110201 3 1567 2637 59.4 Garden Grove city 088903 3 885 1490 59.4 Garden Grove city 088802 1 1005 1696 59.3 Westminster city 099902 3 1129 1907 59.2 Stanton city 087802 1 251 425 59.1 Irvine city 052418 2 847 1435 59.0 Laguna Hills city 062622 5 715 1211 59.0 Stanton city 087801 2 1238 2100 59.0 Westminster city 099801 2 1454 2465 59.0 Anaheim city 086404 3 997 1693 58.9 Anaheim city 086601 2 1030 1749 58.9 Fullerton city 011711 3 531 902 58.9 Garden Grove city 089107 1 538 913 58.9 Garden Grove city 088501 3 956 1626 58.8 Rancho Santa Margarita city 032054 3 354 603 58.7 Santa Ana city 089001 4 1355 2307 58.7 Anaheim city 086602 1 896 1529 58.6 Brea city 001503 3 1018 1741 58.5 Laguna Woods city 062646 5 447 764 58.5 Santa Ana city 075302 2 941 1609 58.5 Santa Ana city 089104 3 834 1429 58.4 Buena Park city 110500 4 519 890 58.3 Buena Park city 110603 1 1060 1817 58.3 Laguna Woods city 062622 1 396 679 58.3 31O Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Lake Forest city 032047 1 589 1010 58.3 Anaheim city 086702 1 824 1415 58.2 Anaheim city 087802 1 813 1396 58.2 Garden Grove city 088403 1 331 570 58.1 Garden Grove city 076103 3 1959 3382 57.9 Santa Ana city 099202 3 774 1337 57.9 Santa Ana city 074501 4 1067 1847 57.8 Garden Grove city 099203 1 697 1207 57.7 Santa Ana city 099247 1 608 1054 57.7 Cypress city 110110 2 749 1300 57.6 Garden Grove city 088106 3 811 1409 57.6 Santa Ana city 075403 3 1262 2192 57.6 La Habra city 001103 3 991 1722 57.5 Santa Ana city 074502 1 1756 3055 57.5 Seal Beach city 099510 4 203 353 57.5 Stanton city 087801 1 451 785 57.5 Anaheim city 087401 4 540 940 57.4 Irvine city 052421 5 304 530 57.4 Anaheim city 011714 1 126 220 57.3 Anaheim city 076102 1 591 1031 57.3 Santa Ana city 075701 3 566 988 57.3 Fullerton city 001802 3 770 1346 57.2 Irvine city 052417 2 450 787 57.2 Anaheim city 087106 1 641 1122 57.1 Garden Grove city 088802 2 1403 2459 57.1 Rancho Santa Margarita city 032051 3 322 564 57.1 Santa Ana city 075301 4 385 674 57.1 Irvine city 075515 3 312 547 57.0 Santa Ana city 074200 3 1980 3476 57.0 Orange city 021914 2 694 1220 56.9 Garden Grove city 088107 1 1161 2044 56.8 Cypress city 110202 1 165 291 56.7 Fullerton city 011200 3 802 1418 56.6 Garden Grove city 088401 3 668 1183 56.5 Huntington Beach city 099241 2 922 1636 56.4 Garden Grove city 089102 3 1041 1848 56.3 Huntington Beach city 099508 3 744 1322 56.3 Santa Ana city 075504 1 583 1035 56.3 Stanton city 088104 2 846 1503 56.3 Anaheim city 086803 2 623 1109 56.2 Anaheim city 087300 4 899 1601 56.2 Placentia city 011711 1 453 806 56.2 Anaheim city 087401 3 402 717 56.1 Santa Ana city 074111 3 1827 3260 56.0 Fullerton city 001903 1 810 1450 55.9 Garden Grove city 088901 4 744 1331 55.9 Garden Grove city 088903 2 1680 3004 55.9 Anaheim city 086501 3 525 941 55.8 Fullerton city 001601 1 608 1093 55.6 La Habra city 001103 2 800 1439 55.6 Anaheim city 087801 1 6221 1121 55.5 317 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Buena Park city 110110 1 269 485 55.5 Fountain Valley city 099229 3 909 1637 55.5 Santa Ana city 074602 5 824 1485 55.5 Huntington Beach city 099212 4 625 1130 55.3 Buena Park city 110302 1 766 1387 55.2 Garden Grove city 088701 3 1194 2162 55.2 Garden Grove city 088801 1 892 1616 55.2 La Habra city 001301 4 575 1041 55.2 La Palma city 110301 4 858 1553 55.2 Brea city 001504 3 362 657 55.1 Fullerton city 011601 4 663 1203 55.1 Santa Ana city 074006 2 825 1501 55.0 Santa Ana city 074601 5 1054 1917 55.0 Anaheim city 087106 2 1114 2028 54.9 Anaheim city 087704 3 636 1158 54.9 Anaheim city 011722 2 449 819 54.8 Anaheim city 087102 2 1263 2306 54.8 Cypress city 110102 3 707 1290 54.8 Westminster city 099222 2 867 1581 54.8 Anaheim city 087001 3 709 1296 54.7 Huntington Beach city 099220 5 736 1348 54.6 Fullerton city 001801 4 441 809 54.5 Anaheim city 086902 2 864 1588 54.4 Fullerton city 011102 2 558 1028 54.3 Buena Park city 110606 2 1043 1923 54.2 Laguna Woods city 062625 2 509 940 54.1 Westminster city 088905 2 1350 2495 54.1 087806 1 33 61 54.1 Fountain Valley city 099251 1 1212 2246 54.0 Huntington Beach city 099212 1 758 1403 54.0 La Habra city 001103 1 569 1054 54.0 Westminster city 099803 2 806 1492 54.0 099701 1 1180 2188 53.9 Garden Grove city 088902 3 701 1302 53.8 Stanton city 110203 1 29 54 53.7 Anaheim city 086701 1 2159 4028 53.6 Buena Park city 110607 3 739 1379 53.6 Garden Grove city 088301 4 366 683 53.6 Irvine city 052505 2 446 832 53.6 Westminster city 099223 1 1158 2160 53.6 Fullerton city 001903 2 793 1483 53.5 Anaheim city 087200 5 1026 1923 53.4 Garden Grove city 088602 2 1202 2249 53.4 La Habra city 001401 3 627 1174 53.4 Fountain Valley city 099251 2 937 1759 53.3 Garden Grove city 088403 2 1488 2793 53.3 Stanton city 087802 2 1017 1907 53.3 Westminster city 099801 3 897 1682 53.3 Fullerton city 011601 3 997 1873 53.2 Irvine city 062611 2 885 1662 53.2 Santa Ana city 074102 2 10441 1965 53.1 318 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 110402 3 551 1039 53.0 Irvine city 052521 2 651 1229 53.0 Placentia city 011712 1 1141 2152 53.0 Placentia city 011721 3 507 957 53.0 Anaheim city 086301 3 1333 2525 52.8 Placentia city 011712 2 644 1220 52.8 Westminster city 099904 1 422 801 52.7 Brea city 001507 1 830 1579 52.6 Anaheim city 086701 4 754 1436 52.5 Huntington Beach city 099244 2 917 1747 52.5 Stanton city 088104 1 1094 2085 52.5 Westminster city 099902 1 560 1073 52.2 Fullerton city 001902 1 601 1156 52.0 Laguna Hills city 042307 5 638 1226 52.0 Santa Ana city 075404 1 1045 2008 52.0 Garden Grove city 088901 2 645 1242 51.9 Placentia city 011720 3 348 671 51.9 Garden Grove city 088302 1 624 1204 51.8 Laguna Woods city 062641 1 331 639 51.8 Los Alamitos city 110014 2 736 1420 51.8 Westminster city 099204 2 495 955 51.8 Garden Grove city 088903 1 1200 2322 51.7 Westminster city 099903 3 596 1156 51.6 Fullerton city 001802 2 934 1813 51.5 Huntington Beach city 099411 2 953 1851 51.5 Santa Ana city 074106 3 631 1225 51.5 Garden Grove city 088902 2 1106 2158 51.3 Fullerton city 011403 5 631 1232 51.2 Orange city 076205 1 1485 2901 51.2 Garden Grove city 088501 1 1395 2737 51.0 Buena Park city 110302 4 692 1361 50.8 Santa Ana city 074108 2 1711 3369 50.8 Fullerton city 001902 2 756 1491 50.7 Fullerton city 011502 2 381 752 50.7 099703 1 232 458 50.7 La Habra city 001404 1 606 1198 50.6 Laguna Woods city 062623 4 419 828 50.6 Anaheim city 087002 1 1128 2232 50.5 Garden Grove city 088402 1 923 1829 50.5 Anaheim city 087704 2 497 987 50.4 Lake Forest city 052423 2 1088 2158 50.4 Garden Grove city 088901 1 636 1265 50.3 099701 2 516 1025 50.3 Buena Park city 110401 3 678 1356 50.0 Irvine city 052410 5 19 38 50.0 La Habra city 001401 1 715 1429 50.0 Lake Forest city 032014 2 1817 3631 50.0 Santa Ana city 075301 3 887 1775 50.0 Seal Beach city 099511 2 2531 506 50.0 Anaheim city 087404 2 518 1039 49.9 Huntington Beach city 099306 3 5631 1129 49.9 sz9 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Irvine city 052528 4 380 762 49.9 Huntington Beach city 099307 1 444 892 49.8 Los Alamitos city 110014 4 539 1083 49.8 Stanton city 087802 3 746 1498 49.8 Anaheim city 086304 3 1000 2014 49.7 Anaheim city 087503 2 1043 2098 49.7 Newport Beach city 063103 2 74 149 49.7 Santa Ana city 075405 1 801 1612 49.7 Huntington Beach city 099305 2 516 1042 49.5 Lake Forest city 052425 3 766 1550 49.4 Santa Ana city 074103 1 791 1600 49.4 Anaheim city 086801 3 460 933 49.3 Garden Grove city 089107 2 1090 2209 49.3 Buena Park city 110202 3 383 779 49.2 Fountain Valley city 099203 2 420 858 49.0 Garden Grove city 088001 2 865 1765 49.0 Orange city 076000 1 625 1276 49.0 062641 2 892 1821 49.0 Anaheim city 086406 4 418 854 48.9 La Habra city 001402 2 986 2016 48.9 Anaheim city 087401 2 461 945 48.8 Orange city 075805 1 605 1241 48.8 Anaheim city 086901 2 566 1162 48.7 Anaheim city 087602 2 680 1395 48.7 Garden Grove city 088502 2 530 1088 48.7 Orange city 076208 1 812 1670 48.6 Los Alamitos city 110015 9 100 206 48.5 Fullerton city 001704 3 333 689 48.3 Huntington Beach city 099220 1 255 528 48.3 Santa Ana city 089102 2 1079 2236 48.3 Buena Park city 110302 2 1203 2497 48.2 La Habra city 001101 2 281 583 48.2 La Habra city 001402 3 980 2033 48.2 087806 2 833 1728 48.2 Dana Point city 042339 3 597 1240 48.1 063103 2 174 362 48.1 Brea city 001506 1 1000 2087 47.9 Fullerton city 011403 3 474 990 47.9 Fullerton city 011101 4 579 1211 47.8 Santa Ana city 074102 4 1198 2508 47.8 Cypress city 110117 1 947 1985 47.7 Orange city 076202 3 862 1809 47.7 Santa Ana city 075404 2 812 1707 47.6 Anaheim city 086407 2 751 1581 47.5 Los Alamitos city 110108 3 308 649 47.5 Anaheim city 086702 3 493 1039 47.4 Huntington Beach city 099412 1 882 1860 47.4 Westminster city 099204 3 712 1503 47.4 Anaheim city 021807 1 934 1973 47.3 Fullerton city 110605 3 613 1298 47.2 Garden Grove city 088301 2 886 1884 47.0 320 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Westminster city 099702 1 1189 2535 46.9 Fullerton city 011000 2 470 1004 46.8 Huntington Beach city 099405 3 939 2005 46.8 La Habra city 001102 1 415 887 46.8 Westminster city 088905 3 598 1277 46.8 087703 2 759 1625 46.7 Anaheim city 087103 1 750 1608 46.6 Huntington Beach city 099212 3 606 1301 46.6 Anaheim city 086303 2 351 757 46.4 Buena Park city 001801 3 333 717 46.4 Buena Park city 110604 3 1278 2762 46.3 Garden Grove city 088601 1 421 912 46.2 Los Alamitos city 110108 2 340 737 46.1 Buena Park city 110303 1 1109 2412 46.0 Irvine city 052525 7 658 1430 46.0 Irvine city 062627 3 433 942 46.0 Santa Ana city 074111 2 672 1461 46.0 Huntington Beach city 099411 3 693 1509 45.9 Cypress city 110109 2 488 1065 45.8 Garden Grove city 088502 1 917 2010 45.6 Rancho Santa Margarita city 032055 1 313 686 45.6 Anaheim city 088403 1 1420 3118 45.5 Orange city 075815 2 711 1563 45.5 Anaheim city 087103 6 322 711 45.3 Fountain Valley city 099227 2 1449 3201 45.3 Anaheim city 086304 2 401 889 45.1 Laguna Woods city 062623 3 587 1304 45.0 Santa Ana city 089001 1 682 1514 45.0 Brea city 001504 4 525 1169 44.9 Fullerton city 011707 1 618 1375 44.9 Garden Grove city 088002 2 886 1972 44.9 Garden Grove city 088201 2 556 1238 44.9 Huntington Beach city 099215 1 1666 3708 44.9 Santa Ana city 099203 1 691 1539 44.9 Huntington Beach city 099508 4 402 897 44.8 Huntington Beach city 099305 3 733 1640 44.7 Orange city 076000 3 699 1569 44.6 Anaheim city 110203 1 1067 2397 44.5 Rancho Santa Margarita city 032054 2 276 620 44.5 Aliso Viejo CDP 042320 4 858 1931 44.4 Anaheim city 087703 4 225 507 44.4 Laguna Woods city 062623 5 263 592 44.4 Santa Ana city 074107 1 375 845 44.4 Anaheim city 086701 3 487 1099 44.3 Irvine city 052513 5 457 1032 44.3 La Habra city 001705 1 1020 2303 44.3 Orange city 021918 3 200 452 44.2 Anaheim city 086701 2 571 1296 44.1 Laguna Hills city 042320 2 180 408 44.1 Orange city 076205 4 3171 720 44.0 Orange city 076206 1 12531 2850 44.0 321 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Santa Ana city 089107 1 1129 2568 44.0 Fullerton city 011707 3 752 1713 43.9 Santa Ana city 099202 1 893 2038 43.8 Garden Grove city 088203 1 952 2184 43.6 Santa Ana city 075405 2 404 927 43.6 Aliso Viejo CDP 062634 3 134 308 43.5 Anaheim city 087602 4 452 1040 43.5 Fullerton city 011102 3 391 899 43.5 Westminster city 099803 3 823 1894 43.5 Fullerton city 011102 4 525 1211 43.4 La Habra city 001303 4 722 1665 43.4 Los Alamitos city 110014 3 547 1261 43.4 Anaheim city 087503 3 266 614 43.3 Lake Forest city 052411 1 893 2060 43.3 Westminster city 088905 1 523 1208 43.3 Stanton city 088101 1 933 2158 43.2 Westminster city 099904 3 424 982 43.2 076202 2 137 317 43.2 Anaheim city 086301 2 758 1759 43.1 Anaheim city 086406 3 408 946 43.1 Anaheim city 086801 1 191 443 43.1 Cypress city 110111 1 602 1398 43.1 Dana Point city 042313 2 401 931 43.1 Laguna Hills city 062647 1 557 1293 43.1 Fullerton city 011504 1 503 1170 43.0 Huntington Beach city 099216 4 309 721 42.9 Anaheim city 086903 3 388 907 42.8 Garden Grove city 088802 3 565 1320 42.8 Laguna Beach city 062605 1 378 883 42.8 Westminster city 099222 3 559 1307 42.8 Fullerton city 011300 3 553 1296 42.7 Dana Point city 042313 6 438 1029 42.6 Stanton city 087801 3 348 817 42.6 Garden Grove city 110001 2 707 1667 42.4 La Habra city 001303 3 548 1293 42.4 Dana Point city 042201 5 383 905 42.3 Huntington Beach city 099305 1 1051 2482 42.3 Huntington Beach city 099307 2 533 1259 42.3 Irvine city 052520 1 173 409 42.3 Lake Forest city 052424 1 703 1660 42.3 Westminster city 099703 1 578 1367 42.3 001101 3 63 149 42.3 Anaheim city 086803 4 286 677 42.2 Anaheim city 087105 2 1159 2746 42.2 Fullerton city 011403 1 273 647 42.2 076208 3 38 90 42.2 Cypress city 110106 2 451 1071 42.1 Orange city 075805 3 597 1417 42.1 Orange city 076205 3 289 687 42.1 Anaheim city 087501 4 230 548 42.0 Huntington Beach city 099306 2 536 1281 41.8 322 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Placentia city 011711 2 110 263 41.8 Cypress city 110117 3 487 1169 41.7 Buena Park city 110201 2 841 2023 41.6 Cypress city 110109 4 707 1704 41.5 Garden Grove city 088302 3 629 1521 41.4 Garden Grove city 088401 2 943 2280 41.4 Westminster city 099222 4 407 984 41.4 Brea city 001504 2 602 1458 41.3 Fullerton city 011000 3 481 1165 41.3 La Habra city 001102 3 528 1277 41.3 Orange city 075902 5 303 733 41.3 Huntington Beach city 099408 1 776 1883 41.2 Tustin Foothills CDP 075504 2 259 629 41.2 Buena Park city 110110 2 449 1093 41.1 Fullerton city 011101 2 649 1579 41.1 075808 2 309 752 41.1 Buena Park city 110401 1 593 1445 41.0 Garden Grove city 087902 1 48 117 41.0 Santa Ana city 074107 2 1028 2516 40.9 Westminster city 088904 1 421 1030 40.9 Brea city 001505 2 766 1879 40.8 Garden Grove city 088401 1 582 1425 40.8 Buena Park city 110402 1 468 1149 40.7 La Palma city 110115 1 382 941 40.6 Anaheim city 086402 2 431 1064 40.5 Los Alamitos city 110015 1 593 1465 40.5 Newport Beach city 063500 1 156 385 40.5 Yorba Linda city 021802 5 598 1476 40.5 063101 1 973 2404 40.5 Buena Park city 110302 3 270 669 40.4 Orange city 075902 4 161 399 40.4 062604 3 295 730 40.4 Huntington Beach city 099235 3 727 1805 40.3 Buena Park city 110604 2 557 1386 40.2 Irvine city 062627 1 543 1350 40.2 Anaheim city 087601 2 433 1081 40.1 Fountain Valley city 099233 2 672 1674 40.1 Orange city 075806 3 318 794 40.1 Placentia city 011715 1 407 1016 40.1 Brea city 021815 2 261 652 40.0 Placentia city 011717 1 517 1294 40.0 Anaheim city 086903 4 593 1485 39.9 Huntington Beach city 099416 3 401 1006 39.9 Newport Beach city 063603 1 1127 2822 39.9 Santa Ana city 074106 2 780 1956 39.9 Westminster city 099801 1 493 1236 39.9 099513 1 121 303 39.9 Fullerton city 011102 1 531 1335 39.8 021816 1 304 764 39.8 087101 1 284 713 39.8 Buena Park city 110607 1 3891 980 39.7 323 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Garden Grove city 087602 2 112 282 39.7 Lake Forest city 052411 2 693 1747 39.7 Rancho Santa Margarita city 032042 2 395 994 39.7 Anaheim city 087701 1 459 1161 39.5 Santa Ana city 074004 4 883 2236 39.5 La Habra city 001301 1 342 871 39.3 Buena Park city 110301 3 593 1511 39.2 Cypress city 110104 1 1021 2603 39.2 Orange city 075902 1 374 955 39.2 Tustin Foothills CDP 075603 3 382 974 39.2 Buena Park city 086801 2 361 923 39.1 Dana Point city 042201 2 611 1564 39.1 Fullerton city 011502 3 497 1273 39.0 Irvine city 052519 3 281 720 39.0 Irvine city 052519 4 510 1307 39.0 Santa Ana city 075303 2 908 2326 39.0 Westminster city 099603 1 514 1318 39.0 Anaheim city 086305 2 687 1768 38.9 Dana Point city 042313 3 610 1569 38.9 Garden Grove city 088105 1 976 2506 38.9 Laguna Woods city 062623 7 339 872 38.9 087703 3 530 1362 38.9 Dana Point city 042313 1 481 1239 38.8 Rancho Santa Margarita city 032053 3 662 1708 38.8 Anaheim city 087601 4 264 682 38.7 Anaheim city 087704 4 592 1529 38.7 Dana Point city 042205 4 357 923 38.7 Newport Beach city 063010 2 645 1667 38.7 Huntington Beach city 099413 2 714 1851 38.6 Anaheim city 087200 1 351 912 38.5 Newport Beach city 063500 7 327 850 38.5 Anaheim city 086802 3 428 1115 38.4 Lake Forest city 032029 1 546 1421 38.4 Buena Park city 110203 2 868 2268 38.3 Garden Grove city 088701 4 293 766 38.3 La Habra city 001101 4 149 389 38.3 Anaheim city 088302 1 449 1174 38.2 Fullerton city 001901 1 514 1346 38.2 Garden Grove city 087503 2 192 503 38.2 Irvine city 052527 3 419 1096 38.2 110604 3 120 314 38.2 Anaheim city 011722 3 315 827 38.1 Garden Grove city 088002 1 587 1543 38.0 Orange city 075901 2 329 866 38.0 Lake Forest city 052416 1 296 781 37.9 Lake Forest city 052425 1 596 1574 37.9 Huntington Beach city 099410 1 423 1121 37.7 Irvine city 052511 4 399 1058 37.7 Irvine city 052521 1 621 1647 37.7 La Habra city 001402 1 419 1113 37.6 Santa Ana city 074005 4 557 1480 37.6 324 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Buena Park city 110402 2 155 413 37.5 Cypress city 110117 4 498 1329 37.5 Irvine city 052511 5 311 829 37.5 Yorba Linda city 021802 1 514 1372 37.5 Laguna Beach city 062605 3 457 1223 37.4 011718 2 137 367 37.3 Huntington Beach city 099220 2 305 819 37.2 Newport Beach city 063004 3 331 890 37.2 Santa Ana city 075902 4 202 543 37.2 Anaheim city 086402 3 518 1398 37.1 La Palma city 110102 3 166 447 37.1 Rancho Santa Margarita city 032051 1 402 1084 37.1 Dana Point city 042310 1 682 1849 36.9 Lake Forest city 052410 1 494 1337 36.9 Orange city 076000 2 644 1743 36.9 Orange city 076102 2 270 731 36.9 Westminster city 099902 2 612 1658 36.9 Cypress city 110106 3 641 1743 36.8 Fullerton city 011000 5 331 899 36.8 Seal Beach city 110008 3 315 855 36.8 Buena Park city 110304 2 671 1828 36.7 La Palma city 110111 3 47 128 36.7 Brea city 001507 2 270 738 36.6 Santa Ana city 075403 4 468 1280 36.6 Brea city 001501 1 578 1584 36.5 Fullerton city 001707 2 253 694 36.5 Huntington Beach city 099235 4 310 849 36.5 Huntington Beach city 099311 2 594 1626 36.5 Anaheim city 086303 1 353 971 36.4 Fullerton city 110605 1 341 936 36.4 Huntington Beach city 099245 2 597 1641 36.4 La Habra city 001705 2 420 1156 36.3 Buena Park city 110401 2 340 942 36.1 Huntington Beach city 099214 2 347 962 36.1 Huntington Beach city 099212 2 386 1073 36.0 La Palma city 110304 2 275 764 36.0 Westminster city 099602 1 381 1057 36.0 087701 2 501 1397 35.9 Garden Grove city 099203 2 234 653 35.8 Huntington Beach city 099416 1 759 2118 35.8 La Habra city 001401 2 345 964 35.8 Anaheim city 087200 4 307 861 35.7 Brea city 001503 2 310 868 35.7 Brea city 021814 2 700 1968 35.6 Laguna Hills city 062622 4 246 691 35.6 La Habra city 001601 4 71 200 35.5 Orange city 076206 3 315 894 35.2 Garden Grove city 088301 3 359 1025 35.0 Huntington Beach city 099306 4 408 1167 35.0 Irvine city 052523 1 270 772 35.0 Anaheim city 021903 3 384 1100 34.9 325 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Irvine city 052527 4 209 599 34.9 Dana Point city 042201 6 243 698 34.8 Orange city 076205 2 346 995 34.8 Los Alamitos city 110014 1 235 678 34.7 Aliso Viejo CDP 062636 1 417 1206 34.6 Huntington Beach city 099242 1 533 1542 34.6 Irvine city 052513 4 361 1044 34.6 La Habra city 001101 1 441 1273 34.6 Huntington Beach city 099242 2 765 2215 34.5 Irvine city 062610 1 508 1472 34.5 Orange city 076201 5 434 1258 34.5 Garden Grove city 110004 2 293 852 34.4 Santa Ana city 099203 2 512 1489 34.4 Yorba Linda city 021810 1 240 698 34.4 063102 1 168 489 34.4 Garden Grove city 088302 2 448 1308 34.3 Irvine city 052418 1 520 1518 34.3 Santa Ana city 075403 1 357 1040 34.3 Brea city 021814 4 584 1707 34.2 Fountain Valley city 099232 2 401 1171 34.2 Dana Point city 042323 3 457 1342 34.1 Orange city 075901 1 260 762 34.1 Anaheim city 021812 3 526 1549 34.0 Anaheim city 086303 3 294 865 34.0 Buena Park city 110304 1 739 2173 34.0 Laguna Beach city 062619 5 190 560 33.9 Newport Beach city 063400 6 295 871 33.9 001401 1 41 121 33.9 Irvine city 052515 4 529 1567 33.8 Laguna Woods city 062635 2 80 237 33.8 Newport Beach city 063006 5 203 600 33.8 021817 1 304 899 33.8 Huntington Beach city 099311 1 404 1201 33.6 075506 2 299 891 33.6 Fullerton city 011000 1 269 804 33.5 032049 1 53 158 33.5 Placentia city 011710 3 226 676 33.4 Westminster city 099903 1 587 1759 33.4 Anaheim city 087602 1 351 1054 33.3 Fountain Valley city 099250 1 513 1542 33.3 Placentia city 021821 2 1181 3542 33.3 Westminster city 088904 3 413 1242 33.3 Yorba Linda city 011718 1 191 576 33.2 Huntington Beach city 099408 2 429 1295 33.1 Irvine city 052519 1 319 963 33.1 Fullerton city 001505 4 409 1238 33.0 Garden Grove city 110004 1 348 1053 33.0 Irvine city 062612 5 402 1217 33.0 Anaheim city 087103 2 231 702 32.9 Orange city 076208 2 275 835 32.9 Anaheim city 087001 2 394 1203 32.8 32(0 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 086407 1 753 2308 32.6 Buena Park city 110401 4 287 880 32.6 Huntington Beach city 099603 1 550 1688 32.6 Westminster city 099241 2 197 605 32.6 Fullerton city 001505 3 368 1131 32.5 Fullerton city 001601 6 316 971 32.5 Laguna Hills city 062621 2 548 1688 32.5 Brea city 001503 1 506 1562 32.4 Dana Point city 042206 2 177 547 32.4 Garden Grove city 088202 2 495 1527 32.4 La Habra city 001102 2 297 918 32.4 Orange city 076000 4 548 1690 32.4 Santa Ana city 074004 3 599 1847 32.4 Orange city 021914 3 264 817 32.3 Orange city 075806 1 404 1249 32.3 Fountain Valley city 099224 2 485 1505 32.2 Placentia city 011721 2 136 423 32.2 Huntington Beach city 099239 2 327 1023 32.0 Huntington Beach city 099413 3 668 2085 32.0 Dana Point city 042313 4 178 558 31.9 Newport Beach city 063006 2 173 542 31.9 Orange city 076201 3 438 1375 31.9 Santa Ana city 075401 1 547 1722 31.8 Anaheim city 021922 2 262 826 31.7 Brea city 001403 2 60 189 31.7 Newport Beach city 062642 2 264 833 31.7 Orange city 076208 3 373 1177 31.7 Seal Beach city 099512 3 184 580 31.7 Irvine city 062628 2 467 1476 31.6 Lake Forest city 052410 2 336 1064 31.6 Newport Beach city 063400 1 281 888 31.6 Newport Beach city 063010 4 206 654 31.5 099506 3 147 466 31.5 Anaheim city 086902 3 491 1564 31.4 Fullerton city 011000 6 374 1194 31.3 Laguna Beach city 062620 4 328 1048 31.3 Orange city 075815 1 755 2410 31.3 Huntington Beach city 099406 2 851 2726 31.2 Huntington Beach city 099508 1 502 1607 31.2 Laguna Hills city 042320 1 531 1703 31.2 Orange city 075812 4 334 1070 31.2 Seal Beach city 099511 4 272 871 31.2 063009 1 24 77 31.2 Rancho Santa Margarita city 032051 2 282 907 31.1 Brea city 001507 3 605 1951 31.0 Buena Park city 110303 2 745 2404 31.0 Lake Forest city 052423 3 431 1391 31.0 Newport Beach city 062800 2 468 1512 31.0 Westminster city 088904 4 458 1476 31.0 