HomeMy WebLinkAbout14 - Regional Analysis of Impediments to Fair Housing ChoiceP0 m CITY OF
z NEWPORT BEACH
City Council Staff Report
May 10, 2016
Agenda Item No. 14
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: Kimberly Brandt, Community Development Director - 949-644-3232,
kbrandt@newportbeachca.gov
PREPARED BY: James Campbell, Principal Planner
0cam pbell(a�newportbeachca.gov
PHONE: 949-644-3210
TITLE: Regional Analysis of Impediments to Fair Housing Choice
ABSTRACT:
Participation in the Federal Community Development Block Grant (CDBG) requires the
City to take steps to further fair housing choice, address discriminatory housing
practices, and address impediments to fair housing choice. Jurisdictions must
periodically prepare an Analysis of Impediments to Fair Housing Choice as a way to
guide efforts to address housing discrimination. The U.S. Department of Housing and
Urban Development (HUD) recommends a regional approach given that many fair
housing issues fall outside a single jurisdiction ability to address. Sixteen Orange
County cities, including the City of Newport Beach, worked together to prepare the draft
Regional Analysis of Impediments to Fair Housing Choice (Attachment A). The
document includes a fair housing plan that will guide each city for the next 5 years.
RECOMMENDATION:
a) Conduct a public hearing;
b) Find this action not subject to the California Environmental Quality Act (CEQA)
pursuant to Sections 15060(c)(2) and 15060(c)(3) of the CEQA Guidelines,
California Code of Regulations, Title 14, Chapter 3; and
c) Approve the 16 City Regional Analysis of Impediments to Fair Housing Choice for
Newport Beach.
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Regional Analysis of Impediments to Fair Housing
May 10, 2016
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FUNDING REQUIREMENTS:
The current adopted budget and the anticipated budget for the upcoming fiscal year will
include sufficient funding for staff to review and potentially implement the recommended
action items. The action items may include several minor code amendments.
Additionally, $12,000 is generally appropriated with the Federal Community
Development Block Grant Annual Action Plan annually for fair housing services. The
Fair Housing Foundation currently provides these services. An increase in funding may
be necessary in the future to provide enhanced services if determined necessary. The
amount of future increases in not known at this time but is not expected to be
significant. Funding could be expensed to the CDBG program; however, due to Federal
limits on administrative costs that can be charged to the program and overall
administration expenses, additional funding may need to come from the General Fund.
DISCUSSION:
The Analysis of Impediments to Fair Housing Choice, which is referred to as the Al,
examines policies, procedures, and practices within a community that may limit a
person's ability to choose their residence free from discrimination. This Al provides an
overview of laws, regulations, conditions or other possible obstacles that may affect an
individual's or a household's access to housing in a community. It also presents local
and regional demographic profiles, assesses the extent of housing needs among
specific groups, identifies existing barriers or impediments that may limit housing
choice, and proposes actions to overcome those barriers. The Al Executive Summary
includes a summary of action recommendations, which are fully described in the fair
housing plan provided in Section 8 of the document.
The 16 participating cities are Anaheim, Buena Park, Costa Mesa, Fountain Valley,
Fullerton, Garden Grove, Huntington Beach, La Habra, Lake Forest, Mission Viejo,
Newport Beach, Orange, Rancho Santa Margarita, San Clemente, Santa Ana and
Tustin. The group represents over 2.1 million residents and is 40.2% of the County
population. The County of Orange is in the process of preparing a similar document for
most of the remaining cities. The City of Irvine has prepared their Al.
Five noticed community workshops were conducted in September and October of 2015.
The meetings provided the opportunity for the community to gain awareness of fair
housing laws, and for residents and service agencies to share fair housing issues and
concerns. To supplement the community meetings and to assist in further
understanding fair housing issues in the region, a Fair Housing Survey was made
available to Orange County residents at the city halls of the 16 cities and via each City's
website. In addition, surveys were provided to service providers by request. The Fair
Housing Survey was also available in Spanish, Vietnamese, and Korean. During the
four-week survey period in September and October 2015, 188 surveys were completed
online or in hardcopy by Orange County residents. The survey and summaries of the
responses are provided in the document and were used during the preparation of the
Al.
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Regional Analysis of Impediments to Fair Housing
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In summary, the City needs to continue to support the provision of fair housing services.
The Fair Housing Foundation provides a series of free public workshops to tenants,
landlords, real estate professionals and property managers. They provide dispute
resolution services and investigate claims of discrimination. The report's findings
suggest that all of the cities should enhance the promotion of fair housing education and
better coordinate when necessary to address larger regional issues that are bigger than
one city can address alone. These types of activities can be staff intensive and the City
relies upon a fair housing service provider. Enhancing efforts could lead to escalating
costs and although these costs are not considered significant, they would need to come
from the General Fund given that the administrative costs with the CDBG program are
limited. Lending practices in Newport Beach were found to be non-discriminatory.
Specific recommendations for Newport Beach are:
1. Consider amending its Reasonable Accommodation procedures to eliminate the
requirement for a public hearing, and to approve them administratively.
2. Consider pursuing a Zoning Code amendment to eliminate the current age
restriction on second units in single-family zones and establish a ministerial
review process.
3. Update Zoning Code to reflect current State density bonus laws.
Staff has not included an analysis of these items at this point. Staff may include
changes in the next round of Zoning Code "clean-up" amendments if they prove
necessary.
Approval of the Al does not mandate the City to follow each recommendation as
presented. However, each year the City must certify to HUD through the CDBG
program that it is taking affirmative steps to further fair housing choice. The
recommendations in the Al will provide the community, City and HUD a framework to
access how the City is performing in the future.
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.
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Regional Analysis of Impediments to Fair Housing
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NOTICING:
Notice of Public Review of the draft Analysis of Impediments was published in the
Orange County Register, La Opinion, and Viet Boa newspaper in early March 2016.
Additionally, a Notice of Public Hearing and 30 -day Public Review was published in the
Daily Pilot on April 9, 2016. The notices and this public hearing are required by the
City's Citizen Participation Plan. Finally, 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).
ATTACHMENT:
Attachment A — Analysis of Impediments to Fair Housing Choice
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Attachment A
Analysis of Impediments to Fair Housing Choice
14-5
City of Newport Beach
City of Anaheim
City of Buena Park
City of Costa Mesa
City of Fountain Valley
City of Fullerton
City of Garden Grove
City of Huntington Beach
City of La Habra
City of Lake Forest
City of Mission Viejo
City of Newport Beach
City of Orange
City of Rancho Santa Margarita
City of San Clemente
City of Santa Ana
City of Tustin
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table of Contents
EXECUTIVE SUMMARY.............................................................................................. i
A. WHAT IS THE ANALYSIS OF IMPEDIMENTS.................................................................. ii
B. DEFINING FAIR HOUSING............................................................................................. ii
C. COMMUNITY PARTICIPATION...................................................................................... ii
D. SUMMARY OF Al FINDINGS AND CONCLUSIONS......................................................... v
E. RECOMMENDED ACTIONS TO ADDRESS IMPEDIMENTS ............................................ vi
1. INTRODUCTION............................................................................................... 1
A. PURPOSE OF THE ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE ...............1
B. LEAD AGENCIES AND GEOGRAPHIC AREA COVERED...................................................1
C. FAIR HOUSING LEGAL FRAMEWORK............................................................................3
D. ORGANIZATION OF THE REGIONAL Al .........................................................................4
E. DATA SOURCES............................................................................................................ 5
2. COMMUNITY PARTICIPATION.......................................................................... 7
A. COMMUNITY WORKSHOPS..........................................................................................7
B. FAIR HOUSING SURVEY................................................................................................8
C. AGENCY CONSULTATION............................................................................................. 9
D. PUBLIC REVIEW............................................................................................................9
3. COMMUNITY AND REGIONAL PROFILES........................................................ 10
A. DEMOGRAPHIC PROFILE............................................................................................10
B. HOUSEHOLD PROFILE................................................................................................22
C. INCOME PROFILE.......................................................................................................26
D. SPECIAL NEEDS HOUSEHOLDS...................................................................................33
E. HOUSING PROFILE......................................................................................................41
F. HOUSING ISSUES PROFILE..........................................................................................48
G. PUBLIC AND ASSISTED HOUSING...............................................................................
SO
H. RESIDENTIAL CARE FACILITIES....................................................................................S3
I. ACCESSIBILITY TO PUBLIC TRANSPORTATION............................................................
S5
TABLE OF CONTENTS
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REGIONAL ANALYSIS OF IMPEDIMENTS
4. MORTGAGE LENDING PRACTICES.................................................................. 60
A. LENDING LAWS AND REGULATIONS..........................................................................60
B. OVERALL LENDING PATTERNS...................................................................................64
C. LENDING PATTERNS BY RACE/ETHNICITY AND INCOME LEVEL.................................68
D. LENDING PATTERNS BY CENSUS TRACT CHARACTERISTICS.......................................80
E. LENDING PERFOMANCE BY LENDER..........................................................................82
F. SUB -PRIME LENDING MARKET...................................................................................86
G. PREDATORY LENDING................................................................................................88
H. FORECLOSURES..........................................................................................................89
5. PUBLIC POLICIES AND PRACTICES.................................................................. 91
A. GENERAL PLAN POLICIES AFFECTING HOUSING DEVELOPMENT..............................91
B. ZONING ORDINANCE..................................................................................................94
C. BUILDING CODES AND OCCUPANCY STANDARDS.....................................................99
D. AFFORDABLE HOUSING DEVELOPMENT..................................................................101
E. OTHER LAND USE POLICIES, PROGRAMS AND CONTROLS ......................................103
F. ZONING REGULATIONS FOR PERSONS WITH DISABILITIES......................................107
G. LOCAL HOUSING AUTHORITIES................................................................................108
H. COMMUNITY REPRESENTATION AND PARTICIPATION............................................112
6. FAIR HOUSING PROFILE................................................................................11"
A. FAIR HOUSING PRACITICES IN THE HOMEOWNERSHIP MARKET ............................114
B. FAIR HOUSING PRACTICES IN THE RENTAL MARKET...............................................118
C. FAIR HOUSING SERVICES..........................................................................................120
D. FAIR HOUSING STATISTICS AND TRENDS.................................................................122
E. TENANT -LANDLORD SERVICES.................................................................................124
F. HATE CRIMES...........................................................................................................126
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A. STATUS OF 2010-2015 ORANGE COUNTY REGIONAL Al ACTIONS ..........................128
B. STATUS OF 2010-2015 SUB -REGIONAL Al ACTIONS ................................................135
8. FAIR HOUSING PLAN....................................................................................142
A. REGIONAL IMPEDIMENTS CARRIED OVER FROM 2010 REGIONAL AND
SUBREGIONAL AI...........................................................................................142
B. PUBLIC SECTOR IMPEDIMENTS................................................................................145
TABLE OF CONTENTS
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
APPENDIX A: COMMUNITY PARTICIPATION
APPENDIX A-1: FAIR HOUSING WORKSHOPS
APPENDIX A-2: FAIR HOUSING SURVEYS
APPENDIX A-3: PUBLIC REVIEW NOTICES
APPENDIX R: PUBLIC TRANSIT AND MAJOR EMPLOYMENT CENTERS
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APPENDIX C-1: HOME PURCHASE LOAN ACTIVITIES 2008-2013
APPENDIX C-2: PERCENT OF DENIED PURCHASE LOANS - BY CENSUS TRACT - APPLICANT
RACE/ETHNICITY
APPENDIX D: HUD WORKSHEET
APPENDIX D: HUD WORKSHEET
TABLE OF CONTENTS
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REGIONAL ANALYSIS OF IMPEDIMENTS
LIST OF TABLES
3-1.
Population Growth 2000-2015...................................................................................................11
3-2.
Age Distribution of Population 2013...........................................................................................12
3-3.
Age Characteristics 2013.............................................................................................................14
3-4.
Racial and Ethnic Composition of Population 2000 and 2013 ....................................................16
3-5.
Growth in Racial/Ethnic Group Populations 2000-2013.............................................................18
3-6.
Limited English Speaking Households 2013................................................................................21
3-7.
Household Growth 2000-2015....................................................................................................22
3-8.
Household Tenure......................................................................................................................
23
3-9.
Average Household Size by Tenure.............................................................................................24
3-10.
2015 State Income Limits for Orange County.............................................................................
26
3-11.
Median Household Income.........................................................................................................27
3-12.
Family Households Below Poverty Level, 2013...........................................................................29
3-13.
Income Levels by Tenure 2012...................................................................................................
31
3-14.
Household Characteristics 2013.................................................................................................34
3-15.
Persons Per Owner and Renter Households, 2013.....................................................................
35
3-16.
Disability Characteristics of Seniors and Working -Age Adults 2013 ...........................................37
3-17.
Homeless Point in Time Count 2013 and 2015...........................................................................40
3-18.
Housing Growth 2000-2015........................................................................................................41
3-19.
Housing Stock by Type 2015.......................................................................................................42
3-20.
Housing Stock by Year Built, 2013..............................................................................................44
3-21.
Cost of Housing, 2015.................................................................................................................45
3-22.
Maximum Affordable Housing Prices and Rents by Income Groups 2015 .................................46
3-23.
Future Housing Needs by Income Level, 2014-2021..................................................................47
3-24.
Overpayment by Tenure 2012....................................................................................................48
3-25.
Overcrowding by Tenure 2013...................................................................................................
50
3-26.
Orange County Housing Authority Section 8 Program Recipients by City ..................................
52
3-27.
Licensed Community Care Facilities............................................................................................54
3-28.
OCTA Bus Fare Structure 2015....................................................................................................56
3-39.
OCTA Cost of Bus Passes 2015....................................................................................................
57
4-1.
Status of Home Purchase Loans 2013.........................................................................................65
4-2.
Status of Home Refinance Loans 2013.......................................................................................
66
4-3.
Status of Home Improvement Loans 2013.................................................................................
67
4-4.
Status of Home Purchase Loans by Applicant Race - 2013 ........................................................
69
4-5.
Home Purchase Loans - Completed Loan Applications Percent of Total, 2008 to 2013............
70
4-6.
Home Purchase Loans - Comparisons, Completed Loan Applications and
Percentof City, 2013.......................................................................................................
72
TABLE OF CONTENTS
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REGIONAL ANALYSIS OF IMPEDIMENTS
4-7.
Denied by Race — Purchase Loans — 2013................................................................................... 73
4-8.
Home Purchase Loans — Denial Rate Percentages, 2008 to 2013 ...............................................
74
4-9.
Purchase Loans — Denied by Race/Ethnicity — Per Census Tract — 2013 .....................................
75
4-10.
Status of Home Purchase Loans by Applicant Income 2013 .......................................................77
4-11.
Denied Home Purchase Loans by Applicant Income 2013.........................................................79
4-12.
Purchase Loans — Denied by Income — Per Census Tract — 2013 ................................................
81
4-13.
Top 10 Lenders —All Home Loan Applications, 2013..................................................................83
4-14.
Top 10 Lenders — Market Share and Income and Minority Categories - All Home Loan
Applications, 2013......................................................................................................................85
4-15.
Home Purchase Loans — Rate Spread, 2011 to 2013..................................................................86
4-16.
Home Purchase Loans — Rate Spread —Top Orange County Lenders, 2011 & 2013 ..................
87
4-17.
All Types of Loans — High Cost Loans (HOEPA), 2011 to 2013 ....................................................88
4-18.
Foreclosures, September 2015...................................................................................................89
4-19.
Foreclosures and Market Sales Prices, September 2014 & 2015 ...............................................90
5-1.
Typical Residential Land Use Designations.................................................................................93
5-2.
Zoning for a Variety of Housing Types........................................................................................
95
5-3.
Affordable Rental Units.............................................................................................................101
5-4.
Development Fees....................................................................................................................102
5-5.
Density Bonus Concessions.......................................................................................................103
5-6.
Community Outreach by Cities.................................................................................................113
6-1.
Discrimination Cases by Protected Class: 2012/13 — 2014/15 .................................................123
6-2.
Tenant/Landlord Complaints and Inquiries 2012/13 — 2014/15 ..............................................125
6-3.
FBI Hate Crime Statistics 2010-2014.........................................................................................127
8-1.
Fair Housing Action Plan 2015/16 — 2019/20...........................................................................148
LIST OF FIGURES
1-1. 16 Orange County Participating Cities.......................................................................................... 2
3-1. Age Distribution 2013.................................................................................................................13
3-2. Population by Race/Ethnicity 2013.............................................................................................17
3-3. Minority Group Population by Census Tracts 2013....................................................................20
3-4. Household Size............................................................................................................................25
3-5. Household Distribution by Income 2013....................................................................................28
4-1. Minority Population - Purchase Loan Denials by Census Tracts 2013 ........................................76
TABLE OF CONTENTS
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REGIONAL ANALYSIS OF IMPEDIMENTS
TABLE OF CONTENTS
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Executive Summary
The U.S. Department of Housing and Urban Development (HUD) requires entitlement jurisdictions --
HUD grant recipients -- to develop an Analysis of Impediments to Fair Housing Choice and evaluate
its fair housing issues as an individual jurisdiction and within the context of a larger region. In Orange
County, 16 entitlement cities have elected to prepare a regional Analysis of Impediments to Fair
Housing Choice, referred to as the Al, to fulfill their HUD requirement and remove barriers to fair
housing choice for all their residents.
A. What is the Analysis of Impediments
This Analysis of Impediments to Fair Housing Choice, which is referred to as the Al, examines policies,
procedures, and practices within a community that may limit a person's ability to choose their
residence free from discrimination. This Al provides an overview of laws, regulations, conditions or
other possible obstacles that may affect an individual or a household's access to housing in a
community. It also presents local and regional demographic profiles, assesses the extent of housing
needs among specific groups, identifies existing barriers or impediments that may limit housing
choice, and proposes actions to overcome those barriers.
Participating Cities
The 16 participating cities within Orange County that have collaborated in the preparation of this
regional Al include:
■ Anaheim
■ Buena Park
■ Costa Mesa
■ Fountain Valley
■ Fullerton
■ Garden Grove
■ Huntington Beach
■ La Habra
Current Al Process
■ Lake Forest
■ Mission Viejo
■ Newport Beach
■ Orange
■ Rancho Santa Margarita
■ San Clemente
■ Santa Ana
■ Tustin
This Al is consistent with the current HUD requirements, and follows the guidelines according to
HUD's Fair Housing Planning Guide. However, in July 2015, HUD announced the release of a final
rule to Affirmatively Further Fair Housing (AFFH), which will replace the existing Al with a new
Assessment of Fair Housing (AFH). The key differences between the current Al and the new AFH are
EXECUTIVE SUMMARY
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
that HUD will provide data and an AFH Assessment Tool Template for conducting the fair housing
analysis; grantees will be required to incorporate fair housing planning into their Consolidated Plans;
and HUD will review assessments upfront as part of the planning process. The due date for the first
AFH is 270 days prior to the program year that begins on or after January 1, 2017 (or January 1, 2018,
depending on grantee type) for which a jurisdiction submits a new Consolidated Plan. Since the
Orange County participating cities have recently submitted their Consolidated Plans for the 2015/16-
2019/20 period, the AFH will not be required until 270 days before the start of the next five-year
cycle in 2020/21.1 Therefore, this Regional Analysis of Impediments to Fair Housing Choice for 16
Orange County Cities is prepared under the current HUD Al requirements.