Laguna Beach city 062632 4 371 1204 30.8 Rancho Santa Margarita city 032054 1 6621 2147 30.8 327 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Cypress city 110114 3 544 1771 30.7 Yorba Linda city 021830 4 240 783 30.7 Laguna Beach city 062619 3 338 1104 30.6 Westminster city 099905 2 390 1276 30.6 Cypress city 110110 3 529 1733 30.5 Garden Grove city 088203 3 206 675 30.5 Anaheim city 087501 1 581 1912 30.4 La Habra city 001403 2 328 1079 30.4 Laguna Beach city 062604 1 224 738 30.4 Dana Point city 042201 3 162 534 30.3 Huntington Beach city 099220 3 384 1268 30.3 Buena Park city 110201 1 521 1725 30.2 Huntington Beach city 099306 5 263 870 30.2 Huntington Beach city 099404 1 724 2397 30.2 Anaheim city 021919 1 441 1465 30.1 Cypress city 110114 1 506 1682 30.1 Dana Point city 042205 2 106 352 30.1 Garden Grove city 110004 3 341 1134 30.1 Huntington Beach city 099309 2 463 1539 30.1 087902 2 191 634 30.1 Cypress city 110113 1 563 1877 30.0 Fountain Valley city 099227 1 258 859 30.0 Los Alamitos city 110012 4 6 20 30.0 Anaheim city 086304 1 480 1606 29.9 Huntington Beach city 099237 1 500 1670 29.9 Huntington Beach city 099402 1 173 578 29.9 Yorba Linda city 021826 2 464 1552 29.9 087703 4 215 720 29.9 Garden Grove city 110003 2 535 1796 29.8 Newport Beach city 063006 6 114 383 29.8 Newport Beach city 063500 2 249 835 29.8 Anaheim city 021916 2 565 1900 29.7 Garden Grove city 088105 2 379 1276 29.7 Irvine city 052517 1 689 2317 29.7 Newport Beach city 063500 4 274 923 29.7 Fullerton city 001505 2 105 355 29.6 Westminster city 099701 1 351 1184 29.6 Fountain Valley city 099202 1 185 627 29.5 Fullerton city 001706 2 315 1067 29.5 Fullerton city 011503 2 266 903 29.5 Garden Grove city 088904 2 156 528 29.5 Huntington Beach city 099405 1 358 1214 29.5 Irvine city 052521 3 207 702 29.5 Laguna Hills city 042307 3 310 1055 29.4 Seal Beach city 099506 1 126 428 29.4 Lake Forest city 052424 3 478 1630 29.3 Newport Beach city 063004 2 476 1627 29.3 Anaheim city 021915 1 553 1896 29.2 Santa Ana city 074110 2 328 1124 29.2 Stanton city 087805 2 50 171 29.2 Placentia city 011717 2 237 814 29.1 328 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Yorba Linda city 021802 4 413 1420 29.1 Buena Park city 110203 1 202 696 29.0 Westminster city 099906 2 385 1329 29.0 Fountain Valley city 099230 2 695 2401 28.9 Laguna Woods city 062623 6 204 707 28.9 Rossmoor CDP 110006 1 402 1395 28.8 Irvine city 052513 2 254 886 28.7 Yorba Linda city 021815 1 526 1832 28.7 Buena Park city 110202 1 398 1394 28.6 Huntington Beach city 099602 2 447 1563 28.6 Lake Forest city 052425 4 527 1841 28.6 Huntington Beach city 099246 3 198 694 28.5 Tustin Foothills CDP 075603 2 383 1343 28.5 Westminster city 099241 1 578 2025 28.5 Buena Park city 110202 2 167 591 28.3 Buena Park city 110604 1 527 1862 28.3 Cypress city 110106 1 210 742 28.3 La Habra city 001101 3 289 1023 28.3 Orange city 076206 2 192 681 28.2 Brea city 021814 1 642 2286 28.1 Fullerton city 001503 4 257 913 28.1 Santa Ana city 075301 2 333 1185 28.1 Fountain Valley city 099231 2 513 1831 28.0 Fullerton city 001705 3 252 900 28.0 Fullerton city 110605 5 682 2440 28.0 Huntington Beach city 099310 2 488 1744 28.0 Laguna Hills city 062621 1 472 1687 28.0 Orange city 021913 3 541 1932 28.0 La Palma city 110116 1 418 1499 27.9 Garden Grove city 110005 2 471 1693 27.8 Huntington Beach city 099407 1 692 2485 27.8 Laguna Hills city 042327 2 254 914 27.8 Santa Ana city 075401 2 505 1816 27.8 Anaheim city 086306 3 278 1003 27.7 Buena Park city 110301 4 287 1036 27.7 Lake Forest city 052410 3 140 505 27.7 Seal Beach city 099512 2 231 835 27.7 Buena Park city 110604 4 242 881 27.5 Yorba Linda city 021802 2 271 987 27.5 Dana Point city 042324 1 200 729 27.4 Anaheim city 086306 2 288 1054 27.3 Fountain Valley city 099225 1 445 1629 27.3 Irvine city 052525 2 280 1026 27.3 Irvine city 052525 6 264 968 27.3 Newport Beach city 062800 1 154 564 27.3 Fullerton city 001601 5 444 1635 27.2 Irvine city 052505 3 199 731 27.2 La Habra city 001708 1 301 1111 27.1 Yorba Linda city 021822 3 272 1004 27.1 Fullerton city 001901 2 365 1351 27.0 Garden Grove city 110010 1 2771 1026 27.0 329 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Orange city 021918 1 340 1259 27.0 Rancho Santa Margarita city 032050 1 173 643 26.9 Rancho Santa Margarita city 032050 2 482 1790 26.9 Santa Ana city 075100 3 445 1657 26.9 Aliso Viejo CDP 042320 3 401 1503 26.7 Anaheim city 021903 1 394 1474 26.7 Huntington Beach city 099216 1 222 833 26.7 Laguna Hills city 042307 2 237 889 26.7 001101 4 133 498 26.7 Dana Point city 042311 4 379 1427 26.6 Dana Point city 042338 1 142 533 26.6 Fountain Valley city 099232 1 433 1627 26.6 Huntington Beach city 099214 1 207 777 26.6 Huntington Beach city 099416 2 390 1464 26.6 Irvine city 052519 2 319 1200 26.6 Irvine city 062629 2 218 821 26.6 Huntington Beach city 099605 1 520 1960 26.5 Placentia city 011716 1 1117 4213 26.5 Westminster city 099703 2 637 2401 26.5 Yorba Linda city 021802 3 340 1283 26.5 Yorba Linda city 021817 1 498 1880 26.5 087805 3 117 441 26.5 Newport Beach city 063500 3 237 897 26.4 Newport Beach city 063603 3 361 1365 26.4 Buena Park city 086803 2 223 847 26.3 Newport Beach city 063007 2 514 1955 26.3 Huntington Beach city 099216 2 402 1537 26.2 Rancho Santa Margarita city 032054 4 328 1258 26.1 Westminster city 099702 3 293 1121 26.1 Irvine city 052526 3 481 1853 26.0 Irvine city 052528 1 174 669 26.0 La Habra city 001301 3 311 1198 26.0 Seal Beach city 099512 4 200 768 26.0 Aliso Viejo CDP 062640 1 403 1557 25.9 La Habra city 001707 1 546 2107 25.9 Newport Beach city 062702 5 334 1292 25.9 Tustin Foothills CDP 075604 3 178 690 25.8 Westminster city 099601 4 224 873 25.7 Yorba Linda city 021827 2 252 982 25.7 Huntington Beach city 099237 2 473 1848 25.6 Irvine city 052505 1 200 784 25.5 Irvine city 052515 3 528 2076 25.4 Orange city 075805 2 339 1337 25.4 Orange city 076101 2 386 1520 25.4 Westminster city 099906 3 372 1462 25.4 Newport Beach city 063006 4 119 471 25.3 Placentia city 011709 4 351 1390 25.3 Seal Beach city 099511 3 150 594 25.3 Newport Beach city 062800 4 141 559 25.2 Dana Point city 042338 2 1074 4273 25.1 Garden Grove city 110001 1 435 1731 25.1 330 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Huntington Beach city 099604 2 456 1817 25.1 Anaheim city 087103 5 363 1452 25.0 Laguna Beach city 062604 4 138 551 25.0 Orange city 021913 2 312 1250 25.0 Brea city 001501 3 694 2788 24.9 Cypress city 110114 2 350 1405 24.9 Dana Point city 042339 1 180 723 24.9 Huntington Beach city 099240 3 423 1702 24.9 Seal Beach city 110007 2 205 822 24.9 Westminster city 099603 3 292 1171 24.9 Irvine city 052506 1 254 1026 24.8 Irvine city 052513 1 205 827 24.8 Irvine city 052525 5 141 569 24.8 Orange city 021914 1 251 1016 24.7 Santa Ana city 074110 1 663 2687 24.7 Aliso Viejo CDP 062639 2 495 2013 24.6 Cypress city 110109 3 294 1194 24.6 Irvine city 052511 3 221 899 24.6 Placentia city 021810 2 273 1110 24.6 Rossmoor CDP 110008 1 237 965 24.6 Orange city 075806 2 247 1008 24.5 Anaheim city 087805 2 108 442 24.4 Huntington Beach city 099306 1 362 1484 24.4 Huntington Beach city 099417 2 401 1643 24.4 Dana Point city 042311 3 204 841 24.3 Garden Grove city 088202 1 315 1297 24.3 Huntington Beach city 099214 3 225 929 24.2 Huntington Beach city 099405 2 291 1204 24.2 Orange city 075812 3 293 1210 24.2 001402 1 8 33 24.2 063102 4 113 467 24.2 Dana Point city 042323 1 352 1459 24.1 Irvine city 052521 4 232 961 24.1 Orange city 075807 2 459 1902 24.1 Placentia city 011709 2 171 711 24.1 001101 2 91 377 24.1 Fountain Valley city 099234 1 314 1308 24.0 Huntington Beach city 099238 1 465 1938 24.0 Aliso Viejo CDP 062634 1 208 872 23.9 Anaheim city 086305 1 240 1005 23.9 Huntington Beach city 099604 1 454 1897 23.9 Irvine city 052517 2 598 2500 23.9 Yorba Linda city 021809 3 171 714 23.9 Fountain Valley city 099204 3 114 479 23.8 Laguna Beach city 042305 1 226 950 23.8 Lake Forest city 052408 4 266 1117 23.8 Fountain Valley city 099229 2 517 2181 23.7 Fountain Valley city 099250 2 266 1121 23.7 Newport Beach city 063400 3 241 1016 23.7 Tustin Foothills CDP 075701 1 204 861 23.7 Fullerton city 001708 3 339 1438 23.6 331 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Fullerton city 011200 4 162 685 23.6 Huntington Beach city 099410 2 184 779 23.6 Laguna Hills city 062625 3 311 1319 23.6 Laguna Woods city 062623 2 26 110 23.6 Placentia city 011710 2 468 1986 23.6 Huntington Beach city 099406 1 400 1699 23.5 Irvine city 052520 3 229 973 23.5 Huntington Beach city 099215 2 407 1743 23.4 Irvine city 052505 5 522 2227 23.4 Laguna Beach city 062619 4 92 394 23.4 Huntington Beach city 099411 1 181 776 23.3 Irvine city 062611 4 123 529 23.3 Tustin Foothills CDP 075702 3 224 960 23.3 Tustin Foothills CDP 075703 2 408 1750 23.3 Newport Beach city 063400 5 79 341 23.2 Orange city 075807 1 264 1137 23.2 Westminster city 099223 3 265 1140 23.2 Fountain Valley city 099224 1 439 1903 23.1 Garden Grove city 110010 3 162 701 23.1 Huntington Beach city 099603 4 299 1296 23.1 Newport Beach city 062800 3 195 844 23.1 Brea city 001501 2 250 1086 23.0 Fountain Valley city 099231 1 426 1855 23.0 Fountain Valley city 099232 3 366 1598 22.9 Brea city 001404 1 83 364 22.8 Huntington Beach city 099311 3 216 946 22.8 Fullerton city 011503 1 174 768 22.7 Newport Beach city 062800 5 284 1251 22.7 Placentia city 011708 3 180 792 22.7 Huntington Beach city 099508 2 189 835 22.6 Rancho Santa Margarita city 032051 6 122 540 22.6 Anaheim city 021919 2 293 1303 22.5 Fullerton city 001704 2 176 782 22.5 Newport Beach city 062644 3 530 2352 22.5 Fountain Valley city 099223 3 124 554 22.4 Laguna Woods city 062621 3 110 491 22.4 Cypress city 110104 2 471 2110 22.3 Fullerton city 011300 2 239 1074 22.3 Orange city 076202 1 256 1148 22.3 Placentia city 021821 1 378 1697 22.3 Dana Point city 042323 4 172 777 22.1 Garden Grove city 110004 4 356 1613 22.1 Tustin Foothills CDP 075702 2 280 1269 22.1 Yorba Linda city 021816 1 244 1103 22.1 Huntington Beach city 099605 2 386 1758 22.0 Lake Forest city 052408 2 553 2509 22.0 Newport Beach city 062642 3 308 1398 22.0 Fountain Valley city 099234 2 375 1716 21.9 Lake Forest city 052425 2 173 790 21.9 Santa Ana city 074107 3 255 1165 21.9 Aliso Viejo CDP 062637 2 2861 1309 21.8 332 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Orange city 075605 1 139 638 21.8 Seal Beach city 099511 5 209 960 21.8 Anaheim city 086305 3 201 928 21.7 Huntington Beach city 099217 2 146 673 21.7 Huntington Beach city 099235 2 177 814 21.7 Huntington Beach city 099243 2 314 1447 21.7 Huntington Beach city 099310 1 373 1725 21.6 Huntington Beach city 099310 3 221 1023 21.6 Irvine city 052515 1 378 1750 21.6 Garden Grove city 088201 3 217 1008 21.5 Garden Grove city 110003 1 297 1379 21.5 Irvine city 052514 3 265 1233 21.5 Westminster city 099702 2 151 702 21.5 Buena Park city 086801 1 141 660 21.4 Laguna Beach city 062619 1 254 1187 21.4 Cypress city 110010 1 303 1425 21.3 Orange city 075811 1 368 1736 21.2 021914 3 182 860 21.2 Aliso Viejo CDP 062636 2 272 1292 21.1 Aliso Viejo CDP 062637 1 313 1486 21.1 Aliso Viejo CDP 062640 2 394 1871 21.1 Dana Point city 042206 1 76 361 21.1 Irvine city 062612 1 390 1848 21.1 Irvine city 062612 6 347 1647 21.1 Newport Beach city 062642 1 161 762 21.1 Newport Beach city 062644 4 303 1444 21.0 Orange city 021918 2 480 2282 21.0 Orange city 075813 1 337 1604 21.0 Cypress city 110111 2 405 1938 20.9 Irvine city 052513 3 240 1147 20.9 Lake Forest city 052410 4 284 1357 20.9 Fountain Valley city 099226 1 396 1906 20.8 Irvine city 062611 3 167 804 20.8 La Palma city 110102 1 338 1622 20.8 Seal Beach city 099512 1 133 638 20.8 Yorba Linda city 021825 1 400 1922 20.8 Fountain Valley city 099226 2 418 2019 20.7 Seal Beach city 099511 1 143 690 20.7 Yorba Linda city 021816 3 124 598 20.7 Brea city 001403 1 313 1520 20.6 Fountain Valley city 099227 3 331 1606 20.6 La Habra city 001301 2 267 1299 20.6 Lake Forest city 052422 1 243 1182 20.6 Garden Grove city 110005 1 300 1461 20.5 Huntington Beach city 099412 2 236 1153 20.5 La Palma city 110102 2 456 2226 20.5 Huntington Beach city 099235 1 247 1212 20.4 Yorba Linda city 021820 2 288 1409 20.4 Fountain Valley city 099251 3 256 1262 20.3 Huntington Beach city 099513 2 161 794 20.3 Newport Beach city 062644 2 240 1180 20.3 333 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Rossmoor CDP 110007 1 250 1233 20.3 Fullerton city 011200 1 191 947 20.2 Huntington Beach city 099217 3 208 1031 20.2 Seal Beach city 110012 4 312 1541 20.2 Fullerton city 001602 4 246 1226 20.1 Portola Hills CDP 052428 2 192 957 20.1 Yorba Linda city 021822 2 352 1755 20.1 021913 2 89 442 20.1 Fullerton city 011707 2 258 1289 20.0 Newport Beach city 062900 1 212 1059 20.0 Anaheim city 021905 1 335 1684 19.9 Anaheim city 021905 2 406 2040 19.9 Irvine city 062612 4 144 724 19.9 Lake Forest city 052422 3 233 1173 19.9 Westminster city 099906 1 398 1997 19.9 Brea city 011717 1 70 353 19.8 Tustin Foothills CDP 075603 1 239 1209 19.8 Yorba Linda city 021816 2 311 1573 19.8 Huntington Beach city 099216 3 189 957 19.7 Irvine city 052511 1 283 1435 19.7 Irvine city 062628 1 255 1292 19.7 Seal Beach city 099504 1 482 2447 19.7 Laguna Beach city 062620 5 110 562 19.6 Lake Forest city 032027 2 626 3192 19.6 Yorba Linda city 021823 1 560 2859 19.6 Cypress city 110010 2 229 1176 19.5 Irvine city 062629 1 361 1854 19.5 La Habra city 001403 1 91 467 19.5 Huntington Beach city 099602 1 104 535 19.4 Irvine city 052514 2 250 1290 19.4 Lake Forest city 052423 1 291 1498 19.4 Villa Park city 075810 2 213 1100 19.4 Yorba Linda city 021809 1 226 1165 19.4 Fullerton city 001704 1 274 1419 19.3 Garden Grove city 088001 1 257 1335 19.3 Newport Beach city 063500 6 223 1155 19.3 Yorba Linda city 021826 1 186 965 19.3 Aliso Viejo CDP 062634 4 173 902 19.2 Huntington Beach city 099309 1 389 2021 19.2 La Palma city 110116 2 360 1877 19.2 Newport Beach city 063400 4 153 798 19.2 032052 1 83 433 19.2 Huntington Beach city 099417 1 443 2315 19.1 Laguna Beach city 062605 4 124 648 19.1 Newport Beach city 063004 1 337 1768 19.1 Yorba Linda city 021810 2 80 418 19.1 011715 1 76 398 19.1 Irvine city 062614 1 421 2219 19.0 Laguna Hills city 042307 6 268 1409 19.0 Newport Beach city 062900 2 143 752 19.0 Placentia city 021820 2 320 1687 19.0 3S4 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% 075701 4 11 58 19.0 Fountain Valley city 099233 1 314 1658 18.9 Orange city 076201 1 146 774 18.9 021914 1 54 285 18.9 Dana Point city 042339 4 178 945 18.8 Laguna Hills city 042328 2 191 1017 18.8 032011 1 204 1086 18.8 Anaheim city 021905 3 277 1484 18.7 Huntington Beach city 099243 1 489 2617 18.7 Lake Forest city 052428 5 182 975 18.7 Orange city 076201 4 161 864 18.6 Placentia city 011712 3 144 775 18.6 Laguna Beach city 062604 2 123 666 18.5 Orange city 075808 1 162 874 18.5 Orange city 075812 2 212 1143 18.5 Orange city 075813 3 334 1808 18.5 Rossmoor CDP 110008 2 204 1103 18.5 Anaheim city 021807 2 340 1843 18.4 Villa Park city 075810 3 144 781 18.4 Aliso Viejo CDP 062638 1 452 2470 18.3 Huntington Beach city 099239 3 171 935 18.3 La Palma city 110115 2 211 1152 18.3 032041 1 72 393 18.3 Huntington Beach city 099245 1 260 1426 18.2 Newport Beach city 062701 1 353 1943 18.2 Placentia city 011709 1 197 1080 18.2 Rancho Santa Margarita city 032048 3 239 1313 18.2 Irvine city 052526 2 344 1904 18.1 Irvine city 062612 2 189 1042 18.1 Laguna Hills city 062621 3 184 1018 18.1 Newport Beach city 062702 1 120 664 18.1 Orange city 075808 2 208 1149 18.1 Fullerton city 001707 3 265 1470 18.0 Lake Forest city 052416 2 349 1937 18.0 Yorba Linda city 021820 1 197 1097 18.0 021917 2 111 621 17.9 Cypress city 110117 2 182 1025 17.8 Laguna Hills city 042307 1 281 1577 17.8 Newport Beach city 063009 1 280 1577 17.8 Santa Ana city 074111 1 208 1169 17.8 Huntington Beach city 099217 1 134 756 17.7 Laguna Beach city 062623 6 205 1159 17.7 Orange city 076202 2 129 730 17.7 Yorba Linda city 021822 1 167 941 17.7 099506 2 64 361 17.7 Newport Beach city 063603 2 254 1447 17.6 Cypress city 110118 2 242 1385 17.5 Santa Ana city 075303 1 180 1031 17.5 Placentia city 011710 1 133 763 17.4 Irvine city 052525 3 149 859 17.3 Los Alamitos city 110015 2 323 1862 17.3 335 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Newport Beach city 063005 2 118 683 17.3 011718 1 47 272 17.3 Fullerton city 001706 3 131 762 17.2 Laguna Beach city 042305 3 263 1527 17.2 Anaheim city 021923 3 190 1110 17.1 Fullerton city 001505 1 311 1823 17.1 Huntington Beach city 099415 1 184 1076 17.1 Huntington Beach city 099702 2 66 385 17.1 Dana Point city 042323 2 194 1139 17.0 Fullerton city 011402 1 163 957 17.0 Huntington Beach city 099240 1 309 1818 17.0 Irvine city 052511 6 154 904 17.0 Lake Forest city 052422 2 292 1713 17.0 042335 1 168 990 17.0 Dana Point city 042305 2 84 496 16.9 Fullerton city 001601 4 74 437 16.9 Lake Forest city 052415 2 346 2043 16.9 021812 2 64 378 16.9 075808 1 74 438 16.9 Newport Beach city 063007 3 330 1969 16.8 Tustin Foothills CDP 075701 3 77 458 16.8 Anaheim city 021920 1 137 818 16.7 Irvine city 052515 2 250 1496 16.7 Irvine city 062630 1 283 1699 16.7 Garden Grove city 076103 1 38 229 16.6 La Habra city 001708 2 230 1385 16.6 Anaheim city 021915 2 85 514 16.5 Cypress city 110118 1 255 1550 16.5 Lake Forest city 052424 2 239 1448 16.5 Irvine city 052417 4 172 1049 16.4 Laguna Beach city 062632 1 313 1921 16.3 Lake Forest city 032029 2 527 3226 16.3 Newport Beach city 063006 3 100 614 16.3 Rancho Santa Margarita city 032055 4 207 1268 16.3 Westminster city 099603 2 126 774 16.3 032011 2 35 215 16.3 Fullerton city 001707 4 280 1727 16.2 Rancho Santa Margarita city 032055 3 177 1095 16.2 Yorba Linda city 021809 2 113 697 162 Anaheim city 021922 4 231 1432 16.1 Fullerton city 001601 2 190 1180 16.1 Irvine city 052522 1 233 1451 16.1 Placentia city 011709 3 195 1208 16.1 Buena Park city 110301 1 207 1297 16.0 Fullerton city 011402 2 208 1301 16.0 Irvine city 052520 2 136 848 16.0 Laguna Beach city 042305 2 128 799 16.0 Orange city 075814 1 400 2497 16.0 Placentia city 011715 3 262 1639 16.0 Tustin Foothills CDP 075604 5 2401 1504 16.0 Fullerton city 011401 2 2121 1332 15.9 33O Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Huntington Beach city 099404 2 369 2323 15.9 Tustin Foothills CDP 075604 1 189 1190 15.9 021918 1 27 170 15.9 Aliso Viejo CDP 062635 2 245 1553 15.8 Anaheim city 021812 2 318 2012 15.8 Orange city 075815 3 164 1037 15.8 Yorba Linda city 021827 1 52 330 15.8 Cypress city 110001 1 166 1056 15.7 Fountain Valley city 099225 2 272 1728 15.7 Orange city 021917 1 146 931 15.7 Rancho Santa Margarita city 032056 2 136 864 15.7 Fountain Valley city 099202 3 49 315 15.6 Anaheim city 021923 1 217 1400 15.5 Huntington Beach city 099412 3 255 1648 15.5 Orange city 075809 3 9 58 15.5 Tustin Foothills CDP 075606 4 195 1258 15.5 Newport Beach city 063500 5 50 324 15.4 Seal Beach city 110012 1 200 1300 15.4 Tustin Foothills CDP 075703 1 343 2224 15.4 Aliso Viejo CDP 062639 1 178 1165 15.3 Fullerton city 001601 3 159 1038 15.3 Huntington Beach city 099514 3 194 1272 15.3 Newport Beach city 062702 3 169 1102 15.3 Irvine city 052421 4 62 408 15.2 Lake Forest city 052427 2 371 2446 15.2 Irvine city 052520 4 194 1287 15.1 Anaheim city 075813 1 59 394 15.0 Dana Point city 042201 4 102 680 15.0 Irvine city 062631 2 116 771 15.0 Rossmoor CDP 110006 2 226 1503 15.0 Tustin Foothills CDP 075606 5 33 220 15.0 Villa Park city 075809 1 152 1010 15.0 Brea city 001506 2 320 2147 14.9 Laguna Beach city 062604 3 63 424 14.9 Yorba Linda city 021829 1 315 2108 14.9 Fountain Valley city 099230 1 293 1985 14.8 Huntington Beach city 099240 4 117 789 14.8 Irvine city 052527 2 439 2964 14.8 Rossmoor CDP 110008 3 204 1381 14.8 Anaheim city 021903 2 203 1384 14.7 Anaheim city 021924 1 640 4357 14.7 Dana Point city 042311 2 132 899 14.7 063103 1 109 742 14.7 Irvine city 052522 4 115 787 14.6 Laguna Beach city 062620 3 127 869 14.6 Lake Forest city 052416 3 194 1333 14.6 Irvine city 052421 3 183 1258 14.5 Placentia city 011718 1 111 766 14.5 Placentia city 011718 2 196 1352 14.5 Rancho Santa Margarita city 032034 3 1911 1316 14.5 Fountain Valley city 099232 4 1461 1014 14.4 337 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Huntington Beach city 099240 2 121 843 14.4 La Palma city 110115 3 207 1450 14.3 Laguna Hills city 042327 3 344 2414 14.3 Laguna Beach city 062620 1 171 1202 14.2 Fullerton city 001602 1 194 1377 14.1 Aliso Viejo CDP 062635 3 158 1131 14.0 Fullerton city 001706 4 109 781 14.0 Irvine city 052514 4 220 1575 14.0 Newport Beach city 063007 1 165 1180 14.0 Aliso Viejo CDP 062636 3 166 1198 13.9 Aliso Viejo CDP 062639 3 323 2323 13.9 Yorba Linda city 021824 1 156 1119 13.9 Newport Beach city 063103 1 51 370 13.8 Aliso Viejo CDP 062641 3 127 925 13.7 Buena Park city 110301 2 179 1303 13.7 Irvine city 052417 1 269 1966 13.7 Laguna Beach city 062620 2 189 1384 13.7 Aliso Viejo CDP 062634 5 177 1300 13.6 Aliso Viejo CDP 062639 4 101 740 13.6 Lake Forest city 052426 2 293 2162 13.6 Anaheim city 021921 2 408 3012 13.5 Huntington Beach city 099514 4 80 594 13.5 Irvine city 052527 1 407 3022 13.5 Laguna Beach city 062632 3 84 620 13.5 Huntington Beach city 099239 1 276 2055 13.4 Irvine city 052528 3 145 1085 13.4 Orange city 075605 4 180 1341 13.4 Brea city 021815 1 60 450 13.3 Buena Park city 086801 3 20 150 13.3 Huntington Beach city 099220 4 194 1458 13.3 Huntington Beach city 099238 2 288 2161 13.3 Fountain Valley city 099231 3 262 1981 13.2 Rancho Santa Margarita city 032043 2 200 1512 13.2 Cypress city 110011 2 169 1292 13.1 Irvine city 052511 2 99 753 13.1 Newport Beach city 063005 1 102 779 13.1 Rossmoor CDP 110007 4 228 1735 13.1 Villa Park city 075809 3 127 973 13.1 Anaheim city 021920 2 166 1279 13.0 Laguna Beach city 062619 2 93 717 13.0 Newport Beach city 063400 2 135 1040 13.0 Placentia city 011715 2 344 2640 13.0 Rancho Santa Margarita city 032053 1 320 2459 13.0 Huntington Beach city 099415 3 84 649 12.9 Orange city 075810 1 29 224 12.9 Villa Park city 075809 2 140 1089 12.9 Dana Point city 042339 2 48 374 12.8 Fountain Valley city 099229 1 221 1725 12.8 Newport Beach city 063010 3 173 1355 12.8 Newport Beach city 063601 3 78 609 12.8 Rancho Santa Margarita city 032053 2 2161 1686 12.8 338 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 021923 2 282 2221 12.7 Las Flores CDP 032053 4 252 1986 12.7 Tustin Foothills CDP 075702 1 115 909 12.7 Fullerton city 001706 1 113 894 12.6 Newport Beach city 062702 4 87 692 12.6 Newport Beach