B. Defining Fair Housing
Fair housing are rules that protect a person from being discriminated against during the sales, rental
or leasing of housing. According to HUD's Fair Housing Planning Guide, and based within the legal
framework of federal and state laws, impediments to fair housing choice are:
■ Any actions, omissions or decisions taken because of race, color, ancestry, national origin,
religion, sex, disability, age, marital status, familial status, source of income, sexual
orientation or any other arbitrary factor that restricts housing choices or the availability of
housing choices, or
■ Any actions, omissions or decisions that have the effect of restricting housing choices or the
availability of housing choices on the basis of race, color, ancestry, national origin, religion,
sex, disability, age, marital status, familial status, source of income, sexual orientation or any
other arbitrary factor.
In California, this also includes discrimination based on one's citizenship or immigration status. HUD
also distinguishes between housing affordability and fair housing. Economic factors that affect a
household's housing choices are not fair housing issues per se. Only when the relationship between
household income, household type, race/ethnicity and other factors create misconceptions, biases
and differential treatment would fair housing concerns arise.
C. Community Participation
In order to identify factors that could indicate impediments to fair housing choice, this Al
incorporated a community outreach effort that included five community meetings, an on-line fair
housing survey, consultation with fair housing and other service providers, and .
Community Workshops
During the preparation of this Al, residents, businesses, and public and private agencies were invited
to participate in the discussion of fair housing issues in Orange County. The five community
workshops were conducted on the following dates and at five different locations:
1 The City of San Clemente adopted a five year Consolidated Plan for the 2013/14-2017/18 period, and therefore
its first AFH will be due by October 1, 2017.
EXECUTIVE SUMMARY
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
■ September 22, 2015 — Assembly Hall, Downtown Anaheim Community Center, 250 E.
Center, Anaheim, 6:00 p.m.
■ September 23, 2015 — Professional Training Center, Tustin Library, 345 E. Main Street,
Tustin, 6:00 p.m.
■ September 24, 2015 – City Hall Council Chambers, 10200 Slater Avenue, Fountain Valley,
6:00 p.m.
■ September 30, 2015 – Santa Ana Police Community Room, 60 Civic Center Plaza, Santa Ana,
6:00 p.m.
■ October 1, 2015 – City Hall, Community Room, 25550 Commercentre Drive, Lake Forest, 6:00
p.m.
The meetings provided the opportunity for the community to gain awareness of fair housing laws,
and for residents and service agencies to share fair housing issues and concerns. To ensure that the
fair housing concerns of low- and moderate -income and special needs residents were addressed,
individual invitation letters were distributed via mail and email, if available, to agencies and
organizations that serve the low- and moderate -income and special needs community.
A notice of the Fair Housing Workshops was available in English, Spanish, and Vietnamese and
published in the Orange County Register, La Opinion, and the Viet Bao Daily News. In addition,
community workshop notices were posted on the various City websites. Copies of the Fair Housing
Workshop notices and each City's outreach mailing list to housing agencies and organizations are
included in Appendix A-1 of this Al. As a result of an extensive outreach effort, attendance at the
public meetings included several service providers and citizen groups that work with residents
considered a protected class according to HUD's definition.
A summary of key comments from the community workshops included:
■ Affordable Housing: Increasing rents coupled with low vacancies have made it difficult to
find affordable rental units. Some feel that landlords use the strong market to discriminate
among potential renters.
■ Information on Housing Discrimination: Many residents lacked information on tenant
rights, such as when landlords asked for immigration documents. Residents did not know
where to get help when they felt they had been discriminated against.
■ Mothers with Children: A common complaint was the difficulty of families, especially
mothers with children, in finding housing.
■ Overcrowding: Problem was brought up by both residents and property managers.
■ Special Needs Housing: Need for affordable rental housing units for seniors, persons with
disabilities, and veterans.
EXECUTIVE SUMMARY
iii
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16 ORANGE COUNTY CITIES
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Fair Housing Survey
To supplement the community meetings and to assist in further understanding fair housing issues in
the region, a Fair Housing Survey was made available to Orange County residents at the City Halls of
the 16 -Cities and via each City's website. In addition, surveys were provided to service providers by
request. The Fair Housing Survey was also available in Spanish, Vietnamese, and Korean. During the
four-week survey period in September and October 2015, 188 surveys were completed online or in
hardcopy by Orange County residents. Of the total, 59 percent were Spanish-speaking, 40 percent
English-speaking, and one percent Vietnamese -speaking respondents. Samples of the Fair Housing
surveys in the four languages are included as Appendix A-2 of this Al.
The survey consisted of questions designed to gather information on a person's experience with fair
housing issues and perception of fair housing issues in their community. A summary of the key
survey results included:
■ Almost 60 percent of respondents completed the survey that was translated in Spanish.
■ 57 percent of respondents have encountered housing discrimination, and of those, 88
percent felt landlord/property managers were responsible.
■ 82 percent of the discrimination occurred in an apartment complex.
■ One-half of those discriminated felt it was because of family status (families with children).
■ Over 90 percent did not report the discrimination incident.
■ 14 percent have been denied reasonable accommodation.
■ Three-quarters of respondents felt they had little to no information on housing
discrimination law, and one-third would not know what to do when discriminated.
Agency Consultation
A Working Group was formed with key staff representing each of the 16 cities participating in the
development of this Al. The Working Group provided valuable information and insight into their
community housing needs and fair housing issues. Monthly meeting were held in various
participating cities to discuss the data needs, the community outreach effort, the Al approval
process, the action plan recommendations, and the review of the Al.
In addition to information gained through the workshops and survey, numerous phone interviews
were conducted with agencies such as the Fair Housing Foundation, the Fair Housing Council of
Orange County, and the Orange County Housing Authority.
Public Review
During a 30 -day public review period from March 9 to April 7, 2016, the draft Al document was made
available at city halls and on websites of the 16 -participating cities. During this review period, no
written comments were received on the draft Al.
EXECUTIVE SUMMARY
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Public review notices were published in the Orange County Register, La Opinion, and Viet Bao Daily
News on March 8, 2016. Published copies of the public review notices are included in Appendix A-3.
D. Summary of Al Findings and Conclusions
The following is a summary of the key findings from the Al:
■ The number of fair housing cases opened by the Fair Housing Foundation and the Fair
Housing Council of Orange County in the 16 participating cities total 85 over the last three
years, with the leading bias based on disability (physical and mental), followed by familial
status, national origin and race.
■ The racial and ethnic distribution of Orange County's population appears diverse, with 56
percent of the total population comprised of Hispanics, Asians, African Americans, and other
non-white groups. However, within the County there are areas of racial/ethnic
concentrations, such as in Santa Ana where over three-quarters of the population is Hispanic
and ten percent Asian. Approximately ten percent of households in the County are
considered to be limited English-speaking households.
■ Denial of reasonable modification or reasonable accommodation is a continuing impediment
to fair housing choice.
■ Incidents of discriminatory advertising that have potentially discouraged a certain type of
renter or buyer have occurred.
■ An average of 35 hate crimes are committed annually within the 16 participating cities. The
highest number of hate crimes have occurred in the Cities of Huntington Beach, Santa Ana,
Newport Beach and Garden Grove.
■ Disparities exist in the home purchase loan denial rates experienced by Hispanic and
Black/African American applicants within the 16 cities, with these groups evidencing loan
denial at rates 1.5 to 1.6 times greater than White applicants. Cities with a large Hispanic
population have a disproportionately smaller number of home purchase loans.
■ Fifteen of the 16 Housing Elements are in compliance with state Housing Law. The City of
San Clemente's draft 2014-2021 Housing Element was submitted for State review in early
2016.
■ Zoning regulations related to second units, single -room occupancy housing (SRO), and
transitional/supportive housing in a few cities should be amended to improve access to
housing choice for all populations.
■ Although all jurisdictions have adopted local density bonus ordinances, the recent addition of
anti -displacement provisions under AB 2222 and modified parking standards for transit -
accessible projects under AB 744, will require updates to local density bonus ordinances.
EXECUTIVE SUMMARY
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
E. Recommended Actions to Address Impediments
The following actions are recommended to address the impediments to fair housing choice in the 16 -
city Regional Al:
Regional Impediments Carried Over from 2010 Regional and Subregional Al
A-1. Housing Discrimination
Recommendations for All Jurisdictions:
■ In partnership with each city's fair housing provider, conduct multi -faceted fair housing
outreach to tenants, landlords, property owners, realtors, and property management
companies. Methods of outreach should include workshops, informational booths,
presentations to civic leaders and community groups, staff trainings, and distribution of
multi-lingual fair housing literature.
■ Conduct focused outreach to small property owners/ landlords; conduct property manager
trainings on a regular basis; promote fair housing certificate training.
■ Provide general counseling and referrals to address tenant -landlord issues, and provide
periodic tenant -landlord walk-in clinics at City Halls and other community locations.
■ Include testing/audits within the scope of work for each city's fair housing provider. Support
enforcement activity and publicize outcomes of fair housing litigation.
A-2. Racial and Ethnic Segregation
Recommendations for All Jurisdictions:
■ Coordinate with fair housing providers to focus fair housing services, education/outreach,
and/or additional testing in areas of racial/ethnic concentrations.
■ Offer a variety of housing opportunities to enhance mobility among residents of all races and
ethnicities. Facilitate the provision of affordable housing throughout the community through:
1) available financial assistance; 2) flexible development standards; 3) density bonuses; and
4) other zoning tools.
■ Promote equal access to information on the availability of affordable housing by providing
information in multiple languages, and through methods that have proven successful in
outreaching to the community, particularly those hard -to -reach groups.
■ Affirmatively market first-time homebuyer and/or housing rehabilitation programs to low
and moderate income areas, and areas of racial/ethnic concentration.
■ Work collaboratively with local housing authorities to ensure affirmative fair marketing plans
and de -concentration policies are implemented.
EXECUTIVE SUMMARY
Vi 14-18
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
A-3. Denial of Reasonable Modifications/ Reasonable Accommodations
Recommendations for All Jurisdictions:
■ Through each city's fair housing contractor, continue to provide fair housing education and
information to apartment managers and homeowner associations on why denial of
reasonable modifications/accommodations is unlawful.
■ Provide information on the unlawful practice of denying reasonable modifications/
accommodations at fair housing seminars conducted by the Apartment Association of
Orange County.
A-4. Discriminatory Advertising
Recommendations for All Jurisdictions:
■ Through each city's fair housing contractor, periodically monitor local newspapers and online
media outlets to identify potentially discriminatory housing advertisements. When
identified, make contact with the individual or firm and provide fair housing education.
■ Take steps to encourage both the Los Angeles Times and Orange County Register to publish a
Fair Housing Notice and a "no pets" disclaimer that indicates rental housing owners must
provide reasonable accommodations, including "service animals" and "companion animals"
for disabled persons.
A-5. Hate Crimes
Recommendations for All Jurisdictions:
■ Continue to monitor FBI data to determine if any hate crimes are housing -related and if there
are actions that may be taken by the City or its fair housing service provider to address
potential discrimination linked to the bias motivations of hate crimes.
■ Continue to coordinate with various City and County housing, building and safety, health and
sanitation, law enforcement and legal aid offices to maintain a comprehensive referral list of
support services for victims of hate crimes or other violent crimes —inclusive of housing
resources.
A-6. Unfair Lending
Recommendations for All Jurisdictions:
■ As resources permit, monitor HMDA data annually using the 2013 HMDA analysis as a
benchmark.
■ As resources permit, monitor the top 10 lenders in Orange County to compare and contrast
loan denial rates and percentage of loans completed to minority populations.
EXECUTIVE SUMMARY
vii 14-19
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
■ Both of the Orange County fair housing service contractors should assist in identifying
potential issues regarding redlining, predatory lending and other illegal lending activities. In
addition, each city should review their agreements annually to make sure that increased and
comprehensive services are being provided, and that education and outreach efforts are
expanded and affirmatively marketed in low and moderate income and racial concentrated
areas.
■ Each city should explore ways to collaborate with local lenders and support lenders' efforts
to work with community groups to help minority households purchase their homes.
Collaborative efforts should ensure that minority groups have access and knowledge of City
programs, supportive services, and provide for networking opportunities with these groups.
■ Coordinate with local lenders to expand outreach efforts to first time homebuyers in
minority neighborhoods.
■ Affirmatively market first-time homebuyer and/or housing rehabilitation programs in
neighborhoods with high denial rates, high minority population concentrations and limited
English speaking proficiency to help increase loan approval rates.
Public Sector Impediments
B-1. Housing Element Compliance
Recommendations for Specific Jurisdictions:
■ The City of San Clemente should pursue State certification of its Housing Element.
B-2. Housing for Persons with Disabilities
Recommendations for Specific Jurisdictions:
■ The City of San Clemente should adopt formal Reasonable Accommodations policy and
procedure in 2016.
■ The Cities of Anaheim, Tustin and La Habra should consider eliminating the processing fee for
reasonable accommodation requests.
■ The City of Newport Beach should consider amending its Reasonable Accommodation
procedures to eliminate the requirement for a public hearing, and to approve
administratively.
B-3. Zoning Regulations
Recommendations for Specific Jurisdictions:
■ The City of Newport Beach should consider pursuing a Zoning Code amendment to eliminate
the current age restriction on second units and establish a ministerial review process.
EXECUTIVE SUMMARY
viii 14-20
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
■ The Cities of Buena Park, Orange and Santa Ana should amend their Zoning Codes to specify
provisions for SRO units.
■ The Cities of Fountain Valley and Orange should amend their Zoning Codes to regulate
transitional and supportive housing as a residential use, subject to the same standards as
other residential uses of the same type in the same zone.
B-4. Density Bonus Incentives
Recommendations for All Jurisdictions:
■ All 16 jurisdictions should amend their Zoning Codes to reflect current State density bonus
law.
EXECUTIVE SUMMARY
ix 14-21
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
1. Introduction
Equal access to housing is fundamental to each person in meeting essential needs and pursuing
personal, educational, employment or other goals. In recognizing equal housing access as a
fundamental right, the federal government and the State of California have both established fair
housing choice as a right protected by law.
A. Purpose of the Analysis of Impediments to Fair Housing
Choice
The purpose of an Analysis of Impediments to Fair Housing Choice is to examine policies, procedures,
and practices within a community that may limit a person's ability to choice their residence free from
discrimination. This Al provides an overview of laws, regulations, conditions or other possible
obstacles or impediments that may affect an individual or a household's access to housing in a
community. HUD defines impediments to fair housing choice as:
■ Any actions, omissions or decisions taken because of race, color, ancestry, national origin,
religion, sex, disability, age, marital status, familial status, source of income, sexual
orientation or any other arbitrary factor that restricts housing choices or the availability of
housing choices; or
■ Any actions, omissions or decisions that have the effect of restricting housing choices or the
availability of housing choices on the basis of race, color, ancestry, national origin, religion,
sex, disability, age, marital status, familial status, source of income, sexual orientation or any
other arbitrary factor.
Once the impediments to fair housing have been identified, the Al presents actions to overcome
those barriers.
B. Lead Agencies and Geographic Area Covered
The following 16 Orange County entitlement cities have collaborated in the preparation of this
regional Al:
■ Anaheim
0 Huntington Beach
0 Rancho Santa Margarita
■ Buena Park
0 La Habra
■ San Clemente
■ Costa Mesa
0 Lake Forest
■ Santa Ana
■ Fountain Valley
■ Mission Viejo
■ Tustin
■ Fullerton
0 Newport Beach
■ Garden Grove
■ Orange
The geographic area covered by this Al is shown in Figure 1-1.
INTRODUCTION
1 14-22
Nus,
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Figure 1-1
:ounty Participating Cities
I€h4 Santa
largpriW
nente
INTRODUCTION
2 14-23
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
C. Fair Housing Legal Framework
Federal
The federal Fair Housing Act of 1968 and the Fair Housing Amendments Act of 1988 (42 U.S. Code §§
3601-3619, 3631) are federal fair housing laws that prohibit discrimination in all aspects of housing,
such as the sale, rental, lease or negotiation for real property. The Fair Housing Act prohibits
discrimination based on race, color, religion, sex and national origin.
In 1988, the Fair Housing Act was amended to extend protections based on familial status and to
persons with disabilities (mental or physical). The Amendments Act requires landlords to provide
"reasonable accommodations" (exceptions) to their rules, policies and operations to allow tenants
with disabilities equal access to housing. The Act also requires landlords to allow disabled tenants to
make reasonable access -related modifications at their own expense.
In 2012, HUD published the Final Report on "Equal Access to Housing In HUD Programs Regardless of
Sexual Orientation or Gender Identity." The new rule prohibits considering a person's marital status,
sexual orientation, or gender identity in making homeless housing assistance available.
In July 2015, HUD announced the release of a final rule to Affirmatively Further Fair Housing (AFFH),
which will replace the existing Al with a new Assessment of Fair Housing (AFH). The new AFH will
incorporate data provided by HUD and use an AFH Assessment Tool Template for conducting the fair
housing analysis. Grantees will incorporate fair housing planning into the Consolidated Plans and
HUD will review assessments upfront as part of the planning process. The first AFH will be required
of entitlement jurisdiction beginning 270 days prior to the program year that begins on or after
January 1, 2017 (or January 1, 2018, depending on grantee type) for which a jurisdiction submits a
new consolidated plan. As mentioned in the Executive Summary of this Al, as the 16 Orange County
participating cities have recently submitted their Consolidated Plans for the 2015/16-2019/20 period,
the AFH will not be required until 270 days before the start of the next five-year cycle in 2020/21.1
Therefore, this Al for the 16 Orange County Cities is prepared under the current HUD Al
requirements.
California
The California Department of Fair Employment and Housing (DFEH) enforces California laws that
provide protection and monetary relief to victims of unlawful housing practices. The Fair
Employment and Housing Act (FEHA; Part 2.8 of the California Government Code, Code Sections
12900-12996) prohibit discrimination and harassment in housing practices.
1 The City of San Clemente adopted o five year Consolidated Plan for the 2013/14-2017/18 period, and therefore
its first AFH will be due by October 1, 2017.
INTRODUCTION
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
The Unruh Act (California Government Code Section 51) protects Californians from discrimination in
public accommodations and requires equal access to the accommodations. The Unruh Act provides
broad protection and has been held by the courts to prohibit any arbitrary discrimination on the
basis of personal characteristics or traits, and applies to a range of types of housing.
The Ralph Civil Rights Act (California Civil Code Section 51.7) prohibits violence and threats of
violence and specifies that housing situations are protected under this Act, including houses,
apartments, hotels, boarding housing and condominiums. Violators of the Ralph Act can be sued for
actual or emotional damages, in addition to civil penalties.
The Bane Civil Rights Act (California Civil Code Section 52.1) provides another layer of protection for
fair housing choice by protecting all people in California from interference by force or threat of force
with an individual's constitutional or statutory rights, including a right to equal access to housing.
The Bane Act also includes criminal penalties for hate crimes. However, convictions under the act
are not allowed for speech alone unless that speech itself threatened violence.
In addition to these acts, California Government Code Sections 111135, 65008 and 65589.5 prohibit
discrimination in programs funded by the state and in any land -use decisions. Government Code
Section 65583, which governs preparation of the Housing Element, requires jurisdictions to include
programs in their Elements to promote housing opportunities for all persons, regardless of race,
religion, sex, marital status, ancestry, national origin, color, familial status, or disability. The Housing
Element must also address any zoning or land use laws or practices that either expressly discriminate
against a group protected by the fair housing laws, or have the effect of discriminating against such a
group.
D. Organization of the Regional Al
The Analysis of Impediments to Fair Housing Choice includes the Executive Summary, eight chapters
and appendices.
Chapter 1: Introduction explains the purpose of this Al, defines fair housing and identifies the 16
participating cities that collaborated in the preparation of the Al.
Chapter 2: Community Participation describes the community outreach effort to receive input on
the housing needs and fair housing issues faced by the community and housing service providers.
This chapter also summarizes the input received from the five community meetings and responses
from the fair housing survey.
Chapter 3: Community and Regional Profiles presents the demographic, socioeconomic, housing,
employment characteristics and public services available to the residents of the 16 participating cities
and Orange County.
Chapter 4: Mortgage Lending Practices analyzes lending activities and practices that could impede
fair housing choices in the 16 participating cities.
INTRODUCTION
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Chapter 5: Public Policies and Practices evaluates various local public policies and actions that could
impede fair housing choice.
Chapter 6: Fair Housing Profile evaluates the fair housing services available to residents and
identifies fair housing complaints and violations in the 16 cities.
Chapter 7: Progress Since 2010 summarizes the private and public sector impediments identified in
the prior Al and the region's progress in implementing actions to address these impediments.
Chapter 8: Fair Housing Plan provide conclusions about fair housing issues and recommends actions
to address impediments in the 16 cities.
At the end of this report, a page is attached that includes the endorsement of the City and a
statement certifying that the Al represents each cities' official conclusions regarding impediments to
fair housing choice and the actions necessary to address these impediments.
E. Data Sources
The following data sources were used to complete this Al. Sources of specific information are
identified in the text, tables and figures.
■ U.S Census Bureau, 2000 and 2010 Census
■ U.S. Census Bureau, American Community Survey (ACS), 2009-2013 Five -Year Estimates
■ U.S. Department of Housing and Urban Development (HUD) website
■ U.S. Department of Housing and Urban Development Comprehensive Housing Affordability
Strategy 2012 (CHAS)
■ Federal Bureau of Investigation (FBI) Uniform Crime Reporting Program
■ California Department of Finance (DOF), 2015 Estimates
■ California Department of Social Services (DSS), Community Care Licensing Division
■ Orange County Transportation Authority (OCTA) website
■ Orange County Community Services, Orange County Homeless Count and Survey Report,
2015
■ Orange County Housing Authority (OCHA) Section 8 Program information, 2015
■ Anaheim Housing Authority (AHA) Section Program information, 2015
■ Garden Grove Housing Authority (GGHA) Section 8 Program information, 2015
■ Santa Ana Housing Authority (SAHA) Section 8 Program information, 2015
■ Fair Housing Council of Orange Quarterly Reports, 2012/13 - 2014/15
■ Fair Housing Foundation Annual Reports, 2012/13 - 2014/15
■ Housing Mortgage Disclosure Act (HMDA) data on lending patterns, 2011-2013
INTRODUCTION
5 14-26
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
■ Documents from the 16 participating cities:
General Plan
2014-2021 Housing Elements
13 Zoning Ordinances
13 Consolidated Annual Performance and Evaluation Report (CAPERS)
13 2015-2020 Consolidation Plan
INTRODUCTION
A 14-27
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
2. Community Participation
In order to identify factors that could indicate impediments to fair housing choice, this Al
incorporated a community outreach effort that included five community meetings, an on-line fair
housing survey, coordination with fair housing service and housing providers, and a public review of
the Draft Al.
A. Community Workshops
During the preparation of this Al, residents, businesses, and public and private agencies were invited
to participate in the discussion of fair housing issues in Orange County. Five community workshops
were conducted in late September and early October 2015 at five different locations. The five
locations were selected to enable residents easier access to the workshops. The community
workshops were held on the following dates:
■ September 22, 2015 — Assembly Hall, Downtown Anaheim Community Center, 250 E.
Center, Anaheim, 6:00 p.m.
■ September 23, 2015 — Professional Training Center, Tustin Library, 345 E. Main Street,
Tustin, 6:00 p.m.
■ September 24, 2015 — City Hall Council Chambers, 10200 Slater Avenue, Fountain Valley,
6:00 p.m.
■ September 30, 2015 — Santa Ana Police Community Room, 60 Civic Center Plaza, Santa Ana,
6:00 p.m.
■ October 1, 2015 — City Hall, Community Room, 25550 Commercentre Drive, Lake Forest,
6:00 p.m.
The meetings provided the opportunity for the community to gain awareness of fair housing laws,
and for residents and service agencies to share fair housing issues and concerns. To ensure that the
fair housing concerns of low- and moderate -income and special needs residents were addressed,
individual invitation letters were distributed via mail and email, if available, to agencies and
organizations that serve the low- and moderate -income and special needs community.
Notices of the Fair Housing Workshops were available in English, Spanish, and Vietnamese. The
workshop notices were published in the Orange County Register, La Opinion (Spanish) and the Viet
Bao Daily News (Vietnamese) weeks prior to the meetings. Thanks to the participating Cities' efforts
to publicize the workshops through posts on their websites, mailings to local service providers, and
communications with local stakeholders and public officials, a total of 54 individuals participated in
the five workshops. In addition, as a result of the extensive outreach effort, the workshops were
attended by several service providers that work with residents considered a protected class
COMMUNITY PARTICIPATION
7
14-28
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
according to HUD's definition. The Fair Housing Workshop notices (English, Spanish and
Vietnamese), workshop sign -in sheet, presentation material, city mailing lists, and a summary of
workshop attendee comments are included as Appendix A-1 of this Al.
Summary of key comments from the community workshops included:
■ Affordable Housing: Increasing rents coupled with low vacancies have made it difficult to
find affordable rental units. Some have indicated that landlords use the strong market to
discriminate among potential renters.
■ Information on Affordable Housing Discrimination: Many residents lacked information on
tenant rights, such as when landlords asked for immigration documents. Residents did not
know where to get help when discriminated.
■ Mothers with Children: A common complaint was the difficulty of families, especially
mothers with children, in finding housing.
■ Overcrowding: The problem of overcrowding was brought up by both residents and
property managers.
■ Special Needs Housing: There is a need for affordable rental housing units for seniors,
persons with disabilities, and veterans.
B. Fair Housing Survey
To supplement the community workshops and to assist in further understanding the fair housing
issues in the region, a Fair Housing Survey was made available to residents at the 16 city halls and
online via the City's website. The surveys, both hardcopy and on-line, were available in English,
Spanish, Vietnamese, and Korean to reflect the diversity of Orange County residents.
The survey consisted of questions designed to gather information on a person's experience with fair
housing issues and perception of fair housing issues in his/her neighborhood. During the four-week
survey period in September and October 2015, 188 surveys were completed online and on
hardcopies. Of the total, 59 percent were Spanish-speaking, 40 percent English-speaking, and one
percent Vietnamese -speaking respondents. A summary of the key questions and responses were the
following:
The survey consisted of questions designed to gather information on a person's experience with fair
housing issues and perception of fair housing issues in their community. A summary of the key
survey results included:
■ Almost 60 percent of respondents completed the survey that was translated in Spanish.
■ 57 percent of respondents have encountered housing discrimination, and of those, 88
percent indicated that landlord/property managers were responsible.
■ 82 percent of the discrimination occurred in an apartment complex.
COMMUNITY PARTICIPATION
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14-29
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
■ One-half of those discriminated responded that it was because of family status (families with
children).
■ Over 90 percent did not report the discrimination incident.
■ 14 percent have been denied reasonable accommodation.
■ Three-quarters of respondents indicated they had little to no information on housing
discrimination law, and one-third would not know what to do when discriminated.
Copies of the survey in four languages and a summary of the results are included in Appendix A-2
C. Agency Consultation
A Working Group was formed with key staff representing each of the 16 cities participating in the
development of this Al. The Working Group provided valuable information and insight into their
community housing needs and fair housing issues. The first meeting of the Working Group was held
in June 2015 and hosted by the City of Garden Grove. Monthly meeting were held in various
participating cities to discuss the data needs, the community outreach effort, the Al approval
process, the action plan recommendations, and the review of the Al.
In addition to information gained through the workshops and survey, numerous phone interviews
were conducted with agencies such as the Fair Housing Foundation, the Fair Housing Council of
Orange County, and the Orange County Housing Authority.
D. Public Review
During a 30 -day public review period from March 9 to April 7, 2016, the draft Al document was made
available at the following locations:
■ City Halls of 16 -participating Cities
■ City websites
During this review period, no written comments were received on the draft Al.
Public review notices were published in the Orange County Register, La Opinion, and Viet Bao Daily
News on March S, 2016. Published copies of the public review notices are included in Appendix A-3.
In addition, all persons that attended the community workshops were emailed or faxed the location
of the public review document on the City's website and asked to provide any further comments for
incorporation into the final Al.
COMMUNITY PARTICIPATION
9
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
3. Community and Regional Profiles
Chapter 3 provides analysis of the demographic, socioeconomic and housing characteristics of the 16
Orange County cities participating in this regional Analysis of Impediments to Fair Housing Choices.
chapter presents a demographic profile, assesses the extent of housing needs among specific income
groups and evaluates the availability of a range of housing choices for residents. Major employers
and transportation access to job centers are identified, and community social services offered by
licensed care facilities are discussed. Data -based analysis of demographic, economic, and housing
conditions within a city or other jurisdiction is integral for evaluating housing demands and potential
fair housing issues for the studied area.
Key data sources for Chapter 3 include: U.S. Census Bureau (Census), American Community Survey
(ACS), HUD Comprehensive Housing Affordability Strategy (CHAS) Data, California Department of
Finance (DOF), California Department of Social Services Community Care Licensing Division, and the
California Employment Development Department (EDD).
A. Demographic Profile
Population Growth
In 2015, the population of the 16 cities participating in this regional Al totals approximately 2.1
million, which represents two-thirds of the total number of residents in Orange County. Table 3-1
details the number and growth rate of the residential populations of the 16 cities, Orange County,
and California between 2000 and 2015. In general, there was consistent positive growth on the city,
county, and state levels during both the 2000-2010 and 2010-2015 time periods. The sole exception
is the City of Santa Ana, which experienced a decrease in population by four percent between 2000
and 2010. During the last five years, the City of Tustin experienced the highest percentage increase
in population growth at 5.4 percent, larger than both the County rate of 4.6 percent and the State
rate of 3.9 percent. However, over the 15 -year period, the City of Lake Forest had the largest
percentage increase in population, with an increase of 36.4 percent growth'. The next fastest
growing cities for this 15 -year period were San Clemente (31.0%), Newport Beach (24.6%), Tustin
(17.9%), and Fullerton (11.9%). No other cities experienced population growth in excess of ten
percent. In comparison, the population of Orange County increased by 10.6 percent while California
grew by 14.3 percent between 2000 and 2015. Although the City of Santa Ana rebounded over the
last five years with a population increase of 3.3 percent, the overall 15 -year growth was still a
negative 0.8 percent. Other low -growth cities included Fountain Valley (3.7%), Mission Viejo (3.8%),
Rancho Santa Margarita (4.0%), Costa Mesa (4.4%), and Huntington Beach (4.6%).
1 The large population growth in Lake Forest is attributed to annexation that occurred in late 2000.
COMMUNITY AND REGIONAL PROFILES
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Sources: U.S. Census 2000 and 2010; CA Dept of Finance E-5 Est., January 2015
*Growth attributed to the annexation of Foothill Ranch and Portola, which occurred in late 2000.
Age Composition
Analyzing the age distribution is important because it affects the future need for jobs, housing and
other social services. For cities that have a majority share of the population under the age of 35
years, future growth planning may need to include additional schools, entry-level jobs, and starter
homes. This age group typically consists of young children, students, recent graduates, or adults just
entering the job market. This indicates that the provision of smaller, affordable housing
opportunities, particularly in the rental market, is needed in the near future to allow this group to
remain in the community. Residents ages 35 to 64 years tend to drive the market demand for
moderate to relatively high cost condominiums and single-family homes. People over 65 years of age
tend to generate demand for low to moderate cost apartments and condominiums, group quarters,
and mobile homes; senior residents may also balance their housing options with the proximity to
social services.
COMMUNITY AND REGIONAL PROFILES
11
14-32
Table 3-1: Population Growth 2000-2015
% Change
to 201012010
% Change
to 2015
-MMMiii
Anaheim
328,014
336,265
351,433
2.5%
4.5%
Buena Park
78,282
80,530
82,767
2.9%
2.8%
Costa Mesa
108,724
109,960
113,455
1.1%
3.2%
Fountain Valley
54,978
55,313
57,021
0.6%
3.1%
Fullerton
126,003
135,161
141,042
7.3%
4.4%
Garden Grove
165,196
170,883
174,774
3.4%
2.3%
Huntington Beach
189,594
189,992
198,389
0.2%
4.4%
La Habra
58,974
60,239
62,079
2.1%
3.1%
Lake Forest
58,707
77,264
80,070
31.6%*
3.6%
Mission Viejo
93,102
93,305
96,652
0.2%
3.6%
Newport Beach
70,032
85,186
87,249
21.6%
2.4%
Orange
128,868
136,416
140,094
5.9%
2.7%
Rancho Santa Margarita
47,214
47,853
49,125
1.4%
2.7%
San Clemente
49,936
63,522
65,399
27.2%
3.0%
Santa Ana
337,977
324,528
335,264
-4.0%
3.3%
Tustin
67,504
75,540
79,601
11.9%
5.4%
Orange County
2,846,289
3,010,232
3,147,655
5.8%
4.6%
California
33,873,086
37,253,956
38,714,725
10.0%
3.9%
Sources: U.S. Census 2000 and 2010; CA Dept of Finance E-5 Est., January 2015
*Growth attributed to the annexation of Foothill Ranch and Portola, which occurred in late 2000.
Age Composition
Analyzing the age distribution is important because it affects the future need for jobs, housing and
other social services. For cities that have a majority share of the population under the age of 35
years, future growth planning may need to include additional schools, entry-level jobs, and starter
homes. This age group typically consists of young children, students, recent graduates, or adults just
entering the job market. This indicates that the provision of smaller, affordable housing
opportunities, particularly in the rental market, is needed in the near future to allow this group to
remain in the community. Residents ages 35 to 64 years tend to drive the market demand for
moderate to relatively high cost condominiums and single-family homes. People over 65 years of age
tend to generate demand for low to moderate cost apartments and condominiums, group quarters,
and mobile homes; senior residents may also balance their housing options with the proximity to
social services.
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REGIONAL ANALYSIS OF IMPEDIMENTS
Table 3-2 details the age distribution in 2013 of the residential populations of the 16 cities, Orange
County, and the State. The age groups are designated as follows: Under 5 years (young children), 5-
17 years (minors), 18-34 (young adults), 35-54 (middle -age adults), 55-64 (future elderly), 65-74
(elderly), and 75 years and older (frail elderly). These divisions are intended to give an overview of
the percent of populations at different age ranges which tend to have similar needs in terms of
housing and social services. In general, the 35-54 years of age group represented the largest share of
the population. The exceptions were the cities of Costa Mesa, Fullerton, La Habra, and Santa Ana,
where the 18-34 age group was the largest proportion. Figure 3-1 illustrates the 2013 age
distribution by the 16 cities.
Source: ACS 2009-2013 5 -Yr Est. Tables DP05 and 50101
COMMUNITY AND REGIONAL PROFILES
12
14-33
Table 3-2: Age Distribution of Population 2013
Anaheim
7.7%
19.4%
26.0%
27.4%
9.6%
5.4%
4.4%
Buena Park
6.3%
18.2%
24.5%
29.0%
10.5%
6.2%
5.3%
Costa Mesa
6.5%
14.5%
30.8%
29.6%
9.7%
4.7%
4.1%
Fountain Valley
4.3%
15.2%
19.8%
29.0%
13.5%
10.4%
7.8%
Fullerton
6.4%
16.9%
27.5%
27.4%
9.8%
6.0%
6.0%
Garden Grove
6.1%
18.9%
24.1%
29.1%
10.5%
6.2%
5.2%
Huntington Beach
5.0%
15.0%
22.5%
30.1%
12.4%
8.4%
6.4%
La Habra
7.5%
18.5%
27.0%
26.7%
10.1%
4.7%
5.4%
Lake Forest
5.9%
18.0%
21.1%
32.7%
12.3%
6.2%
3.9%
Mission Viejo
5.1%
17.2%
18.2%
30.3%
14.1%
8.2%
6.9%
Newport Beach
3.9%
13.4%
21.6%
27.4%
14.3%
10.6%
8.7%
Orange
6.5%
15.9%
26.7%
29.5%
10.2%
6.3%
4.8%
Rancho Santa Margarita
6.0%
22.2%
21.5%
34.1%
9.8%
3.8%
2.5%
San Clemente
6.6%
18.7%
17.1%
30.6%
13.1%
8.1%
5.8%
Santa Ana
8.7%
21.5%
28.7%
27.0%
7.3%
4.0%
2.9%
Tustin
7.5%
19.1%
26.3%
29.8%
9.1%
4.7%
3.5%
Orange County
6.3%
17.7%
24.0%
28.9%
11.0%
6.5%
5.5%
California
6.7%
17.8%
24.9%
27.7%
11.1%
6.4%
5.4%
Source: ACS 2009-2013 5 -Yr Est. Tables DP05 and 50101
COMMUNITY AND REGIONAL PROFILES
12
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Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Tustin
Orange County
California
United States
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Figure 3-1: Age Distribution 2013
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
■ Under 18 ■ 18-34 35-54 ■ 55-64 65+
Source: ACS 2009-2013 5 Yr Est. Tables DP05 and 50101
Table 3-3 contains summary age indicators for the 16 cities, Orange County, and California. In each
jurisdiction, the median age of the residential population has increased between 2000 and 2013,
indicating a general trend towards a "greying" of the population. The highest median age in 2013
was seen in Newport Beach (43.7), followed by Fountain Valley (43.4), Mission Viejo (43.0),
Huntington Beach (40.6), and San Clemente (40.1). The lowest median age in 2013 was Santa Ana's
29.2 years, followed by Anaheim (32.8), La Habra (33.2), Tustin (33.3), and Costa Mesa (33.8). In
comparison, the median age in 2013 was 36.4 years for Orange County, and 35.4 years statewide.
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 3-3: Age Characteristics 2013
Median Age • P..
Depend.Depend. Depend. •..