city 063006 1 63 505 12.5 Newport Beach city 063008 9 110 877 12.5 Coto de Caza CDP 032044 3 222 1789 12.4 Newport Beach city 063500 8 97 788 12.3 Orange city 075605 3 244 1978 12.3 Rancho Santa Margarita city 032049 3 195 1588 12.3 Newport Beach city 062643 1 85 694 12.2 Rancho Santa Margarita city 032049 1 294 2411 12.2 Orange city 021912 3 135 1115 12.1 Irvine city 052522 2 144 1202 12.0 Newport Beach city 062701 2 115 959 12.0 Orange city 021917 2 158 1314 12.0 Anaheim city 021920 4 230 1926 11.9 Huntington Beach city 099415 4 301 2531 11.9 Huntington Beach city 099513 1 140 1189 11.8 Anaheim city 021920 3 152 1307 11.6 Laguna Hills city 042327 1 210 1805 11.6 Laguna Hills city 042328 1 152 1312 11.6 Aliso Viejo CDP 062635 1 139 1209 11.5 Cypress city 110011 1 167 1456 11.5 Orange city 021912 2 152 1318 11.5 Orange city 021913 1 96 840 11.4 Anaheim city 021922 1 159 1401 11.3 Coto de Caza CDP 032045 2 189 1674 11.3 Lake Forest city 052428 3 101 893 11.3 Lake Forest city 052428 4 253 2248 11.3 Villa Park city 075810 1 101 892 11.3 Aliso Viejo CDP 062634 2 250 2226 11.2 Coto de Caza CDP 032045 1 131 1170 11.2 Yorba Linda city 021830 1 153 1372 11.2 Newport Beach city 063007 4 91 822 11.1 Rancho Santa Margarita city 032049 4 299 2699 11.1 Lake Forest city 052408 1 133 1208 11.0 Irvine city 052523 2 201 1841 10.9 Irvine city 052525 1 130 1191 10.9 Newport Beach city 062643 2 149 1361 10.9 Newport Beach city 062645 1 190 1746 10.9 Irvine city 052528 2 93 865 10.8 Newport Beach city 062702 2 99 928 10.7 Lake Forest city 052426 1 113 1071 10.6 Newport Beach city 062645 2 95 900 10.6 Newport Beach city 063004 4 139 1313 10.6 Rancho Santa Margarita city 032051 5 66 622 10.6 Anaheim city 021923 4 83 791 10.5 Placentia city 021810 1 461 439 10.5 Yorba Linda city 021825 2 1541 1469 10.5 339 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Anaheim city 021915 3 164 1573 10.4 Fullerton city 110605 4 106 1018 10.4 Huntington Beach city 099308 1 519 5044 10.3 Irvine city 052513 6 92 893 10.3 Orange city 075604 5 145 1404 10.3 Coto de Caza CDP 032044 2 184 1811 10.2 Laguna Beach city 062632 2 27 265 10.2 Yorba Linda city 021817 2 91 894 10.2 Yorba Linda city 021829 2 183 1795 10.2 Rancho Santa Margarita city 032042 1 379 3768 10.1 Santa Ana city 075806 3 42 417 10.1 Seal Beach city 110012 3 94 927 10.1 Huntington Beach city 099703 1 37 370 10.0 Irvine city 052506 2 149 1496 10.0 Irvine city 052523 3 148 1477 10.0 Irvine city 062631 3 81 810 10.0 Fullerton city 001602 2 99 998 9.9 Lake Forest city 052427 1 263 2658 9.9 Huntington Beach city 099514 1 145 1487 9.8 Newport Beach city 062645 4 67 682 9.8 Yorba Linda city 011717 1 22 226 9.7 Coto de Caza CDP 032046 4 110 1148 9.6 Tustin Foothills CDP 075605 2 189 1966 9.6 Anaheim city 021916 1 158 1667 9.5 Huntington Beach city 099246 2 178 1872 9.5 Irvine city 052417 3 183 1943 9.4 Orange city 075604 4 114 1213 9.4 Los Alamitos city 110108 1 112 1207 9.3 Lake Forest city 052411 3 108 1168 9.2 Yorba Linda city 021824 2 162 1765 9.2 Seal Beach city 110012 2 99 1085 9.1 Cypress city 110109 1 64 711 9.0 Irvine city 052525 4 142 1574 9.0 Newport Beach city 062645 3 97 1080 9.0 021917 1 44 496 8.9 Orange city 075814 2 73 829 8.8 Orange city 075816 2 120 1369 8.8 Yorba Linda city 021830 2 137 1564 8.8 021816 3 45 513 8.8 Rancho Santa Margarita city 032050 3 167 1924 8.7 Yorba Linda city 021810 3 84 991 8.5 Huntington Beach city 099246 1 102 1217 8.4 Newport Beach city 063010 1 162 1924 8.4 Newport Beach city 063010 5 76 907 8.4 Yorba Linda city 021830 3 180 2157 8.3 Huntington Beach city 099413 1 147 1802 8.2 Lake Forest city 052415 1 169 2064 8.2 Anaheim city 021921 1 118 1493 7.9 032041 1 46 580 7.9 032049 2 51 646 7.9 Newport Coast CDP 062643 3 101 1297 7.8 340 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Yorba Linda city 021829 3 116 1489 7.8 Fullerton city 001602 3 52 671 7.7 Coto de Caza CDP 032044 1 76 1009 7.5 Coto de Caza CDP 032046 2 117 1594 7.3 Huntington Beach city 099244 1 153 2099 7.3 Aliso Viejo CDP 062633 1 194 2704 7.2 Huntington Beach city 099514 5 69 961 7.2 Irvine city 052420 3 193 2746 7.0 Laguna Hills city 062647 3 59 839 7.0 Las Flores CDP 032056 4 112 1594 7.0 Orange city 021912 1 58 832 7.0 Aliso Viejo CDP 062638 2 132 1919 6.9 Portola Hills CDP 052428 1 90 1318 6.8 Yorba Linda city 021828 3 126 1845 6.8 Laguna Hills city 042333 1 129 1913 6.7 Rancho Santa Margarita city 032048 4 122 1823 6.7 Tustin Foothills CDP 075606 2 48 715 6.7 Irvine city 052420 2 140 2141 6.5 Yorba Linda city 021827 3 112 1724 6.5 032011 2 28 434 6.5 Aliso Viejo CDP 062633 2 58 914 6.3 Irvine city 052421 2 84 1331 6.3 Rossmoor CDP 110007 3 58 923 6.3 Yorba Linda city 021828 2 81 1359 6.0 Tustin Foothills CDP 075604 2 89 1546 5.8 Tustin Foothills CDP 075606 1 60 1047 5.7 Irvine city 062631 1 63 1138 5.5 Irvine city 052522 3 33 615 5.4 Newport Beach city 062644 1 86 1599 5.4 Huntington Beach city 099514 2 80 1507 5.3 Placentia city 021815 1 9 174 5.2 021816 2 20 382 5.2 075807 2 6 115 5.2 Irvine city 052526 1 31 622 5.0 Stanton city 110113 1 19 388 4.9 Irvine city 052420 1 123 2551 4.8 Dana Point city 042324 2 46 996 4.6 Coto de Caza CDP 032044 4 63 1447 4.4 Irvine city 052421 1 78 1823 4.3 Laguna Hills city 042333 2 109 2514 4.3 Rancho Santa Margarita city 032042 3 59 1365 4.3 Anaheim city 021922 3 38 922 4.1 Rancho Santa Margarita city 032050 4 31 786 3.9 Tustin Foothills CDP 075606 3 40 1038 3.9 Lake Forest city 052408 3 59 1551 3.8 Yorba Linda city 021812 1 32 834 3.8 Huntington Beach city 099415 2 43 1231 3.5 Rancho Santa Margarita city 032043 1 96 2775 3.5 062604 3 351 1 042 3.4 Yorba Linda city 021828 1 47 1501 3.1 Rancho Santa Margarita city 032056 1 221 803 2.7 S41 Place Name Census Tract Block Group # Low /Mod Total Population Low /Mod% Irvine city 062631 4 20 822 2.4 Las Flores CDP 032056 3 35 2072 1.7 Brea city 021814 3 9 1036 0.9 Lake Forest city 052426 3 8 1397 0.6 Anaheim city 021813 9 0 10 0.0 Anaheim city 021923 2 0 342 0.0 Anaheim city 075813 3 0 106 0.0 Coto de Caza CDP 032046 3 0 189 0.0 Coto de Caza CDP 032046 1 0 756 0.0 Coto de Caza CDP 032046 3 0 470 0.0 Cypress city 110010 3 0 75 0.0 Garden Grove city 088904 1 0 125 0.0 Garden Grove city 110010 2 0 157 0.0 Irvine city 052518 1 0 2 0.0 Newport Beach city 062610 1 0 7 0.0 Newport Beach city 062645 1 0 416 0.0 Orange city 021915 2 0 85 0.0 Orange city 075810 3 0 60 0.0 Villa Park city 075811 1 0 79 0.0 Villa Park city 075813 1 0 28 0.0 Villa Park city 075814 2 0 58 0.0 Yorba Linda city 021823 2 0 338 0.0 Yorba Linda city 021827 1 0 520 0.0 001707 2 0 184 0.0 021912 3 0 95 0.0 052404 1 0 20 0.0 052426 1 0 36 0.0 063102 3 0 64 0.0 075604 4 0 34 0.0 087801 3 01 22 0.0 Technical Appendix D 2008 Home Mortgage Disclosure Act Data for Orange County �4S Table D -1 Orange County Disposition of Loan Applications By Race /Ethnicity — 2008 FHA, FSA/RHS and VA Home Purchase Loans Loans Originated Applications Approved, but Not Accepted Applications Denied Total Applications Percent Denied American Indian /Alaska Native 29 4 9 42 21.4% Asian 238 28 80 346 23.1% Black or African American 64 13 20 97 20.6% Nat. Hawaiian /Other Pacific Isl. 41 4 8 53 15.1% White 2,408 313 671 3,392 19.8% Two or More Races 4 0 1 5 20.0% Joint (White/Minority Race 104 14 28 146 19.2% Race Not Available 275 54 130 459 28.3% Total 3,163 430 947 4,540 20.9% Hispanic or Latino 795 104 340 1,239 27.4% Joint (Hispanic /Latino & Non Hispanic /Latino ) 167 16 29 212 13.7% Conventional Home Purchase Loans Loans Originated Applications Approved, but Not Accepted Applications Denied Total Applications Percent Denied American Indian /Alaska Native 74 20 46 140 32.9% Asian 4,824 979 1,261 7,064 17.9% Black or African American 117 30 56 203 27.6% Nat. Hawaiian /Other Pacific Isl. 108 21 34 163 20.9% White 10,917 2,360 3,685 16,962 21.7% Two or More Races 20 1 5 26 19.2% Joint (White/Minority Race 458 72 109 639 17.1% Race Not Available 2,515 644 1,011 4,170 24.2% Total 19,033 4,127 6,207 29,367 21.1% Hispanic or Latino 1,788 690 1,181 3,659 32.3% Joint (Hispanic /Latino & Non Hispanic /Latino) 411 72 111 594 18.7% mjzji Table D -1 continued Orange County Disposition of Loan Applications By Race /Ethnicity — 2008 Refinance Loan Applications Loans Originated Applications Approved, but Not Accepted Applications Denied Total Applications Percent Denied American Indian /Alaska Native 123 48 408 579 70.5% Asian 2,686 763 1,604 5,053 31.7% Black or African American 160 58 242 460 52.6% Nat. Hawaiian /Other Pacific Isl. 175 44 223 442 50.5% White 18,419 4,302 10,791 33,512 32.2% Two or More Races 29 1 24 54 44.4% Joint (White/Minority Race 490 87 311 888 35.0% Race Not Available 5,037 1,374 3,407 9,818 34.7% Total 27,119 6,677 17,010 50,806 33.5% Hispanic or Latino 2,902 1,178 3,651 7,731 47.2% Joint (Hispanic /Latino & Non Hispanic /Latino ) 647 113 398 1,158 34.4% Home Improvement Loans Loans Originated Applications Approved, but Not Accepted Applications Denied Total Applications Percent Denied American Indian /Alaska Native 39 7 100 146 68.5% Asian 189 47 242 478 50.6% Black or African American 24 4 45 73 61.6% Nat. Hawaiian /Other Pacific Isl. 10 4 25 39 64.1% White 1,848 336 1,409 3,593 39.2% Two or More Races 0 0 3 3 100.0% Joint (White/Minority Race 45 5 45 95 47.4% Race Not Available 722 222 633 1,577 40.1% Total 2,877 625 2,502 6,004 41.7% Hispanic or Latino 342 96 556 994 55.9% Joint (Hispanic /Latino & Non Hispanic /Latino) 88 9 64 161 39.8% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 4 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 4 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 4 -3 Disposition of Applications to Refinance Loans on 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 4-4 Disposition of Applications for Home Improvement Loans 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Table construction by Castaneda & Associates S45 Table D -2 Orange County Disposition of FHA Loan Applications By Race /Ethnicity -2004 and 2008 Race/Ethnicity Loans Originated App. Approved But Not Accepted Applications Denied Total Applications Percent Denied 2004 2008 2004 2008 2004 2008 2004 2008 2004 2008 White, Non Hispanic 67 1,613 0 209 4 331 71 2,153 5.6% 15.4% Hispanic 79 795 8 104 18 340 105 1,239 17.1% 27.4% Asian 14 238 3 28 3 80 20 346 15.0% 23.1% American Indian /Alaska Native 10 29 0 4 0 9 10 42 0.0% 21.4% Black or African American 6 64 0 13 1 20 7 97 14.3% 20.6% Nat. Hawaiian/Other Pac.ISI. 3 41 1 4 0 8 4 53 0.0% 15.1% 2 or More Minority Races 0 4 0 0 2 1 2 5 100.0% 20.0% Joint White/Minority 7 104 0 14 1 28 8 146 12.5% 19.2% Race Not Available 48 275 12 54 14 130 74 459 18.9% 28.3% Subtotal 234 3,163 24 430 43 947 301 4,540 14.3% 20.9% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 4 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2004 and 2008 Table construction by Castaneda & Associates OJIM Table D -3 Orange County Disposition of Conventional Loan Applications By Race /Ethnicity -2004 and 2008 Race/Ethnicity Loans Originated App. Approved But Not Accepted Applications Denied Total Applications Percent Denied 2004 2008 2004 2008 2004 2008 2004 2008 2004 2008 White, Non Hispanic 23,785 9,129 3,806 1,670 3,871 2,504 31,462 13,303 12.3% 18.8% Hispanic 12,275 1,788 2,382 690 3,868 1,181 18,525 3,659 20.9% 32.3% Asian 8,501 4,824 2,004 979 1,911 1,261 12,416 7,064 15.4% 17.9% American Indian /Alaska Native 899 74 118 20 219 46 1,236 140 17.7% 32.9% Black or African American 603 117 94 30 216 56 913 203 23.7% 27.6% Nat. Hawaiian /Other Pac. Isl. 611 108 129 21 204 34 944 163 21.6% 20.9% 2 or More Minority Races 57 20 16 1 15 5 88 26 17.0% 19.2% Joint White/Minority 1,005 458 202 72 167 109 1,374 639 12.2% 17.1% Race Not Available 12,041 2,515 3,523 644 4,081 1,011 19,645 4,170 20.8% 24.2% Subtotal 59,777 19,033 12,274 4,127 14,552 6,207 86,603 29,367 16.8% 21.1% Source: Aggregate Table 4 -2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2004 and 2008 Table construction by Castaneda & Associates 347 Table D -4 Orange County FHA/VA Denial Rates by Income and Race /Ethnicity — 2008 Income Category Loans Ori inated App. Approved But Not Accepted Applications Denied Total Applications Percent Denied Very Low White, Non Hispanic 19 1 5 25 20.0% Hispanic 40 1 20 61 32.8% Asian 2 0 1 3 33.3% American Indian /Alaska Native 0 0 0 0 0.0% Black or African American 1 0 0 1 0.0% Nat. Hawaiian /Other Pac. IsI. 1 0 0 1 0.0% 2 or More Minority Races 0 0 0 0 0.0% Joint White/Minority 0 0 0 0 0.0% Race Not Available 3 4 11 18 61.1% Subtotal 66 6 37 109 33.9% Low White, Non Hispanic 182 17 40 239 16.7% Hispanic 179 23 96 298 32.2% Asian 28 4 16 48 33.3% American Indian /Alaska Native 10 0 4 14 28.6% Black or African American 17 1 4 22 18.2% Nat. Hawaiian /Other Pac. Isl. 2 0 1 3 33.3% 2 or More Minority Races 0 0 0 0 0.0% Joint White/Minority 8 1 5 14 35.7% Race Not Available 32 8 28 68 41.2% Subtotal 458 54 194 706 27.5% Moderate White, Non Hispanic 429 65 78 572 13.6% Hispanic 327 45 138 510 27.1 % Asian 87 11 21 119 17.6 % American Indian /Alaska Native 9 1 3 13 23.1% Black or African American 15 5 7 27 25.9% Nat. Hawaiian /Other Pac. Isl. 14 1 3 18 16.7% 2 or More Minority Races 2 0 1 3 33.3% Joint White/Minority 31 3 4 38 10.5% Race Not Available 99 12 37 148 25.0% Subtotal 1,013 143 292 1,448 20.2% 348 Table D -4 continued Orange County FHA/VA Denial Rates by Income and Race /Ethnicity — 2008 Income Category Loans Originate App. Approved But Not Accepted Applications Denied Total Applications Percent Denied Above Moderate White, Non Hispanic 940 115 183 1,238 14.8% Hispanic 234 34 73 341 21.4% Asian 118 13 38 169 22.5% American Indian /Alaska Native 10 3 2 15 13.3% Black or African American 28 7 9 44 20.5% Nat. Hawaiian /Other Pac. Isl. 23 3 3 29 10.3% 2 or More Minority Races 2 0 0 2 0.0% Joint White/Minority 56 10 18 84 21.4% Race Not Available 137 29 48 214 22.4% Subtotal 1,548 214 374 2,136 17.5% All Income Levels White, Non Hispanic 1,570 198 306 2,074 14.8% Hispanic 780 103 327 1,210 27.0% Asian 235 28 76 339 22.4% American Indian /Alaska Native 29 4 9 42 21.4% Black or African American 61 13 20 94 21.3% Nat. Hawaiian /Other Pac. Isl. 40 4 7 51 13.7% 2 or More Minority Races 4 0 1 5 20.0% Joint White/Minority 95 14 27 136 19.90/c Race Not Available 271 53 124 448 27.7% Subtotal 3,085 417 897 4,399 20.4% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5- 1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Table construction by Castaneda & Associates S -" Table D -5 Orange County Conventional Denial Rates by Income and Race /Ethnicity -2008 Income Category Loans Originated App. Approved But Not Accepted Applications Denied Total Applications Percent Denied Very Low White, Non Hispanic 192 47 79 318 24.8% Hispanic 76 32 88 196 44.9% Asian 100 20 59 179 33.0% American Indian /Alaska Native 1 1 3 5 60.0% Black or African American 5 3 4 12 33.3% Nat. Hawaiian /Other Pac. Isl. 6 1 4 11 36.4% 2 or More Minority Races 0 0 1 1 100.0% Joint White/Minority 3 1 1 5 20.6% Race Not Available 44 9 70 123 56.9% Subtotal 427 114 309 850 36.4% Low White, Non Hispanic 907 162 243 1,312 18.5% Hispanic 455 179 272 906 30.0% Asian 805 133 164 1,102 14.9% American Indian /Alaska Native 18 4 11 33 33.5% Black or African American 12 7 17 36 47.2% Nat. Hawaiian /Other Pac. Isl. 11 2 4 17 23.5% 2 or More Minority Races 4 0 2 6 33.3% Joint White/Minority 18 3 7 28 25.0% Race Not Available 239 93 128 460 27.8% Subtotal 2,469 583 848 3,900 21.7% Moderate White, Non Hispanic 1,942 326 446 2,714 16.4% Hispanic 600 244 413 1,257 32.9% Asian 1,372 265 313 1,950 16.1% American Indian /Alaska Native 13 3 14 30 467% Black or African American 44 6 12 62 19.4% Nat. Hawaiian /Other Pac. Isl. 33 9 8 50 16.0% 2 or More Minority Races 3 0 0 3 0.0% Joint White/Minority 70 12 21 103 20.4% Race Not Available 466 135 197 798 24.7% Subtotal 4,543 1,000 1,424 6,967 20.4% 350 Table D -5 continued Orange County Conventional Denial Rates by Income and Race /Ethnicity -2008 Income Category Loans Originate App. Approved But Not Accepted Applications Denied Total Applications Percent Denied Above Moderate White, Non Hispanic 6,032 1,131 1,689 8,852 19.1% Hispanic 647 224 400 1,271 31.5% Asian 2,463 549 694 3,706 18.7% American Indian /Alaska Native 42 12 16 70 22.9% Black or African American 56 14 22 92 23.9% Nat. Hawaiian /Other Pac. Isl. 57 9 17 83 20.5% 2 or More Minority Races 13 1 2 16 12.5% Joint White/Minority 358 53 78 489 16.0% Race Not Available 1,720 397 590 2,707 21.8% Subtotal 11,388 2,390 3,508 17,286 20.3% All Income Levels White, Non Hispanic 9,073 1,666 2,457 13,196 18.6% Hispanic 1,778 679 1,173 3,630 32.3% Asian 4,740 967 1,230 6,937 17.7% American Indian /Alaska Native 74 20 44 138 31.9% Black or African American 117 30 55 202 27.2% Nat. Hawaiian /Other Pac. Isl. 107 21 33 161 20.5% 2 or More Minority Races 20 1 5 26 19.2% Joint White/Minority 449 69 107 625 17.1% Race Not Available 2,469 634 985 4,088 24.1% Subtotal 18,827 4,087 6,089 29,003 21.0% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 5- 2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Income, Race and Ethnicity of Applicant, 2008 Table construction by Castaneda & Associates Notes: 1. APPLICANTS ARE SHOWN IN ONLY ONE RACE CATEGORY. FOR PURPOSES OF CATEGORIZATION, THE GENERAL RULE IS: THE RACE (INCLUDING SITUATIONS WHERE RACE WAS REPORTED AS NOT PROVIDED OR NOT APPLICABLE) OF THE APPLICATION IS CATEGORIZED BY THE RACE OF THE FIRST PERSON LISTED ON THE APPLICATION UNLESS THE "JOINT" RACE DEFINITION APPLIES. ('JOINT- MEANS ONE APPLICANT REPORTS A SINGLE RACIAL DESIGNATION OF 'WHITE" AND THE OTHER APPLICANT REPORTS ONE OR MORE MINORITY RACIAL DESIGNATIONS.) IF THE "JOINT" DEFINITION DOES NOT APPLY, THE RACE OF THE FIRST PERSON ON THE APPLICATION IS CATEGORIZED AS FOLLOWS: • THE REPORTED RACE WHEN A SINGLE RACIAL DESIGNATION IS REPORTED; OR • "2 OR MORE MINORITY RACES" W HEN TWO OR MORE MINORITY RACIAL DESIGNATIONS ARE REPORTED; OR • THE MINORITY RACE WHEN TWO RACIAL DESIGNATIONS ARE REPORTED AND ONE IS WHITE. 2. "NOT AVAILABLE" INCLUDES SITUATIONS WHERE INFORMATION WAS REPORTED AS NOT PROVIDED OR NOT APPLICABLE. FOR THE INCOME CLASSIFICATION, ZEROS AND INVALID CODES ARE INCLUDED. 3. APPLICANTS ARE SHOWN IN ONLY ONE ETHNICITY CATEGORY. FOR PURPOSES OF CATEGORIZATION, THE GENERAL RULE IS: THE ETHNICITY (INCLUDING SITUATIONS WHERE ETHNICITY WAS REPORTED AS NOT PROVIDED OR NOT APPLICABLE) OF THE APPLICATION IS CATEGORIZED BY THE ETHNICITY OF THE FIRST PERSON LISTED ON THE APPLICATION UNLESS THE "JOINT' ETHNICITY DEFINITION APPLIES. ( "JOINT" MEANS ONE APPLICANT REPORTS ETHNICITY AS HISPANIC OR LATINO AND THE OTHER APPLICANT REPORTS ETHNICITY AS NOT HISPANIC OR LATINO.) 4. "MINORITY STATUS" COMBINES INFORMATION REPORTED ON RACE AND ETHNICITY. "WHITE NON - HISPANIC" CONSISTS OF APPLICANTS OF WHITE RACE WHO ARE NOT OF HISPANIC OR LATINO ORIGIN. THE "OTHERS, INCLUDING HISPANIC" CATEGORY CONSISTS OF APPLICANTS OF MINORITY RACES OR HISPANIC OR LATINO ORIGIN. APPLICANTS NOT SHOWN ARE NON - HISPANICS WHERE RACE IS NOT AVAILABLE, WHITES WHERE ETHNICITY IS NOT AVAILABLE AND THOSE WHERE BOTH RACE AND ETHNICITY ARE NOT AVAILABLE. 