City/Areaiii iRatio Ratio Ratio Yrs Yrs
Anaheim 30.3 32.8 58.4 15.6 42.9 27.1% 9.8%
Buena Park 32.0 35.5 56.4 18.0 38.4 24.5% 11.5%
Costa Mesa 32.0 33.8 42.5 12.5 30.1 21.0% 8.8%
Fountain Valley 38.1 43.4 60.4 29.2 31.2 19.5% 18.2%
Fullerton 32.9 34.4 54.6 18.6 36.0 23.3% 12.0%
Garden Grove 32.3 35.6 57.2 17.9 39.3 25.0% 11.4%
Huntington Beach 36.0 40.6 53.6 22.8 30.7 20.0% 14.8%
La Habra 31.5 33.2 56.6 15.9 40.7 26.0% 10.1%
Lake Forest* 35.1 38.4 52.8* 15.1* 37.7* 23.9% 10.1%
Mission Viejo 37.5 43.0 59.5 24.0 35.5 22.3% 15.1%
Newport Beach 41.6 43.7 57.7 30.4 27.3 17.3% 19.3%
Orange 33.2 35.4 50.7 16.8 33.9 22.4% 11.1%
Rancho Santa Margarita 31.9 35.2 52.6 9.7 42.9 28.2% 6.3%
San Clemente 38.0 40.1 64.4 22.9 41.6 25.3% 13.9%
Santa Ana 26.5 29.2 58.8 10.8 48.0 30.2% 6.9%
Tustin 31.8 33.3 53.4 12.6 40.9 26.6% 8.2%
Orange County 33.3 36.4 56.4 18.8 37.6 24.0% 12.0%
California 33.3 35.4 57.1 18.6 38.6 24.5% 11.8%
Source: ACS 2009-2013 5 -Yr Est. Tables DP05 and S0101
* 2012 value from ACS 2008-2012 Table 50101
The dependency ratio, which is the ratio of the population under 18 and over 65 years of age to the
population 18 to 64, is an indicator of the reliance of children and senior citizens on the working age
population. The range of the dependency ratio is measured from 0 (low) to 100 (high); the lower the
dependency ratio, the lesser the "burden" is on a community's working age residents. The
dependency ratio is an important indication of the demand for social services and senior housing.
According to Table 3-3, the dependency ratio in 2013 was 56.4 in Orange County, and 57.1 in
California. Cities with notably higher dependency ratios included San Clemente (64.4), Fountain
Valley (60.4), and Mission Viejo (59.5).
In addition to the composite age dependency ratio, Table 3-3 includes the proportion of minor -age
dependency versus elderly dependency, as well as the percentages of the total populations that are
under 18 years and 65 years or older, respectively. The old age dependency ratio and the child
COMMUNITY AND REGIONAL PROFILES
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
dependency ratio can inform with greater detail the types of services and housing options needed in
a particular jurisdiction. For example, the dependency ratios of Santa Ana (58.8) and Newport Beach
(57.7) indicate similar degrees of the social burden on working age residents. However, Newport
Beach has an old -age dependency ratio of 30.4 and a child dependency ratio of 27.3, indicating a
great demand for senior housing and social service targeted for the elderly. With an old age
dependency ratio of 10.8 and a child dependency ratio of 48.0 in Santa Ana indicates the types of
housing and social services needed would skew more towards childcare and other youth -targeted
amenities, with relatively less demand for senior services.
Age and fair housing intersect when managers or property owners make housing decisions based on
the age of residents or the familial status (families with children). For example, managers and
property owners may prefer to rent to mature residents, limit the number of children in their
complex or discourage older residents due to their disabilities. Although a housing provider may
establish reasonable occupancy limits and set reasonable rules about the behavior of tenants, those
rules cannot single out children for restrictions that do not also apply to adults.
Race and Ethnicity
The race and ethnic composition of a population influence fair housing issues to the extent that
certain racial and ethnic groups may experience discrimination. These influences are due to factors
such as color, language spoken, or other cultural factors.
Table 3-4 presents the racial and ethnic characteristics of the 16 cities and Orange County residents.
It shows that the County experienced major shifts in racial and ethnic composition since 2000. In
2000, over one-half of the countywide population was non -Hispanic White, but by 2013 the
proportion of the non -Hispanic White population decreased to 43.5 percent. During the same
period, the Hispanic population increase from 30.8 percent to 33.8 percent. The largest shift
occurred in the non -Hispanic Asian/Pacific Islander group, which accounted for 13.8 percent of the
total County population in 2000 and increased to 18.5 percent in 2013.
Table 3-4 and Figure 3-1 show the racial/ethnic composition by the 16 cities. The City of Santa Ana
had the highest proportion of Hispanic residents in the County at 78.5 percent in 2013. Other cities
with high representation of Hispanic residents included La Habra (60.3%), Anaheim (52.6%), Buena
Park (38.5%), and Orange (38.4%). The other key minority group was non -Hispanic Asian/Pacific
Islander residents. The city with the highest proportion of non -Hispanic Asian residents was the City
of Garden Grove (38.8%). This was followed by the Cities of Fountain Valley (33.8%), and Buena Park
(28.7%). The city that experienced the largest percent change of the minority population between
2000 and 2013 was Newport Beach. Although the number of Hispanic and non -Hispanic Asian
residents in the city was relatively small (7,189 Hispanic and 6,008 non -Hispanic Asian), these two
racial/ethnic groups in Newport Beach more than doubled in size during the 13 -year period.
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Source: Census 2000 SF1 Table P004, ACS 2009-2013 5Vr Est. Table DP05
NH: Non -Hispanic
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Table 3-4:
Racial and Ethnic Composition
of Population
2000 and 2013
HispanicCity/Area %
•
2000
46.8%
35.9%
2.4%
12.3%
2.8%
Anaheim
2013
52.6%
27.4%
2.4%
15.6%
2.1%
2000
33.5%
38.2%
3.6%
21.3%
3.4%
Buena Park
2013
38.5%
26.3%
4.3%
28.7%
2.2%
2000
31.8%
56.8%
1.2%
7.4%
2.8%
Costa Mesa
2013
35.2%
51.6%
1.2%
9.7%
2.4%
2000
10.7%
58.5%
1.1%
26.2%
4.1%
Fountain Valley
2013
15.8%
46.6%
1.2%
33.8%
2.6%
2000
30.2%
48.7%
2.1%
16.2%
2.8%
Fullerton
2013
34.5%
36.1%
2.5%
23.9%
2.9%
2000
32.5%
32.5%
1.1%
31.4%
2.5%
Garden Grove
2013
36.8%
21.3%
1.0%
38.8%
2.0%
2000
14.7%
71.9%
0.7%
9.5%
3.3%
Huntington Beach
2013
18.7%
66.1%
0.7%
11.3%
3.1%
2000
49.0%
41.4%
1.4%
6.0%
2.3%
La Habra
2013
60.3%
28.7%
1.6%
7.5%
1.9%
2000
18.6%
66.7%
1.7%
9.8%
3.2%
Lake Forest
2013
23.5%
56.9%
1.6%
14.5%
3.6%
2000
12.1%
76.0%
1.1%
7.8%
3.1%
Mission Viejo
2013
15.8%
70.9%
1.5%
8.0%
3.8%
2000
4.7%
89.0%
0.5%
4.1%
1.7%
Newport Beach
2013
8.4%
81.6%
0.6%
7.0%
2.4%
2000
32.2%
54.6%
1.4%
9.4%
2.4%
Orange
2013
38.4%
45.9%
1.0%
12.8%
2.0%
2000
13.0%
74.4%
1.7%
7.5%
3.5%
Rancho Santa Margarita
2013
18.8%
66.8%
1.1%
10.7%
2.7%
2000
15.9%
78.4%
0.6%
2.7%
2.4%
San Clemente
2013
17.5%
75.4%
0.7%
3.5%
3.0%
2000
76.1%
12.4%
1.3%
9.0%
1.2%
Santa Ana
2013
78.5%
9.6%
1.1%
10.1%
0.7%
2000
34.2%
44.8%
2.6%
15.1%
3.2%
Tustin
2013
39.4%
32.3%
2.3%
23.2%
2.8%
2000
30.8%
51.3%
1.5%
13.8%
3.1%
Orange County
2013
33.8%
43.5%
1.5%
18.5%
2.6%
Source: Census 2000 SF1 Table P004, ACS 2009-2013 5Vr Est. Table DP05
NH: Non -Hispanic
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Other cities with a significant change in the Hispanic population between 2000 and 2013 included the
Cities of Lake Forest (68.2%) Fountain Valley (50.3%), and Rancho Santa Margarita (48.1%). For the
non -Hispanic Asian population, the Cities of Lake Forest (96.7%), Tustin (74.4%), and San Clemente
(66.1%) also experienced large percentage changes between 2000 and 2013.
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Tustin
Orange County
California
United States
Figure 3-2: Population by Race/Ethnicity 2013
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
■ NH White ■ Hispanic NH Asian/Pacific Islander ■ NH Black Other/Multiracial
Source: ACS 2009-2013 5 Yr Est. Table DP05
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Source: Census 2000 SF1 Table P004, ACS 2009-2013 5Yr Est. Table DP05
COMMUNITY AND REGIONAL PROFILES
18 14-39
Table
3-5: Growth in Racial/Ethnic
Group Populations 2000-2013
NH Asian/Pacific
Islander
Other
•.
Anaheim
153,374
178,723
16.5%
117,607
93,099
-20.8%
7,939
8,174
3.0%
40,182
53,204
32.4%
8,912
6,881
-22.8%
Buena Park
26,221
31,406
19.8%
29,885
21,417
-28.3%
2,826
3,481
23.2%
16,696
23,396
40.1%
2,654
1,822
-31.3%
Costa Mesa
34,523
39,018
13.0%
61,778
57,223
-7.4%
1,313
1,278
-2.7%
8,022
10,731
33.8%
3,088
2,621
-15.1%
Fountain Valley
5,870
8,823
50.3%
32,144
26,031
-19.0%
584
669
14.6%
14,302
18,891
32.1%
2,249
1,497
-33.4%
Fullerton
38,014
47,230
24.2%
61,420
49,371
-19.6%
2,675
3,476
29.9%
20,381
32,657
60.2%
3,513
3,968
13.0%
Garden Grove
53,608
63,617
18.7%
53,735
36,826
-31.5%
1,873
1,803
-3.7%
51,798
67,121
29.6%
4,182
3,418
-18.3%
Huntington Beach
27,798
36,204
30.2%
136,237
127,779
-6.2%
1,383
1,332
-3.7%
17,976
21,850
21.6%
6,200
6,032
-2.7%
La Habra
28,922
36,748
27.1%
24,399
17,507
-28.2%
808
949
17.5%
3,432
4,537
32.2%
1,324
1,157
-12.6%
Lake Forest
10,913
18,351
68.2%
39,161
44,521
13.7%
998
1,236
23.8%
5,760
11,330
96.7%
1,875
2,815
50.1%
Mission Viejo
11,266
14,856
31.9%
70,735
66,870
-5.5%
1,032
1,412
36.8%
7,244
7,588
4.7%
2,825
3,585
26.9%
Newport Beach
3,301
7,189
117.8%
62,342
70,174
12.6%
354
541
52.8%
2,844
6,008
111.3%
1,191
2,089
75.4%
Orange
41,434
52,967
27.8%
70,292
63,298
-9.9%
1,798
1,353
-24.7%
12,166
17,613
44.8%
3,131
2,768
-11.6%
Rancho Santa Margarita
6,139
9,094
48.1%
35,132
32,281
-8.1%
787
519
-34.1%
3,530
5,166
46.3%
1,626
1,295
-20.4%
San Clemente
7,933
11,174
40.9%
39,155
48,232
23.2%
320
448
40.0%
1,355
2,250
66.1%
1,173
1,890
61.1%
Santa Ana
257,097
257,998
0.4%
41,984
31,466
-25.1%
4,309
3,750
-13.0%
30,405
33,047
8.7%
4,182
2,458
-41.2%
Tustin
23,110
30,139
30.4%
30,264
24,690
-18.4%
1,785
1,739
-2.6%
10,194
17,775
74.4%
2,151
2,154
0.1%
Source: Census 2000 SF1 Table P004, ACS 2009-2013 5Yr Est. Table DP05
COMMUNITY AND REGIONAL PROFILES
18 14-39
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Residential Segregation
The racial and ethnic distribution of Orange County's population appears diverse with 56 percent of
the total population composed of Hispanic, non -Hispanic Asian, non -Hispanic Black/African
American, and other. However, within the County there are areas of racial/ethnic concentrations.
For example, the City of Santa Ana's population is over three-quarters Hispanic and ten percent non -
Hispanic Asian. Areas of racial/ethnic minority concentration are neighborhoods with a
disproportionately high number of minority (non-White) residents.
To illustrate areas of minority "concentration" on a geographic level, census tracts that exceed the
countywide average of minorities, measured at 56 percent in 2013 was mapped. Figure 3-3 displays
the Orange County census tracts with the minority population representing more than 56 percent of
the total population of the census tract. As the map illustrates, concentrations of minorities are most
prevalent in central and northern Orange County in cities such as Santa Ana, Garden Grove, Anaheim,
and Buena Park.
Linguistic Isolation
Table 3-6 details the percent of total households in 2013 that were considered to be limited English-
speaking households. The Census defines a limited speaking household as a household "in which no
member 14 years old and over: 1) speaks only English; or 2) speaks a non-English language and
speaks English 'very well."' In other words, all household members 14 and older have at least some
difficulty with English proficiency. According to Table 3-6, 9.6 percent of Orange County households
and 9.9 percent of California households fall under this definition. The Cities with larger percentages
than the County and State were Santa Ana (23.1%), Garden Grove (18.5%), Buena Park (17.8%),
Anaheim (14.2%), La Habra (11.8%), and Tustin (10.1%). The table also lists the prevalence of limited
English proficiency among households whose primary spoken language is not English. For example,
among all Buena Park households whose primary spoken language is Spanish, 29.2 percent were
considered to be limited English-speaking households. In general, households speaking Asian/Pacific
Islander languages display the largest degree of linguistic isolation. As presented in the table, 40.5
percent of Santa Ana's households whose primary language was Asian/Pacific Islander had limited
English-speaking proficiency. Other cities that exhibited similar linguistic isolation among
Asian/Pacific Islander -speaking households included Garden Grove (38.1%), and Buena Park (35.2%).
Language barriers can serve as an impediment to fair housing accessibility. Residents who lack
proficiency with the English language may have difficulties accessing services and information
pertaining to fair housing, or may be obstructed by reluctance on the part of landlords to rent units
to non-English speaking tenants. Another fair housing concern could arise if foreign -born owners of
rental housing advertise only in their native languages, thus restricting choice in the renter market.
Limited English proficiency may also hinder access to social services, or affect a resident's
employment opportunities and educational attainment.
COMMUNITY AND REGIONAL PROFILE
19
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
COMMUNITY AND REGIONAL PROFILES
20
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Source: ACS 2009-2013 5Yr Est. Table 51602
COMMUNITY AND REGIONAL PROFILES
21
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Table 3-6: Limited English Speaking Households 2013
% of HH by Primary Language
Limited English
Speaking as % of Other
Total MMM
Anaheim
14.2%
22.9%
17.5%
30.9%
26.0%
Buena Park
17.8%
29.2%
14.2%
35.2%
33.9%
Costa Mesa
5.8%
19.2%
7.3%
17.1%
2.9%
Fountain Valley
8.4%
9.9%
11.4%
26.1%
13.2%
Fullerton
9.6%
14.9%
11.5%
29.6%
11.7%
Garden Grove
18.5%
16.7%
11.5%
38.1%
15.0%
Huntington Beach
4.0%
13.1%
8.4%
23.1%
26.9%
La Habra
11.8%
22.7%
17.7%
30.3%
7.4%
Lake Forest
4.9%
12.8%
19.6%
16.7%
26.5%
Mission Viejo
3.1%
7.8%
13.2%
17.5%
12.4%
Newport Beach
1.8%
6.9%
5.2%
19.2%
1.2%
Orange
9.0%
22.0%
7.7%
28.5%
19.2%
Rancho Santa Margarita
4.5%
18.6%
13.9%
13.2%
45.0%
San Clemente
1.7%
12.7%
4.9%
10.6%
0.0%
Santa Ana
23.1%
27.8%
9.4%
40.5%
10.1%
Tustin
10.1%
21.4%
12.4%
18.4%
47.4%
Orange County
9.6%
20.6%
12.0%
29.8%
17.7%
California
9.9%
23.1%
17.2%
28.3%
18.9%
Source: ACS 2009-2013 5Yr Est. Table 51602
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
B. Household Profile
Household Growth
Table 3-7 details the number and growth rate of households within the 16 cities, Orange County, and
the State of California between 2000 and 2015. In general, there was consistent positive growth on
the city, county, and state levels during both the 2000-2010 and 2010-2015 time periods. During
the last five years, the City of Tustin experienced the largest percent increase number of household
at 3.0 percent -- larger than the 2.0 percent growth rate for both Orange County and California. Over
a 15 -year period (2000-2015), the City of Lake Forest witnessed the largest percentage increase in
households, with an increase of 32.9 percent. The only other cities to experience double-digit
growth during the 15 -year period were San Clemente (24.0%) and Newport Beach (17.3%). In
comparison, total households within Orange County increased by 8.2 percent and within California
by 11.5 percent between 2000 and 2015. The City of Garden Grove had the lowest overall household
growth rate, with a 0.5 percent increase between 2000 and 2015, followed by La Habra (0.9%), Santa
Ana (1.0%), and Buena Park (2.0%).
Sources: Census 2010 Redistricting Data, CA Dept of Finance E-5 Est., January 2015
*Growth attributed to the annexation of Foothill Ranch and Portola, which occurred in late 2000.
COMMUNITY AND REGIONAL PROFILES
22
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Table 3-7:
Household Growth 2000-2015
City/Area
% Change %
2000-2010 2010-2015
Change
Anaheim
96,969
98,294
100,406
1.4%
2.1%
Buena Park
23,332
23,686
23,788
1.5%
0.4%
Costa Mesa
39,206
39,946
40,404
1.9%
1.1%
Fountain Valley
18,162
18,648
18,785
2.7%
0.7%
Fullerton
43,609
45,391
45,978
4.1%
1.3%
Garden Grove
45,791
46,037
46,020
0.5%
0.0%
Huntington Beach
73,657
74,285
76,028
0.9%
2.3%
La Habra
18,947
18,977
19,108
0.2%
0.7%
Lake Forest
20,008
26,224
26,580
31.1%*
1.4%
Mission Viejo
32,449
33,208
33,596
2.3%
1.2%
Newport Beach
33,071
38,751
38,779
17.2%
0.1%
Orange
40,946
43,367
43,528
5.9%
0.4%
Rancho Santa Margarita
16,253
16,665
16,714
2.5%
0.3%
San Clemente
19,395
23,906
24,049
23.3%
0.6%
Santa Ana
73,002
73,174
73,765
0.2%
0.8%
Tustin
23,831
25,203
25,956
5.8%
3.0%
Orange County
935,287
992,781
1,012,422
6.1%
2.0%
California
11,502,871
12,577,498
12,830,035
9.3%
2.0%
Sources: Census 2010 Redistricting Data, CA Dept of Finance E-5 Est., January 2015
*Growth attributed to the annexation of Foothill Ranch and Portola, which occurred in late 2000.
COMMUNITY AND REGIONAL PROFILES
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Tenure
Table 3-8 shows the distribution of total occupied housing units by tenure in 2000 and 2013. In
general, the percentage of renter households increased more than owner household in most of the
16 cities, a trend also displayed on the county and state levels. The exceptions were the Cities of
Fullerton, San Clemente, and Tustin where the percentage of renters declined from 2000 to 2013.
For example, renters in the City of San Clemente represented 37.6 percent of all households in the
city in 2000, but declined to 34.4 percent by 2013. The city with the highest percentage of renters in
2013 was Costa Mesa, where nearly 60 percent of total households were renters. Other cities with
large percentages of renter households in 2013 were Santa Ana (54.0%), Anaheim (52.2%), and
Tustin (49.4%). The cities with low percentages of renter households in 2013 were Mission Viejo
(21.6%), Rancho Santa Margarita (28.2%), Fountain Valley (29.0%), and Lake Forest (29.9%).
Anaheim
Table 3-8: Household Tenure
•••2013
•
•
Renter
50.0% 50.0%
47.8%
52.2%
Buena Park
57.1%
42.9%
56.1%
43.9%
Costa Mesa
40.5%
59.5%
40.3%
59.7%
Fountain Valley
74.7%
25.3%
71.0%
29.0%
Fullerton
53.9%
46.1%
54.4%
45.6%
Garden Grove
59.6%
40.4%
55.8%
44.2%
Huntington Beach
60.6%
39.4%
59.2%
40.8%
La Habra
56.6%
43.4%
55.3%
44.7%
Lake Forest
72.0%
28.0%
70.1%
29.9%
Mission Viejo
81.4%
18.6%
78.4%
21.6%
Newport Beach
55.7%
44.3%
55.4%
44.6%
Orange
62.6%
37.4%
59.5%
40.5%
Rancho Santa Margarita
78.3%
21.7%
71.8%
28.2%
San Clemente
62.4%
37.6%
65.6%
34.4%
Santa Ana
49.3%
50.7%
46.0%
54.0%
Tustin
49.6%
50.4%
50.6%
49.4%
Orange County
61.4%
38.6%
58.7%
41.3%
California
56.9%
43.1%
55.3%
44.7%
Source: Census 2000 SF 1 Table DP -1, ACS 2009-2013 5 -Yr. Est. Table DP04
COMMUNITY AND REGIONAL PROFILES
23
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Household Size
Household size is an important indicator identifying sources of population growth as well as
overcrowding in individual housing units. A city's average household size will increase over time if
trends move toward larger families. In communities where the population is aging, the average
household size typically declines. Growth trends in the city can be attributed to cultural differences
in relation to household size, privacy, and co -habitation of extended families. For instance, single -
person households or seniors may often occupy smaller apartments or condominiums due to the
lower cost and size of such homes. Younger families with children often prefer larger single-family
homes. Understanding changes in household composition can thus provide insight into current and
future housing needs.
According to the 2013 ACS data presented in Table 3-9, the average household size of Orange County
declined slightly from 3.02 in 2000 to 3.00 in 2013. However, at the city level, the household size
changed significantly between 2000 and 2013 in several of the 16 cities. For example, cities such as
Buena Park, Fullerton, Garden Grove, La Habra, Newport Beach, and Tustin experienced a decline of
0.15 to 0.22 in average household size. The Cities of Costa Mesa, Fountain Valley and Mission Viejo
exhibited increases over the 2000 to 2013 period, with the City of Santa Ana experiencing the largest
increase from 4.45 to 4.55 over this period.
Source: Census 2000 SF1 Table H012, ACS 2009-2013 5Yr Est. Table 825010
COMMUNITY AND REGIONAL PROFILES
24
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Table 3-9: Average Household Size
by Tenure
20130
Renter
Anaheim
3.39
3.46
3.33
3.34
3.24
3.45
Buena Park
3.51
3.39
3.66
3.32
3.28
3.36
Costa Mesa
2.68
2.72
2.65
2.69
2.66
2.71
Fountain Valley
2.97
3.07
2.73
3.00
3.07
2.79
Fullerton
3.02
2.97
3.08
2.83
2.87
2.77
Garden Grove
3.72
3.72
3.71
3.56
3.49
3.67
Huntington Beach
2.59
2.60
2.59
2.56
2.58
2.54
La Habra
3.25
3.07
3.47
3.08
3.04
3.13
Lake Forest
2.89
2.86
2.97
2.89
2.93
2.79
Mission Viejo
2.80
2.76
2.92
2.84
2.87
2.71
Newport Beach
2.24
2.38
2.06
2.09
2.30
1.83
Orange
3.07
2.99
3.20
3.02
2.91
3.20
Rancho Santa Margarita
2.94
3.06
2.64
2.90
3.06
2.35
San Clemente
2.63
2.66
2.58
2.56
2.59
2.51
Santa Ana
4.45
4.47
4.42
4.55
4.54
4.57
Tustin
3.04
2.96
3.13
2.82
2.70
2.93
Orange County
3.02
3.00
3.06
3.00
2.96
3.05
California
2.94
2.98
2.88
2.87
2.93
2.79
Source: Census 2000 SF1 Table H012, ACS 2009-2013 5Yr Est. Table 825010
COMMUNITY AND REGIONAL PROFILES
24
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 3-9 also shows the difference in household sizes by tenure. It shows that at the countywide
level, renters had larger household sizes than owners for both 2000 and 2013. At the city level,
household size patterns varied among cities. Renters had larger household sizes than owners in cities
such as Anaheim, Garden Grove, Orange, and Tustin, while in cities such as Fountain Valley, Lake
Forest, Mission Viejo, Newport Beach, and Rancho Santa Margarita, owner household sizes were
higher than renters in 2013.
Figure 3-4 illustrates the most recent average household sizes estimated by the California State
Department of Finance (DOF), which provides annual estimates of population, household and
housing for all cities in the state. The 2015 DOF data shows that the County's average household size
is 3.06. It also shows that the City of Santa Ana has the largest household size among the all 16 cities
at 4.48. In fact, according to the DOF estimates, Santa Ana is tied with the Cities of South EI Monte
and Parlier as having the ninth highest household size among all California cities -- the city with the
state's highest household is Greenfield (Monterey County) at 4.82.
5
4.5
4
3.5
3
2.5
2
1.5
1
0.5
0
Figure 3-4: Household Size
\eJ eye oma elo ya
a 0�° re Qa ao a� �y a\ °� at e e, ea ea
Pia a O� \\e �a�� 49 o� L�e� �° �
0a °c`a �a� 4 e�Q
Source: DOF 2015 Estimates
COMMUNITY AND REGIONAL PROFILES
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
C. Income Profile
Household income is the most important factor determining a household's ability to balance housing
costs with other basic life necessities. Although economic factors that affect a household's housing
choice are not a fair housing issue per se, the relationships among household income, household
type, race/ethnicity and other factors often create misconceptions and biases that raise fair housing
issues.
County Income Limits
Most state and federal housing programs are benchmarked to specific income limits. Consistent with
federal regulations, income categories defined by HUD are: extremely low income (0-30% of Area
Mean Income); low income (31-50% of AMI); moderate income (51-80% of AMI); and above
moderate (greater than 80% of AMI). HUD does not publish income limits for above moderate
income households as federal housing programs are not eligible to households earning greater than
80 percent of the AMI. Table 3-10 presents HUD and State income limits by income group for Orange
County.
The State of California also provides income limits that are updated annually, in accordance with
procedures established by HUD at the federal level. The State income limits apply to designated
programs and are used to determine applicant eligibility and to calculate affordable housing costs for
applicable housing assistance programs.
Table 3-10: 2015 HUD and State Income Limits for Orange County
Income Group Percent AMI 2015 Income Limit
HUD
Extremely Low
< 30%
$28,900
Low
31%-50%
$48,150
Moderate
51%-80%
$77,050
Above Moderate
>80%
$77,050+
State
Extremely Low
< 30%
$28,900
Very Low
31%-50%
$48,150
Low
51%-80%
$77,050
Moderate
81%-120%
$104,650
Above Moderate
> 120%
--
Source: HUD and State HCD, Income Limits 2015
Based on $87,200 AMI for a four -person household
COMMUNITY AND REGIONAL PROFILES
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Household Income
As estimated in the 2013 ACS, the median household income in Orange County was $75,422 and the
median family household income was $84,765. The difference between the two is that a family
consists of two or more people (one of whom is the householder) related by birth, marriage, or
adoption residing in the same housing unit. A household consists of all people who occupy a housing
unit regardless of relationship. A household may consist of a person living alone or multiple
unrelated individuals or families living together. Table 3-11 lists the income figures for each of the 16
cities and also compares these figures to Orange County and California. As shown in the table, the
following cities had median household incomes significantly above the County median of $75,422:
Newport Beach ($106,333), Rancho Santa Margarita ($104,113), Mission Viejo ($96,210), Lake Forest
($93,631), and San Clemente ($90,071) -- cities located primarily in the southern portion of Orange
County. Cities with median household incomes significantly lower than the countywide median
included: Santa Ana ($53,335), Anaheim ($59,165), Garden Grove ($59,648), and La Habra ($61,702) -
- cities located more in the northern portion of the county.
Table 3-11:
Median Household Income
Median..
Anaheim
Household Income Households
$59,165
$63,380
Buena Park
$66,371
$70,703
Costa Mesa
$65,830
$75,810
Fountain Valley
$80,870
$90,317
Fullerton
$67,384
$76,760
Garden Grove
$59,648
$61,890
Huntington Beach
$81,389
$97,443
La Habra
$61,702
$68,218
Lake Forest
$93,631
$108,636
Mission Viejo
$96,210
$108,545
Newport Beach
$106,333
$146,011
Orange
$78,838
$86,226
Rancho Santa Margarita
$104,113
$118,383
San Clemente
$90,071
$106,382
Santa Ana
$53,335
$51,045
Tustin
$73,194
$80,897
Orange County
$75,422
$84,765
California
$61,094
$69,661
Source: ACS 2009-2013 5Yr Est. DP03
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Household Income Distribution
Additional analysis was completed on incomes by household distribution, as shown in Figure 3-5.
Almost all cities had significant proportions (over 20%) of their households with incomes of $100,000
or more, with the exception of the City of Santa Ana. In fact, one-half of the households in the Cities
of Newport Beach and Rancho Santa Margarita earn more than $100,000 annually. On the other end
of the spectrum, cities where 40 to 50 percent of the households earning less than $50,00 per year
included Santa Ana, Garden Grove, Anaheim, and La Habra.
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Tustin
Orange County
California
United States
Figure 3-5: Household Distribution by Income 2013
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
■ Less than $25,000 0$25,000-$49,999 I-" $50,000 - $74,999 ■ $75,000 - $99,999 $100,000 or more
Source: ACS 2009-2013 5 Yr Est. Table DP03
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REGIONAL ANALYSIS OF IMPEDIMENTS
Poverty Level
Table 3-12 presents the percentage of family households below the poverty line in 2013. It shows
that countywide, approximately nine percent of all families were below the poverty level. The City of
Santa Ana's percentage of families below poverty (18.5%) was double the countywide figure in 2013.
Other cities with family poverty levels higher than the countywide average poverty level included
Garden Grove (13.6%), Anaheim (13.3%), Fullerton (11.1%), La Habra (11.0%), Costa Mesa (10.6%),
and Tustin (9.0%). As indicated in the table below, single female headed households, and especially
those with children, evidence much higher rates of poverty than family households as a whole.
Table 3-12: Family Households Below Poverty Level, 2013
Families HHs with Single Female
Children Single Female Headed HHs with
City/Area All Family HI -Is < 18 Yrs Headed HH Children < 18 Yrs
Anaheim 13.3% 19.1% 31.8% 41.5%
Buena Park 9.0% 13.2% 18.1% 25.0%
Costa Mesa 10.6% 16.9% 20.6% 29.2%
Fountain Valley 5.5% 8.6% 14.6% 28.1%
Fullerton 11.1% 16.9% 24.2% 34.0%
Garden Grove 13.6% 19.2% 21.8% 31.4%
Huntington Beach 5.8% 8.6% 14.0% 21.7%
La Habra 11.0% 16.1% 20.0% 31.6%
Lake Forest 4.2% 5.4% 8.8% 13.5%
Mission Viejo 3.4% 4.5% 11.3% 14.5%
Newport Beach 5.5% 6.2% 21.5% 20.8%
Orange 8.2% 13.2% 19.9% 30.6%
Rancho Santa Margarita 3.4% 3.9% 13.5% 18.8%
San Clemente 5.4% 9.0% 17.8% 25.3%
Santa Ana 18.5% 24.8% 31.8% 43.9%
Tustin 9.0% 12.1% 20.5% 23.9%
Orange County 8.8% 13.1% 21.0% 29.6%
California 12.0% 17.8% 27.4% 36.8%
Source: ACS 2009-2013 5Yr Est. Table DP03
COMMUNITY AND REGIONAL PROFILES
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Household Income by Tenure
The U.S. Department of Housing and Urban Development (HUD) periodically receives "custom
tabulations" of data from the U.S. Census Bureau that are largely not available through standard
Census products, referred to as the Comprehensive Housing Affordability Strategy (CHAS) data. The
most recently available CHAS estimates are derived from the 2008-2012 ACS. The primary purpose
of the CHAS data is to investigate the extent of housing problems and housing needs, particularly for
low income households. This is estimated by the number of households that have certain housing
problems and have income low enough to qualify for HUD's programs (primarily 30, 50, and 80
percent of AMI). The CHAS data are used by local governments to plan how to spend HUD funds, and
may also be used by HUD to distribute grant funds
Table 3-13 details CHAS estimates of the distribution of households by income levels in 2012.
Income levels of owners and renters were compared at the county and city levels. In summary, there
was a major difference in the composition of the extremely low and low income households between
the renter and owner categories. In Orange County 42 percent of the renters earned less than 50
percent of the area median income (AMI), while just 17 percent of homeowners earned less than this
level of income. The following cities had over one half of their renters earning 50 percent or less of
the AMFI: Santa Ana (56%), Garden Grove (55%), Anaheim (53%) and Buena Park (53%).
In Orange County, 57 percent of owner households were in the income category that earn above 100
percent of the AMI. The eight cities that have their owner households above the County figure
include: Newport Beach (74%), Orange (70%), San Clemente (64%), Lake Forest (64%), Mission Viejo
(64%), Huntington Beach (62%), Orange (60%), and Tustin (60%).
On the other hand, just 26 percent of renter households in Orange County are in the income
category that earn above 100 percent of the AMI. The following eight cities have renters below the
County average: Fountain Valley (25%), Orange (25%), Fullerton (21%), Anaheim (15%), Buena Park
(15%), La Habra (14%), Garden Grove (14%), and Santa Ana (11%).
COMMUNITY AND REGIONAL PROFILES
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
COMMUNITY AND REGIONAL PROFILES
31
14-52
Table
3-13: Income Levels by Tenure
2012
Low
0-30% AM 1
Low
31-50% AMI
Moderate
:0
AboveExtremely
ModerateCity'County
00
.. 00
Anaheim
98,435
18,890
19.2%
16,935
17.2%
21,065
21.4%
10,925
11.1%
30,620
31.1%
Owner
47,620
3,905
8.2%
5,260
11.0%
9,285
19.5%
6,260
13.1%
22,910
48.1%
Renter
50,810
14,985
29.5%
11,675
23.0%
11,780
23.2%
4,665
9.2%
7,710
15.2%
Buena Park
22,730
3,545
15.6%
3,725
16.4%
5,175
22.8%
2,625
11.5%
7,655
33.7%
Owner
13,070
815
6.2%
1,335
10.2%
2,980
22.8%
1,705
13.0%
6,235
47.7%
Renter
9,660
2,730
28.3%
2,390
24.7%
2,195
22.7%
920
9.5%
1,420
14.7%
Costa Mesa
40,525
6,070
15.0%
5,590
13.8%
8,205
20.2%
5,020
12.4%
15,630
38.6%
Owner
16,525
1,680
10.2%
1,575
9.5%
2,500
15.1%
1,630
9.9%
9,135
55.3%
Renter
24,000
4,390
18.3%
4,015
16.7%
5,705
23.8%
3,390
14.1%
6,495
27.1%
Fountain Valley
18,575
2,010
10.8%
1,815
9.8%
3,645
19.6%
2,225
12.0%
8,875
47.8%
Owner
13,320
915
6.9%
1,125
8.4%
2,255
16.9%
1,475
11.1%
7,550
56.7%
Renter
5,250
1,095
20.9%
690
13.1%
1,390
26.5%
750
14.3%
1,325
25.2%
Fullerton
44,575
7,645
17.2%
6,215
13.9%
8,135
18.3%
4,695
10.5%
17,890
40.1%
Owner
24,080
1,920
8.0%
2,305
9.6%
3,405
14.1%
2,830
11.8%
13,625
56.6%
Renter
20,490
5,725
27.9%
3,910
19.1%
4,730
23.1%
1,865
9.1%
4,265
20.8%
Garden Grove
45,930
9,470
20.6%
7,525
16.4%
10,265
22.3%
5,355
11.7%
13,315
29.0%
Owner
25,830
2,580
10.0%
3,300
12.8%
5,875
22.7%
3,515
13.6%
10,560
40.9%
Renter
20,100
6,890
34.3%
4,225
21.0%
4,390
21.8%
1,840
9.2%
2,755
13.7%
Huntington Beach
74,045
8,275
11.2%
7,945
10.7%
12,375
16.7%
7,855
10.6%
37,600
50.8%
Owner
44,530
3,265
7.3%
3,775
8.5%
5,950
13.4%
4,030
9.1%
27,515
61.8%
Renter
29,515
5,010
17.0%
4,170
14.1%
6,425
21.8%
3,825
13.0%
10,085
34.2%
La Habra
18,370
3,335
18.2%
2,890
15.7%
4,205
22.9%
2,115
11.5%
5,825
31.7%
Owner
10,100
1,120
11.1%
1,070
10.6%
1,950
19.3%
1,285
12.7%
4,675
46.3%
Renter
8,270
2,215
26.8%
1,820
22.0%
2,255
27.3%
830
10.0%
1,150
13.9%
Lake Forest
27,050
2,015
7.4%
2,580
9.5%
4,390
16.2%
3,150
11.6%
14,915
55.1%
Owner
19,195
950
4.9%
1,475
7.7%
2,600
13.5%
1,970
10.3%
12,200
63.6%
Renter
7,860
1,065
13.5%
1,105
14.1%
1,790
22.8%
1,180
15.0%
2,715
34.5%
COMMUNITY AND REGIONAL PROFILES
31
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Source: CHAS Data 2008-2012
COMMUNITY AND REGIONAL PROFILES
32
14-53
Table
3-13: Income Levels by Tenure
2012
Low
Low
ModerateExtremely
..Moderate
City/County
Total HHs
0-30% AM
1
31-50%
AMI
:0
00
.. 00
Mission Viejo
33,235
2,520
7.6%
3,440
10.4%
5,065
15.2%
3,205
9.6%
19,005
57.2%
Owner
25,790
1,350
5.2%
2,070
8.0%
3,470
13.5%
2,500
9.7%
16,400
63.6%
Renter
7,440
1,170
15.7%
1,370
18.4%
1,595
21.4%
705
9.5%
2,605
35.0%
Newport Beach
38,345
4,175
10.9%
3,060
8.0%
4,090
10.7%
2,615
6.8%
24,405
63.6%
Owner
21,115
1,605
7.6%
1,165
5.5%
1,710
8.1%
1,115
5.3%
15,520
73.5%
Renter
17,230
2,570
14.9%
1,895
11.0%
2,380
13.8%
1,500
8.7%
8,885
51.6%
Orange
43,115
5,730
13.3%
4,835
11.2%
8,070
18.7%
4,600
10.7%
19,880
46.1%
Owner
26,260
1,750
6.7%
2,070
7.9%
4,120
15.7%
2,670
10.2%
15,655
59.6%
Renter
16,855
3,980
23.6%
2,765
16.4%
3,950
23.4%
1,930
11.5%
4,225
25.1%
Rancho Santa Margarita
16,370
1,125
6.9%
1,330
8.1%
2,200
13.4%
1,930
11.8%
9,790
59.8%
Owner
11,775
455
3.9%
720
6.1%
1,210
10.3%
1,155
9.8%
8,240
70.0%
Renter
4,595
670
14.6%
610
13.3%
990
21.5%
775
16.9%
1,550
33.7%
San Clemente
24,070
2,560
10.6%
2,605
10.8%
3,830
15.9%
2,315
9.6%
12,760
53.0%
Owner
15,690
1,160
7.4%
1,140
7.3%
1,875
12.0%
1,430
9.1%
10,085
64.3%
Renter
8,380
1,400
16.7%
1,465
17.5%
1,955
23.3%
885
10.6%
2,675
31.9%
Santa Ana
72,635
15,770
21.7%
15,250
21.0%
18,725
25.8%
8,315
11.4%
14,575
20.1%
Owner
34,265
4,105
12.0%
5,605
16.4%
9,025
26.3%
5,340
15.6%
10,190
29.7%
Renter
38,370
11,665
30.4%
9,645
25.1%
9,700
25.3%
2,975
7.8%
4,385
11.4%
Tustin
24,715
3,455
14.0%
3,340
13.5%
4,840
19.6%
2,420
9.8%
10,665
43.2%
Owner
12,620
830
6.6%
1,120
8.9%
1,970
15.6%
1,185
9.4%
7,515
59.5%
Renter
12,095
2,625
21.7%
2,220
18.4%
2,870
23.7%
1,235
10.2%
3,150
26.0%
Orange County
990,265
141,360
14.3%
127,185
12.8%
178,110
18.0%
102,330
10.3%
441,275
44.6%
Owner
587,210
45,885
7.8%
54,810
9.3%
90,840
15.5%
60,240
10.3%
335,435
57.1%
Renter
403,055
95,475
23.7%
72,375
18.0%
87,270
21.7%
42,090
10.4%
105,840
26.3%
Source: CHAS Data 2008-2012
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D. Special Needs Households
Certain households, because of their unique characteristics and needs, have more barriers to finding
decent and affordable housing. These households are considered "special needs groups" and include
families with female heads of household, large households, seniors, persons with disabilities, persons
with HIV/AIDS, and homeless persons or families in need of emergency shelter. Due to their physical
or socioeconomic conditions, their greater need for support services or special accommodations, or
other factors, special needs households may have some difficulties in finding affordable housing. In
certain situations they may be more susceptible to discriminatory housing practices. The following
discussion highlights particular characteristics that could impede fair housing access for special needs
groups.