5151 Table D -6 Orange County Disposition of FHA Loans by Characteristics of Census Tract in Which Property is Located — 2008 Income Category Loans Originated Application Approved But Not Accepted Applications Denied Total Applications Percent Denied Very Low Less Than 10% Minority 10 -19% Minority 20 -49% Minority 50 -79% Minority 80 -100% Minority 67 5 46 118 39.0 % Low Less Than 10% Minority 10 -19% Minority 20 -49% Minority 114 22 22 158 13.9% 50 -79% Minority 657 72 218 947 23.0% 80 -100% Minority 265 45 125 435 28.7% Moderate Less Than 10% Minority 11 1 4 16 25.0% 10 -19% Minority 18 51 9 1 32 28.1% 20 -49% Minority 739 96 182 1,017 17.9% 50 -79% Minority 384 491 94 527 17.8% 80 -100% Minority 25 21 11 38 28.9% Above Moderate Less Than 10% Minority 10 -19% Minority 222 37 56 315 17.8% 20 -49% Minority 639 93 176 908 19.4% 50 -79% Minority 22 2 4 28 14.3% 80 -100% Minority All Other Tracts 1 1 0.0% Total 1 3,163 4301 947 1 4,540 20.9% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 7 -1 Disposition of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Characteristics of Census Tract in Which Property is Located, 2008 Table construction by Castaneda & Associates Notes: "MINORITY" MEANS (1) ALL RACES OTHER THAN WHITE AND (2) WHITES OF HISPANIC OR LATINO ORIGIN THE VERY LOW- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS LESS THAN 50 PERCENT OF THE MEDIAN MSAIMD INCOME, BASED ON THE 2000 CENSUS OF POPULATION AND HOUSING. THE LOW- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS AT LEAST 50 PERCENT AND LESS THAN 80 PERCENT OF THE MEDIAN MSA/MD INCOME. THE MODERATE- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS AT LEAST 80 PERCENT AND LESS THAN 120 PERCENT OF THE MEDIAN MSAIMD INCOME. THE ABOVE MODERATE- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS 120 PERCENT OR MORE OF THE MEDIAN MSA/MD INCOME EXCLUDES CENSUS TRACTS WITH NO REPORTED INCOME 5152 Table D -7 Orange County Disposition of Conventional Loans by Characteristics of Census Tract in Which Property is Located — 2008 Income Category Loans Originated Application Approved But Not Accepted Applications Denied Total Applications Percent Denied Very Low Less Than 10% Minority 10 -19% Minority 20 -49% Minority 50 -79% Minority 80 -100% Minority 223 85 175 483 36.2% Low Less Than 10% Minority 74 2 2 78 2.6% 10 -19% Minority 45 6 15 66 22.7% 20 -49% Minority 526 114 148 788 18.8% 50 -79% Minority 2,583 608 932 4,123 22.6% 80-100% Minority 974 302 578 1,854 31.2% Moderate Less Than 10% Minority 149 271 28 1 204 13.7% 10 -19% Minority 361 73 151 585 25.8% 20 -49% Minority 3,764 705 1,166 5,635 20.7% 50 -79% Minority 1,736 3871 563 2,686 21.0% 80 -100% Minority 103 251 42 170 24.7% Above Moderate Less Than 10% Minority 234 60 103 397 25.9% 10 -19% Minority 2,689 601 872 4,162 21.0% 20 -49% Minority 5,287 1,066 1,349 7,702 17.5% 50 -79% Minority 283 65 83 431 19.3% 80 -100% Minority All Other Tracts 2 1 0 3 0.0% Total 1 19,033 4,1271 6,207 1 29,367 21.1% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 7- 2 Disposition of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Characteristics of Census Tract in Which Property is Located, 2008 Table construction by Castaneda & Associates Notes: "MINORITY" MEANS (1) ALL RACES OTHER THAN WHITE AND (2) WHITES OF HISPANIC OR LATINO ORIGIN THE VERY LOW- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS LESS THAN 50 PERCENT OF THE MEDIAN MSAIMD INCOME, BASED ON THE 2000 CENSUS OF POPULATION AND HOUSING. THE LOW- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS AT LEAST 50 PERCENT AND LESS THAN 80 PERCENT OF THE MEDIAN MSA/MD INCOME. THE MODERATE- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS AT LEAST 80 PERCENT AND LESS THAN 120 PERCENT OF THE MEDIAN MSAIMD INCOME. THE ABOVE MODERATE- INCOME CATEGORY CONSISTS OF CENSUS TRACTS WHERE THE MEDIAN FAMILY INCOME IS 120 PERCENT OR MORE OF THE MEDIAN MSA/MD INCOME EXCLUDES CENSUS TRACTS WITH NO REPORTED INCOME 3153 Table D -8 Orange County Reasons for Loan Denial by Race /Ethnicity - 2008 _ FHA, FSA/RHS Home Purchase Loans Race/Ethnicity Debt -to- Income Ratio Employ. History Credit History Collateral Insufficient Cash Unverifiable Information Credit App. Incomplete Mortgage Insurance Denied Other Total American Indian /Alaska Native 40.0% 0.0% 20.0% 20.0% 0.0% 0.0% 10.0% 0.0% 10.0% 10 Asian 44.2% 2.3% 15.1% 10.5% 2.3% 7.0% 4.7% 0.0% 14.0% 86 Black or African American 27.3% 0.0% 22.7% 18.2% 4.5% 4.5% 4.5% 0.0% 18.2% 22 Nat. Hawaiian /Other Pacific Isl. 57.1% 0.0% 14.3% 0.0% 0.0% 0.0% 14.3% 0.0% 14.3% 7 White 37.9% 2.3% 13.3% 10.3% 3.4% 5.0% 6.4% 0.3% 21.1% 700 2 or More Races 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0 Joint (White/Minority Race 32.10 7.1% 7.1% 3.60 7.10 0.706 10.7% 0.0% 21.4% 28 Race Not Available 39.2% 2.8% 14.0% 6.3% 4.9% 7.0% 11.2% 0.0% 14.7% 143 Hispanic or Latino 40.2% 1.4% 16.0% 8.7% 3.4% 5.6% 4.8% 0.3% 19.7% 356 Joint (Hispanic /Latino & Non- Hispanic/Latino 32.1% 3.6% 17.9% 7.1% 0.0% 7.1% 0.0% 0.0% 32.1% 28 Conventional Race/Ethnicity Debt -to- Income Ratio Employ. History Credit History Collateral Insufficient Cash Unverifiable Information Credit App. Incomplete Mortgage Insurance Denied Other Total American Indian /Alaska Native 26.4% 0.0% 5.7% 7.5% 17.0% 9.4% 7.5% 0.0% 26.4% 53 Asian 20.9% 2.0% 6.6% 15.4% 5.3% 11.3% 15.1% 0.6% 22.9% 1,420 Black or African American 23.3% 0.0% 15.0% 6.7% 3.3% 6.7% 20.0% 1.7% 23.3% 60 Nat. Hawaiian /Other Pacific Isl. 39.4% 3.0% 3.0% 9.1% 3.0% 3.0% 6.1% 0.0% 33.3% 33 White 23.1% 1.5% 8.5% 14.4% 5.2% 10.2% 12.6% 1.2% 23.3% 4,086 2 or More Races 40.0% 0.0% 20.0% 0.0% 0.0% 0.0% 20.0% 0.0% 20.0% 5 Joint White /Minorit Race 22.9% 1.7% 3.4% 19.5% 3.4% 10.2% 12.7% 0.8% 25.4% 118 Race Not Available 24.3% 2.2% 8.8% 12.1% 5.7% 11.8% 11.3% 0.6% 23.2% 1,034 Hispanic or Latino 21.1% 1.0% 10.3% 13.5% 6.6% 11.1% 7.2% 1.6% 27.6% 1,252 Joint (Hispanic /Latino & Non- Hispanic/Latino 25.0% 0.8% 9.2% 13.3% 7.5% 5.8% 16.7% 0.8% 20.8% 120 354 Table D -8 continued Orange County Reasons for Loan Denial by Race /Ethnicity - 2008 Refinance Race/Ethnicity Debt -to- Income Ratio Employ. History Credit History Collateral Insufficient Cash Unverifiable Information Credit App. Incomplete Mortgage Insurance Denied Other Total American Indian /Alaska Native 31.5% 0.6% 14.3% 26.8% 1.8% 3.0% 6.0% 1.2% 14.9% 168 Asian 21.4% 1.3% 5.8% 31.2% 2.4% 6.9% 12.8% 0.2% 17.9% 1,458 Black or African American 31.6% 2.2% 14.7% 21.3% 2.9% 5.9% 3.7% 0.0% 17.6% 136 Nat. Hawaiian /Other Pacific Isl. 25.9% 2.1% 8.4% 37.1% 1.4% 7.7% 7.7% 0.7% 9.1% 143 White 24.5% 0.9% 10.5% 26.2% 2.6% 7.5% 10.7% 0.2% 16.9% 9,235 2 or More Races 22.2% 0.0% 0.0% 55.6% 0.0% 0.0% 0.0% 0.0% 22.2% 9 Joint (White/Minority Race 17.4% 0.0% 15.2% 31.3% 3.1% 4.9% 11.6% 0.0% 16.5% 224 Race Not Available 26.6% 1.0% 11.8% 25.8% 2.3% 7.3% 8.8% 0.2% 16.2% 3,131 Hispanic or Latino 28.1% 0.9% 12.2% 27.6% 2.7% 7.1% 6.8% 0.3% 14.2% 3,064 Joint (Hispanic /Latino & Non - Hispanic /Latino 26.0% 1.7% 12.5% 28.7% 2.4% 3.7% 8.8% 0.3% 15.9% 296 3155 Table D -8 continued Orange County Reasons for Loan Denial by Race /Ethnicity - 2008 Home Improvement Race/Ethnicity Debt -to- Income Ratio Employ. History Credit History Collateral Insufficient Cash Unverifiable Information Credit App. Incomplete Mortgage Insurance Denied Other Total American Indian /Alaska Native 27.0% 0.0% 40.5% 10.8% 0.0% 2.7% 10.8% 0.0% 8.1% 37 Asian 25.7% 1.1% 20.2% 21.3% 1.1% 9.8% 2.7% 0.0% 18.0% 183 Black or African American 28.6% 0.0% 52.4% 4.8% 4.8% 0.0% 4.8% 0.0% 4.8% 21 Nat. Hawaiian /Other Pacific Isl. 27.8% 0.0% 22.2% 22.2% 0.0% 5.6% 5.6% 0.0% 16.7% 18 White 28.9% 0.9% 23.4% 20.3% 1.2% 5.0% 6.4% 0.0% 13.9% 926 2 or More Races 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1 Joint White /Minoru Race 22.7% 0.0% 13.6% 40.9% 0.0% 0.0% 9.1% 0.0% 13.6% 22 Race Not Available 14.9% 0.2% 55.6% 9.9% 1.0% 3.6% 3.2% 0.0% 11.6% 585 Hispanic or Latino 33.1% 0.6% 28.0% 18.3% 0.9% 3.4% 5.4% 0.0% 10.3% 350 Joint (Hispanic /Latino & Non - Hispanic /Latino 17.2% 0.0% 34.5% 34.5% 3.4% 0.0% 6.9% 0.0% 3.4% 29 Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 8 -1 Reasons for Denial of Applications for FHA, FSA/RHS and VA Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 8 -2 Reasons for Denial of Applications for Conventional Home - Purchase Loans, 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 8 -3 Reasons for Denial of Applications to Refinance Loans on 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Aggregate Table 8 -4 Reasons for Denial of Applications for Home Improvement Loans 1 to 4 Family and Manufactured Home Dwellings, by Race, Ethnicity, Gender and Income of Applicant, 2008. Table construction by Castaneda & Associates 315(0 Technical Appendix E Loan Denial Rates for Census Tracts with a High Number of Loan Applications 357 Table E -1 Entitlement Cities FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 755.15 Irvine 79% 51.4% 755.15 Santa Ana 79% 51.4% 877.01 Anaheim 54% 43.8% 752.02 Santa Ana 95% 41.2% 868.02 Anaheim 67% 40.7% 762.01 Orange 34% 36.4% 742.00 Santa Ana 95% 36.4% 320.51 Rancho Santa Margarita 32% 35.3% 870.02 Anaheim 59% 34.6% 864.04 Anaheim 82% 33.3% 891.02 Garden Grove 82% 33.3% 750.02 Santa Ana 96% 33.3% 891.02 Santa Ana 82% 33.3% 320.14 Lake Forest 47% 33.3% 741.06 Santa Ana 62% 30.4% 878.02 Anaheim 65% 29.4% 1105.00 Buena Park 79% 27.8% 320.53 Rancho Santa Margarita 23% 27.3% 992.27 Fountain Valle 61% 26.7% 881.01 Garden Grove 45% 26.7% 749.01 Santa Ana 98% 26.7% 741.03 Santa Ana 93% 25.0% 863.01 Anaheim 74% 25.0% 219.13 Orange 70% 25.0% 1103.02 Buena Park 63% 23.8% 320.29 Lake Forest 30% 23.5% 320.27 Lake Forest 44% 23.3% 868.01 Anaheim 50% 22.7% 868.01 Buena Park 50% 22.7% 864.07 Anaheim 58% 22.2% 747.02 Santa Ana 96% 22.2% 525.25 Irvine 42% 22.2% 320.50 Rancho Santa Margarita 27% 21.9% 741.02 Santa Ana 93% 21.1% 884.03 Anaheim 74% 20.6% 884.03 Garden Grove 74% 20.6% 876.02 Anaheim 62% 20.0% 876.02 Garden Grove 62% 20.0% 524.11 Lake Forest 49% 18.8% 524.22 Lake Forest 26% 18.8% 3158 Table E -1 continued Entitlement Cities FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Denied 754.05 Santa Ana 18.8% 320.56 Rancho Santa Margarita q49% 18.5% 746.01 Santa Ana 18.2% 219.23 Anaheim 17.6% 754.01 Santa Ana 17.6% 867.01 Anaheim 65% 16.7% 867.01 Fullerton 65% 16.7% 524.16 Lake Forest 34% 16.7% 762.02 Orange 39% 16.7% 878.06 Anaheim 78% 16.7% 878.06 Garden Grove 78% 16.7% 866.01 Anaheim 87% 15.8% 754.03 Santa Ana 62% 15.7% 1102.03 Anaheim 41% 15.0% 1102.03 Buena Park 41% 15.0% 320.54 Rancho Santa Margarita 28% 14.3% 888.01 Garden Grove 81% 13.3% 740.06 Santa Ana 75% 12.9% 863.03 Anaheim 53% 12.8% 874.01 Anaheim 72% 12.1% 1103.01 Buena Park 56% 11.8% 218.12 Anaheim 33% 11.1% 760.00 Orange 51% 10.7% 760.00 Santa Ana 51% 10.7% 740.04 Santa Ana 73% 10.5% 13.03 La Habra 68% 10.0% 1102.01 Anaheim 53% 10.0% 1102.01 Buena Park 53% 10.0% 877.04 Anaheim 58% 8.0% 871.03 Anaheim 58% 5.9% 1103.04 Buena Park 55% 5.6% 1104.01 Buena Park 51% 5.6% 762.08 Orange 30% 4.0% 867.02 Anaheim 75% 0.0% 320.55 Rancho Santa Margarita 37% 0.0% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates 3� Table E -2 Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 746.02 Santa Ana 97% 44.2% 752.02 Santa Ana 95% 44.2% 742.00 Santa Ana 95% 41.6% 749.01 Santa Ana 98% 41.3% 740.03 Santa Ana 95% 40.4% 998.01 Westminster 67% 38.9% 873.00 Anaheim 85% 37.7% 320.55 Rancho Santa Margarita 37% 37.5% 747.01 Santa Ana 98% 36.8% 627.02 Newport Beach 8% 36.4% 750.02 Santa Ana 96% 36.2% 747.02 Santa Ana 96% 36.0% 864.07 Anaheim 58% 35.6% 320.54 Rancho Santa Margarita 28% 35.1% 635.00 Newport Beach 11% 34.6% 320.51 Rancho Santa Margarita 32% 34.1% 890.01 Garden Grove 90% 33.8% 890.01 Santa Ana 90% 33.8% 754.03 Santa Ana 62% 33.3% 1105.00 Buena Park 79% 33.3% 996.01 Westminster 73% 32.8% 889.02 Garden Grove 81% 32.7% 891.02 Garden Grove 82% 32.5% 891.02 Santa Ana 82% 32.5% 872.00 Anaheim 65% 32.1% 994.16 Huntington Beach 24% 31.4% 761.03 Garden Grove 78% 30.5% 761.03 Orange 78% 30.5% 320.53 Rancho Santa Margarita 23% 30.1% 626.43 Newport Beach 22% 29.9% 320.50 Rancho Santa Margarita 27% 29.7% 762.06 Orange 32% 29.4% 876.02 Anaheim 62% 29.3% 876.02 Garden Grove 62% 29.3% 320.14 Lake Forest 47% 28.9% 864.04 Anaheim 82% 28.8% 219.18 Orange 38% 28.3% 993.10 Huntington Beach 20% 28.0% 762.08 Orange 30% 27.8% 878.05 Anaheim 68% 27.8% Soo Table E -2 continued Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 740.06 Santa Ana 75% 27.5% 992.24 Fountain Valle 42% 27.3% 992.27 Fountain Valle 61% 26.9% 626.45 Newport Beach 17% 26.8% 741.07 Santa Ana 43% 26.8% 997.03 Huntington Beach 48% 26.0% 997.03 Westminster 48% 26.0% 996.03 Huntington Beach 30% 25.9% 996.03 Westminster 30% 25.9% 524.10 Irvine 34% 25.9% 524.10 Lake Forest 34% 25.9% 636.03 Newport Beach 14% 25.7% 1104.01 Buena Park 51% 25.4% 758.13 Orange 36% 25.0% 1102.01 Anaheim 53% 25.0% 1102.01 Buena Park 53% 25.0% 741.02 Santa Ana 93% 24.7% 626.44 Newport Beach 13% 24.7% 880.01 Garden Grove 61% 24.6% 888.01 Garden Grove 81% 24.6% 884.01 Garden Grove 58% 24.2% 219.21 Anaheim 35% 24.1% 993.11 Huntington Beach 18% 23.9% 867.02 Anaheim 75% 23.9% 740.04 Santa Ana 73% 23.6% 877.04 Anaheim 58% 23.5% 1102.03 Anaheim 41% 23.5% 1102.03 Buena Park 41% 23.5% 759.01 Orange 50% 23.3% 890.04 Santa Ana 89% 23.3% 15.01 La Habra 27% 23.2% 525.15 Irvine 60% 23.2% 877.01 Anaheim 54% 23.1% 748.03 Santa Ana 92% 23.0% 320.29 Lake Forest 30% 22.7% 885.02 Garden Grove 75% 22.6% 762.01 Orange 34% 22.2% 756.04 Orange 22% 22.2% 762.02 Orange 39% 22.2% 117.07 Fullerton 29% 22.1% Sol Table E -2 continued Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 994.08 Huntington Beach 22% 22.0% 524.16 Lake Forest 34% 22.0% 758.15 Orange 34% 22.0% 15.05 Fullerton 31% 22.0% 755.15 Irvine 79% 21.8% 755.15 Santa Ana 79% 21.8% 741.06 Santa Ana 62% 21.7% 883.01 Garden Grove 58% 21.6% 320.27 Lake Forest 44% 21.5% 218.12 Anaheim 33% 21.0% 760.00 Orange 51% 20.9% 760.00 Santa Ana 51% 20.9% 1103.02 Buena Park 63% 20.8% 885.01 Garden Grove 74% 20.8% 1102.02 Anaheim 61% 20.7% 1102.02 Buena Park 61% 20.7% 320.34 Rancho Santa Margarita 23% 20.6% 992.15 Huntington Beach 30% 20.3% 626.04 Irvine 11% 20.3% 110.00 Fullerton 40% 20.3% 863.03 Anaheim 53% 20.0% 993.06 Huntington Beach 20% 20.0 % 992.32 Fountain Valle 29% 20.0% 886.01 Garden Grove 74% 20.0% 320.49 Rancho Santa Margarita 24% 20.0% 867.01 Anaheim 65% 19.7% 867.01 Fullerton 65% 19.7% 887.02 Garden Grove 76% 19.7% 863.01 Anaheim 74% 19.7% 869.03 Anaheim 63% 19.6% 995.14 Huntington Beach 17% 19.5% 746.01 Santa Ana 93% 19.5% 524.08 Irvine 22% 19.4% 524.08 Lake Forest 22% 19.4% 626.12 Irvine 31% 19.4% 1103.01 Buena Park 56% 18.9% 871.03 Anaheim 58% 18.8% 320.43 Rancho Santa Margarita 15% 18.8% 219.03 Anaheim 42% 18.6% 993.09 Huntington Beach 15% 18.6% 302 Table E -2 continued Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 994.15 Huntington Beach 20% 18.5% 997.02 Huntington Beach 64% 18.5% 997.02 Westminster 64% 18.5% 525.27 Irvine 53% 18.5% 524.18 Irvine 48% 18.4% 634.00 Newport Beach 7% 17.9% 751.00 Santa Ana 78% 17.7% 883.02 Anaheim 47% 17.6% 883.02 Garden Grove 47% 17.6% 320.48 Rancho Santa Margarita 24% 17.6% 756.05 Orange 27% 17.3% 17.04 Fullerton 48% 17.3% 116.02 Anaheim 83% 17.3% 116.02 Fullerton 83% 17.3% 868.02 Anaheim 67% 17.2% 874.01 Anaheim 72% 16.8% 320.56 Rancho Santa Margarita 28% 16.5% 994.13 Huntington Beach 33% 16.5% 626.10 Irvine 41% 16.4% 626.10 Newport Beach 41% 16.49/a 994.17 Huntington Beach 20% 16.3% 525.17 Irvine 41% 16.2 % 630.07 Newport Beach 12% 16.0% 524.21 Irvine 28% 15.9% 1106.04 Buena Park 55% 15.7% 525.25 Irvine 42% 15.3% 219.23 Anaheim 37% 15.0% 13.03 La Habra 68% 15.0% 13.01 La Habra 43% 14.9% 524.25 Lake Forest 32% 14.9% 884.03 Anaheim 74% 14.6% 884.03 Garden Grove 74% 14.6% 888.02 Garden Grove 76% 14.3% 888.02 Westminster 76% 14.3% 524.17 Irvine 36% 14.3% 219.22 Anaheim 36% 14.3% 524.24 Lake Forest 33% 14.0% 992.31 Fountain Valle 30% 14.0% 16.01 Fullerton 26% 13.7% 16.01 La Habra 26% 13.7% 3003 Table E -2 continued Entitlement Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied — 2008 Census Tract City Percent Minority Percent Denied 992.43 Huntington Beach 19% 13.0% 993.08 Huntington Beach 22% 12.9% 219.13 Orange 70% 12.7% 219.12 Anaheim 19% 12.5% 219.12 Orange 19% 12.5% 889.01 Garden Grove 77% 12.5% 889.01 Westminster 77% 12.5% 16.02 Fullerton 25% 12.0% 1106.03 Buena Park 78% 11.9% 524.20 Irvine 50% 11.9% 219.20 Anaheim 26% 11.7% 17.07 Fullerton 69% 11.3% 17.07 La Habra 69% 11.3% 879.01 Garden Grove 72% 9.2% 992.44 Huntington Beach 12% 7.8% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates WON Table E -3 Urban County Cities FHA Loan Application Denial Rates by Census Tract With 15+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 877.01 Unincorporated 54% 43.8% 423.10 Dana Point 37% 30.8% 878.02 Stanton 65% 29.4% 320.53 Unincorporated 23% 27.3% 881.01 Stanton 45% 26.7% 626.38 Aliso Viejo 29% 25.0% 219.13 Unincorporated 70% 25.0% 626.35 Aliso Viejo 28% 22.2% 626.35 Laguna Woods 28% 22.2% 320.23 Unincorporated 16% 19.4% 524.22 Unincorporated 26% 18.8% 320.56 Unincorporated 28% 18.5% 320.52 Unincorporated 13% 17.8% 867.01 Unincorporated 65% 16.7% 762.02 Unincorporated 39% 16.7% 878.06 Stanton 78% 16.7% 878.06 Unincorporated 78% 16.7% 1102.03 Stanton 41% 15.0% 524.27 Unincorporated 32% 13.3% 1103.01 La Palma 56% 11.8% 218.21 Placentia 46% 11.8% 218.12 Unincorporated 33% 11.1% 218.12 Yorba Linda 33% 11.1% 626.25 Aliso Viejo 39% 8.6% 626.25 Laguna Hills 39% 8.6% 626.25 Laguna Woods 39% 8.6% 626.37 Aliso Viejo 27% 6.3% 423.20 Aliso Viejo 33% 4.3% 423.20 Laguna Hills 33% 4.3% 762.08 Unincorporated 30% 4.0% 626.39 Aliso Viejo 30% 0.0% 524.28 Unincorporated 22% 0.0% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates S05 Table E -4 Urban County Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 218.27 Yorba Linda 31% 34.9% 626.21 Laguna Hills 30% 33.9% 626.21 Laguna Woods 30% 33.9% 422.01 Dana Point 20% 33.3% 626.43 Unincorporated 22% 29.9% 218.02 Yorba Linda 25% 28.4% 219.18 Unincorporated 38% 28.3% 762.08 Unincorporated 30% 27.8% 878.05 Stanton 68% 27.8% 878.05 Unincorporated 68% 27.8% 626.20 Laguna Beach 11% 27.1% 626.45 Unincorporated 17% 26.8% 218.16 Unincorporated 17% 26.2% 218.16 Yorba Linda 17% 26.2% 997.03 Unincorporated 48% 26.0% 1101.02 Cypress 56% 25.4% 1101.02 La Palma 56% 25.4% 758.13 Villa Park 36% 25.0% 881.01 Stanton 45% 24.6% 320.23 orated 16% 24.6% 423.35 Hills *Dana 29% 24.5% 423.35 porated 29% 24.5% 423.24 oint 12% 24.1% 423.23 Dana Point 12% 24.0% 423.07 Laguna Hills 36% 23.7% 1102.03 Stanton 41% 23.5% 423.05 Dana Point 9% 23.5% 423.05 Laguna Beach 9% 23.5% 320.52 Unincorporated 13% 23.4% 15.01 Brea 27% 23.2% 15.01 Unincorporated 27% 23.2% 877.01 Unincorporated 54% 23.1% 423.38 Dana Point 14% 22.7% 626.22 Laguna Hills 11% 22.7% 626.22 Laguna Woods 11% 22.7% 218.21 Placentia 46% 22.7% 626.34 Aliso Vie'o 2606 22.2% 756.04 Unincorporated 22% 22.2% 762.02 Unincorporated 39% 22.2% 15.05 Brea 31% 22.0% Soo Table E -4 continued Urban County Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 320.53 Unincorporated 23% 21.4% 218.12 Unincorporated 33% 21.0% 218.12 Yorba Linda 33% 21.0% 1102.02 Cypress 61% 20.7% 524.27 Unincorporated 32% 20.4% 626.04 Laguna Beach 11% 20.3% 626.04 Unincorporated 11% 20.3% 320.49 Unincorporated 24% 20.0% 756.03 Unincorporated 22% 20.0% 867.01 Unincorporated 65% 19.7% 756.06 Unincorporated 24% 19.7% 218.22 Yorba Linda 21% 19.7% 117.15 Placentia 27% 19.6% 117.15 Unincorporated 27% 19.6% 423.10 Dana Point 37% 19.6% 1103.01 La Palma 56% 18.9% 626.19 Laguna Beach 9% 18.9% 631.02 Unincorporated 19% 18.5% 997.02 Unincorporated 64% 18.5% 524.26 Unincorporated 30% 17.6% 422.05 Dana Point 23% 17.5% 756.05 Unincorporated 27% 17.3% 320.46 Unincorporated 14% 17.3% 626.35 Aliso Viejo 28% 17.2% 626.38 Aliso Viejo 29% 17.2% 626.35 Laguna Woods 28% 17.2% 423.20 Aliso Viejo 33% 16.7% 423.20 Laguna Hills 33% 16.7% 320.56 Unincorporated 28% 16.5% 994.17 Unincorporated 20% 16.3% 1100.08 Seal Beach 17% 16.1% 1100.08 Unincorporated 17% 16.1% 524.21 Unincorporated 28% 15.9% 626.23 Laguna Beach 8% 15.7% 626.23 Laguna Hills 8% 15.7% 626.23 Laguna Woods 8% 15.7% 1106.04 Unincorporated 55% 15.7% 626.39 Aliso Viejo 30% 15.3% 218.15 Brea 20% 15.2% 218.15 Placentia 20% 15.2% S07 Table E -4 continued Urban County Cities Conventional Loan Application Denial Rates by Census Tract With 50+ Applications and by Percent Minority Rank Ordered by Percent Denied - 2008 Census Tract City Percent Minority Percent Denied 218.15 Unincorporated 20% 15.2% 218.15 Yorba Linda 20% 15.2% 626.25 Aliso Viejo 39% 14.3% 626.25 Laguna Hills 39% 14.3% 626.25 Laguna Woods 39% 14.3% 219.13 Unincorporated 70% 12.7% 626.41 Aliso Viejo 38% 12.5% 626.41 Laguna Woods 38% 12.5% 626.41 Unincorporated 38% 12.5% 219.12 Unincorporated 19% 12.5% 524.20 Unincorporated 50% 11.9% 320.44 Unincorporated 13% 11.8% 626.33 Aliso Viejo 26% 11.7% 17.07 Unincorporated 69% 11.3% 626.40 Aliso Viejo 27% 1 10.9% 879.01 Stanton 72% 9.2% 524.28 Unincorporated 22% 9.1% 626.37 Aliso Viejo 27% 7,7% 626.46 Laguna Woods 7% 1.4% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates m Technical Appendix F FHA and Conventional Loan Denial Rates by City and Census Tract 309 Table F -1 Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 116.02 Anaheim 83% 57% 9 1 3 13 23.1% 117.14 Anaheim 81% 56% 0 0 1 1 100.0% 117.20 Anaheim 93% 47% 2 0 3 5 60.0% 117.22 Anaheim 67% 74% 5 0 1 6 167% 218.07 Anaheim 28% 100% 7 1 0 8 0.0% 218.12 Anaheim 33% 109% 15 1 2 18 11.1% 218.13 Anaheim 74% 82% 1 0 0 1 0.0% 219.03 Anaheim 42% 118% 9 1 2 12 16.7% 219.05 Anaheim 29% 144% 11 0 2 13 15.4% 219.12 Anaheim 19% 194% 0 0 0 0 0.0% 219.15 Anaheim 33% 151% 4 1 3 8 37.5% 219.16 Anaheim 24% 171% 1 0 0 1 0.0% 219.19 Anaheim 26% 153% 4 0 0 4 0.0% 219.20 Anaheim 26% 160% 8 0 0 8 0.0% 219.21 Anaheim 35% 180% 0 0 1 1 100.0% 219.22 Anaheim 36% 1 127% 1 10 21 2 14 1 14.3% 219.23 Anaheim 1 37% 1 157% 11 31 3 17 17.6% 219.24 Anaheim 1 43% 1 145% 2 1 1 2 5 40.0% 761.01 Anaheim 1 63% 1 79% 8 01 5 13 38.5% 761.02 Anaheim 64% 69% 0 0 0 0 0.0% 863.01 Anaheim 74% 78% 12 0 4 16 25.0% 863.03 Anaheim 53 % 78% 30 4 5 39 12.8% 863.04 Anaheim 53% 93% 7 1 1 9 11.1% 863.05 Anaheim 44% 107% 8 0 2 10 20.0% 863.06 Anaheim 53% 92% 3 2 1 6 16.7% 864.02 Anaheim 68% 80% 12 1 1 14 7.1% 864.04 Anaheim 82% 71% 10 2 6 18 33.3% 864.05 Anaheim 83% 58% 7 1 4 12 33.3% 864.06 Anaheim 64% 74% 1 0 01 1 0.0% 864.07 Anaheim 58% 81% 17 4 61 27 22.2% 865.01 Anaheim 85% 57% 7 1 1 9 11.1% 865.02 Anaheim 92% 58% 6 3 5 14 35.7% 866.01 Anaheim 87% 53% 13 3 3 19 15.8% 867.01 Anaheim 65% 79% 24 1 5 30 167% 867.02 Anaheim 75% 61% 19 4 0 23 0.0% 868.01 Anaheim 50% 96% 17 0 5 22 22.7% 868.02 Anaheim 67% 71% 10 6 11 27 40.7% 868.03 Anaheim 58% 71% 11 0 2 13 15.4% 869.01 Anaheim 66% 55% 4 0 0 4 0.0% 869.02 Anaheim 51% 83% 6 1 1 8 12.5% S7 L) Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 869.03 Anaheim 63% 67% 6 1 1 8 12.5% 870.01 Anaheim 66% 67% 5 0 0 5 0.0% 870.02 Anaheim 59% 65% 16 1 9 26 34.6% 871.01 Anaheim 67% 66% 3 0 2 5 40.0% 871.02 Anaheim 78% 63% 5 0 0 5 0.0% 871.03 Anaheim 58% 83% 14 2 1 17 5.9% 871.05 Anaheim 62% 91% 1 0 1 2 50.0% 871.06 Anaheim 72% 72% 2 2 1 5 20.0% 872.00 Anaheim 65% 66% 5 2 3 10 30.0% 873.00 Anaheim 85% 57% 8 3 2 13 15.4% 874.01 Anaheim 72% 76% 26 3 4 33 12.1% 874.03 Anaheim 86% 49% 1 0 0 1 0.0% 874.04 Anaheim 91% 60% 1 0 0 1 0.0% 874.05 Anaheim 89% 52% 6 0 7 13 53.8% 875.01 Anaheim 80% 65% 7 1 3 11 27.3% 875.03 Anaheim 75% 1 66% 1 2 01 51 7 1 71 A% 875.04 Anaheim 1 87% 1 45% 1 1 01 01 1 1 0.0% 876.01 Anaheim 1 70% 1 64% 1 4 01 1 1 5 1 20.0% 876.02 Anaheim 1 62% 1 79% 1 11 1 1 31 15 1 20.0% 877.01 Anaheim 54% 82% 9 0 71 16 43.8% 877.03 Anaheim 72% 89% 10 1 3 14 21.4% 877.04 Anaheim 58% 80% 20 3 2 25 8.0% 878.01 Anaheim 56% 75% 10 1 2 13 15.4% 878.02 Anaheim 65% 70% 12 0 5 17 29.4% 878.03 Anaheim 87% 49% 4 0 2 6 33.3% 878.05 Anaheim 68% 67% 9 2 3 14 21.4% 878.06 Anaheim 78% 52% 12 3 3 18 167% 883.02 Anaheim 47% 88% 1 0 2 3 66.7% 884.02 Anaheim 75% 73% 0 0 4 4 100.0% 884.03 Anaheim 74% 80% 25 2 7 34 20.6% 1102.01 Anaheim 53% 84% 15 3 2 20 10.0% 1102.02 Anaheim 61% 68% 7 1 2 10 20.0% 1102.03 Anaheim 41% 88% 15 2 3 20 15.0% 1104.02 Anaheim 69% 65% 7 0 3 10 30.0% Subtotal 611 79 186 876 21.2% 371 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 18.01 Buena Park 71% 63% 5 0 2 7 28.6% 868.01 Buena Park 50% 96% 17 0 5 22 22.7% 1101.10 Buena Park 51% 80% 4 1 2 7 28.6% 1102.01 Buena Park 53% 84% 15 3 2 20 10.0% 1102.02 Buena Park 61% 68% 7 1 2 10 20.0% 1102.03 Buena Park 41% 88% 15 2 3 20 15.0% 1103.01 Buena Park 56% 101% 13 2 2 17 11.8% 1103.02 Buena Park 63% 85% 16 0 5 21 23.8% 1103.04 Buena Park 55% 89% 15 2 1 18 5.6% 1104.01 Buena Park 51% 89% 15 2 1 18 5.6% 1105.00 Buena Park 79% 56% 9 4 5 18 27.8% 1106.03 Buena Park 78% 57% 7 0 1 8 12.5% 1106.04 Buena Park 55% 102% 4 0 1 5 20.0% 1106.06 Buena Park 84% 46% 2 1 0 3 0.0% 1106.07 Buena Park 62% 66% 7 2 0 9 0.0% Subtotal 151 20 32 203 15.8% 992.02 Fountain My. 83% 83% 6 0 0 6 0.0% 992.03 Fountain My. 75% 89% 1 0 1 2 50.0% 992.04 Fountain V1 y. 65% 81% 1 0 0 1 0.0% 992.23 Fountain My. 69% 84% 0 0 0 0 0.0% 992.24 Fountain My. 42% 123% 0 0 0 0 0.0% 992.25 Fountain VI . 42% 132% 1 0 0 1 0.0% 992.26 Fountain VI . 56% 128% 1 0 0 1 0.0% 992.27 Fountain My. 61% 94% 9 2 4 15 26.7% 992.29 Fountain My. 41% 111% 3 4 7 14 50.0% 992.30 Fountain My. 26% 119% 8 1 2 11 18.2% 992.31 Fountain My. 30% 148% 3 0 0 3 0.0% 992.32 Fountain VI . 