Female -Headed Households with Children
Single -parent families, particularly female -headed families with children, often require special
consideration and assistance because of their greater need for affordable housing and accessible day
care, healthcare and other supportive services. Because of their relatively lower income and higher
living expenses, female -headed families have comparatively limited opportunities for finding
affordable and decent housing. Fair housing service providers have indicated that female -headed
families may also be discriminated against in the rental housing market because some landlords are
concerned about the ability of these households to make regular rent payments. Consequently,
landlords may require more stringent credit checks or higher security deposits for women, which
would be a violation of fair housing laws.
As presented in Table 3-14 single female head of households with children represents 5.9 percent of
the total countywide households in 2013. Single female -headed family households with children
were also three times more prevalent than single male family households with children. The cities
with the highest percentage of single female head family households include the Cities of Santa Ana
(10.0%), Anaheim (8.5%), and Tustin (8.4%).
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City/Area
Table 3-14: Household Characteristics
HouseholdsHouseholds
2013
% With % With
Person(s) Persons Ave. HH
Age 65+ Under 18 Size
% Single % Single
Female Male HH
% of HH with with
Total HH Children Children
Ave.
Family
HH Size
Anaheim
22.8%
44.7%
3.39
76.0%
8.5%
2.6%
3.86
Buena Park
27.3%
42.2%
3.51
81.9%
8.0%
4.1%
3.78
Costa Mesa
17.5%
30.5%
2.68
59.5%
6.3%
2.0%
3.34
Fountain Valley
37.1%
31.6%
2.97
75.8%
4.2%
1.7%
3.40
Fullerton
24.7%
35.4%
3.02
70.5%
5.9%
2.2%
3.50
Garden Grove
28.1%
45.5%
3.72
79.5%
7.7%
2.6%
4.09
Huntington Beach
27.2%
28.1%
2.59
65.6%
4.7%
1.8%
3.13
La Habra
23.4%
41.7%
3.25
76.0%
6.1%
3.9%
3.74
Lake Forest
19.9%
38.3%
2.89
75.1%
4.6%
1.8%
3.36
Mission Viejo
28.8%
34.5%
2.80
74.8%
3.2%
1.5%
3.23
Newport Beach
30.7%
20.9%
2.24
54.8%
3.2%
1.0%
2.90
Orange
24.2%
36.8%
3.07
72.2%
6.4%
2.7%
3.53
Rancho Santa Margarita
13.3%
44.8%
2.94
77.8%
7.4%
2.3%
3.38
San Clemente
26.0%
34.5%
2.63
69.9%
5.1%
2.0%
3.15
Santa Ana
21.0%
55.5%
4.45
81.7%
10.0%
4.6%
4.64
Tustin
17.7%
42.8%
3.04
72.3%
8.4%
2.8%
3.55
Orange County
25.7%
37.1%
3.02
71.6%
5.9%
2.2%
3.53
California
24.9%
36.8%
2.94
68.6%
7.2%
2.7%
3.53
Source: ACS 2009-2013 5Yr Est. Table DP02
Large Households
Large households are defined as having five or more members. These households are usually
families with more than one child or families with extended family members such as in-laws or
grandparents. These can also include multiple families living in one housing unit in order to save on
housing costs. Large households are a special needs group because the availability of adequately
sized, affordable housing units is often limited. To save for necessities such as food, clothing and
medical care, lower- and moderate -income large households may reside in smaller units, resulting in
overcrowding. Furthermore, families with children, especially those who are renters, may face
discrimination or differential treatment in the housing market. For example, some landlords may
charge large households a higher rent or security deposit, limit the number of children in a complex,
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REGIONAL ANALYSIS OF IMPEDIMENTS
confine them to a specific location, limit the time children can play outdoors, or choose not to rent to
families with children altogether, which would violate fair housing laws.
Table 3-15 displays the percentage of households by the number of persons by owner and renter in
2013. In general, on the city, county, and state levels, households with five or more members are
more prevalent among renter households than among owner households. The only exceptions were
the Cities of Fountain Valley, Newport Beach, and Rancho Santa Margarita. Santa Ana had the
largest percent of large households (5 or more persons in household) among both renters (38.6%)
and owners (37.9%), followed by Garden Grove (25.7% of renter households and 24.9% of owner
households). Among renter households, other cities with the high percentages of large households
were La Habra (25.7%), Buena Park (23.2%), and Anaheim (22.0%). For owner households, Anaheim
(20.5%) and Buena Park (19.9%) also had high occurrences of households with five or more
members. For both types of tenure, the city with the lowest percent of large households was
Newport Beach - 2.6 percent of total renter households and 6.8 percent of total owner households.
Table
3-15: Persons Per Owner and Renter
Owner HouseholdsHousehold
Households, 2013
Anaheim
14.9%
28.4%
36.1%
20.5%
21.2%
24.2%
32.6%
22.0%
Buena Park
14.5%
27.5%
38.1%
19.9%
11.7%
24.7%
40.4%
23.2%
Costa Mesa
24.2%
34.5%
32.0%
9.3%
29.6%
33.9%
24.7%
11.9%
Fountain Valley
15.2%
34.3%
36.4%
14.1%
29.5%
28.9%
30.7%
10.9%
Fullerton
17.7%
33.4%
36.2%
12.7%
24.0%
27.2%
32.3%
16.5%
Garden Grove
14.9%
25.4%
34.9%
24.9%
15.4%
19.5%
39.4%
25.7%
Huntington Beach
21.8%
40.1%
30.3%
7.8%
30.5%
32.2%
28.4%
8.9%
La Habra
18.2%
31.6%
36.3%
13.9%
20.7%
19.7%
34.6%
24.9%
Lake Forest
18.8%
32.1%
39.4%
9.7%
24.9%
26.2%
32.2%
16.7%
Mission Viejo
18.2%
37.8%
35.4%
8.7%
25.0%
24.1%
37.3%
13.6%
Newport Beach
27.5%
41.9%
23.8%
6.8%
41.6%
34.1%
21.7%
2.6%
Orange
17.3%
34.5%
35.3%
12.9%
24.1%
25.3%
30.1%
20.4%
Rancho Santa Margarita
13.5%
28.3%
46.1%
12.2%
30.8%
24.6%
34.3%
10.3%
San Clemente
19.0%
39.1%
33.2%
8.7%
32.4%
30.1%
26.5%
11.0%
Santa Ana
12.0%
19.1%
31.0%
37.9%
14.1%
16.2%
31.1%
38.6%
Tustin
22.0%
29.2%
35.2%
13.6%
22.2%
25.5%
34.3%
18.0%
Orange County
19.0%
33.1%
34.3%
13.6%
25.3%
26.4%
31.3%
16.9%
California
20.0%
33.4%
32.6%
14.0%
29.5%
25.6%
30.1%
14.8%
Source: A CS 2009-2013 5 Y Est. Table 825009
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REGIONAL ANALYSIS OF IMPEDIMENTS
Seniors
As shown previously in Tables 3-2 and 3-3 in the Age Composition section of this chapter, the elderly
(persons over the age of 65) comprised 12.0 percent of total Orange County residents in 2013, and
5.5 percent in the over 75 years, which is considered "frail elderly." Eleven percent of the population
was between 55 and 64 years of age, comprising the "future elderly" generation that will age into
senior status in the upcoming years. Cities which exceed or equal the countywide percent of elderly
residents include Newport Beach (19.3%), Fountain Valley (18.2%), Mission Viejo (15.1%), Huntington
Beach (14.8%), San Clemente (13.9%), and Fullerton (12.0%). In terms of households, previous Table
3-15 shows that approximately one-quarter (25.7%) of total Orange County households have one or
more elderly members. The cities with high percentages of total households featuring one or more
persons over the age of 65 were Fountain Valley (37.1%), Newport Beach (30.7%), Mission Viejo
(28.8%), and Garden Grove (28.1%).
Persons with Disabilities
Fair housing choice for persons with disabilities can be compromised based on the nature of their
disability. Fair housing service providers have indicated at persons with physical disabilities may face
discrimination in the housing market because of the need for wheelchairs, home modifications to
improve accessibility or other forms of assistance. Landlords/owners sometimes fear that a unit
might sustain wheelchair damage or might refuse to exempt disabled tenants with service/guide
animals from a no -pet policy. A major barrier to housing for people with mental disabilities is
opposition based on the stigma of mental disability. Landlords sometimes refuse to rent to tenants
with a history of mental illness. Neighbors may object when a house becomes a group home for
persons with mental disabilities.
Table 3-16 presents information on persons with disabilities in Orange County and the 16 cities. As
shown in the table, Orange County residents with a disability account of 5.5 percent of the 18-64 age
group and 31.6 percent of the senior population. Of the 16 cities participating in this Al, Santa Ana
has the highest percentage of residents with a disability, with 7.1 percent of the 18-64 age group and
38.4 percent of seniors. The type of disability most prevalent among countywide residents,
especially among seniors, include ambulatory difficulties (19.8%) and those with independent living
difficulties (15.7%).
Other cities with relatively high percentage of residents with a disability include Garden Grove (6.4%
of the 18-64 age group and 36.9% of seniors) and La Habra (7.1% of the 18-64 age group and 34.7%
of seniors). Ambulatory difficulties and independent living difficulties appear to be the key types of
disabilities among senior residents. Again, the City of Garden Grove has the highest percentages in
both categories for seniors with 24.2 percent with ambulatory difficulties and 19.9 percent with
independent living difficulties. As Table 3-17 shows, other cities with a relatively high proportion of
seniors with these two difficulties include Costa Mesa, Anaheim, Santa Ana, La Habra and Tustin.
COMMUNITY AND REGIONAL PROFILES
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REGIONAL ANALYSIS OF IMPEDIMENTS
Table 3-16:
Disability Characteristics
of Seniors and Working -Age Adults 2013
% Pop.
Type of Disability
Independent
City/Area
with a
Disability
Hearing.•Living
18-64
6.0%
1.0%
0.9%
2.4%
2.9%
1.1%
2.4%
Anaheim
65+
35.5%
12.7%
6.4%
10.4%
23.5%
11.7%
19.2%
18-64
6.8%
1.0%
1.2%
2.8%
3.5%
1.4%
2.2%
Buena Park
65+
34.5%
14.9%
7.7%
11.9%
21.5%
9.3%
16.0%
18-64
5.6%
1.0%
1.3%
2.5%
2.6%
1.2%
2.0%
Costa Mesa
65+
34.6%
13.8%
6.4%
11.8%
24.2%
10.6%
17.3%
18-64
5.8%
1.3%
1.3%
2.4%
2.7%
1.3%
2.1%
Fountain Valley
65+
30.2%
12.0%
5.4%
9.1%
18.9%
7.9%
14.6%
18-64
5.8%
1.0%
1.3%
2.3%
2.7%
1.0%
2.2%
Fullerton
65+
32.6%
14.0%
6.5%
9.2%
18.8%
8.8%
15.1%
18-64
6.4%
1.2%
1.0%
3.0%
2.9%
1.2%
2.7%
Garden Grove
65+
36.9%
13.7%
6.1%
13.4%
24.2%
12.4%
19.9%
18-64
5.3%
1.2%
0.7%
2.2%
2.5%
1.1%
1.7%
Huntington Beach
65+
28.9%
13.3%
4.5%
8.3%
17.2%
7.1%
12.1%
18-64
7.1%
1.2%
1.2%
2.6%
3.9%
1.1%
2.4%
La Habra
65+
34.7%
12.6%
6.0%
8.8%
22.8%
8.0%
16.5%
18-64
4.5%
1.3%
0.8%
1.6%
2.0%
1.2%
1.5%
Lake Forest
65+
28.1%
11.0%
4.2%
8.2%
17.7%
7.9%
14.8%
18-64
4.8%
1.1%
0.5%
2.0%
2.1%
1.1%
1.7%
Mission Viejo
65+
30.0%
13.1%
6.8%
11.2%
21.9%
11.4%
15.9%
18-64
3.2%
0.7%
0.3%
1.3%
1.2%
0.5%
1.0%
Newport Beach
65+
23.8%
10.2%
3.2%
6.1%
13.2%
5.5%
10.8%
18-64
5.1%
1.2%
0.9%
2.0%
2.0%
0.9%
2.1%
Orange
65+
32.0%
12.4%
6.1%
7.7%
20.6%
9.5%
15.5%
18-64
3.6%
0.8%
0.9%
1.3%
1.1%
0.6%
0.9%
Rancho Santa Margarita
65+
20.7%
9.4%
6.2%
6.7%
12.3%
4.4%
11.0%
18-64
6.0%
1.7%
0.7%
2.1%
2.4%
1.0%
1.7%
San Clemente
65+
25.0%
13.1%
4.6%
6.0%
14.9%
6.9%
11.1%
18-64
7.1%
1.0%
3.2%
2.0%
2.6%
1.1%
1.9%
Santa Ana
65+
38.4%
13.5%
11.2%
11.4%
22.7%
9.1%
18.1%
18-64
4.5%
1.0%
1.1%
1.5%
1.8%
0.8%
1.4%
Tustin
65+
32.3%
9.9%
5.5%
9.3%
21.1%
11.5%
18.7%
18-64
5.5%
1.0%
1.1%
2.1%
2.4%
1.0%
1.9%
Orange County
65+
31.6%
12.9%
5.9%
9.5%
19.8%
9.1%
15.7%
18-64
8.0%
1.5%
1.5%
3.4%
3.9%
1.6%
2.9%
California
65+
36.8%
14.7%
6.9%
10.5%
24.0%
10.4%
18.2%
Source: ACS 2009-2013 Syr Est. Table S1810
Note: Single person may have multiple difficulties.
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Persons with disabilities might require special housing with ramps, elevators, modified bathrooms,
kitchens and doorways. Therefore, the Fair Housing Act, as amended in 1988, requires that cities and
counties provide reasonable accommodation to rules, policies, practices and procedures where such
accommodation may be necessary to afford individuals with disabilities equal housing opportunities.
Although fair housing laws intend that all people have equal access to housing, the law also
recognizes that people with disabilities may need extra tools to achieve equality. Reasonable
accommodation is one of the tools intended to further housing opportunities for people with
disabilities. For developers and providers of housing for people with disabilities, who are often
confronted with siting or use restrictions, reasonable accommodation provides a means of
requesting from the local government flexibility in the application of land -use, zoning and building
code regulations or, in some instances, even a waiver of certain restrictions or requirements because
it is necessary to achieve equal access to housing. Cities and counties are required to consider
requests for accommodations related to housing for people with disabilities and to provide the
accommodation when it is determined to be "reasonable" based on fair housing laws and the case
law interpreting the statutes.
Persons with HIV/AIDS
According to the California Public Health Department, Center for Infectious Diseases, there were a
total of 45,670 persons living with HIV and 71,883 persons living with AIDS within the State as of
December 31, 2012. New drugs, better treatment, and preventive education have reduced the
number of AIDS fatalities. However, new cases of HIV infection continue to occur. Between the
years 2001 and 2013, there were a total of 4,174 new cases of HIV reported in Orange County,
averaging 321 cases per year for the 13 year time period.
Persons with HIV/AIDS face an array of barriers to obtaining and maintaining affordable, stable
housing. For persons living with HIV/AIDS, access to safe, affordable housing could be as important
to their general health and wellbeing as access to quality healthcare. For many, the persistent
shortage of stable housing can be the primary barrier to consistent medical care and treatment. In
addition, persons with HIV/AIDS may be targets of hate crimes. Despite federal and state anti-
discrimination laws, many people face illegal eviction from their homes when their illness is exposed.
The Fair Housing Amendments Act of 1988, which is primarily enforced by HUD, prohibits housing
discrimination against persons with disabilities, including persons with HIV/AIDS.
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REGIONAL ANALYSIS OF IMPEDIMENTS
Homeless Persons
Over the last several decades, the increasing homeless population has become issues of local,
regional, and national significance. Lack of affordable housing can exacerbate homelessness, and
hinders a community's ability to effectively address this challenge. A homeless family or individual as
defined by federal regulations is a person or family that lacks a fixed and regular nighttime residence.
The homeless population can be divided into two major groups, the sheltered and the unsheltered
homeless. Sheltered homeless are those individuals or families whose primary residence is an
emergency shelter, transitional housing, a domestic violence shelter, a shelter for runaway children,
or people living in a motel/hotel under a voucher arrangement. Unsheltered homeless are individual
or families with a primary nighttime residence that is a public or private place not designed for or
ordinarily used as a regular sleeping accommodation for human beings, including a car, park,
abandoned building, bus or train station, airport, or camping ground.
Once every two years, Orange County conducts a count of the number of homeless in the county in a
given 24-hour period, which is known as the Homeless Point -in -Time (PIT) count survey. The PIT is a
one night snapshot of homelessness. The 2015 PIT count was conducted in the evening of January
23, 2015 for the sheltered count and the morning of January 24, 2015 for the unsheltered count.
In the 2015 PIT count survey, 4,452 homeless persons were counted, as shown in Table 3-17. The
2015 count was represents approximately 0.14 percent of the total countywide population. It was
also slightly higher than the previous 2013 PIT count of 4,251 homeless persons. This increase of 201
homeless person between the 2013 and 2015 PIT count was a slight shift from previous counts
between 2011 and 2013, when the homeless counts declined by 2,688 persons. The 2015 count
survey also shows that 2,251 homeless persons (51%) live in shelters and the remaining 2,201 are
unsheltered (49%). Of those living in shelters, approximately 40 percent were living in emergency
shelters and 60 percent in transitional housing. These shelter facilities are defined as:
■ Emergency Shelter — A facility that provides overnight shelter and fulfills a client's basic
needs (i.e. food, clothing, medical care) either on-site or through off-site services. The
permitted length of stay can vary from one day at a time to three months.
■ Transitional Housing — A residence that provides housing for up to two years. Residents of
transitional housing usually include supportive services designed to assist the homeless in
achieving greater economic independence and a permanent, stable living situation. Services
may include mental and physical health care interventions, substance abuse treatment, job
training and employment services, individual and group counseling and life skills training. In
addition, some substance abuse programs offer limited transitional housing services in
addition to treatment.
Overall, homeless persons living in shelters declined by approximately 13 percent from the 2013
count, and homeless persons unsheltered increased by 31 percent from the 2013 count.
The 2015 PIT count survey also indicates there were 3,354 homeless households, and of the total
homeless households, 61 percent lived in unsheltered conditions. Other key findings from the 2015
count include:
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■ 31 percent of all homeless persons are persons in households with children
■ Almost all (99%+) of homeless families were housed in emergency shelters or transitional
housing programs
■ Five percent of homeless people are youths and young adults
■ 13 percent of homeless adults have a serious mental illness, and nearly two-thirds are
unsheltered
■ 12 percent of homeless adults are veterans
■ The number of chronically homeless declined by 30 percent and the homeless with chronic
substance abuse declined by 54 percent from the 2013 count
Table 3-17:
Homeless Point In Time Count
2013 and 2015
% Change
W. .-
HOMELESS PERSONS
Sheltered
2,573
60.5%
2,251
50.6%
-12.5%
Emergency Shelter
1,145
44.5%
925
41.1%
-19.2%
Transitional Housing
1,428
55.5%
1,326
58.9%
-7.1%
Unsheltered
1,678
39.5%
2,201
49.4%
31.2%
Total
4,251
100.0%
4,452
100.0%
4.7%
HOMELESS HOUSEHOLDS
Sheltered
1,545
48.4%
1,315
39.2%
-14.9%
Unsheltered
1,644
51.6%
2,039
60.8%
24.0%
Total
3,189
100.0%
3,354
100.0%
5.2%
HOMELESS SUBPOPULATIONS
Chronically Homeless*
829
580
-30.0%
Veterans
446
447
0.2%
Severely Mentally III
480
475
-1.0%
Chronic Substance Abuse
986
458
-53.5%
Persons with HIV/AIDS
89
81
-9.0%
ANNUALIZED ESTIMATE
Homeless Persons per Year
1
12,707
1
15,291
20.3%
Sources: Orange County Homeless 2015 PIT Report; Orange County Homeless County & Survey Report, July 2013
*Includes Chronically Homeless Individuals and Persons in Chronically Homeless Families
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E. Housing Profile
Housing Growth
Table 3-18 details the number and growth rate of the housing stock of the 16 cities, Orange County,
and California between 2000 and 2015. In general, there was consistent positive growth on the 16
cities, county and state levels during both the 2000-2010 and 2010-2015 time periods. The sole
exception is the City of Garden Grove, which decreased in number of housing units by one-tenth of
one percent between 2010 and 2015. During the last five years, Tustin experienced the greatest rate
of housing growth at 3.0 percent, larger than both the county rate of 2.0 percent and the state rate
of 1.7 percent. Overall, the City of Lake Forest had the largest percentage increase in housing; Lake
Forest's growth rate was 32.2 percent during the 2000s and 1.4 percent from 2010 to 2015, totaling
34.0 percent housing growth during the 15 -year period. The only other cities to experience double-
digit growth for the same time period were San Clemente (26.5%) and Newport Beach (18.6%). In
comparison, total housing units within Orange County increased by 10.3 percent and within
California by 13.9 percent between 2000 and 2015. The City of Garden Grove had the lowest overall
housing growth rate, with a 2.2 percent increase between 2000 and 2015, followed by La Habra
(3.2%), Buena Park (3.8%), and Santa Ana (3.9%).
Sources: 2010 Census; Dept of Finance E-5 estimates, January 2015
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Table 3-18: Housing Growth 2000-2015
City/Areaoil
% Change
000111illi2.1%
�=
Anaheim
99,719
104,237
106,407
4.5%
Buena Park
23,826
24,623
24,726
3.3%
0.4%
Costa Mesa
40,406
42,120
42,592
4.2%
1.1%
Fountain Valley
18,473
19,164
19,303
3.7%
0.7%
Fullerton
44,771
47,869
48,474
6.9%
1.3%
Garden Grove
46,703
47,755
47,727
2.3%
-0.1%
Huntington Beach
75,662
78,003
79,896
3.1%
2.4%
La Habra
19,441
19,924
20,060
2.5%
0.7%
Lake Forest
20,486
27,088
27,454
32.2%
1.4%
Mission Viejo
32,985
34,228
34,619
3.8%
1.1%
Newport Beach
37,288
44,193
44,211
18.5%
0.0%
Orange
41,920
45,111
45,267
7.6%
0.3%
Rancho Santa Margarita
16,515
17,260
17,309
4.5%
0.3%
San Clemente
20,653
25,966
26,116
25.7%
0.6%
Santa Ana
74,588
76,896
77,477
3.1%
0.8%
Tustin
25,501
26,476
27,262
3.8%
3.0%
Orange County
969,484
1,048,907
1,069,450
8.2%
2.0%
California
12,214,550
13,680,081
13,914,715
12.0%
1.7%
Sources: 2010 Census; Dept of Finance E-5 estimates, January 2015
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Housing Type
The majority of Orange County's housing stock is comprised of single-family dwelling units.
According to the California Department of Finance 2015 estimates, which are presented in Table 3-
19, 62.7 percent of the countywide housing stock is single-family units (detached and attached).
Over one-third (34.2%) the housing stock is multi -family units (two dwelling units or more) and 3.1
percent are mobile homes. Of the 16 cities, Mission Viejo (83.7%), Fountain Valley (75.7%) and
Rancho Santa Margarita (74.7%) have the highest percentage of single-family units in their housing
stock. The city with the highest proportion of multi -family units is Tustin, which has slightly more
multi -family units (48.9%) than single-family units (47.8%). Other cities with a high percentage of
multi -family units include Costa Mesa (48.3%) and Anaheim (44.9%).
Table
Anaheim
3-19:
42.2%
Housing Stock by
8.5%
Type 2015
MultipleDU
10.7%
34.2%
Mobile
4.4%
Buena Park
58.2%
7.3%
7.0%
26.0%
1.4%
Costa Mesa
39.4%
10.1%
13.4%
34.9%
2.2%
Fountain Valley
65.6%
10.1%
3.6%
18.7%
2.0%
Fullerton
50.3%
10.1%
8.4%
29.5%
1.8%
Garden Grove
57.2%
8.3%
8.8%
22.3%
3.4%
Huntington Beach
48.7%
11.6%
12.1%
23.7%
3.9%
La Habra
53.1%
7.5%
7.7%
27.2%
4.4%
Lake Forest
54.3%
15.1%
5.5%
20.5%
4.6%
Mission Viejo
71.4%
12.3%
2.6%
13.5%
0.1%
Newport Beach
45.6%
15.9%
11.6%
24.3%
2.7%
Orange
57.5%
10.7%
10.8%
18.2%
2.7%
Rancho Santa Margarita
54.0%
20.7%
3.6%
21.6%
0.1%
San Clemente
56.9%
10.0%
15.7%
15.1%
2.3%
Santa Ana
45.9%
7.3%
9.7%
31.8%
5.2%
Tustin
34.7%
13.1%
14.8%
34.1%
3.3%
Orange County
1 50.7%
12.0%
8.7%
25.5%
3.1%
Source: CA Dept of Finance E-5 estimates, January 2015
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Age of Housing Stock
Over one-third of the existing housing stock in the county was constructed after 1980. This leaves
approximately two-thirds of the homes over 35 years old. The median age of an Orange County
home is 40 years. In general, homes built more than 30 years ago are likely to require structural
renovation and increased maintenance, resulting in greater costs for the owner. Older homes can
also create health and safety problems for occupants. Older, deteriorated structures often do not
meet current building code standards and lack safety features such as fire suppression, home
security devices and seismic safety retrofits. In fact, stringent seismic safety codes were not
developed until after the 1971 Sylmar earthquake. After that event, many building codes were
revised to ensure structures could withstand seismic activity of similar magnitude. Additionally, in
1978 the federal government prohibited the use of lead-based paint on residential property;
therefore, homes built prior to 1979 have a potential risk of containing lead-based paint. Lead
poisoning can cause learning disabilities, behavioral problems and even brain damage in children.'
As presented in Table 3-20 , the age of the housing stock varies across the 16 cities. Among the 16
cities, Buena Park's housing stock is the oldest, with the median year of home construction in 1962.
This is followed by the Cities of Garden Grove (1964), La Habra (1967) and Santa Ana (1967). The city
with newest homes is Rancho Santa Margarita, with the median year of home construction in 1992.
Other cities with newer residential construction include Lake Forest and San Clemente (both with
1981 as the median year of home construction). In San Clemente, 21.2 percent of its housing was
constructed within the last 15 years.
Housing Cost and Affordability
Many housing problems are directly related to the cost of housing in a community. If housing costs
are relatively high in comparison to household income, a correspondingly high prevalence of
excessive housing cost burden and overcrowding occurs. This section evaluates the affordability of
the housing stock in Orange County and the 16 cities accessible to low and moderate income
households.
Housing Prices. The value of homes varies substantially among the 16 cities, because prices depend
on the age, size and location of homes. As shown in Table 3-21, the average sales price of all homes
in Orange County (single-family and condominiums) was $615,000 in September 2015. In
comparison to the previous year (2014), the average sales price increased by approximately five
percent. Among the 16 cities, the highest sales price in September 2015 was in the City of Newport
Beach, with prices averaging almost $1.5 million. The second and third highest home sale prices
among the 16 cities were in the Cities of San Clemente and Huntington Beach at $860,000 and
$719,000, respectively.
Home sale prices in the $400,000 range include the Cities of Santa Ana ($445,000), Rancho Santa
Margarita ($455,000), Buena Park ($462,500), La Habra ($470,000), Garden Grove ($475,000), and
Anaheim ($485,000). An interesting fact is that the median age of Santa Ana's housing stock is 48
2Executive Order 12898—Environmental Justice
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years old, while Rancho Santa Margarita has the youngest housing stock among the 16 cities at only
23 years. In general, home sale prices are lower in communities of older homes, such as the Cities of
Buena Park, La Habra, and Garden Grove, where the median age of homes are about 50 years old.
Table 3-20: Housing Stock by Year Built, 2013
Median
Year iii .
City/Area Built Before 1940 M later
Anaheim 1972 2.6% 24.7% 43.2% 22.5% 7.0%
Buena Park 1962 2.4% 43.9% 36.3% 12.4% 5.1%
Costa Mesa 1969 1.6% 24.9% 50.2% 17.3% 6.1%
Fountain Valley 1972 0.5% 2.4% 78.5% 13.1% 5.5%
Fullerton 1969 5.5% 26.1% 44.2% 15.6% 8.7%
Garden Grove 1964 1.8% 38.7% 40.7% 14.1% 4.6%
Huntington Beach 1972 1.6% 6.6% 67.5% 19.4% 4.9%
La Habra 1967 2.2% 30.6% 48.4% 15.0% 3.9%
Lake Forest 1981 0.2% 1.7% 44.2% 51.6% 2.3%
Mission Viejo 1979 0.4% 0.8% 51.9% 43.1% 3.8%
Newport Beach 1974 3.8% 18.4% 41.3% 24.4% 12.1%
Orange 1972 5.3% 15.6% 47.6% 23.1% 8.5%
Rancho Santa Margarita 1992 0.2% 0.5% 3.3% 90.7% 5.3%
San Clemente 1981 2.0% 11.8% 34.8% 30.2% 21.2%
Santa Ana 1967 7.3% 27.0% 46.6% 15.4% 3.6%
Tustin 1979 1.8% 4.9% 46.4% 36.4% 10.5%
Orange County 1975 2.6% 15.7% 44.8% 27.2% 9.3%
California 1974 9.5% 20.4% 32.0% 26.0% 11.8%
Source: ACS 2009-2013 5Yr Est. Tables 825034 and 825035
Rental Rates. Table 3-21 also shows the average monthly rents of all rental units. According to
information from RealFact.com, rental units in Orange County are renting, on average, at $1,848 per
month. Average monthly rental rates by cities was available from another source, Realtor.com. The
rental rate data shows that monthly rents range from $1,800 in the City of Garden Grove to as high
as $4,800 in the City of Newport Beach. A recent article in the Orange County Register states that an
improving job market and ongoing barriers to home -buying are driving up apartment rents in
Orange County at the fastest pace in eight years. According to the article, the countywide average
monthly rental rate of $1,848 is an all-time high, and 6.9 percent more than a year ago. As a result
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of a low inventory of rental units and high demand, vacancy rates are very low -- 5.3 percent
according to 2015 DOF estimates -- thus, owners can raise rents. According to the Orange County
Register, New York had the nation's highest apartment rent at $3,374 a month and San Francisco
was second, averaging $2,392 a month. Los Angeles County's average rent is $1,552 a month, with
the Inland Empire's average rent at $1,159.
Table 3-21: Cost of Housing, 2015
Sold'Average Average
Sales Price of Monthly Rental
City/Area Homes
Anaheim 250 $485,000 $1,900
Buena Park 53 $462,500 $2,200
Costa Mesa 93 $700,000 $2,300
Fountain Valley 53 $687,500 $1,900
Fullerton 124 $507,000 $2,300
Garden Grove 111 $475,000 $1,800
Huntington Beach 231 $719,000 $2,500
La Habra 64 $470,000 $1,900
Lake Forest 98 $650,000 $2,600
Mission Viejo 125 $605,000 $2,800
Newport Beach 102 $1,475,000 $4,800
Orange 130 $566,000 $2,300
Rancho Santa Margarita 64 $455,000 $2,200
San Clemente 73 $860,000 $3,200
Santa Ana 167 $445,000 $2,000
Tustin 74 $572,500 $2,500
Orange County 3,193 $615,000 $1,8003
Source:
1 RealtyTrack and CorelLogic, September 2015. Includes average of single family and condominium units
z Realtor.com, December 2015
3. RealFacts, Spring 2015
Affordability. Based on federal and state guidelines that households should not spend more than 30
percent of their gross income on housing, Table 3-22 estimates the maximum housing costs
affordable to Extremely Low Income, Very Low Income, Low Income, and Moderate Income
households in Orange County. The affordability threshold is based upon the four -person household.
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Using updated income guidelines, current housing affordability in terms of home ownership can be
estimated for the various income groups. According to the State Income Limits for 2015, the Area
Median Income (AMI) for a family of four in Orange County is $87,200. The income limit for an
Extremely Low Income household (0-30% AMI) is $28,900, a Very Low Income household (31-50%
AMI) is $48,150, a Low Income household (51-80% AMI) is $77,050, and Moderate Income (81-120%
AMI) is $104,650.
Assuming that the potential homebuyer for each income group has sufficient down payment, credit,
and maintains housing expenses no greater than 30 percent of their income, the maximum
affordable home prices can be calculated. Table 3-22 presents maximum affordability purchase
prices and rents. Previous Table 3-21 is compared with information in Table 3-22, and it appears
that:
■ Extremely Low, Very Low, and Low Income households cannot afford housing (rental or
ownership) of adequate size in any of the 16 cities -- in particular, Extremely Low and Very
Low Income households.
■ On average, even Moderate Income households would find it difficult to purchase a home
that costs more than $475,200. Based on the average sales price of homes presented in
previous Table 3-22, Moderate Income households would have been able to purchase a
home in 2015 in the cities of Buena Park, Garden Grove, La Habra, Rancho Santa Margarita,
and Santa Ana.
Table 3-22: Maximum Affordable Housing Prices and Rents by Income Groups 2015
Max. Home Max. Home
Income Category Income Limit Purchase Price Rental Rate
Area Median Income (4 -Persons): $87,200
Extremely Low Income (0-30% AMI) $28,900 $116,600 $504
Very Low Income (31%- 50% AMI) $48,150 $195,900 $890
Lower Income (51-%- 80% AMI) $77,050 $315,500 $1,494
Moderate Income (101-120% AMI) $104,650 $475,200 $2,316
Calculation of affordable rent is based on 30% of gross household income. Calculation of affordable home purchase is
based on down payment of 10%, annual interest rate of 4.00% 30 -year fixed mortgage, utilities of $150 (ELI), $200 (VLI),
$250 (LI), $300 (MI), and tax/insurance of 20% of housing expense.
Future Housing Needs
Article 10.6 of the Government Code Section 65580-65590 requires all California localities to adopt a
Housing Element as part of their General Plan. State Housing Element Law requires that cities and
counties develop local housing programs to meet its "fair share" of existing and future housing needs
for all income groups. The Southern California Association of Governments (SCAG), through the fifth -
cycle of the Regional Housing Needs Assessment (RHNA), allocated the regional fair share of housing
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needs to all cities within the five county region (Imperial, Los Angeles, Orange, San Bernardino, and
Ventura Counties) for the 2014-2021 period. Each city is required to implement housing programs
through it Housing Element to accommodate the level of housing growth identified in the RHNA by
household income categories.
Table 3-23 presents the distribution of the future housing needs for each of the 16 cities by four
household income categories. As presented in the table, the City of Anaheim has the largest number
of housing needs (5,702 units) during the 2014-2021 period, with the second largest need in the City
of Lake Forest (2,727 units). On the other hand, the cities with the fewest number of future housing
needs during the 2014-2021 period are the Cities of Costa Mesa and Rancho Santa Margarita, each
with two units, followed by La Habra (4 units) and Newport Beach (5 units). With the exception of
the Cities of Fullerton and San Clemente, each of the 16 cities have adopted Housing Elements which
were certified by the State Department of Housing and Community Development (HCD). More
details on the Housing Elements are discussed in Chapter 5: Public Policies and Practices.