29% 128% 2 0 0 2 0.0% 992.33 Fountain My. 36% 110% 2 0 1 3 33.3% 992.34 Fountain My. 35% 122% 4 1 2 7 28.6% 992.50 Fountain My. 38% 112% 0 0 0 0 0.0% 992.51 Fountain My. 52% 84% 1 0 0 1 0.0% Subtotal 42 8 17 67 25.4% 15.03 Fullerton 38% 93% 2 0 1 3 33.3% 15.05 Fullerton 31% 115% 5 1 0 6 0.0% 16.01 Fullerton 26% 122% 4 0 0 4 0.0% 16.02 Fullerton 25% 161% 5 0 0 5 0.0% 17.04 Fullerton 48% 128% 3 0 3 6 50.0% 17.05 Fullerton 50% 98% 4 1 3 8 37.5% S72 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract Cit Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 17.06 Fullerton 24% 174% 0 0 0 0 0.0% 17.07 Fullerton 69% 131% 4 0 0 4 0.0% 17.08 Fullerton 48% 143% 4 1 0 5 0.0% 18.01 Fullerton 71% 63% 5 0 2 7 28.6% 18.02 Fullerton 68% 61% 7 1 0 8 0.0% 19.01 Fullerton 52% 91% 6 2 3 11 27.3% 19.02 Fullerton 50% 78% 7 2 4 13 30.8% 19.03 Fullerton 56% 67% 5 0 1 6 16.7 % 110.00 Fullerton 40% 92% 10 0 0 10 0.0% 111.01 Fullerton 55% 75% 5 1 2 8 25.0% 111.02 Fullerton 66% 88% 9 2 0 11 0.0% 112.00 Fullerton 37% 86% 5 0 0 5 0.0% 113.00 Fullerton 32% 95% 3 0 0 3 0.0% 114.01 Fullerton 29% 117% 0 0 0 0 0.0% 114.02 Fullerton 19% 141% 1 0 0 1 0.0% 114.03 Fullerton 54% 70% 8 1 0 9 0.0% 115.02 Fullerton 57% 66% 1 1 0 2 0.0% 115.03 Fullerton 26% 124% 1 1 0 2 0.0% 115.04 Fullerton 49% 58% 3 1 0 4 0.0% 116.01 Fullerton 78% 55% 2 0 3 5 60.0% 116.02 Fullerton 83% 57% 9 1 3 13 23.1% 117.07 Fullerton 29% 106% 11 0 3 14 21.4% 117.08 Fullerton 43% 74% 1 0 0 1 0.0% 117.11 Fullerton 62% 63% 6 2 4 12 33.3% 117.12 Fullerton 60% 80% 6 0 2 8 25.0% 867.01 Fullerton 65% 79% 24 1 5 30 16.7% 1106.05 Fullerton 71% 94% 5 0 0 5 0.0% Subtotal 171 19 39 229 17.0% 761.03 Garden Gr. 78% 66% 3 0 1 4 25.0% 875.03 Garden Gr. 75% 66% 2 0 5 7 71.4% 876.02 Garden Gr. 62% 79% 11 1 3 15 20.0% 878.06 Garden Gr. 78% 52% 12 3 3 18 16.7% 879.01 Garden Gr. 72% 71% 11 0 1 12 8.3% 879.02 Garden Gr. 82% 67% 1 0 2 3 66.7% 880.01 Garden Gr. 61% 91% 3 0 0 3 0.0% 880.02 Garden Gr. 55% 100% 3 1 3 7 42.9% 881.01 Garden Gr. 45% 90% 10 1 4 15 26.7% 881.04 Garden Gr. 55% 75% 2 0 0 2 0.0% 881.05 Garden Gr. 61% 96% 2 0 4 6 66.7% 881.06 Garden Gr. 61% 59% 7 0 1 8 12.5% 373 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 881.07 Garden Gr. 73% 63% 7 0 2 9 22.2% 882.01 Garden Gr. 54% 88% 1 1 1 3 33.3% 882.02 Garden Gr. 52% 110% 4 1 0 5 0.0% 882.03 Garden Gr. 58% 77% 2 0 0 2 0.0% 883.01 Garden Gr. 58% 78% 5 1 0 6 0.0% 883.02 Garden Gr. 47% 88% 1 0 2 3 66.7% 884.01 Garden Gr. 58% 91% 3 0 2 5 40.0% 884.02 Garden Gr. 75% 73% 0 0 4 4 100.0% 884.03 Garden Gr. 74% 80% 25 2 7 34 20.6% 885.01 Garden Gr. 74% 65% 4 0 4 8 50.0% 885.02 Garden Gr. 75% 74% 9 1 0 10 0.0% 886.01 Garden Gr. 74% 62% 5 0 2 7 28.6% 886.02 Garden Gr. 65% 72% 0 0 0 0 0.0% 887.01 Garden Gr. 77% 58% 4 0 2 6 33.3% 887.02 Garden Gr. 76% 59% 1 0 0 1 0.0% 888.01 Garden Gr. 81% 57% 12 1 2 15 13.3% 888.02 Garden Gr. 76% 76% 3 1 3 7 42.9% 889.01 Garden Gr. 77% 70% 1 0 0 1 0.0% 889.02 Garden Gr. 81% 78% 1 0 0 1 0.0% 889.03 Garden Gr. 86% 79% 0 0 2 2 100.0% 889.04 Garden Gr. 82% 97% 0 0 1 1 100.0% 890.01 Garden Gr. 90% 72% 2 1 1 4 25.0% 890.03 Garden Gr. 89% 62% 3 1 4 8 50.0% 891.02 Garden Gr. 82% 75% 11 1 6 18 33.3% 891.04 Garden Gr. 93% 43% 2 0 1 3 33.3% 891.06 Garden Gr. 82% 50% 1 0 0 1 0.0% 891.07 Garden Gr. 78% 89% 7 0 0 7 0.0% 999.02 Garden Gr. 55% 81% 3 1 0 4 0.0% 999.03 Garden Gr. 70% 67% 2 0 0 2 0.0% 999.05 Garden Gr. 33% 76% 2 0 1 3 33.3% 999.06 Garden Gr. 30% 122% 10 1 1 12 8.3% 1100.01 Garden Gr. 29% 111% 3 1 0 4 0.0% 1100.03 Garden Gr. 26% 115% 10 0 0 10 0.0% 1100.04 Garden Gr. 23% 120% 8 0 2 10 20.0% 1100.05 Garden Gr. 23% 126% 2 0 0 2 0.0% Subtotal 221 20 77 318 24.2% 992.12 Hunt. Beach 42% 79% 6 1 1 8 12.5% 992.14 Hunt. Beach 23% 99% 4 0 0 4 0.0% 992.15 Hunt. Beach 30% 98% 6 1 2 9 22.2% 992.16 Hunt. Beach 25% 118% 3 1 2 6 33.3% 992.17 Hunt. Beach 17% 141% 5 2 0 7 0.0% S74 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 992.20 Hunt. Beach 20% 102% 0 0 0 0 0.0% 992.35 Hunt. Beach 26% 105% 4 1 2 7 28.6% 992.37 Hunt. Beach 23% 124% 3 0 1 4 25.0% 992.38 Hunt. Beach 26% 156% 0 1 2 3 66.7% 992.39 Hunt. Beach 23% 152% 3 0 3 6 50.0% 992.40 Hunt. Beach 20% 132% 1 0 3 4 75.0% 992.41 Hunt. Beach 43% 98% 1 0 0 1 0.0% 992.42 Hunt. Beach 47% 103% 4 0 0 4 0.0% 992.43 Hunt. Beach 19% 122% 9 1 3 13 23.1% 992.44 Hunt. Beach 12% 136% 3 2 0 5 0.0% 992.45 Hunt. Beach 24% 126% 0 0 1 1 100.0% 992.46 Hunt. Beach 29% 151% 2 0 0 2 0.0% 993.05 Hunt. Beach 34% 71% 7 2 1 10 10.0% 993.06 Hunt. Beach 20% 91% 3 1 0 4 0.0% 993.07 Hunt. Beach 18% 88% 2 0 0 2 0.0% 993.08 Hunt. Beach 22% 236% 1 0 0 1 0.0% 993.09 Hunt. Beach 15% 139% 2 0 1 3 33.3% 993.10 Hunt. Beach 20% 159% 1 0 0 1 0.0% 993.11 Hunt. Beach 18% 126% 0 0 1 1 100.0% 994.02 Hunt. Beach 76% 57% 0 0 0 0 0.0% 994.04 Hunt. Beach 20% 136% 1 0 0 1 0.0% 994.05 Hunt. Beach 28% 104% 7 0 1 8 12.5% 994.06 Hunt. Beach 27% 112% 2 1 0 3 0.0% 994.07 Hunt. Beach 20% 122% 3 0 0 3 0.0% 994.08 Hunt. Beach 22% 115% 1 0 0 1 0.0% 994.10 Hunt. Beach 42% 80% 2 2 1 5 20.0% 994.11 Hunt. Beach 46% 74% 4 1 0 5 0.0% 994.12 Hunt. Beach 23% 119% 4 0 1 5 20.0% 994.13 Hunt. Beach 33% 134% 7 3 3 13 23.1% 994.15 Hunt. Beach 20% 161% 0 1 0 1 0.0% 994.16 Hunt. Beach 24% 88% 2 0 1 3 33.3% 994.17 Hunt. Beach 20% 129% 3 0 1 4 25.0% 995.08 Hunt. Beach 26% 87% 3 0 1 4 25.0% 995.13 Hunt. Beach 14% 187% 0 0 0 0 0.0% 995.14 Hunt. Beach 17% 197% 0 0 0 0 0.0% 996.02 Hunt. Beach 33% 106% 3 0 0 3 0.0% 996.03 Hunt. Beach 30% 111% 7 0 1 8 12.5% 996.04 Hunt. Beach 26% 116% 4 1 0 5 0.0% 996.05 Hunt. Beach 30% 127% 1 0 0 1 0.0% 997.02 Hunt. Beach 64% 88% 3 0 1 4 25.0% 375 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract -- 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 997.03 Hunt. Beach 48% 116% 1 0 2 3 66.7% Subtotal 128 22 36 186 19.4% 524.08 Irvine 22% 140% 6 1 2 9 22.2% 524.10 Irvine 34% 94% 3 0 1 4 25.0% 524.17 Irvine 36% 150% 6 1 2 9 22.2% 524.18 Irvine 48% 77% 6 1 0 7 0.0% 524.20 Irvine 50% 183% 7 3 2 12 16.7% 524.21 Irvine 28% 154% 4 1 2 7 28.6% 525.05 Irvine 46% 100% 2 1 1 4 25.0% 525.06 Irvine 25% 153% 0 0 0 0 0.0% 525.11 Irvine 28% 134% 2 0 2 4 50.0% 525.13 Irvine 33% 133% 3 1 1 5 20.0% 525.14 Irvine 37% 130% 3 1 2 6 33.3% 525.15 Irvine 60% 130% 3 0 0 3 0.0% 525.17 Irvine 41% 102% 9 0 2 11 18.2% 525.18 Irvine 100% 0% 0 1 0 1 0.0% 525.19 Irvine 38% 110% 7 0 2 9 22.2% 525.20 Irvine 30% 135% 2 0 0 2 0.0% 525.21 Irvine 51% 87% 1 1 0 2 0.0% 525.22 Irvine 52% 143% 3 0 0 3 0.0% 525.23 Irvine 50% 152% 1 0 0 1 0.0% 525.25 Irvine 42% 137% 12 2 4 18 22.2% 525.26 Irvine 44% 132% 3 0 1 4 25.0% 525.27 Irvine 53% 142% 4 0 2 6 33.3% 525.28 Irvine 39% 123% 1 0 0 1 0.0% 626.04 Irvine 11% 177% 3 0 2 5 40.0% 626.10 Irvine 41% 105% 3 0 0 3 0.0% 626.11 Irvine 52% 86% 1 0 0 1 0.0% 626.12 Irvine 31% 124% 2 0 3 5 60.0% 626.14 Irvine 60% 94% 0 0 0 0 0.0% 626.26 Irvine 65% 63% 0 0 0 0 0.0% 626.27 Irvine 49% 82% 0 0 0 0 0.0% 626.28 Irvine 39% 158% 0 1 1 2 50.0% 626.29 Irvine 28% 162% 0 0 0 0 0.0% 626.30 Irvine 23% 185% 0 0 0 0 0.0% 626.31 Irvine 23% 239% 0 0 2 2 100.0% 755.15 Irvine 79% 62% 16 1 18 35 51.4% Subtotal 113 16 52 181 28.7% S70 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 11.01 La Habra 38% 108% 9 0 2 11 18.2% 11.02 La Habra 45% 94% 10 0 0 10 0.0% 11.03 La Habra 60% 75% 6 0 1 7 14.3% 12.01 La Habra 82% 57% 7 2 2 11 18.2% 12.02 La Habra 75% 65% 6 0 1 7 14.3% 13.01 La Habra 43% 92% 13 0 1 14 7.1% 13.03 La Habra 68% 75% 27 0 3 30 10.0% 13.04 La Habra 77% 57% 6 2 1 9 11.1% 14.01 La Habra 53% 78% 4 1 1 6 16.7% 14.02 La Habra 53% 90% 10 0 2 12 16.7% 14.03 La Habra 28% 119% 6 1 1 8 12.5% 14.04 La Habra 75% 69% 6 1 2 9 22.2% 15.01 La Habra 27% 125% 6 0 0 6 0.0% 16.01 La Habra 26% 122% 4 0 0 4 0.0% 17.05 La Habra 50% 98% 4 1 3 8 37.5% 17.07 La Habra 69% 131% 4 0 0 4 0.0% 17.08 La Habra 48% 143% 4 1 0 5 0.0% Subtotal 132 9 20 161 12.4% 320.14 Lake Forest 47% 73% 9 1 5 15 33.3% 320.27 Lake Forest 44% 102% 36 10 14 60 23.3% 320.29 Lake Forest 30% 125% 12 1 4 17 23.5% 320.47 Lake Forest 26% 89% 7 0 1 8 12.5% 524.08 Lake Forest 22% 140% 6 1 2 9 22.2% 524.10 Lake Forest 34% 94% 3 0 1 4 25.0% 524.11 Lake Forest 49% 104% 10 3 3 16 18.8% 524.15 Lake Forest 19% 160% 4 1 1 6 16.7% 524.16 Lake Forest 34% 118% 17 3 4 24 16.7% 524.22 Lake Forest 26% 136% 13 0 3 16 18.8% 524.23 Lake Forest 34% 120% 5 1 0 6 0.0% 524.24 Lake Forest 33% 113% 10 1 2 13 15.4% 524.25 Lake Forest 32% 104% 12 1 1 14 7.1% Subtotal 144 23 41 208 19.7% 626.10 Newport Bch. 41% 105% 3 0 0 3 0.0% 626.42 Newport Bch. 11% 166% 0 0 0 0 0.0% 626.43 Newport Bch. 22% 272% 0 0 1 1 100.0% 626.44 Newport Bch. 13% 214% 0 0 0 0 0.0% 626.45 Newport Bch. 17% 245% 1 0 0 1 0.0% 627.01 Newport Bch. 8% 200% 0 0 0 0 0.0% 627.02 Newport Bch. 8% 196% 0 0 0 0 0.0% 628.00 Newport Bch. 10% 135% 0 0 0 0 0.0% 377 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 629.00 Newport Bch. 5% 221% 0 0 0 0 0.0% 630.04 Newport Bch. 10% 143% 0 0 0 0 0.0% 630.05 Newport Bch. 8% 190% 0 0 0 0 0.0% 630.06 Newport Bch. 7% 166% 0 0 0 0 0.0% 630.07 Newport Bch. 12% 211% 0 0 0 0 0.0% 630.08 Newport Bch. 11% 149% 0 0 0 0 0.0% 630.09 Newport Bch. 12% 199% 0 0 0 0 0.0% 630.10 Newport Bch. 13% 203% 0 2 0 2 0.0% 631.01 Newport Bch. 26% 94% 0 0 0 0 0.0% 631.03 Newport Bch. 12% 145% 1 0 0 1 0.0% 634.00 Newport Bch. 7% 153% 0 0 0 0 0.0% 635.00 Newport Bch. 11% 130% 0 0 0 0 0.0% 636.01 Newport Bch. 31% 103% 3 0 2 5 40.0% 636.03 Newport Bch. 14% 112% 2 0 1 3 33.3% Subtotal 10 2 4 16 25.0% 219.12 Orange 19% 194% 01 01 01 0 0.0% 219.13 Orange 70% 96% 9 31 41 16 25.0% 219.14 Orange 44% 110% 4 01 01 4 0.0% 219.15 Orange 33% 151% 4 1 1 31 8 37.5% 219.17 Orange 18% 161% 2 0 0 2 0.0% 219.18 Orange 38% 120% 9 2 3 14 21.4% 756.04 Orange 22% 197% 4 0 1 5 20.0% 756.05 Orange 27% 177% 5 0 1 6 16.7% 758.05 Orange 42% 102% 6 0 1 7 14.3% 758.06 Orange 48% 90% 4 0 1 5 20.0% 758.07 Orange 52% 108% 5 1 6 12 50.0% 758.08 Orange 21% 129% 4 2 0 6 0.0% 758.09 Orange 21% 185% 0 0 1 1 100.0% 758.10 Oran a 23% 186% 2 0 0 2 0.0% 758.11 Orange 58% 98% 2 0 0 2 0.0% 758.12 Orange 52% 86% 3 0 0 3 0.0% 758.13 Orange 36% 127% 5 1 2 8 25.0% 758.14 Orange 37% 176% 1 0 0 1 0.0% 758.15 Orange 34% 102% 11 2 1 14 7.1% 758.16 Orange 56% 98% 6 0 0 6 0.0% 759.01 Oran a 50% 78% 6 0 5 11 45.5% 759.02 Orange 43% 75% 7 1 0 8 0.0% 760.00 Orange 51% 86% 23 2 3 28 10.7% 761.01 Orange 63% 79% 8 0 5 13 38.5% 761.02 Orange 64% 69% 0 0 0 0 0.0% S72 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 761.03 Orange 78% 66% 3 0 1 4 25.0% 762.01 Orange 34% 105% 20 1 12 33 36.4% 762.02 Orange 39% 86% 16 4 4 24 16.7% 762.04 Orange 79% 61% 3 0 0 3 0.0% 762.05 Orange 46% 88% 6 0 4 10 40.0% 762.06 Orange 32% 96% 8 1 1 10 10.0% 762.08 Orange 30% 90% 22 2 1 251 4.0% Subtotal 208 23 60 291 20.6% 320.34 Ran. St. Marg. 23% 195% 7 1 2 10 20.0% 320.42 Ran. St. Marg. 19% 165% 3 1 2 6 33.3% 320.43 Ran. St. Marg. 15% 230% 6 0 0 6 0.0% 320.48 Ran. St. Marg. 24% 133% 7 1 1 9 11.1% 320.49 Ran. St. Marg. 24% 158% 8 1 3 12 25.0% 320.50 Ran. St. Marg. 27% 128% 19 6 7 32 21.9% 320.51 Ran. St. Marg. 32% 97% 18 4 12 34 35.3% 320.53 Ran. St. Marg. 23% 130% 22 2 9 33 27.3% 320.54 Ran. St. Marg. 28% 103% 15 3 3 21 14.3% 320.55 Ran. St. Marg. 37% 106% 12 3 0 15 0.0% 320.56 Ran. St. Marg. 28% 163% 19 3 5 27 18.5% Subtotal 136 25 44 205 21.5% 740.03 Santa Ana 95% 59% 9 0 5 14 35.7% 740.04 Santa Ana 73% 85 % 16 1 2 19 10.5% 740.05 Santa Ana 86% 69% 2 0 1 3 33.3% 740.06 Santa Ana 75% 63% 25 2 4 31 12.9% 741.02 Santa Ana 93% 80% 12 3 4 19 21.1% 741.03 Santa Ana 93% 78% 13 2 5 20 25.0% 741.06 Santa Ana 62% 76% 12 4 7 23 30.4% 741.07 Santa Ana 43% 94% 2 0 0 2 0.0% 741.08 Santa Ana 43% 94% 2 0 0 2 0.0% 741.09 Santa Ana 95% 78% 2 0 3 5 60.0% 741.10 Santa Ana 78% 118% 5 0 2 7 28.6% 741.11 Santa Ana 81% 93% 6 2 2 10 20.0% 742.00 Santa Ana 95 % 75% 13 1 8 22 36.4% 743.00 Santa Ana 97% 70% 4 2 2 8 25.0% 744.03 Santa Ana 95% 48% 0 0 0 0 0.0% 744.05 Santa Ana 95% 41% 6 0 5 11 45.5% 744.06 Santa Ana 92% 45% 5 0 2 7 28.6% 744.07 Santa Ana 93% 48% 7 0 5 12 41.7% 745.01 Santa Ana 99% 48% 1 0 4 5 80.0% 745.02 Santa Ana 97% 74% 6 0 5 11 45.5% 3�9 Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 746.01 Santa Ana 93% 55% 15 3 4 22 18.2% 746.02 Santa Ana 97% 59% 8 2 2 12 16.7% 747.01 Santa Ana 98% 72% 8 1 4 13 30.8% 747.02 Santa Ana 96% 71% 19 2 6 27 22.2% 748.01 Santa Ana 98% 60% 6 0 4 10 40.0% 748.02 Santa Ana 94% 49% 3 1 2 6 33.3% 748.03 Santa Ana 92% 66% 4 0 1 5 20.0% 748.05 Santa Ana 98% 49% 4 0 2 6 33.3% 748.06 Santa Ana 99% 49% 0 0 3 3 100.0% 749.01 Santa Ana 98% 46% 9 2 4 15 26.7% 749.02 Santa Ana 99% 45% 4 1 4 9 44.4% 750.02 Santa Ana 96% 47% 12 0 6 18 33.3% 750.03 Santa Ana 96% 41% 1 0 0 1 0.0% 750.04 Santa Ana 96% 42% 1 0 2 3 66.7% 751.00 Santa Ana 78% 51% 9 1 2 12 16.7% 752.01 Santa Ana 97% 1 71% 1 9 1 1 21 121 16.7% 752.02 Santa Ana 95% 59% 6 4 7 17 41.2% 753.01 Santa Ana 70% 80% 2 1 1 4 25.0% 753.02 Santa Ana 82% 67% 8 1 3 12 25.0% 753.03 Santa Ana 44% 112% 7 1 0 8 0.0% 754.01 Santa Ana 49% 112% 14 0 3 17 17.6% 754.03 Santa Ana 62% 76% 39 4 8 51 15.7% 754.04 Santa Ana 61% 77% 5 0 1 6 16.7% 754.05 Santa Ana 37% 76% 11 2 3 16 18.8% 755.15 Santa Ana 79% 62% 16 1 18 35 51.4% 757.01 Santa Ana 43% 94% 5 0 1 6 16.7% 758.06 Santa Ana 48% 90% 4 0 1 5 20.0% 759.02 Santa Ana 43% 75% 7 1 0 8 0.0% 760.00 Santa Ana 51% 86% 23 2 3 28 10.7% 889.03 Santa Ana 86% 79% 0 0 2 2 100.0% 890.01 Santa Ana 90% 72 % 2 1 1 4 25.0% 890.04 Santa Ana 89% 56% 4 1 3 8 37.5% 891.02 Santa Ana 82% 75% 11 1 6 18 33.3% 891.04 Santa Ana 93% 43% 2 0 1 3 33.3% 891.05 Santa Ana 97% 45% 1 0 1 2 50.0% 891.07 Santa Ana 78% 89% 7 0 0 7 0.0% 992.02 Santa Ana 83% 83% 6 0 0 6 0.0% 992.03 Santa Ana 75% 89 % 1 0 1 2 50.0% 992.47 Santa Ana 89% 76% 1 0 1 2 50.0% 992.48 Santa Ana 89% 55% 2 0 1 3 33.3% rM Table F -1 continued Entitlement Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total App. Percent Denied 992.49 Santa Ana 97% 59% 0 0 0 0 0.0% Subtotal 444 51 180 675 26.7% 888.02 Westminster 76% 76% 3 1 3 7 42.9% 889.01 Westminster 77% 70% 1 0 0 1 0.0% 889.04 Westminster 82% 97% 0 0 1 1 100.0% 889.05 Westminster 79% 85% 1 0 0 1 0.0% 992.03 Westminster 75% 89% 1 0 1 2 50.0% 992.04 Westminster 65% 81% 1 0 0 1 0.0% 992.22 Westminster 59% 77% 1 0 1 2 50.0% 992.23 Westminster 69% 84% 0 0 0 0 0.0% 992.41 Westminster 43% 98% 1 0 0 1 0.0% 996.01 Westminster 73% 62% 4 2 4 10 40.0% 996.02 Westminster 33% 106% 3 0 0 3 0.0% 996.03 Westminster 30% 111% 7 0 1 8 12.5% 997.01 Westminster 72% 80% 1 0 0 1 0.0% 997.02 Westminster 64% 88% 3 0 1 4 25.0% 997.03 Westminster 48% 116% 1 0 2 3 66.7% 998.01 Westminster 67% 82% 0 0 0 0 0.0% 998.02 Westminster 75% 54% 1 0 1 2 50.0% 998.03 Westminster 78% 62% 0 0 0 0 0.0% 999.02 Westminster 55% 81% 3 1 0 4 0.0% 999.03 Westminster 70% 67% 2 0 0 2 0.0% 999.04 Westminster 72% 56% 2 0 0 2 0.0% 999.05 Westminster 33% 76% 2 0 1 3 33.3% 999.06 Westminster 30% 122% 10 1 1 12 8.3% Subtotal 48 5 17 70 24.3% Total 2,436 314 790 3,540 22.3% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates SRI Table F -2 Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 116.02 Anaheim 83% 57% 37 6 9 52 17.3% 117.14 Anaheim 81% 56% 0 1 0 1 0.0% 117.20 Anaheim 93% 47% 11 3 12 26 46.2% 117.22 Anaheim 67% 74% 14 4 3 21 14.3% 218.07 Anaheim 28% 100% 17 5 4 26 15.4% 218.12 Anaheim 33% 109% 41 8 13 62 21.0% 218.13 Anaheim 74% 82% 0 3 0 3 0.0% 219.03 Anaheim 42% 118% 44 4 11 59 18.6% 219.05 Anaheim 29% 144% 25 5 16 46 34.8% 219.12 Anaheim 19% 194% 59 4 9 72 12.5% 219.15 Anaheim 33% 151% 27 6 8 41 19.5% 219.16 Anaheim 24% 171% 24 6 8 38 21.1% 219.19 Anaheim 26% 153% 20 8 7 35 20.0% 219.20 Anaheim 26% 160% 100 13 15 128 11.7% 219.21 Anaheim 35% 180% 37 7 14 58 24.1% 219.22 Anaheim 36% 127% 1 47 71 91 63 14.3% 219.23 Anaheim 37% 157% 82 14 17 113 15.0% 219.24 Anaheim 43% 145% 31 1 7 39 17.9% 761.01 Anaheim 63% 79% 14 3 7 24 29.2% 761.02 Anaheim 64% 69% 4 1 3 8 37.5% 863.01 Anaheim 74% 78% 34 15 12 61 19.7% 863.03 Anaheim 53% 78% 84 12 24 120 20.0% 863.04 Anaheim 53% 93% 24 3 8 35 22.9% 863.05 Anaheim 44% 107% 29 5 5 39 12.8% 863.06 Anaheim 53% 92% 19 2 5 26 19.2% 864.02 Anaheim 68% 80% 27 2 10 39 25.6% 864.04 Anaheim 82% 71% 38 9 19 66 28.8% 864.05 Anaheim 83% 58% 13 6 8 27 29.6% 864.06 Anaheim 64 % 74% 12 1 1 14 7.1% 864.07 Anaheim 58% 81% 23 15 21 59 35.6% 865.01 Anaheim 85% 57% 16 1 7 24 29.2% 865.02 Anaheim 92% 58% 14 13 14 41 34.1% 866.01 Anaheim 87% 53% 29 5 13 47 27.7% 867.01 Anaheim 65% 79% 47 14 15 76 19.7% 867.02 Anaheim 75% 61% 38 13 16 67 23.9% 868.01 Anaheim 50% 96% 28 5 7 40 17.5% 868.02 Anaheim 67 % 71% 38 10 10 58 17.2% 868.03 Anaheim 58% 71% 20 11 8 39 20.5% 869.01 Anaheim 66% 55% 14 7 3 24 12.5% 869.02 Anaheim 51% 83% 25 4 10 39 25.6. 382 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 869.03 Anaheim 63% 67% 28 13 10 51 19.6% 870.01 Anaheim 66% 67% 15 3 9 27 33.3% 870.02 Anaheim 59% 65% 28 6 3 37 8.1% 871.01 Anaheim 67% 66% 9 2 7 18 38.9% 871.02 Anaheim 78% 63% 14 10 8 32 25.0% 871.03 Anaheim 58% 83% 57 8 15 80 18.8% 871.05 Anaheim 62% 91% 24 6 9 39 23.1% 871.06 Anaheim 72% 72% 17 5 5 27 18.5% 872.00 Anaheim 65% 66% 32 6 18 56 32.1% 873.00 Anaheim 85% 57% 32 11 26 69 37.7% 874.01 Anaheim 72% 76% 74 25 20 119 16.8% 874.03 Anaheim 86% 49% 5 2 3 10 30.0% 874.04 Anaheim 91% 60% 14 4 8 26 30.8% 874.05 Anaheim 89% 52% 11 1 5 17 29.4% 875.01 Anaheim 80% 65% 19 7 9 35 25.7% 875.03 Anaheim 75% 66% 1 23 101 121 45 26.7% 875.04 Anaheim 87% 45% 6 5 9 20 45.0% 876.01 Anaheim 70% 64% 16 4 9 29 31.0% 876.02 Anaheim 62% 79% 34 7 17 58 29.3% 877.01 Anaheim 54% 82% 31 9 12 52 23.1% 877.03 Anaheim 72% 89% 26 3 9 38 23.7% 877.04 Anaheim 58% 80% 41 11 16 68 23.5% 878.01 Anaheim 56% 75% 35 3 9 47 19.1% 878.02 Anaheim 65% 70% 31 5 11 47 23.4% 878.03 Anaheim 87% 49% 15 2 3 20 15.0% 878.05 Anaheim 68% 67% 29 10 15 54 27.8% 878.06 Anaheim 78% 52% 24 8 14 46 30.4% 883.02 Anaheim 47% 88% 39 3 9 51 17.6% 884.02 Anaheim 75% 73% 23 3 12 38 31.6% 884.03 Anaheim 74% 80% 118 17 23 158 14.6% 1102.01 Anaheim 53% 84% 33 12 15 60 25.0% 1102.02 Anaheim 61% 68% 43 3 12 58 20.7% 1102.03 Anaheim 41% 88% 49 3 16 68 23.5% 1104.02 Anaheim 69% 65% 18 2 7 27 25.9% Subtotal 2,219 491 773 3,483 22.2% 383 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 18.01 Buena Park 71% 63% 12 3 4 19 21.1% 868.01 Buena Park 50% 96% 28 5 7 40 17.5% 1101.10 Buena Park 51% 80% 30 3 3 36 8.3% 1102.01 Buena Park 53% 84% 33 12 15 60 25.0% 1102.02 Buena Park 61% 68% 43 3 12 58 20.7% 1102.03 Buena Park 41% 88% 49 3 16 68 23.5% 1103.01 Buena Park 56% 101% 42 1 10 53 18.9% 1103.02 Buena Park 63% 85 % 34 8 11 53 20.8% 1103.04 Buena Park 55% 89% 32 4 9 45 20.0% 1104.01 Buena Park 51% 89% 38 6 15 59 25.4% 1105.00 Buena Park 79% 56% 24 12 18 54 33.3% 1106.03 Buena Park 78% 57% 53 6 8 67 11.9% 1106.04 Buena Park 55% 102% 55 15 13 83 15.7% 1106.06 Buena Park 84% 46% 5 1 3 9 33.3% 1106.07 Buena Park 62% 66% 15 3 9 27 33.3% Subtotal 1 1 493 85 153 731 20.9% 992.02 Fountain My. 83% 83% 33 6 10 49 20.4% 992.03 Fountain My. 75% 89% 17 10 5 32 15.6% 992.04 Fountain My. 65% 81% 23 7 8 38 21.1% 992.23 ain VI . 69% 84% 21 0 2 23 8.7% 992.24 ain VI *Fountain 42% 123% 40 16 21 77 27.3% 992.25 ain VI 42% 132% 26 6 4 36 11.1% 992.26 VI . 56% 128% 17 4 6 27 22.2% 992.27 Fountain My. 61% 94% 31 7 14 52 26.9% 992.29 Fountain My. 41% 111% 28 15 5 48 10.4% 992.30 Fountain My. 26% 119% 32 5 11 48 22.9% 992.31 Fountain My. 30% 148% 35 8 7 50 14.0% 992.32 Fountain My. 29% 128% 36 4 10 50 20.0% 992.33 Fountain My. 36% 110% 20 1 8 29 27.6% 992.34 Fountain My. 35% 122% 22 8 10 40 25.0% 992.50 Fountain My. 38% 112 % 7 1 6 14 42.9% 992.51 Fountain My. 52% 84% 28 7 9 44 20.5% Subtotal 416 105 136 657 20.7% 15.03 Fullerton 38% 93% 25 5 3 33 9.1% 15.05 Fullerton 31% 115% 59 12 20 91 22.0% 16.01 Fullerton 26% 122% 55 8 10 73 13.7% 16.02 Fullerton 25% 161% 40 4 6 50 12.0% 17.04 Fullerton 48% 128 % 75 11 18 104 17.3% 17.05 Fullerton 50% 98% 23 8 7 38 18.4% 17.06 Fullerton 24% 174% 15 3 8 26 30.8% r Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 17.07 Fullerton 69% 131% 49 6 7 62 11.3% 17.08 Fullerton 48% 143% 24 9 9 42 21.4% 18.01 Fullerton 71% 63% 12 3 4 19 21.1% 18.02 Fullerton 68% 61% 21 6 9 36 25.0% 19.01 Fullerton 52% 91% 15 3 6 24 25.0% 19.02 Fullerton 50% 78% 20 3 6 29 20.7% 19.03 Fullerton 56% 67% 13 0 3 16 18.8% 110.00 Fullerton 40% 92% 44 7 13 64 20.3% 111.01 Fullerton 55% 75% 15 1 3 19 15.8% 111.02 Fullerton 66% 88% 20 2 8 30 26.7% 112.00 Fullerton 37% 86% 30 4 12 46 26.1% 113.00 Fullerton 32% 95% 12 0 0 12 0.0% 114.01 Fullerton 29% 117% 12 3 2 17 11.8% 114.02 Fullerton 19% 141% 20 3 6 29 20.7% 114.03 Fullerton 54% 70% 22 1 7 30 23.3% 115.02 Fullerton 57% 66% 14 4 3 21 14.3% 115.03 Fullerton 26% 124% 4 3 3 10 30.0% 115.04 Fullerton 49% 58% 10 4 2 16 12.5% 116.01 Fullerton 78% 55% 14 7 2 23 8.7% 116.02 Fullerton 83% 57% 37 6 9 52 17.3% 117.07 Fullerton 29% 106% 44 9 15 68 22.1% 117.08 Fullerton 43% 74% 18 2 5 25 20.0% 117.11 Fullerton 62% 63% 27 3 7 37 18.9% 117.12 Fullerton 60% 80% 19 2 12 33 36.4% 867.01 Fullerton 65% 79% 47 14 15 76 19.7% 1106.05 Fullerton 71% 94% 33 6 5 44 11.4% Subtotal 888 162 245 1,295 18.9% 761.03 Garden Gr. 78% 66% 30 11 18 59 30.5% 875.03 Garden Gr. 75 % 66% 23 10 12 45 26.7% 876.02 Garden Gr. 62% 79% 34 7 17 58 29.3% 878.06 Garden Gr. 78% 52% 24 8 14 46 30.4% 879.01 Garden Gr. 72% 71% 53 6 6 65 9.2% 879.02 Garden Gr. 82% 67% 25 4 9 38 23.7% 880.01 Garden Gr. 61% 91% 40 9 16 65 24.6% 880.02 Garden Gr. 55% 100% 31 8 9 48 18.8% 881.01 Garden Gr. 45% 90% 26 2 6 34 17.6% 881.04 Garden Gr. 55% 75% 11 1 3 15 20.0% 881.05 Garden Gr. 61% 96% 21 3 5 29 17.2% 881.06 Garden Gr. 61% 59% 21 11 6 38 15.8% 385 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract city Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 881.07 Garden Gr. 73% 63% 26 3 8 37 21.6% 882.01 Garden Gr. 54% 88% 25 4 7 36 19.4% 882.02 Garden Gr. 52% 110% 34 7 7 48 14.6% 882.03 Garden Gr. 58% 77% 20 1 4 25 16.0% 883.01 Garden Gr. 58% 78% 33 7 11 51 21.6% 883.02 Garden Gr. 47% 88% 39 3 9 51 17.6% 884.01 Garden Gr. 58% 91% 46 4 16 66 24.2% 884.02 Garden Gr. 75% 73% 23 3 12 38 31.6% 884.03 Garden Gr. 74% 80% 118 17 23 158 14.6% 885.01 Garden Gr. 74% 65% 37 5 11 53 20.8% 885.02 Garden Gr. 75% 74% 27 14 12 53 22.6% 886.01 Garden Gr. 74% 62% 34 6 10 50 20.0% 886.02 Garden Gr. 65% 72% 25 6 12 43 27.9% 887.01 Garden Gr. 77% 58% 22 4 6 32 18.8% 887.02 Garden Gr. 76% 59% 41 12 13 66 19.7% 888.01 Garden Gr. 81% 57% 36 10 15 61 24.6% 888.02 Garden Gr. 76% 76% 75 3 13 91 14.3% 889.01 Garden Gr. 77% 70% 38 11 7 56 12.5% 889.02 Garden Gr. 81% 78% 22 13 17 52 32.7% 889.03 Garden Gr. 86% 79% 30 11 8 49 16.3% 889.04 Garden Gr. 82% 97% 29 6 8 43 18.6% 890.01 Garden Gr. 90% 72% 40 9 25 74 33.8% 890.03 Garden Gr. 89% 62% 17 8 15 40 37.5% 891.02 Garden Gr. 82% 75% 43 11 26 80 32.5% 891.04 Garden Gr. 93% 43% 5 1 6 12 50.0% 891.06 Garden Gr. 82% 50% 13 0 8 21 38.1% 891.07 Garden Gr. 78% 89% 25 6 11 42 26.2% 999.02 Garden Gr. 55% 81% 17 6 2 25 8.0% 999.03 Garden Gr. 70% 67% 32 3 5 40 12.5% 999.05 Garden Gr. 33% 76% 6 2 1 9 11.1% 999.06 Garden Gr. 30% 122% 36 4 7 47 14.9% 1100.01 Garden Gr. 29% 111% 25 6 5 36 13.9% 1100.03 Garden Gr. 26% 115% 22 3 11 36 30.6% 1100.04 Garden Gr. 23% 120% 28 6 2 36 5.6% 1100.05 Garden Gr. 23% 126% 18 5 5 28 17.9% Subtotal 1,446 300 479 2,225 21.5% 992.12 Hunt. Beach 42% 79% 25 7 5 37 13.5% 992.14 Hunt. Beach 23% 99% 19 4 5 28 17.9% 992.15 Hunt. Beach 30% 98% 42 5 12 59 20.3% 992.16 Hunt. Beach 25% 118% 13 3 12 28 42.9% MW Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 992.17 Hunt. Beach 17% 141% 27 5 9 41 22.0% 992.20 Hunt. Beach 20% 102% 16 5 9 30 30.0% 992.35 Hunt. Beach 26% 105% 14 1 6 21 28.6% 992.37 Hunt. Beach 23% 124% 27 5 9 41 22.0% 992.38 Hunt. Beach 26% 156% 13 3 8 24 33.3% 992.39 Hunt. Beach 23% 152% 20 1 7 28 25.0% 992.40 Hunt. Beach 20% 132% 20 4 4 28 14.3% 992.41 Hunt. Beach 43% 98 % 16 4 3 23 13.0% 992.42 Hunt. Beach 47% 103% 19 11 8 38 21.1% 992.43 Hunt. Beach 19% 122% 63 4 10 77 13.0% 992.44 Hunt. Beach 12% 136% 38 9 4 51 7.8% 992.45 Hunt. Beach 24% 126% 20 6 6 32 18.8% 992.46 Hunt. Beach 29% 151% 25 1 3 29 10.3% 993.05 Hunt. Beach 34% 71% 31 4 7 42 16.7% 993.06 Hunt. Beach 20% 91% 46 6 13 65 20.0% 993.07 Hunt. Beach 18% 88% 24 3 12 39 30.8% 993.08 Hunt. Beach 22% 236% 52 9 9 70 12.9% 993.09 Hunt. Beach 15% 139% 58 12 16 86 18.6% 993.10 Hunt. Beach 20% 159% 33 3 14 50 28.0% 993.11 Hunt. Beach 18% 126% 48 6 17 71 23.9% 994.02 Hunt. Beach 76% 57% 17 5 14 36 38.9% 994.04 Hunt. Beach 20% 136% 18 5 12 35 34.3% 994.05 Hunt. Beach 28% 104% 16 3 6 25 24.0% 994.06 Hunt. Beach 27% 112% 31 4 10 45 22.2% 994.07 Hunt. Beach 20% 122% 22 3 6 31 19.4% 994.08 Hunt. Beach 22% 115% 34 5 11 50 22.0% 994.10 Hunt. Beach 42% 80% 17 3 3 23 13.0% 994.11 Hunt. Beach 46% 74% 9 2 1 12 8.3% 994.12 Hunt. Beach 23% 119% 19 2 8 29 27.6% 994.13 Hunt. Beach 33% 134% 62 14 15 91 16.5% 994.15 Hunt. Beach 20% 161 % 35 9 10 54 18.5% 994.16 Hunt. Beach 24% 88% 28 7 16 51 31.4% 994.17 Hunt. Beach 20% 129% 56 16 14 86 16.3% 995.08 Hunt. Beach 26% 87% 24 0 8 32 25.0% 995.13 Hunt. Beach 14% 187% 14 3 9 26 34.6% 995.14 Hunt. Beach 17% 197% 53 13 16 82 19.5% 996.02 Hunt. Beach 33% 106% 20 3 5 28 17.9% 996.03 Hunt. Beach 30% 111 % 35 5 14 54 25.9% 996.04 Hunt. Beach 26% 116% 19 8 5 32 15.6% 996.05 Hunt. Beach 30% 127% 19 3 4 26 15.4% S27 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 997.02 Hunt. Beach 64% 88% 32 12 10 54 18.5% 997.03 Hunt. Beach 48% 116% 27 10 13 50 26.0% Subtotal 1,316 256 418 1,990 21.0% 524.08 Irvine 22% 140% 48 10 14 72 19.4% 524.10 Irvine 34% 94% 34 9 15 58 25.9% 524.17 Irvine 36% 150% 56 16 12 84 14.3% 524.18 Irvine 48% 77% 136 28 37 201 18.4% 524.20 Irvine 50% 183% 204 47 34 285 11.9% 524.21 Irvine 28% 154% 45 13 11 69 15.9% 525.05 Irvine 46% 100% 19 6 12 37 32.4% 525.06 Irvine 25% 153% 20 2 1 23 4.3% 525.11 Irvine 28% 134% 32 8 6 46 13.0% 525.13 Irvine 33% 133% 26 6 6 38 15.8% 525.14 Irvine 37% 130% 27 4 6 37 16.2% 525.15 Irvine 60% 130% 94 22 35 151 23.2% 525.17 Irvine 41% 102% 76 17 18 111 16.2% 525.18 Irvine 100% 0% 2 1 0 3 0.0% 525.19 Irvine 38% 110% 21 8 7 36 19.4% 525.20 Irvine 30% 135% 26 3 3 32 9.4% 525.21 Irvine 51% 87% 17 7 5 29 17.2% 525.22 Irvine 52% 143% 14 5 3 22 13.6% 525.23 Irvine 50% 152% 16 3 6 25 24.0% 525.25 Irvine 42% 137% 101 15 21 137 15.3% 525.26 Irvine 44% 132% 21 9 7 37 18.9% 525.27 Irvine 53% 142% 42 11 12 65 18.5% 525.28 Irvine 39% 123% 10 3 2 15 13.3% 626.04 Irvine 11% 177% 196 47 62 305 20.3% 626.10 Irvine 41% 105% 155 24 35 214 16.4% 626.11 Irvine 52% 86% 10 3 9 22 40.9% 626.12 Irvine 31% 124% 49 5 13 67 19.4% 626.14 Irvine 60% 94 % 22 3 3 28 10.7% 626.26 Irvine 65% 63% 4 0 0 4 0.0% 626.27 Irvine 49% 82% 24 4 5 33 15.2% 626.28 Irvine 39% 158% 12 12 4 28 14.3% 626.29 Irvine 28% 162% 17 3 6 26 23.1% 626.30 Irvine 23% 185% 8 1 1 10 10.0% 626.31 Irvine 23% 239% 30 3 12 45 26.7% 755.15 Irvine 79% 62% 214 40 71 325 21.8% Subtotal 1,828 398 494 2,720 18.2% :: Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 11.01 La Habra 38% 108% 39 3 7 49 14.3% 11.02 La Habra 45% 94% 25 9 10 44 22.7% 11.03 La Habra 60% 75% 13 1 3 17 17.6% 12.01 La Habra 82% 57% 20 9 11 40 27.5% 12.02 La Habra 75% 65% 11 2 7 20 35.0% 13.01 La Habra 43% 92% 46 11 10 67 14.9% 13.03 La Habra 68% 75% 44 7 9 60 15.0% 13.04 La Habra 77% 57% 15 9 11 35 31.4% 14.01 La Habra 53% 78% 19 4 2 25 8.0% 14.02 La Habra 53% 90% 24 7 7 38 18.4% 14.03 La Habra 28% 119% 15 4 4 23 17.4% 14.04 La Habra 75% 69% 19 11 5 35 14.3% 15.01 La Habra 27% 125% 45 8 16 69 23.2% 16.01 La Habra 26% 122% 55 8 10 73 13.7% 17.05 La Habra 50% 98% 23 8 7 38 18.4% 17.07 La Habra 69% 131% 49 6 7 62 11.3% 17.08 La Habra 48% 143% 24 9 9 42 21.4% Subtotal 486 116 135 737 18.3% 320.14 Lake Forest 47% 73% 42 17 24 83 28.9% 320.27 Lake Forest 44% 102% 70 14 23 107 21.5% 320.29 Lake Forest 30% 125% 42 9 15 66 22.7% 320.47 Lake Forest 26% 89% 31 8 6 45 13.3% 524.08 Lake Forest 22% 140% 48 10 14 72 19.4% 524.10 Lake Forest 34% 94% 34 9 15 58 25.9% 524.11 Lake Forest 49% 104% 32 5 5 42 11.9% 524.15 Lake Forest 19% 160% 32 6 6 44 13.6% 524.16 Lake Forest 34% 118% 33 6 11 50 22.0% 524.22 Lake Forest 26% 136% 37 3 4 44 9.1% 524.23 Lake Forest 34% 120% 17 3 8 28 28.6% 524.24 Lake Forest 33% 113% 37 12 8 57 14.0% 524.25 Lake Forest 32% 104 %p 47 10 10 67 14.9% Subtotal 502 112 149 763 19.5% 626.10 Newport Bch. 41% 105% 155 24 35 214 16.4% 626.42 Newport Bch. 11% 166% 23 7 8 38 21.1% 626.43 Newport Bch. 22% 272% 49 5 23 77 29.9% 626.44 Newport Bch. 13% 214% 44 11 18 73 24.7% 626.45 Newport Bch. 17% 245% 34 7 15 56 26.8% 627.01 Newport Bch. 8% 200 % 29 8 7 44 15.9% 627.02 Newport Bch. 8% 196% 46 10 32 88 36.4% 628.00 Newport Bch. 10% 135% 15 4 8 27 29.6% Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 629.00 Newport Bch. 5% 221% 13 2 6 21 28.6% 630.04 Newport Bch. 10% 143% 18 3 4 25 16.0% 630.05 Newport Bch. 8% 190% 1 1 2 4 50.0% 630.06 Newport Bch. 7% 166% 19 0 12 31 38.7% 630.07 Newport Bch. 12% 211% 32 10 8 50 16.0% 630.08 Newport Bch. 11% 149% 11 1 2 14 14.3% 630.09 Newport Bch. 12% 199% 13 5 5 23 21.7% 630.10 Newport Bch. 13% 203 % 30 4 4 38 10.5% 631.01 Newport Bch. 26% 94% 10 5 1 16 6.3% 631.03 Newport Bch. 12% 145% 12 3 5 20 25.0% 634.00 Newport Bch. 7% 153% 44 20 14 78 17.9% 635.00 Newport Bch. 11% 130% 40 11 27 78 34.6% 636.01 Newport Bch. 31% 103% 21 5 9 35 25.7% 636.03 Newport Bch. 14% 112% 44 8 18 70 25.7% Subtotal 703 154 263 1,120 23.5% 219.12 Orange 19% 194% 1 59 1 4 1 91 72 1 12.5% 219.13 70% 96% 44 11 8 63 12.7% 219.14 tOrange a 44% 110% 16 6 10 32 31.3% 219.15 e 33% 151% 1 27 1 61 81 41 1 19.5% 219.17 Orange 18% 161% 141 5 8 27 1 29.6% 219.18 Oran a 38% 120% 36 7 17 60 28.3% 756.04 Oran e 22% 197% 53 10 18 81 22.2% 756.05 Orange 27% 177% 54 8 13 75 17.3% 758.05 Orange 42% 102% 15 3 8 26 30.8% 758.06 Orange 48% 90% 30 3 4 37 10.8% 758.07 Orange 52% 108% 23 6 18 47 38.3% 758.08 Orange 21% 129% 21 3 3 27 11.1% 758.09 Orange 21% 185% 25 5 4 34 11.8% 758.10 Orange 23% 186% 23 6 4 33 12.1% 758.11 Orange 58% 98% 7 3 1 11 9.1% 758.12 Orange 52% 86 % 27 6 3 36 8.3% 758.13 Orange 36% 127% 37 11 16 64 25.0% 758.14 Oran e 37% 176% 27 6 6 39 15.4% 758.15 Orange 34% 102% 30 9 11 50 22.0% 758.16 Orange 56% 98% 29 4 2 35 5.7% 759.01 Orange 50% 78% 42 4 14 60 23.3% 759.02 Orange 43% 75% 23 10 4 37 10.8% 760.00 Orange 51% 86 % 64 27 24 115 20.9% 761.01 Orange 63% 79% 14 3 7 24 29.2% 761.02 Orange 64% 69% 4 1 3 8 37.5% 39 D Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 761.03 Orange 78% 66% 30 11 18 59 30.5% 762.01 Orange 34% 105% 74 17 26 117 22.2% 762.02 Orange 39% 86% 42 7 14 63 22.2% 762.04 Orange 79% 61% 14 7 8 29 27.6% 762.05 Orange 46% 88% 28 3 11 42 26.2% 762.06 Orange 32% 96% 33 3 15 51 29.4% 762.08 Orange 30% 90% 103 11 44 158 27.8% Subtotal 1,068 226 359 1,653 21.7% 320.34 Ran. St. Mar. 23% 195% 41 9 13 63 20.6% 320.42 Ran. St. Mar. 19% 165% 32 9 6 47 12.85 320.43 Ran. St. Mar. 15% 230% 40 12 12 64 18.85 320.48 Ran. St. Mar. 24% 133% 50 6 12 68 17.6% 320.49 Ran. St. Mar. 24% 158% 74 10 21 105 20.0% 320.50 Ran. St. Mar. 27% 128% 65 13 33 111 29.7% 320.51 Ran. St. Mar. 32% 97% 45 11 29 85 34.1% 320.53 Ran. St. Mar. 23% 130% 125 35 69 229 30.1% 320.54 Ran. St. Mar. 28% 103% 50 13 34 97 35.1% 320.55 Ran. St. Mar. 37% 106% 51 9 36 96 37.5% 320.56 Ran. St. Mar. 28% 163% 65 21 17 103 16.5% Subtotal 638 148 282 1,068 26.4% 740.03 Santa Ana 95% 59% 22 12 23 57 40.4% 740.04 Santa Ana 73% 85% 46 9 17 72 23.6% 740.05 Santa Ana 86% 69% 19 6 17 42 40.5% 740.06 Santa Ana 75% 63% 40 10 19 69 27.5% 741.02 Santa Ana 93% 80% 42 16 19 77 24.7% 741.03 Santa Ana 93% 78% 21 8 15 44 34.1% 741.06 Santa Ana 62% 76% 33 14 13 60 217% 741.07 Santa Ana 43% 94% 42 10 19 71 26.8% 741.08 Santa Ana 43% 94% 15 5 9 29 31.0% 741.09 Santa Ana 95% 78% 16 6 8 30 26.7% 741.10 Santa Ana 78% 118% 12 1 6 19 31.6% 741.11 Santa Ana 81% 93% 26 8 15 49 30.6% 742.00 Santa Ana 95% 75% 35 10 32 77 41.6% 743.00 Santa Ana 97% 70% 19 4 7 30 23.3% 744.03 Santa Ana 95% 48% 1 1 1 3 33.3% 744.05 Santa Ana 95% 41% 20 8 8 36 22.2% 744.06 Santa Ana 92% 45% 7 4 5 16 31.3% 744.07 Santa Ana 93% 48% 12 6 14 32 43.8% 745.01 Santa Ana 99% 48% 7 3 6 16 37.5% 745.02 Santa Ana 97% 74% 11 4 10 25 40.0% 3�1 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 746.01 Santa Ana 93% 55% 47 15 15 77 19.5% 746.02 Santa Ana 97% 59% 24 5 23 52 44.2% 747.01 Santa Ana 98% 72% 26 10 21 57 36.8% 747.02 Santa Ana 96% 71% 28 4 18 50 36.0% 748.01 Santa Ana 98% 60% 19 4 15 38 39.5% 748.02 Santa Ana 94% 49% 14 5 15 34 44.1% 748.03 Santa Ana 92% 66% 42 5 14 61 23.0% 748.05 Santa Ana 98% 49% 7 5 4 16 25.0% 748.06 Santa Ana 99% 49% 10 0 5 15 33.3% 749.01 Santa Ana 98% 46% 33 4 26 63 41.3% 749.02 Santa Ana 99% 45% 9 8 17 34 50.0% 750.02 Santa Ana 96% 47% 23 14 21 58 36.2% 750.03 Santa Ana 96% 41% 4 4 1 9 11.1% 750.04 Santa Ana 96% 42% 1 1 2 4 50.0% 751.00 Santa Ana 78% 51% 37 14 11 62 17.7% 752.01 Santa Ana 97% 71% 22 7 15 44 34.1% 752.02 Santa Ana 95% 59% 23 6 23 52 44.2% 753.01 Santa Ana 70% 80% 23 10 10 43 23.3% 753.02 Santa Ana 82% 67% 23 5 9 37 24.3% 753.03 Santa Ana 44% 112% 20 6 13 39 33.3% 754.01 Santa Ana 49% 112% 28 4 5 37 13.5% 754.03 Santa Ana 62% 76% 59 3 31 93 33.3% 754.04 Santa Ana 61% 77% 22 7 9 38 23.7% 754.05 Santa Ana 37% 76% 10 4 2 16 12.5% 755.15 Santa Ana 79% 62% 214 40 71 325 21.8% 757.01 Santa Ana 43% 94% 32 2 7 41 17.1% 758.06 Santa Ana 48% 90% 30 3 4 37 10.8% 759.02 Santa Ana 43% 75% 23 10 4 37 10.8% 760.00 Santa Ana 51% 86% 64 27 24 115 20.9% 889.03 Santa Ana 86% 79% 30 11 8 49 16.3% 890.01 Santa Ana 90% 72% 40 9 25 74 33.8% 890.04 Santa Ana 89% 56% 43 13 17 73 23.3% 891.02 Santa Ana 82% 75% 43 11 26 80 32.5% 891.04 Santa Ana 93% 43% 5 1 6 12 50.0% 891.05 Santa Ana 97% 45% 15 8 6 29 20.7% 891.07 Santa Ana 78% 89% 25 6 11 42 26.2% 992.02 Santa Ana 83% 83% 33 6 10 49 20.4% 992.03 Santa Ana 75% 89% 17 10 5 32 15.6% 992.47 Santa Ana 89% 76% 10 10 11 31 35.5% 992.48 Santa Ana 89% 55% 14 3 10 27 37.0% 3J°2 Table F -2 continued Entitlement Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 992.49 Santa Ana 97% 59% 9 3 7 19 36.8% Subtotal 1,647 468 840 2,955 28.4% 888.02 Westminster 76% 76% 75 3 13 91 14.3% 889.01 Westminster 77% 70% 38 11 7 56 12.5% 889.04 Westminster 82% 97% 29 6 8 43 18.6% 889.05 Westminster 79% 85% 29 5 5 39 12.8% 992.03 Westminster 75% 89% 17 10 5 32 15.6% 992.04 Westminster 65% 81 % 23 7 8 38 21.1% 992.22 Westminster 59% 77% 26 5 8 39 20.5% 992.23 Westminster 69% 84% 21 0 2 23 8.7% 992.41 Westminster 43% 98% 16 4 3 23 13.0% 996.01 Westminster 73% 62% 28 11 19 58 32.8% 996.02 Westminster 33% 106% 20 3 5 28 17.9% 996.03 Westminster 30% 111% 35 5 14 54 25.9% 997.01 Westminster 72% 80% 23 5 7 35 20.0% 997.02 Westminster 64% 88% 32 12 10 54 18.5% 997.03 Westminster 48% 116% 27 10 13 50 26.0% 998.01 Westminster 67% 82% 30 3 21 54 38.9% 998.02 Westminster 75% 54% 7 7 8 22 36.4% 998.03 Westminster 78% 62% 25 5 8 38 21.1% 999.02 Westminster 55% 81% 17 6 2 25 8.0% 999.03 Westminster 70% 67% 32 3 5 40 12.5% 999.04 Westminster 72% 56% 20 4 4 28 14.3% 999.05 Westminster 33% 76% 6 2 1 9 11.1% 999.06 Westminster 30% 122% 36 4 7 47 14.9% Subtotal 612 131 183 926 19.8% TOTAL 1 14,262 1 3,1521 4,909 1 22,323 1 22.0% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates 3J° 3 Table F -3 Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 423.20 Aliso Viejo 33% 95% 22 0 1 23 4.3% 423.33 Aliso Viejo 32% 103% 7 2 1 10 10.0% 626.25 Aliso Viejo 39% 76% 29 3 3 35 8.6% 626.33 Aliso Viejo 26% 177% 10 1 2 13 15.4% 626.34 Aliso Viejo 26% 144% 8 4 2 14 14.3% 626.35 Aliso Viejo 28% 142% 12 2 4 18 22.2% 626.36 Aliso Viejo 33% 107% 2 1 2 5 40.0% 626.37 Aliso Viejo 27% 130 % 14 1 1 16 6.3% 626.38 Aliso Viejo 29% 122% 10 2 4 16 25.0% 626.39 Aliso Viejo 30% 135% 24 5 0 29 0.0% 626.40 Aliso Viejo 27% 129% 8 0 2 10 20.0% 626.41 Aliso Viejo 38% 93% 7 5 2 14 14.3% 626.47 Aliso Viejo 22% 101% 1 0 1 2 50.0% Subtotal 154 26 25 205 12.2% 14.03 Brea 28% 119% 6 1 1 8 12.5% 14.04 Brea 1 75% 1 69% 1 61 1 1 2 1 9 1 22.2% 15.01 Brea 27% 125% 6 0 01 6 1 0.0% 15.03 Brea 38% 93% 2 01 1 1 3 1 33.3% 15.04 Brea 49% 79% 3 21 01 5 1 0.0% 15.05 Brea 31% 115% 5 1 0 6 0.0% 1 5.06 Brea 31% 128% 4 0 1 5 20.0% 15.07 Brea 34% 92% 8 1 2 11 18.2% 117.09 Brea 22% 134% 1 0 0 1 0.0% 117.17 Brea 21% 113% 1 0 0 1 0.0% 218.14 Brea 31% 126% 5 0 1 6 16.7% 218.15 Brea 20% 125% 9 1 2 12 16.7% Subtotal 56 7 10 73 13.7% 1100.01 Cypress 29% 111% 3 1 0 4 0.0% 1100.10 Cypress 37% 121% 2 0 0 2 0.0% 1100.11 Cypress 31% 149% 4 0 0 4 0.0% 1101.02 Cypress 56% 115 %p 3 0 0 3 0.0% 1101.04 Cypress 45% 100% 5 1 1 7 14.3% 1101.06 Cypress 32% 101% 2 0 1 3 33.3% 1101.09 Cypress 43% 100% 0 0 0 0 0.0% 1101.10 Cypress 51% 80% 4 1 2 7 28.6% 1101.11 Cypress 42% 98% 8 4 1 13 7.7% 1101.13 Cypress 46% 112% 0 0 0 0 0.0% 1101.14 Cypress 34% 110% 2 1 1 4 25.0% 1101.17 Cypress 39% 105% 0 0 1 1 100.0% 1101.18 Cypress 66% 173% 0 01 0 0 0.0% 39 � Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 1102.02 Cypress 61% 68% 7 1 2 10 20.0% Subtotal 40 9 9 58 15.5% 422.01 Dana Point 20% 96% 2 1 4 7 57.1% 422.05 Dana Point 23% 125% 1 0 2 3 66.7% 422.06 Dana Point 11% 102% 1 0 2 3 66.7% 423.05 Dana Point 9% 176% 0 0 0 0 0.0% 423.10 Dana Point 37% 85% 16 2 8 26 30.8% 423.11 Dana Point 21% 127% 3 0 1 4 25.0% 423.13 Dana Point 38% 86% 1 0 1 2 50.0% 423.23 Dana Point 12% 129% 1 1 1 3 33.3% 423.24 Dana Point 12% 163% 2 0 0 2 0.0% 423.38 Dana Point 14% 135% 5 2 2 9 22.2% 423.39 Dana Point 25% 119% 1 0 0 1 0.0% Subtotal 33 6 21 60 35.0% 1101.02 La Palma 56% 115% 3 0 0 3 0.0% 1101.11 La Palma 1 42% 1 98% 1 81 41 1 131 7.7% 1101.15 La Palma 63% 123% 4 1 0 5 0.0% 1101.16 La Palma 72% 107% 1 0 0 1 0.0% 1103.01 La Palma 56% 101% 13 2 2 171 11.8% 1103.04 Palma 55% 102% 6 1 0 7 0.0% Subtotal 4Laguna 35 8 3 46 6.5% 423.05 una Bch. 9% 176% 0 0 0 0 0.0% 626.04 Bch. 11% 177% 3 0 2 5 40.0% 626.05 Laguna Bch. 16% 103% 0 0 1 1 100.0% 626.19 Laguna Bch. 9% 142% 0 0 0 0 0.0% 626.20 Laguna Bch. 11% 172% 0 0 1 1 100.0% 626.23 Laguna Bch. 8% 102% 3 0 1 4 25.0% 626.32 Laguna Bch. 12% 189% 0 0 0 0 0.0% Subtotal 6 0 5 11 45.5% 423.07 Laguna Hills 36% 108% 5 1 1 7 14.3% 423.20 Laguna Hills 33% 95% 22 0 1 23 4.3% 423.27 Laguna Hills 23% 147% 2 0 0 2 0.0% 423.28 Laguna Hills 15% 217 % 0 0 0 0 0.0% 423.33 Laguna Hills 32% 103% 7 2 1 10 10.0% 423.35 Laguna Hills 29% 110% 8 0 1 9 11.1% 626.21 Laguna Hills 30% 104% 4 3 3 10 30.0% 626.22 Laguna Hills 11% 71% 0 0 0 0 0.0% 626.23 Laguna Hills 8 % 102% 3 0 1 4 25.0% 626.25 Laguna Hills 39% 76% 29 3 3 35 8.6% 626.47 Laguna Hills 22% 101% 1 0 1 2 50.0% Subtotal 81 9 12 102 11.8% 3J° 5 Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 626.21 Laguna Woods 30% 104% 4 3 3 10 30.0% 626.22 Laguna Woods 11% 71% 0 0 0 0 0.0% 626.23 Laguna Woods 8% 102% 3 0 1 4 25.0% 626.25 Laguna Woods 39% 76% 29 3 3 35 8.6% 626.35 Laguna Woods 28% 142% 12 2 4 18 22.2% 626.41 Laguna Woods 38% 93% 7 5 2 14 14.3% 626.46 Laguna Woods 7% 61% 0 0 0 0 0.0% 626.47 Laguna Woods 22% 101% 1 0 1 2 50.0% Subtotal 56 13 14 83 16.9% 1100.07 Los Alamitos 15% 148% 1 0 0 1 0.0% 1100.12 Los Alamitos 24% 164% 2 0 0 2 0.0% 1100.14 Los Alamitos 38% 79% 1 1 1 3 33.3% 1100.15 Los Alamitos 22% 111% 1 0 1 2 50.0% 1101.06 Los Alamitos 32% 101% 2 0 1 3 33.3% 1101.08 Los Alamitos 34% 112% 0 0 0 0 0.0% 1101.13 Los Alamitos 1 46% 1 112% 1 01 01 01 01 0.0% 1101.17 Los Alamitos 39 % 105% 0 0 1 1 100.0% Subtotal 7 1 4 12 33.3% 117.08 Placentia 43% 74% 6 0 0 6 0.0% 117.09 Placentia 22% 134% 1 0 0 1 0.0% 117.10 Placentia 25% 123% 3 0 0 3 0.0% 117.11 Placentia 62% 63% 6 2 4 12 33.3% 117.12 Placentia 60% 80% 6 0 2 8 25.0% 117.15 Placentia 27% 134% 6 1 2 9 22.2% 117.17 Placentia 21% 113% 1 0 0 1 0.0% 117.18 Placentia 25% 127% 2 0 2 4 50.0% 117.20 Placentia 93% 47% 2 0 3 5 60.0% 117.21 Placentia 72% 61% 8 1 4 13 30.8% 117.22 Placentia 67% 74% 5 0 1 6 16.7% 218.10 Placentia 23% 112% 6 1 0 7 0.0% 218.13 Placentia 74% 82% 1 0 0 1 0.0% 218.15 Placentia 20% 125% 9 1 2 12 16.7% 218.20 Placentia 34% 133% 1 0 1 2 50.0% 218.21 Placentia 46% 102% 14 1 2 17 11.8% Subtotal 77 7 23 107 21.5% 995.02 Seal Beach 62% 51% 0 0 0 0 0.0% 995.04 Seal Beach 12% 151% 0 0 0 0 0.0% 995.06 Seal Beach 13% 129% 0 0 0 0 0.0% 995.09 Seal Beach 6% 60% 0 0 0 0 0.0% 995.10 Seal Beach 8% 57% 0 0 0 0 0.0% 3J° (o Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 995.11 Seal Beach 14% 124% 0 0 0 0 0.0% 995.12 Seal Beach 18% 145% 1 1 1 3 33.3% 1100.07 Seal Beach 15% 148% 1 0 0 1 0.0% 1100.08 Seal Beach 17% 125% 1 0 1 2 50.0% 1100.12 Seal Beach 24% 164% 2 0 0 2 0.0% Subtotal 5 1 2 8 25.0% 878.01 Stanton 56% 75% 10 1 2 13 15.4% 878.02 Stanton 65% 70% 12 0 5 17 29.4% 878.03 Stanton 87% 49% 4 0 2 6 33.3% 878.05 Stanton 68% 67% 9 2 3 14 21.4% 878.06 Stanton 78% 52% 12 3 3 18 16.7% 879.01 Stanton 72% 71% 11 0 1 12 8.3% 879.02 Stanton 82% 67% 1 0 2 3 66.7% 881.01 Stanton 45% 90% 10 1 4 15 26.7% 881.04 Stanton 55% 75% 2 0 0 2 0.0% 881.05 Stanton 61% 96% 2 0 4 6 66.7% 881.06 Stanton 61% 59% 7 0 1 8 12.5% 1101.13 Stanton 46% 112% 0 0 0 0 0.0% 1102.03 Stanton 41% 88% 15 2 3 20 15.0% Subtotal 95 9 30 134 22.4% 758.09 Villa Park 21% 185% 0 0 1 1 100.0% 758.10 Villa Park 23% 186% 2 0 0 2 0.0% 758.11 Villa Park 58% 98% 2 0 0 2 0.0% 758.12 Villa Park 52% 86% 3 0 0 3 0.0% 758.13 Villa Park 36% 127 % 5 1 2 8 25.0% 758.14 Villa Park 37% 176 % 1 0 0 1 0.0% Subtotal 13 1 3 17 17.6% 117.17 Yorba Linda 21% 113% 1 0 0 1 0.0% 117.18 Yorba Linda 25% 127% 2 0 2 4 50.0% 218.02 Yorba Linda 25% 122% 8 2 3 13 23.1% 218.09 Yorba Linda 18% 126% 2 0 0 2 0.0% 218.10 Yorba Linda 23% 112% 6 1 0 7 0.0% 218.12 Yorba Linda 33% 109% 15 1 2 18 11.1% 218.15 Yorba Linda 20% 125% 9 1 2 12 16.7% 218.16 Yorba Linda 17% 138% 9 1 2 12 16.7% 218.17 Yorba Linda 23% 122% 8 0 2 10 20.0% 218.20 Yorba Linda 34% 133% 1 0 1 2 50.0% 218.22 Yorba Linda 21 % 143% 6 0 2 8 25.0% 218.23 Yorba Linda 26% 139% 4 0 0 4 0.0% 218.24 Yorba Linda 24% 168% 1 0 0 1 0.0% S�7 Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Ori inated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 218.25 Yorba Linda 26% 163% 3 1 0 4 0.0% 218.26 Yorba Linda 30% 105% 3 0 0 3 0.0% 218.27 Yorba Linda 31% 183% 4 2 1 7 14.3% 218.28 Yorba Linda 33% 197% 3 0 2 5 40.0% 218.29 Yorba Linda 29% 184% 1 0 0 1 0.0% 218.30 Yorba Linda 22% 169% 2 0 0 2 0.0% 219.24 Yorba Linda 43% 145% 2 1 2 5 40.0% Subtotal 90 10 21 121 17.4% 11.01 Unincorp. 38% 108% 9 0 2 11 18.2% 12.01 Unincorp. 82% 57% 7 2 2 11 18.2% 14.01 Unincorp. 53% 78% 4 1 1 6 16.7% 14.02 Unincorp. 53% 90% 10 0 2 12 16.7% 15.01 Unincorp. 27% 125% 6 0 0 6 0.0% 15.06 Unincorp. 31% 128% 4 0 1 5 20.0% 17.07 Unincorp. 69% 131% 4 0 0 4 0.0% 19.03 Unincorp. 56% 67% 5 0 1 6 16.7% 117.11 Unincorp. 62% 63% 6 2 4 12 33.3% 117.15 Unincorp. 27% 134% 6 1 21 9 22.2% 117.18 Unincorp. 25% 127% 2 0 2 4 50.0% 218.12 33% 109% 15 1 2 18 11.1 218.15 *in 20% 125% 9 1 2 12 16.7% 218.16 p. 17% 138% 9 1 2 12 16.7% 218.17 . 23% 122% 8 0 2 10 20.0% 219.12 Unincorp. 19% 194% 0 0 0 0 0.0% 219.13 Unincorp. 70% 96% 9 3 4 16 25.0% 219.14 Unincorp. 44% 110% 4 0 0 4 0.0% 219.17 Unincorp. 18% 161% 2 0 0 2 0.0% 219.18 Unincorp. 38% 120% 9 2 3 14 21.4% 219.24 Unincorp. 43% 145% 2 1 2 5 40.0% 320.11 Unincorp. 10% 162% 3 1 0 4 0.0% 320.23 Unincorp. 16% 157% 21 4 6 31 19.4% 320.41 Unincorp. 21% 212% 0 0 0 0 0.0% 320.42 Unincorp. 19% 165% 3 1 2 6 33.3% 320.44 Unincorp. 13% 255% 0 0 0 0 0.0% 320.45 Unincorp. 22% 151% 10 1 2 13 15.4% 320.46 Unincorp. 14% 262% 1 0 2 3 66.7% 320.49 Unincorp. 24% 158% 8 1 3 12 25.0% 320.52 Unincorp. 13% 203% 78 10 19 107 17.8% 320.53 Unincorp. 23% 130% 22 2 9 33 27.3% 320.56 Unincorp. 28% 163% 19 3 5 27 18.5% Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 423.35 Unincorp. 29% 110% 8 0 1 9 11.1% 524.04 Unincorp. 63% 107% 0 0 0 0 0.0% 524.20 Unincorp. 50% 183% 7 3 2 12 16.7% 524.21 Unincorp. 28% 154% 4 1 2 7 28.6% 524.22 Unincorp. 26% 136% 13 0 3 16 18.8% 524.26 Unincorp. 30% 161% 9 0 4 13 30.8% 524.27 Unincorp. 32% 150% 7 6 2 15 13.3% 524.28 Unincorp. 22% 149% 19 3 0 22 0.0% 626.04 Unincorp. 11% 177% 3 0 2 5 40.0% 626.41 Unincorp. 38% 93% 7 5 2 14 14.3% 626.43 Unincorp. 22% 272% 0 0 1 1 100.0% 626.45 Unincorp. 17% 245% 1 0 0 1 0.0% 630.09 Unincorp. 12% 199% 0 0 0 0 0.0% 631.01 Unincorp. 26% 94% 0 0 0 0 0.0% 631.02 Unincorp. 19% 100% 4 0 3 7 42.9% 631.03 Unincorp. 12% 145% 1 0 0 1 0.0% 755.04 Unincorp. 37% 112% 6 0 1 7 14.3% 755.06 Unincorp. 31% 121% 3 1 3 7 42.9% 756.03 Unincorp. 22% 122% 5 1 3 9 33.3% 756.04 Unincorp. 22% 197% 4 0 1 5 20.0% 756.05 Unincorp. 27% 177% 5 0 1 6 16.7% 756.06 Unincorp. 24% 207% 1 1 0 2 0.0% 757.01 Unincorp. 43% 94% 5 0 1 6 16.7% 757.02 Unincorp. 21% 125% 3 0 1 4 25.0% 757.03 Unincorp. 18% 150% 3 0 0 3 0.0% 758.07 Unincorp. 52% 108% 5 1 6 12 50.0% 758.08 Unincorp. 21% 129% 4 2 0 6 0.0% 762.02 Unincorp. 39% 86% 16 4 4 24 16.7% 762.04 Unincorp. 79% 61% 3 0 0 3 0.0% 762.08 Unincorp. 30% 90% 22 2 1 25 4.0% 867.01 Unincorp. 65 % 79% 24 1 5 30 16.7% 871.01 Unincorp. 67% 66% 3 0 2 5 40.0% 877.01 Unincorp. 54% 82% 9 0 7 16 43.8% 877.03 Unincorp. 72% 89% 10 1 3 14 21.4% 878.01 Unincorp. 56% 75% 10 1 2 13 15.4% 878.05 Unincorp. 68% 67% 9 2 3 14 21.4% 878.06 Unincorp. 78% 52% 12 3 3 18 16.7% 879.02 Unincorp. 82% 67% 1 0 2 3 66.7% 992.30 Unincorp. 26% 119% 8 1 2 11 18.2% 994.17 Unincorp. 20% 129% 3 0 1 4 25.0% 3�1 Table F -3 continued Urban County Cities FHA Loan Application Denial Rates by City and Census Tract — 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted Apps. Denied Total Apps. Percent Denied 995.06 Unincorp. 13% 129% 0 0 0 0 0.0% 995.13 Unincorp. 14% 187% 0 0 0 0 0.0% 997.01 Unincorp. 72% 80% 1 0 0 1 0.0% 997.02 Unincorp. 64% 88% 3 0 1 4 25.0% 997.03 Unincorp. 48% 116% 1 0 2 3 66.7% 1100.06 Unincorp. 18% 149% 0 0 0 0 0.0% 1100.07 Unincorp. 15% 148% 1 0 0 1 0.0% 1100.08 Unincorp. 17% 125% 1 0 1 2 50.0% 1106.04 Unincorp. 55% 102% 4 0 1 5 20.0% Subtotal 563 77 161 801 20.1% TOTAL 1,311 184 343 1,838 18.7% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates Gi Table F -4 Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 423.20 Aliso Viejo 33% 95% 58 17 15 90 16.7% 423.33 Aliso Viejo 32% 103% 29 6 7 42 16.7% 626.25 Aliso Viejo 39% 76% 83 7 15 105 14.3% 626.33 Aliso Viejo 26% 177% 77 14 12 103 11.7% 626.34 Aliso Viejo 26% 144% 57 13 20 90 22.2% 626.35 Aliso Viejo 28% 142% 65 7 15 87 17.2% 626.36 Aliso Viejo 33% 107% 30 5 12 47 25.5% 626.37 Aliso Viejo 27% 130% 50 10 5 65 7.7% 626.38 Aliso Viejo 29% 122% 63 9 15 87 17.2% 626.39 Aliso Viejo 30% 135% 123 27 27 177 15.3% 626.40 Aliso Viejo 27% 129% 41 8 6 55 10.9% 626.41 Aliso Viejo 38% 93% 79 12 13 104 12.5% 626.47 Aliso Viejo 22% 101% 36 5 1 42 2.4% Subtotal 791 140 163 1,094 14.9% 14.03 Brea 28% 119% 15 4 4 23 17.4% 14.04 Brea 75% 69% 19 11 5 35 14.3% 15.01 Brea 27% 125% 45 8 16 69 23.2% 15.03 Brea 38% 93% 25 5 3 33 9.1% 15.04 Brea 49% 79% 24 2 6 32 18.8% 15.05 Brea 31% 115% 59 12 20 91 22.0% 15.06 Brea 31% 128% 32 7 6 45 13.3% 15.07 Brea 34% 92% 20 3 8 31 25.8% 117.09 Brea 22% 134% 19 2 5 26 19.2% 117.17 Brea 21% 113% 20 3 5 28 17.9% 218.14 Brea 31% 126% 29 5 3 37 8.1% 218.15 Brea 20% 125% 63 21 15 99 15.2% Subtotal 370 83 96 549 17.5% 1100.01 Cypress 29% 111% 25 6 5 36 13.9% 1100.10 Cypress 37% 121% 30 3 3 36 8.3% 1100.11 Cypress 31% 149% 23 1 0 24 0.0% 1101.02 Cypress 56% 115% 42 5 16 63 25.4% 1101.04 Cypress 45% 100% 31 6 7 44 15.9% 1101.06 Cypress 32% 101% 27 5 5 37 13.5% 1101.09 Cypress 43% 100% 29 2 6 37 16.2% 1101.10 Cypress 51% 80% 23 3 5 31 16.1% 1101.11 Cypress 42% 98% 33 3 6 42 14.3% 1101.13 Cypress 46% 112% 11 2 2 15 13.3% 1101.14 Cypress 34% 110% 32 9 6 47 12.8% 1101.17 Cypress 39% 105% 51 2 8 25 32.0% 1101.18 Cypress 66% 173% 7 3 2 12 10% SMI Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 1102.02 Cypress 61% 68% 43 3 12 58 20.7% Subtotal 371 53 83 507 16.4% 422.01 Dana Point 20% 96% 41 9 25 75 33.3% 422.05 Dana Point 23% 125% 56 10 14 80 17.5% 422.06 Dana Point 11% 102% 32 5 7 44 15.9% 423.05 Dana Point 9% 176% 34 5 12 51 23.5% 423.10 Dana Point 37% 85% 64 14 19 97 19.6% 423.11 Dana Point 21% 127% 38 8 2 48 4.2% 423.13 Dana Point 38% 86% 24 7 7 38 18.4% 423.23 Dana Point 12% 129% 62 11 23 96 24.0% 423.24 Dana Point 12% 163% 29 15 14 58 24.1% 423.38 Dana Point 14% 135% 42 9 15 66 22.7% 423.39 Dana Point 25% 119% 27 7 6 40 15.0% Subtotal 449 100 144 693 20.8% 1101.02 La Palma 56% 115% 42 5 16 63 25.4% 1101.11 La Palma 42% 1 98% 1 33 1 31 6 42 1 14.3% 1101.15 La Palma 63% 123% 12 3 2 17 11.8% 1101.16 La Palma 72% 107% 171 4 3 241 12.5% 1103.01 La Palma 56% 101% 42 1 10 53 18.9% 1103.04 La Palma 55% 102% 32 4 9 45 20.0% Subtotal 178 20 46 244 18.9% 423.05 La E Bch. 9% 176% 34 5 12 51 23.5% 626.04 La Bch. 11% 177% 196 47 62 305 20.3% 626.05 Laguna Bch. 16% 103% 16 4 7 27 25.9% 626.19 Laguna Bch. 9% 142% 33 10 10 53 18.9% 626.20 Laguna Bch. 11% 172% 45 6 19 70 27.1% 626.23 Laguna Bch. 8% 102% 72 14 16 102 15.7% 626.32 Laguna Bch. 12% 189% 25 5 16 46 34.8% Subtotal 421 91 142 654 21.7% 423.07 Laguna Hills 36% 108% 42 3 14 59 23.7% 423.20 Laguna Hills 33% 95% 58 17 15 90 16.7% 423.27 Laguna Hills 23% 147% 26 5 8 39 20.5% 423.28 Laguna Hills 15% 217% 20 1 2 23 8.7% 423.33 Laguna Hills 32% 103% 29 6 7 42 16.7% 423.35 Laguna Hills 29% 110% 87 24 36 147 24.5% 626.21 Laguna Hills 30% 104% 63 15 40 118 33.9% 626.22 Laguna Hills 11% 71% 45 6 15 66 22.7% 626.23 Laguna Hills 8% 102% 72 14 16 102 15.7% 626.25 Laguna Hills 39% 76% 83 7 15 105 14.3% 626.47 Laguna Hills 22% 101% 36 5 1 42 2.4% Subtotal 561 103 169 833 20.3% iw-j Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 626.21 Laguna Woods 30% 104% 63 15 40 118 33.9% 626.22 Laguna Woods 11% 71% 45 6 15 66 22.7% 626.23 Laguna Woods 8% 102% 72 14 16 102 15.7% 626.25 Laguna Woods 39% 76% 83 7 15 105 14.3% 626.35 Laguna Woods 28% 142% 65 7 15 87 17.2% 626.41 Laguna Woods 38% 93% 79 12 13 104 12.5% 626.46 Laguna Woods 7% 61% 71 1 1 73 1.4% 626.47 Laguna Woods 22% 101% 36 5 1 42 2.4% Subtotal 514 67 116 697 16.6% 1100.07 Los Alamitos 15% 148% 22 9 5 36 13.9% 1100.12 Los Alamitos 24% 164% 33 5 4 42 9.5% 1100.14 Los Alamitos 38% 79% 15 1 0 16 0.0% 1100.15 Los Alamitos 22% 111% 29 7 6 42 14.3% 1101.06 Los Alamitos 32% 101% 27 5 5 37 13.5% 1101.08 Los Alamitos 34% 112% 11 0 2 13 15.4% 1101.13 Los Alamitos 46% 112% 11 2 2 15 13.3% 1101.17 Los Alamitos 39% 105% 15 2 8 25 32.0% Subtotal 163 31 32 226 14.2% 117.08 Placentia 43% 74% 18 2 5 25 20.0% 117.09 Placentia 22% 134% 19 2 5 26 19.2% 117.10 Placentia 25% 123% 16 3 2 21 9.5% 117.11 Placentia 62% 63% 27 3 7 37 18.9% 117.12 Placentia 60% 80% 19 2 12 33 36.4% 117.15 Placentia 27% 134% 41 4 11 56 19.6% 117.17 Placentia 21% 113% 20 3 5 28 17.9% 117.18 Placentia 25% 127% 24 2 6 32 18.8% 117.20 Placentia 93% 47% 11 3 12 26 46.2% 117.21 Placentia 72% 61% 12 6 6 24 25.0% 117.22 Placentia 67% 74% 14 4 3 21 14.3% 218.10 Placentia 23% 112% 20 1 5 26 19.2% 218.13 Placentia 74% 82% 0 3 0 3 0.0% 218.15 Placentia 20% 125% 63 21 15 99 15.2% 218.20 Placentia 34% 133% 32 1 8 41 19.5% 218.21 Placentia 46% 102% 43 8 15 66 22.7% Subtotal 379 68 117 564 20.7% 995.02 Seal Beach 62% 51% 1 0 0 1 0.0% 995.04 Seal Beach 12% 151% 15 2 10 27 37.0% 995.06 Seal Beach 13% 129% 3 1 7 11 63.6% 995.09 Seal Beach 6% 60% 3 0 1 4 25.0% 995.10 Seal Beach 8% 57% 0 1 0 1 0.0% +lr Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 995.11 Seal Beach 14% 124% 17 3 0 20 0.0% 995.12 Seal Beach 18% 145% 15 7 6 28 21.4% 1100.07 Seal Beach 15% 148% 22 9 5 36 13.9% 1100.08 Seal Beach 17% 125% 45 7 10 62 16.1% 1100.12 Seal Beach 24% 164% 33 5 4 42 9.5% Subtotal 154 35 43 232 18.5% 878.01 Stanton 56% 75% 35 3 9 47 19.1% 878.02 Stanton 65% 70% 31 5 11 47 23.4% 878.03 Stanton 87% 49% 15 2 3 20 15.0% 878.05 Stanton 68% 67% 29 10 15 54 27.8% 878.06 Stanton 78% 52% 24 8 14 46 30.4% 879.01 Stanton 72% 71% 53 6 6 65 9.2% 879.02 Stanton 82% 67% 25 4 9 38 23.7% 881.01 Stanton 45% 90% 40 9 16 65 24.6% 881.04 Stanton 55% 75% 11 1 3 15 20.0% 881.05 Stanton 61% 96% 21 6 5 32 15.6% 881.06 Stanton 61% 59% 21 11 6 38 15.8% 1101.13 Stanton 46% 112% 11 2 2 15 13.30 1102.03 Stanton 41% 88% 491 3 16 68 23.5% Subtotal 365 70 115 550 20.9% 758.09 Villa Park 21% 185% 25 5 4 34 11.8% 758.10 Villa Park 23% 186% 23 6 4 33 12.15 758.11 Villa Park 58% 98% 7 3 1 11 9.1% 758.12 Villa Park 52% 86% 27 6 3 36 8.3% 758.13 Villa Park 36% 127% 37 11 16 64 25.0% 758.14 Villa Park 37% 176% 27 6 6 39 15.4% Subtotal 146 37 34 217 15.7% 117.17 Yorba Linda 21% 113% 20 3 5 28 17.9% 117.18 Yorba Linda 25% 127% 24 2 6 32 18.8% 218.02 Yorba Linda 25% 122% 52 16 27 95 28.4% 218.09 Yorba Linda 18% 126% 18 2 8 28 28.6% 218.10 Yorba Linda 23% 112% 20 1 5 26 19.2% 218.12 Yorba Linda 33% 109% 41 8 13 62 21.0% 218.15 Yorba Linda 20% 125% 63 21 15 99 15.2% 218.16 Yorba Linda 17% 138% 40 8 17 65 26.2% 218.17 Yorba Linda 23% 122% 24 10 5 39 12.8% 218.20 Yorba Linda 34% 133% 32 1 8 41 19.5% 218.22 Yorba Linda 21% 143% 150 46 48 244 19.7% 218.23 Yorba Linda 26% 139% 28 8 6 42 14.3% 218.24 Yorba Linda 24% 168% 11 4 2 17 11.8% 1' =: Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 218.25 Yorba Linda 26% 163% 28 13 8 49 16.3% 218.26 Yorba Linda 30% 105% 29 5 2 36 5.6% 218.27 Yorba Linda 31% 183% 33 8 22 63 34.9% 218.28 Yorba Linda 33% 197% 29 7 2 38 5.3% 218.29 Yorba Linda 29% 184% 35 3 9 47 19.1% 218.30 Yorba Linda 22% 169% 32 8 3 43 7.0% 219.24 Yorba Linda 43% 145% 31 1 7 39 17.9% Subtotal 740 175 218 1,133 19.2% 11.01 Unincorp. 38% 108% 39 3 7 49 14.3% 12.01 Unincorp. 82% 57% 20 9 11 40 27.5% 14.01 Unincorp. 53% 78% 19 4 2 25 8.0% 14.02 Unincorp. 53% 90% 24 7 7 38 18.4% 15.01 Unincorp. 27% 125% 45 8 16 69 23.2% 15.06 Unincorp. 31% 128% 32 7 6 45 13.3% 17.07 Unincorp. 69% 131% 49 6 7 62 11.3% 19.03 Unincorp. 56% 67% 13 0 3 16 18.8% 117.11 Unincorp. 62% 63% 27 3 7 37 18.9% 117.15 Unincorp. 27% 134% 41 4 11 56 19.6% 117.18 Unincorp. 25% 127% 24 2 6 32 18.8% 218.12 Unincorp. 33% 109% 41 8 13 62 21.0% 218.15 Unincorp. 20% 125% 63 21 15 99 15.2% 218.16 Unincorp. 17% 138% 40 8 17 65 26.2% 218.17 Unincorp. 23% 122% 24 10 5 39 12.8% 219.12 Unincorp. 19% 194% 59 4 9 72 12.5% 219.13 Unincorp. 70% 96% 44 11 8 63 12.7% 219.14 Unincorp. 44% 110% 16 6 10 32 31.3% 219.17 Unincorp. 18% 161% 14 5 8 27 29.6% 219.18 Unincorp. 38% 120% 36 7 17 60 28.3% 21924 Unincorp. 43% 145% 31 1 7 39 17.9% 320.11 Unincorp. 10% 162% 8 1 4 13 30.8% 320.23 Unincorp. 16% 157% 206 67 89 362 24.6% 320.41 Unincorp. 21% 212% 7 5 4 16 25.0% 320.42 Unincorp. 19% 165% 32 9 6 47 12.8% 320.44 Unincorp. 13% 255% 53 14 9 76 11.8% 320.45 Unincorp. 22% 151% 19 3 6 28 21.4% 320.46 Unincorp. 14% 262% 81 24 22 127 17.3% 320.49 Unincorp. 24% 158% 74 10 21 105 20.0% 320.52 Unincorp. 13% 203% 363 76 134 573 23.4 % 320.53 Unincorp. 23% 130% 97 17 31 145 21.4% 320.56 Unincorp. 28% 163% 65 21 17 103 16.5% 2M Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract - 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 423.35 Unincorp. 29% 110% 87 24 36 147 24.5% 524.04 Unincorp. 63% 107% 4 0 1 5 20.0% 524.20 Unincorp. 50% 183% 204 47 34 285 11.9% 524.21 Unincorp. 28% 154% 45 13 11 69 15.9% 524.22 Unincorp. 26% 136% 27 3 4 34 11.8% 524.26 Unincorp. 30% 161% 155 27 39 221 17.6% 524.27 Unincorp. 32% 150% 57 17 19 93 20.4% 524.28 Unincorp. 22% 149% 56 4 6 66 9.1% 626.04 Unincorp. 11% 177% 196 47 62 305 20.3% 626.41 Unincorp. 38% 93% 79 12 13 104 12.5% 626.43 Unincorp. 22% 272% 49 5 23 77 29.9% 626.45 Unincorp. 17% 245% 34 7 15 56 26.8% 630.09 Unincorp. 12% 199% 13 5 5 23 21.7% 631.01 Unincorp. 26% 94% 10 5 1 16 6.3% 631.02 Unincorp. 19% 100% 54 12 15 81 18.5% 631.03 Unincorp. 12% 145% 12 3 5 20 25.0% 755.04 Unincorp. 37% 122% 23 4 7 34 20.6% 755.06 Unincorp. 31% 121% 25 1 6 32 18.8% 756.03 Unincorp. 22% 122% 29 15 11 55 20.0% 756.04 Unincorp. 22% 197% 53 10 18 81 22.2% 756.05 Unincorp. 27% 177% 54 8 13 75 17.3% 756.06 Unincorp. 24% 207% 50 7 14 71 19.7% 757.01 Unincorp. 43% 94% 32 2 7 41 17.1% 757.02 Unincorp. 21% 125% 25 3 14 42 33.3% 757.03 Unincorp. 18% 150% 33 4 9 46 19.6% 758.07 Unincorp. 52% 108% 23 6 18 471 38.3% 758.08 Unincorp. 21% 129% 21 3 3 27 11.1% 762.02 Unincorp. 39% 86% 42 7 14 63 22.2% 762.04 Unincorp. 79% 61% 14 7 8 29 27.6% 762.08 Unincorp. 30% 90% 103 11 44 158 27.8% 867.01 Unincorp. 65% 79% 47 14 15 76 19.7% 871.01 Unincorp. 67% 66% 9 2 7 18 38.9% 877.01 Unincorp. 54% 82% 31 9 12 52 23.1% 877.03 Unincorp. 72% 89% 26 3 9 38 23.7% 878.01 Unincorp. 56% 75% 35 3 9 47 19.1% 878.05 Unincorp. 68% 67% 29 10 15 54 27.8% 878.06 Unincorp. 78% 52% 24 8 14 46 30.4% 879.02 Unincorp. 82% 67% 25 4 9 38 23.7% 992.30 Unincorp. 26% 119% 32 5 11 48 22.9% Im Table F -4 continued Urban County Cities Conventional Loan Application Denial Rates by City and Census Tract — 2008 Census Tract City Percent Minority Med. Income as % of MSA Loans Originated App. Approved But Not Accepted App. Denied Total App. Percent Denied 994.17 Unincorp. 20% 129% 56 16 14 86 16.3% 995.06 Unincorp. 13% 129% 3 1 7 11 63.6% 995.13 Unincorp. 14% 187% 14 3 9 26 34.6% 997.01 Unincorp. 72% 80% 23 5 7 35 20.0% 997.02 Unincorp. 64% 88% 32 12 10 54 18.5% 997.03 Unincorp. 48% 116% 27 10 13 50 26.0% 1100.06 Unincorp. 18% 149% 24 4 4 32 12.5% 1100.07 Unincorp. 15% 148% 22 9 5 36 13.9% 1100.08 Unincorp. 17% 125% 45 7 10 62 16.1% 1106.04 Unincorp. 55% 102% 55 15 13 83 15.7% Subtotal 3,874 840 1,203 5,917 20.3% TOTAL 9,476 1 1,913 2,721 114,1101 19.3% Source: Federal Financial Institutions Examination Council, Home Mortgage Disclosure Act: Aggregate Table 1 Disposition of Applications, by Location of Property and Type of Loan, 2008 Table construction by Castaneda & Associates 407 This Page Intentionally Left Blank 4 02 Technical Appendix G Survey of Zoning and Planning Codes, Policies and Practices that May Pose an Impediment to Fair Housing Choice 409 FAIR HOUSING COUNCIL OF ORANGE COUNTY Fwfl Drhpgn n rbueM6 201 S. Broadway • Santa Ana, CA 92701 714/569 -0823 • Fax 714/835 -0281 • www.fairhousingoc.org SURVEY OF ZONING AND PLANNING CODES, POLICIES AND PRACTICES THAT MAY POSE AN IMPEDIMENT TO FAIR HOUSING CHOICE Name of Jurisdiction: Completing Department: Completed By: Date Completed: INTRODUCTION City of Newport Beach Planning Department Melinda Whelan 4/19/2010 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 24 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 and local developers of housing. 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. QUESTIONS [NOTE: For document automation please enable macros and then double click check boxes to check or uncheck I 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 Background 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 situating of group homes for individuals with 410 disabilities (but not families similarly sized and situated). Such definitions are prohibited because they could have the effect 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. 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 who were allowed to do so to five. Under the invalidated 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. For example, a city may have a definition of 'family' as follows: "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. [emphasis added] A definition of family should look to whether the household functions as a cohesive unit instead of distinguishing between related and unrelated persons. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: The 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 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 definition of "family" or "single housekeeping unit" 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 definition of "dwelling unit" or "residential unit" have the effect of discriminating against unrelated individuals with disabilities who reside together in a congregate or group living arrangement? Yes ❑ No X Background The definition of a "dwelling unit" or "residential unit" may exclude or restrict housing opportunities for individuals with disabilities by mischaracterizing congregate or group 411 living arrangements as "boarding or rooming house" a "hotel' or a "residential care facility'. Both State and Federal fair housing laws prohibit definitions of dwelling that either intentionally discriminate against people with disabilities or have the effect of excluding such individuals from housing. Generally, all dwellings are covered by fair housing laws, with a "dwelling" being defined as "a temporary or permanent dwelling place, abode or habitation to which one intends to return as distinguished from the place of temporary sojourn or transient visit." Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: The Zoning Code definition of a "dwelling unit" is: Any area within a structure on any parcel which: A. Contains separate or independent living facilities for one or more persons, with area or equipment for sleeping, sanitation and food preparation, and which has independent exterior access to ground level; or B. Is being utilized for residential purposes by one or more persons separately or independently from occupants of other areas within the structure. This definition does not have the effect of excluding or restricting housing opportunities for individuals with disabilities, or discriminating against unrelated individuals with disabilities who reside together in a congregate or group living arrangement. 3. Does the code or any policy document define "disability ", if at all, at least as broadly as the federal Fair Housing Act? Yes X No ❑ Background The federal Fair Housing Act (FHA) defines disability /handicap as follows: "Handicap" means, with respect to a person- - (1) a physical or mental impairment which substantially limits one or more of such person's major life activities, (2) a record of having such an impairment, or (3) being regarded as having such an impairment, but such term does not include current, illegal use of or addiction to a controlled substance (as defined in section 102 of the Controlled Substances Act (21 U.S.C. 802)). The term "physical or mental impairment" 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. 412 The California Fair Employment and Housing Act (FEHA) definition is somewhat broader, in that removes the word "substantially ". The FEHA definition is: (1) A physical or mental impairment that limits one or more of a person's major life activities (2) A record of having, or being perceived as having, a physical or mental impairment. It does not include current illegal use of, or addiction to, a controlled substance (as defined by Section 102 of the Federal Controlled Substance Act, 21 U.S.C. Sec. 802). Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: The 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 person who has a record of that type of impairment, not including current, illegal use of a controlled substance." This definition of disability is similar to the FEHA definition. 4. Are personal characteristics of residents, including, but not necessarily limited to, disability, considered? Yes ❑ No X Backoround 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 people, 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 conditional use permit or 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 DOXHUD 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 -4-13 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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 2 and 3. Explanation of Answer Given Above In light of the background provided, please arrived at the answer: provide a brief explanation of the how you Except when granting access to disabled individuals and groups that exceeds housing access granted to other similarly situated groups, the code does 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. 5. Does the code limit housing opportunities for disabled individuals through restrictions on the provision of on -site supportive services? Yes ❑ No X Background Housing for disabled persons, to be sustainable, successful and to allow them to fully use and enjoy the housing, 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." Joint Statement of the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 2. Explanation of Answer Given Above In light of the background provided, please arrived at the answer: provide a brief explanation of the how you The code places no restrictions on the provision of any on -site supportive services required by disabled individuals. 6. Does the jurisdiction policy have more restrictive limits for occupancies involving disabled residents than for other occupancies of unrelated, non - disabled persons? Yes ❑ No X Background 414 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." Joint Statement of the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 3. Explanation of Answer Given Above In light of the background provided, please arrived at the answer: provide a brief explanation of the how you The code does not consider whether groups living together are related or unrelated. 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, the City makes an exception for groups of disabled individuals. The 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. 7. 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? Yes X No ❑ Background Ajoint 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 415 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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, pages 4 and 5. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: Zoning Code Chapter 20.98 provides for reasonable accommodation. 8. If the jurisdiction supplies or manages housing, is there a clear policy to allow disabled persons residing in or seeking to reside in the housing to make or request reasonable physical modifications or to request reasonable accommodations? Yes ❑ No ❑ N/A X If `Yes', is the policy communicated to applicants or residents? Yes ❑ No ❑ Explanation of Answer Given Above Please Drovide a brief description of the Dolicv. its dissemination and its 9. Does the jurisdiction require a public hearing for disabled persons seeking specific exceptions to zoning and land -use rules (variances) necessary for them to be able fully use and enjoy housing? Yes X No ❑ If `Yes', is the process the same as for other applications for variances, or does it impose added requirements? Background 410 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. In acting consistently with "affirmatively furthering fair housing," it is considered preferable to have a reasonable accommodation procedure intended to facilitate a disabled applicant's request for exceptions to zoning and land use rules, that does not require a public hearing process. As previously explained in the joint statement by DOJ and HUD: "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 the Department of Justice and the Department of Housing and Urban Development, Group Homes, Local Land Use, and the Fair Housing Act, August 18, 1999, page 5. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you ernveo ar me answer, ano an explanaton of any ouierences for persons wrrn arsaomues: 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 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. 10.Does the zoning code distinguish housing for persons with disabilities from other residential uses by requiring an application for a conditional use permit (CUP)? Yes ❑ No X Background See the Background section for questions 7 and 9 above. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you ernveo ar me answer ana wear aspeULS of use mUraer me need ror a The code does not distinguish housing for persons with disabilities who are residing as a single housekeeping unit from any other residential use in which individuals are residing as a single housekeeping unit. Licensed residential care facilities with six or fewer residents can also establish in any residential zone without a use permit or reasonable accommodation. Licensed residential care facilities with seven or more residents, and unlicensed residential care facilities, may establish in residential zones with a CUP or reasonable accommodation, but they are the only group not living as a single housekeeping unit that can do so. By providing an opportunity to establish residences with a CUP or reasonable accommodation to disabled groups only, the code gives more favorable treatment to disabled groups not living as single housekeeping units than it gives to non - disabled groups that are not living as a single housekeeping unit. Therefore, groups of disabled individuals are distinguished only to 417 11.Describe the development standards, if any, for the provision of disabled - accessible parking for multiple - family projects. Disabled - accessible parking standards for new multiple - family projects are provided within the 2007 Edition of the California Building Code. 12. Does the code contain any development standards or special provisions for making housing accessible to persons with disabilities? Yes ❑ No X Does it specifically reference the accessibility requirements contained in the Fair Housing Amendments Act of 1988? Yes ❑ No X Background Generally, under the federal Fair Housing Amendments Act of 1988, both privately owned and publicly assisted single- story, multi - family housing units built for first occupancy on or after March 13, 1991— including both 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, or 2) are ground floor units in non - elevator buildings containing four or more units. These standards, encompassing seven basic provisions, are codified at Code of Federal Regulations Title 24, Part 100.205. Additionally, under Section 504 of the Rehabilitation Act of 1973, it is unlawful to discriminate based on disability in federally assisted programs. This section provides that no otherwise qualified individual shall, solely by reason of his or her disability, be excluded from participation (including employment), denied program benefits, or be subjected to discrimination on account of disability under any program or activity receiving federal funding assistance. Section 504 also contains accessibility provisions for dwellings developed or substantially rehabilitated with federal funds. For the purposes of compliance with Section 504, "accessible" means ensuring that programs and activities, when viewed in their entirety, are accessible to and usable by individuals with disabilities. For housing purposes, the Section 504 regulations define an accessible dwelling unit as a unit that is located on an accessible route and can be approached, entered, and used by individuals with physical disabilities. A unit that is on an accessible route and is adaptable and otherwise in compliance with the standards set forth in Code of Federal Regulations Title 24, Part 8.32 is accessible. In addition, the Section 504 regulations impose specific accessibility requirements for new construction and alteration of housing and non - housing facilities in HUD assisted programs. Section 8.32 of the regulations states that compliance with the appropriate technical criteria in the Uniform Federal Accessibility Standards (UFAS), or a standard that is equivalent to or stricter than the UFAS, is an acceptable means of meeting the technical accessibility requirements in Sections 8.21, 8.22, 8.23 and 8.25 of the Section 504 regulations. However, meeting Section 504 accessibility requirements does not exempt housing from other accessibility requirements that may be required under fair housing laws. The following Section 504 requirements apply to all federally assisted newly constructed housing and to substantial rehabilitation of housing with 15 or more units: 4Z8 A minimum of five percent of total dwelling units (but not less than one unit) accessible for individuals with mobility impairments; An additional two percent of dwelling units (but not less than one) accessible for persons with hearing or vision impairments; and All units made adaptable that are on the ground level or can be reached by an elevator. Fair housing laws do not impose a duty on local jurisdictions to include accessibility provisions in their codes, or to enforce the accessibility provisions of fair housing laws. However, the inclusions of accessibility standards and /or plan checking for accessibility compliance are significant ways that jurisdictions can affirmatively further fair housing choice for persons with disabilities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and of the standards, if any: The provision for making housing accessible to persons with disabilities is found within the 2007 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 jurisdiction conduct plan checking for accessibility compliance of covered multi - family new construction? Yes 21 No ❑ Background See the final paragraph of the Background section of question 12. If `Yes', please give a brief description of process and what items are checked. During plan check the Building Department enforces requirements from the 2007 Edition of the California Building Code regarding accessibility of covered multi - family new construction. 14.Is there a zoning ordinance or other development policy that encourages or requires the inclusion of housing units affordable to low and /or moderate income households (so- called 'inclusionary housing')? Yes ® No ❑ Background An analysis of impediments to fair housing choice must be careful to not substitute or conflate housing affordability policy with policies intended to affirmatively further fair housing. While household income is not a characteristic addressed by fair housing laws, it is appropriate to recognize that a lack of affordable housing can have a disparate impact on housing choice, on the basis of characteristics protected by fair housing laws. As demonstrated in the outcome in the recent court case of U.S. ex rel. Anti - Discrimination Center v. Westchester County, which involved failures to affirmatively further fair housing by Westchester County, New York, in appropriate circumstances the provision 4?q and situation of affordable housing can be a tool to address a lack of fair housing choice in highly segregated communities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: Currently Housing Element Program 2.21 requires a proportion of affordable housing in new residential developments or levies an in -lieu fee. A draft Inclusionary Housing Ordinance has been prepared and is currently available for public review on the City's website. The Ordinance creates a new chapter that will be included in Title 19 (Subdivision Code) of the Municipal Code and provides the basis for the in -lieu fees and procedures for the implementation of Housing Program 2.2.1. The Ordinance is anticipated to be adopted mid -year 2010. 15. Does the zoning ordinance allow for mixed uses? Yes X No ❑ If `Yes', does the ordinance or other planning policy document consider the ability of mixed -use development to enhance housing affordability? Also, do development standards for mixed -uses take into consideration the challenges of providing housing accessible to persons with disabilities in such mixed uses? Background The purpose of this inquiry relates to housing affordability and fair housing choice as discussed in the Background section of question 14. Also, 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 CFR Title 24, Part 100.205 and CCR Title 24 accessibility requirements. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief overview of the development standards: Yes, the zoning ordinance allows for mixed uses. The ordinance considers the ability of mixed -use development to enhance housing affordability and the Building Code includes standards or mixed -uses to take into consideration the challenges of providing housing accessible to persons with disabilities in such mixed -uses. 16.Does the zoning ordinance provide for any of the following: 1) development incentives for the provision of affordable housing beyond those provided by state law; 2) development by right of affordable housing; or, 3) a zoning overlay to allow for affordable housing development? Yes X No ❑ Background The purpose of this inquiry relates to housing affordability and fair housing choice as discussed in the Background section of the question 14. 420 Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you 3rriveo at the answer ano a oneT overview OT the oevelopment stanoaras: The zoning ordinance does not provide any incentives for the provision of affordable housing beyond those provided by state law but the Housing Element does. The zoning ordinance does allow the development of affordable housing by right with no special permits required when it is provided voluntarily and there are no deviations from the development standards found within the Zoning Code requested. 17.Does the zoning ordinance describe any areas in this jurisdiction as exclusive? Yes ❑ No X Are there exclusions or discussions in the ordinance or any planning policy document of limiting housing on the basis of any of the following characteristics covered by fair housing laws? Yes ❑ No X If `Yes', check all of the following that apply: Race ❑ Color ❑ Sex ❑ Religion ❑ Age ❑ Disability ❑ Familial Status ❑ National Origin ❑ 18.Are there any standards for Senior Housing in the zoning ordinance? Yes X No ❑ If `Yes', do the standards comply with state or federal law on housing for older persons (i.e., solely occupied by persons 62 years of age or older, or occupied by at least one person 55 years of age, or other qualified permanent resident pursuant to Civil Code §51.3)? Yes X No ❑ Is the location of Senior Housing treated differently than that other rental or for -sale housing? Yes ❑ No X If 'Yes', explain. Background Under federal law housing discrimination against families with children is permitted only in housing in which all the residents are 62 years of age or older or where at least 80% of the occupied units have one person who is 55 years of age or older. Generally, California law states that a housing provider using the lower age limitation of 55 years must have at least 35 units to use the familial status discrimination exemption. Also, California law, with narrow exceptions, requires all residents to be "senior citizens" or "qualified permanent residents ", pursuant to Civil Code §51.3. The 1988 amendments to the federal Fair Housing Act exempt "housing for older persons" from the prohibitions against familial discrimination. This means that housing 421- communities and facilities that meet the criteria for the federal Housing for Older Persons Act (HOPA) may legally exclude families with children. Such housing is still bound by all other aspects of fair housing law (such as prohibition of discrimination based on race, national origin or disability). Section 3607(b)(2) defines "housing for older persons" as housing: (A) provided under any State or Federal program that the Secretary determines is specifically designed and operated to assist elderly persons (as defined in the State of Federal program); or (B) intended for, and solely occupied by, persons 62 years of age or older; or (C) intended and operated for occupancy by persons 55 years of age or older and — (i) at least 80 percent of the occupied units are occupied by at least one person who is 55 years of age or older; (ii) the housing facility or community publishes and adheres to policies and procedures that demonstrate the intent required under this subparagraph; and (iii) the housing facility or community complies with rules issued by the Secretary for verification of occupancy, which shall — (1) provide for verification by reliable surveys and affidavits, and (11) include examples of the types of policies and procedures relevant to a determination of compliance with the requirement of clause (ii). Such surveys and affidavits shall be admissible in administrative and judicial proceedings for the purposes of such verification. Subsection (C) was changed by the Housing for Older Persons Act of 1995 (HOPA) to remove some of the uncertainties created by a provision in the 1988 Amendments that required the "existence of significant facilities and services specifically designed to meet the physical and social needs of older persons." The HOPA also provides for a good faith defense in an action for monetary damages under this subsection. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you irnvea at me answer ana a onef overview of the Zoning Code Ch. 20.85 allows for the creation of granny units pursuant to California Government Code Section 65852.1 in zoning districts where there is only one dwelling unit permitted. Other than Ch. 20.85, there are no other standards for senior housing within the zoning ordinance and it is not treated differently than other rental or for -sale housinq. 19.Does the zoning code distinguish senior citizen housing from other residential uses by the application of a conditional use permit (CUP)? Yes ❑ No X 422 Background Senior housing is an important component of the community's housing stock. Demographic projections show that many communities will experience a growth in the elderly population. As a population ages, seniors need a variety of housing opportunities. Also, there is a higher prevalence of persons with disabilities within the senior population. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and what aspects of use trigger the need for a permit: The Zoning Code distinguishes between convalescent housing and residential uses but not between senior citizen housing and residential uses. 20.Does the zoning code or other planning policy document address housing for "special needs" populations? Yes X No 0 Background Special needs populations typically are considered to be homeless people, victims of domestic violence, people with disabilities (including those recovering from substance abuse), youth in crisis, people living with HIV /AIDS and the frail elderly. Of these groups, homeless people, victims of domestic violence, people with disabilities, and people living with HIV /AIDS have direct fair housing implications. There is a high incidence of disability in the homeless population, domestic violence overwhelming impacts women; and people living with HIV /AIDS are considered disabled under fair housing laws. While age is not a characteristic protected under federal fair housing law, it is covered under state law, and the higher incidence of disability in the frail elderly introduces possible fair housing implication for that population as well. These populations often rely on group homes or service - enriched multi - family settings for housing opportunities. To the extent that zoning and other planning policy documents fail to provide for, or impose barriers to, these types of housing an impediment to fair housing choice might exist. As previously noted, according to the DOJ and HUD, the term 'group home' does not have a specific legal meaning. While it often implies a living situation for people with disabilities, it also applies to any group of unrelated persons, often sharing common characteristics, who live together in a dwelling. This broader use of the term encompasses 'special needs' individuals. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer and a brief explanation of 'special needs' provisions, if any: Housing Element Goal H5 and Housing Programs 5.1.1 through 5.1.6 found in the Housing Element address the housing needs of the special needs population within the City. 423 21. Does the zoning ordinance establish occupancy standards or maximum occupancy limits that are more restrictive than state law, which incorporates the Uniform Housing Code (UHC)? Yes ❑ No X Background Occupancy standards sometimes can impede housing choice for families with children or for disabled persons. For example, some jurisdiction's zoning regulations have attempted to limit occupancy to five related persons occupying a single family home, or to strictly establish an occupancy standard of no more than two persons per bedroom. Such regulations can limit housing availability for some families with children, or prevent the development of housing for disabled persons. The federal Fair Housing Act (FHA) also 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." [Section 807(b)(1)] HUD implements section 589 of the Quality Housing and Work Responsibility Act (QHWRA) of 1988 by adopting as its policy on occupancy standards for purposes of enforcement actions under the FHA, the standards provided in the Memorandum of General Counsel Frank Keating to Regional Counsel dated March 20, 1991. The purpose of that Memorandum was "to articulate more fully the Department's position on reasonable occupancy policies and to describe the approach that the Department takes on its review of occupancy cases." The Memorandum states the following: "Specifically, the Department believes that an occupancy policy of two persons in a bedroom, as a general rule, is reasonable under the Fair Housing Act. [. .] However, the reasonableness of any occupancy policy is rebuttable, and neither the February 21 [1991] memorandum nor this memorandum implies that Department will determine compliance with the Fair Housing Act based solely on the number of people permitted in each bedroom." [emphasis added] The memorandum goes on to reiterate statements taken from the final rule implementing the Fair Housing Amendments Act of 1988 as follows: • "[T]here is nothing in the legislative history that indicates any intent on the part of Congress to provide for the development of a national occupancy code ...." "Thus, the Department 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 that, in connection with a complaint alleging discrimination on the basis of familial status, the Department will carefully examine any such nongovernmental restriction to determine whether it operates unreasonably to limit or exclude families with children." "U.S. Department of Housing and Urban Development, Memorandum to All Regional Counsel from Frank Keating on the subject of Fair Housing Enforcement Policy: Occupancy Cases, March 20, 1991. O i Essentially, HUD has established a starting point for assessing the reasonableness of occupancy restrictions, but has stated that the specific facts of each living situation must inform the final determination of reasonableness. While the above discussion relates to matters of discrimination affecting families with children, a similar analysis applies to standards that may limit housing choice for persons with disabilities. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrivea at me answer ana the star The specific facts of each living situation inform the final determination of any occupancy limits imposed when uses apply for a use permit. For uses granted a use permit in residential zones, the Zoning Code sets forth a general occupancy limit of two residents per bedroom plus one additional resident, but allows flexibility for an applicant to request and receive a different number of occupants when appropriate. NBMC Section 20.91A.050.C.2 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." 22.Does the jurisdiction encourage or require affordable housing developments to give an admission preference to individuals already residing within the jurisdiction? Yes ❑ No X If 'Yes', is it a requirement? Yes ❑ No ❑ Background This practice may have fair housing implications if the population of the jurisdiction lacks diversity or does not reflect the demographic makeup of the larger region in which it is located. There may be a barrier to fair housing choice, in that the policy can have a discriminatory affect on the basis of characteristics considered by fair housing laws. For example if a jurisdiction already lacks housing suitable to people with mobility - related disabilities, the local population may have an under representation of such individuals, when compared to the population generally. Newly developed accessible housing that could meet the needs of such individuals, but which has a local resident admission preference, would be less likely to improve the ability of people with mobility - related disabilities to live in the jurisdiction. Likewise, a jurisdiction with an under representation of minority residents is likely to perpetuate that situation if a local resident admission preference is implemented for new affordable housing development. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: 425 23. Does the jurisdiction have any redevelopment areas? Yes X No If `Yes', does the jurisdiction analyze possible impacts on fair housing choice resulting from its redevelopment activities? Yes ❑ No X Background Redevelopment activities can result in the permanent displacement of residents. If the housing opportunities created by the redevelopment activity could result in a different demographic mix of residents, consideration needs to be given as to whether this difference represents an impediment, an enhancement or is neutral with respect to fair housing choice. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer: Santa Ana Heights is considered a redevelopment area however the County oversees the redevelopment activities. 24.Does the zoning ordinance or other planning or policy document include a discussion of fair housing? Yes X No ❑ If 'Yes', how does the jurisdiction propose to further fair housing? Background Affirmatively furthering fair housing is an important responsibility of local government. In order to receive certain federal funds a jurisdiction must certify that it is taking actions to "affirmatively further fair housing" (AFFH). Although a jurisdiction may have numerous plans, policies, and standards, fair housing is rarely discussed in a zoning ordinance. Other documents of a jurisdiction may discuss the need to affirmatively further fair housing and the policies and actions that are in place to do so. Explanation of Answer Given Above In light of the background provided, please provide a brief explanation of the how you arrived at the answer, a description of where AFFH discussions, if any, may be found, and a brief summary of how AFFH is accomplished: The Zoning Code provides a definition of fair housing laws. In accordance with federal and state Fair Housing laws Zoning Code Chapter 20.98 provides reasonable accommodations in the City's zoning and land use regulations, policies and practices, when needed to provide an individual with a disability an equal opportunity to use and enjoy a dwelling. IDENTIFIED IMPEDIMENTS AND PROPOSED CORRECTIVE ACTIONS Based on your responses to questions 1 -24, please: 420 a) provide a concise list of the zoning and planning impediments to fair housing choice hat you nave iaentunea The City does not believe its Code contains any zoning or planning impediments to fair housing choice. b) describe the actions that will be taken over the next five years to remove or ameliorate the identified impediments. ACKNOWLEDGMENTS: Thanks go to David A. Acevedo and Jesus Velo, of the HUD Los Angeles Fair Housing and Equal Opportunity Office, and Ralph Castaneda, Jr., of Castaneda & Associates, for providing substantial content that went into the preparation of this survey. PLEASE RETURN COMPLETED SURVEY VIA E -MAIL TO DAVID LEVY AT: dievy(a)-fairhousingoc.org