Table 3-23: Future Housing Needs by Income Level, 2014-2021
ModerateIncome Categories
Total 0
Housing % % Above
Cities/County Units Very Low Moderate
Anaheim 5,702 22.0% 15.9% 18.2% 43.9%
Buena Park 339 22.4% 15.6% 18.3% 43.7%
Costa Mesa 2 50.0% 50.0% 0.0% 0.0%
Fountain Valley 358 23.2% 16.5% 18.2% 42.2%
Fullerton 1,841 22.3% 16.2% 18.3% 43.1%
Garden Grove 747 22.0% 16.1% 18.1% 43.9%
Huntington Beach 1,353 23.1% 16.3% 18.3% 42.3%
La Habra 4 25.0% 25.0% 25.0% 25.0%
Lake Forest 2,727 23.7% 16.5% 18.2% 41.5%
Mission Viejo 177 23.7% 16.4% 18.6% 41.2%
Newport Beach 5 20.0% 20.0% 20.0% 40.0%
Orange 363 22.9% 16.3% 18.2% 42.7%
Rancho Santa Margarita 2 50.0% 50.0% 0.0% 0.0%
San Clemente 581 23.1% 16.4% 18.6% 42.0%
Santa Ana 204 22.1% 15.7% 18.1% 44.1%
Tustin 1,227 23.1% 15.9% 18.3% 42.8%
Source: SCAG RHNA Final Allocation Plan 2014-2021
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F. Housing Issues Profile
Overpayment
According to HUD standards, a household is considered "cost -burdened" or overpaying for housing if
housing costs (rent plus utilities) make up more than 30 percent of the household's income.
Households are "severely cost burdened" or severely overpaying if they spend more than 50 percent
of their income on housing costs. A major consequence of overpayment is that less income is
available to satisfy other critical household needs, such as transportation, medical and education.
According to Table 3-24, overpayment (greater than 30% of income) for housing occurred in 44.5
percent of total households in 2012, and severe overpayment (greater than 50% of income) occurred
in 21.2 percent of total households. Additionally, the incidence of overpayment was higher for
renters than owners, with 52.0 percent of renter households and 39.3 percent of owner households
spending more than 30 percent of their income on housing costs.
Source: CHAS Data 2012
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Table 3-24: Overpayment by Tenure
2012
Overpayment
Severe
Overpayment
City/County
0���
Anaheim
41.5%
59.1%
50.6%
19.0%
31.3%
25.2%
Buena Park
40.4%
54.8%
46.6%
14.8%
27.4%
20.1%
Costa Mesa
40.7%
50.6%
46.5%
20.6%
24.1%
22.7%
Fountain Valley
34.7%
53.2%
39.9%
16.9%
28.6%
20.2%
Fullerton
36.9%
53.1%
44.4%
15.8%
29.3%
22.0%
Garden Grove
38.5%
55.8%
46.1%
17.5%
29.9%
22.9%
Huntington Beach
37.3%
47.0%
41.2%
15.4%
24.3%
18.9%
La Habra
40.2%
57.5%
48.0%
14.1%
19.0%
15.5%
Lake Forest
37.1%
45.0%
39.4%
14.0%
19.0%
15.5%
Mission Viejo
36.0%
55.4%
40.4%
15.2%
28.0%
18.0%
Newport Beach
39.6%
42.2%
40.7%
22.3%
23.4%
22.8%
Orange
39.6%
51.8%
44.4%
16.7%
26.0
20.3%
Rancho Santa Margarita
42.4%
51.1%
45.0%
15.0%
22.3%
17.1%
San Clemente
44.6%
50.7%
46.7%
21.9%
28.7%
24.3%
Santa Ana
42.8%
55.3%
49.4%
20.5%
28.4%
24.7%
Tustin
43.6%
55.3%
49.3%
17.5%
26.6%
21.9%
Orange County
39.3%
52.0%
44.5%
17.5%
26.6%
21.2%
Source: CHAS Data 2012
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The rate of overpayment varied across jurisdictions, with over one-half (50.6%) of the total
households in Anaheim overpaying, compared to 39.4 percent of Lake Forest households overpaying.
Anaheim also had one-quarter (25.2%) of its households paying over 50 percent of their income on
housing -- the highest percentage of severe overpayment among the 16 cities. In all cases, renter
households were uniformly more likely to be cost burdened than owner households throughout the
16 cities. The incidence of overpayment among renter households was highest in the Cities of
Anaheim and La Habra, where 59.1 percent and 57.5 percent of households were cost burdened,
respectively. Among owner households, the highest percentage of overpaying occurred in the Cities
of San Clemente (44.6%) and Tustin (43.6%).
Overcrowding
A lack of affordable housing can result in overcrowded households. As defined by HUD,
overcrowding occurs when there is more than one person per room (excluding kitchens, bathrooms
and hallways). Occupancy by more than 1.5 persons per room is considered severe overcrowding.
Table 3-25 shows the overcrowding rate among renters and owners in the 16 cities and Orange
County in 2013. As shown in the table, 9.3 percent of all households countywide were overcrowded.
Overcrowding was substantially higher among renters than owners, with 16.8 percent of renters and
4.0 percent of owner households living in overcrowded conditions.
The prevalence of overcrowding varied among the 16 cities. In the City of Santa Ana, almost one-
third (32.5%) of the households lived in overcrowded conditions, significantly higher than the 9.3
percent overcrowding countywide. This was followed by La Habra with 19.1 percent of households
living in overcrowded condition. The lowest percentage of overcrowding occurred in Newport Beach,
where only 1.2 percent of household lived in overcrowding conditions. It should be noted that
Newport Beach also has the lowest household size among the 16 cities at 2.24 persons per
household. In all cases, rental overcrowding was significantly higher than owner occupied housing.
Overcrowding was particularly high among renter households in Santa Ana and La Habra, where 42.6
percent and 33.1 percent of households were overcrowded, respectively.
This indicates the need for larger rental units and/or rental subsidies to allow large households to
afford adequately sized units. Conditions of overcrowding are largely a combination of the lack of
large rental units and the inability of most large renter households to afford larger units and lack of
available adequately -sized rental units, as larger housing units tend to be more common in the
homeownership market.
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Source: ACS 2009-2013 5Yr Est. Table 825014
G. Public and Assisted Housing
The availability and location of public and assisted housing is a fair housing concern if such housing is
concentrated in one area of a city and, therefore, a household's access to housing may be limited to
that area. In addition, public/assisted housing, including Section 8 rental assistance, must be
accessible to qualified households regardless of race/ethnicity, disability or other special needs or
protected class.
Section 8 Rental Assistance Housing Program
The Section 8 Housing Choice Voucher Program provides rental subsidies to low-income families that
spend more than 30 percent of their gross income on housing costs. The program pays the
difference between 30 percent of the recipients' monthly income and the federally approved
COMMUNITY AND REGIONAL PROFILES
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Table 3-25: Overcrowding by Tenure
Percentage of Total Households
•
2013
Overcrowded
(1.51+ PPR)
���
0Total
Anaheim
8.1%
26.2%
17.6%
1.7%
10.5%
6.3%
Buena Park
4.1%
21.3%
11.7%
0.4%
6.7%
3.2%
Costa Mesa
1.8%
12.0%
7.9%
0.3%
4.1%
2.6%
Fountain Valley
1.8%
6.5%
3.1%
0.2%
0.8%
0.4%
Fullerton
3.2%
17.5%
9.7%
1.0%
7.0%
3.8%
Garden Grove
10.5%
23.4%
16.2%
2.5%
8.4%
5.1%
Huntington Beach
0.5%
6.1%
2.8%
0.1%
2.0%
0.9%
La Habra
7.8%
33.1%
19.1%
2.6%
21.1%
10.9%
Lake Forest
1.0%
12.5%
4.5%
0.3%
3.7%
1.3%
Mission Viejo
1.1%
9.3%
2.8%
0.4%
1.2%
0.5%
Newport Beach
0.5%
2.0%
1.2%
0.1%
1.0%
0.5%
Orange
3.2%
21.0%
10.4%
0.6%
8.0%
3.6%
Rancho Santa Margarita
0.9%
9.3%
3.3%
0.2%
2.8%
0.9%
San Clemente
0.9%
8.3%
3.4%
0.1%
4.5%
1.6%
Santa Ana
20.7%
42.6%
32.5%
7.1%
22.3%
15.3%
Tustin
4.1%
16.1%
10.0%
1.3%
4.4%
2.8%
Orange County
4.0%
16.8%
9.3%
1.1%
6.9%
3.5%
Source: ACS 2009-2013 5Yr Est. Table 825014
G. Public and Assisted Housing
The availability and location of public and assisted housing is a fair housing concern if such housing is
concentrated in one area of a city and, therefore, a household's access to housing may be limited to
that area. In addition, public/assisted housing, including Section 8 rental assistance, must be
accessible to qualified households regardless of race/ethnicity, disability or other special needs or
protected class.
Section 8 Rental Assistance Housing Program
The Section 8 Housing Choice Voucher Program provides rental subsidies to low-income families that
spend more than 30 percent of their gross income on housing costs. The program pays the
difference between 30 percent of the recipients' monthly income and the federally approved
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payment standard. Recipients of Section 8 vouchers are able to find their own housing, including
single-family homes, townhouses and apartments. Under this program, owners are given favorable
tax treatment provided that they preserve the units at rents that are affordable to low-income
households.
Within the 16 cities participating in the regional Al, there are four housing authorities that administer
the Housing Choice Voucher Program: Orange County Housing Authority (OCHA), Anaheim Housing
Authority (AHA), Garden Grove Housing Authority (GGHA), and the Santa Ana Housing Authority
(SAHA).
Orange County Housing Authority. Within the 16 cities, the Orange County Housing Authority, as of
October 2015, assists 6,263 households through the Section 8 Housing Choice Voucher Program. The
total includes 774 households who have moved to Orange County through portability (housing
vouchers issued by another housing authority, but administered by OCHA), and 852 households that
are assisted by OCHA but live in the Cities of Garden Grove or Anaheim, which have their own
housing authorities. As of October 2015, approximately 46,000 households are on the OCHA waiting
list for the program.
As presented in Table 3-26, of the 16 cities, the OCHA administers the largest number of Section 8
vouchers to the City of Huntington Beach, with 926 households (15%). This is followed by the City of
Costa Mesa with 607 households (10%). The racial/ethnic characteristics of recipients include 40
percent non -Hispanic Whites, 27 percent non -Hispanic Asians, 22 percent Hispanic and 10 percent
non -Hispanic Black/African American. As previously shown in this chapter, the non -Hispanic White
population represents 44 percent of the countywide total in 2013. The Hispanic population
represented 34 percent, non -Hispanic Asian 19 percent and non -Hispanic Black less than two
percent. When comparing the elderly and disabled recipients of Section 8 vouchers, 43 percent of
the households include at least one elderly person, and 40 percent are disabled head of households.
Anaheim Housing Authority. According to the Anaheim Housing Authority, as of February 2016,
there are 6,162 Section 8 Housing Voucher and Project -Based Voucher recipients. Of the total
recipients, 35 percent are Hispanic, 28 percent are non -Hispanic Asian/Pacific Islander, 28 percent
are non -Hispanic White, eight percent are non -Hispanic Black/African American, and less than one
percent are Native American. Also, 42 percent of the total recipients are elderly and 37 percent are
disabled. In addition, there are 31,033 households on the waiting list to participate in Section 8 and
Project -Based Voucher programs and 12,893 households in the Affordable Housing program. Of
those on the waiting list to participate in the Section 8 and Project -Based programs, 33 percent are
Hispanic, 26 percent are non -Hispanic Black/African American, 21 percent are non -Hispanic
Asian/Pacific Islander, 19 percent non -Hispanic White, and one percent non -Hispanic Native
American. The waiting list for the Affordable Housing programs includes 48 percent Hispanic, 21
percent non -Hispanic White, 19 percent non -Hispanic Asian/Pacific Islander, nine percent non -
Hispanic Black/African American, , and one percent Native American.
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Table 3-26: Orange County Housing Authority
Section 8 Program Recipients by City
Anaheim
385
123
99
98
60
5
136
173
Buena Park
464
115
156
51
140
2
149
163
Costa Mesa
607
366
107
113
13
5
235
220
Fountain Valley
480
111
34
334
4
4
335
187
Fullerton
590
242
194
71
76
7
207
238
Garden Grove
575
43
38
471
11
8
279
160
Huntington Beach
926
426
151
301
41
7
452
364
La Habra
187
49
113
9
15
1
66
80
Lake Forest
239
141
46
17
34
1
82
119
Mission Viejo
264
187
28
17
30
2
117
150
Newport Beach
144
99
20
7
15
2
69
52
Orange
598
220
189
137
46
6
264
254
Rancho Santa Margarita
145
84
27
8
24
2
66
70
San Clemente
136
102
24
4
5
1
84
69
Santa Ana
6
1
2
0
2
1
0
3
Tustin
517
190
184
58
82
3
177
191
Total
6,263
2,499
1,412
1,696
598
57
2,718
2,493
Percent of Total
39.9%
22.5%
27.1%
9.5%
0.9%
43.4%
39.8%
Source: Housing Authority of Orange County as of October 2015
Garden Grove Housing Authority. According to information provided by the Garden Grove Housing
Authority (GGHA) in November 2015, there are approximately 2,300 Section 8 Program participants
in Garden Grove. The largest racial/ethnic group participating in the program are non -Hispanic Asian
residents, which represents 80 percent of the total recipients. Hispanic families account of 11
percent, non -Hispanic White 16 percent and non -Hispanic Black/African American one percent.
Approximately 56 percent of the total Section 8 participants are elderly and 33 percent are disabled.
There were approximately 16,000 households on the current waiting list for the GGHA Section 8
Program, and of those, Asians account for over one-half (56%), while Hispanic residents account for
19 percent. Also, over one-half (56%) of residents on the waiting list are the elderly and one-third
(33%) are persons with disabilities.
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Santa Ana Housing Authority. According to information provided by the Santa Ana Housing
Authority (SAHA) in December 2015, there are 1,761 recipients participating in the Section 8 Voucher
Program. Of the Section 8 recipients, over one-half (53%) are non -Hispanic Asian residents, followed
by approximately one-third (34%) Hispanic residents. Non -Hispanic Whites account for nine percent
and non -Hispanic Black/African Americans account for three percent. Additionally, elderly recipients
represent one-half (50.5%) of the total and persons with disabilities account for 41 percent.
According to SAHA, there are 5,128 residents on the current Section 8 Voucher waiting list. Hispanic
and non -Hispanic Asian residents together account for three-quarters of the total residents on the
waiting list, with Hispanics at 46 percent and non -Hispanic Asians at 31 percent. Waiting list
residents that are elderly or disabled represent 18 percent and 16 percent, respectively.
H. Residential Care Facilities
Individuals with special needs, including the elderly or persons with physical or mental disabilities,
need access to suitable housing in their community. This segment of the population often needs
affordable housing that is located near public transportation, social and health services, and
shopping. Persons with disabilities may require units equipped with wheelchair accessibility or other
special features that accommodate physical or sensory limitations. Depending on the severity of the
disability and support program regulations and reimbursement levels, people may live independently
with some assistance in their own homes, in assisted living, or other special care facilities.
Table 3-27 shows the number of licensed community care facilities in the each of the 16 cities. In
total, there are 2,105 licensed community care facilities, with 1,011 facilities serving adults, elderly
and persons with disabilities (including children) that are located in the 16 cities. The licensed care
facilities for the special needs residents are defined as follows by the California Department of Social
Services, Community Care Licensing Division:
■ Adult Residential Facilities (ARF) provide 24-hour non-medical care for adults ages 18 years
through 59 years old who are unable to provide for their own daily needs. ARFs include
board and care homes for adults with developmental disabilities and mental illnesses.
■ Residential Care Facilities for the Elderly (RCFE) provide care, supervision, and assistance
with daily living activities, such as bathing and grooming. In California, "elderly" is considered
age 60 and above.
■ Adult Day Care facilities provide care to persons 18 years of age or older in need of personal
services, supervision, or assistance essential for sustaining the activities of daily living or for
the protection of these individuals on less than a 24-hour basis.
■ Children's Residential Group Homes provide 24-hour non-medical care and supervision to
children. Services include social, psychological, and behavioral programs for troubled youth.
■ Small Family Homes (SFH) provide 24-hour care in the licensee's family residence for six or
fewer children who require special supervision as a result of a mental or developmental
disability or physical handicap.
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In addition to the residential care facilities described above, there are a wide variety of programs to
assist special needs populations and homeless individuals and families, who are homeless or at risk of
homelessness. Many programs also target specific groups such as youth, veterans, or persons with
HIV/AIDS.
Table 3-27: Licensed Community Care Facilities
Asst. Living
Resid. Care Children's
Adult Resid. Adult Residential Small Family
City/Area Facilities im Day Care Group Homes Homes
Anaheim 96 97 8 2 0
Buena Park 29 26 1 3 0
Costa Mesa 9 42 1 9 2
Fountain Valley 2 42 1 2 1
Fullerton 11 38 2 6 0
Garden Grove 33 41 1 3 0
Huntington Beach 1 54 1 1 4
La Habra 1 16 0 0 0
Lake Forest 7 40 0 0 0
Mission Viejo 9 147 2 0 1
Newport Beach 0 13 0 0 0
Orange 23 47 3 11 1
Rancho Santa Margarita 0 0 0 0 0
San Clemente 1 20 0 0 1
Santa Ana 34 27 1 7 0
Tustin 2 22 1 5 0
Total 258 672 22 49 10
Source: California Department of Social Services, Community Care Licensing Division
https://secure. dss. ca. gov/CareFacilitySearch/home/selecttype/
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I. Accessibility to Public Transportation
Public transit is often the only travel option for lower income households. Public transit should link
lower income households to major employment centers. A lack of relationship between public
transit, job centers, and affordable housing may impede Fair Housing Choice because persons who
depend on public transit will be limited in the choice of where they can live.
Elderly persons and persons with disabilities are more likely than other groups to be transit
dependent. Many rely on public transit to visit doctors, go shopping, or attend activities offered at
the community centers. Housing for the elderly and persons with disabilities should be located near
transit routes, or alternative transit should be made available for persons with special needs. This
section discusses the accessibility of public transit to lower income residents and housing for persons
with special needs.
Public Transit - OCTA
The Orange County Transportation Authority (OCTA) was formed in 1991 and provides transportation
services to commuters moving throughout 34 cities and unincorporated areas of Orange County. The
use of bus transportation and regional intermodal connections reduces freeway traffic congestion,
improves safety and efficiency on local roads, and provides transportation options to people with
special needs. The OCTA administrative offices are located in the City of Orange and it maintains bus
operations bases in the cities of Garden Grove and Santa Ana. First Transit, which contracts with
OCTA to provide public transit services to about operates about one-third of OCTA's Fixed Routes out
of the Anaheim and Irvine bases. MV Transportation operates OCTA's paratransit base for the
authority's ACCESS service also in Irvine. In addition to bus services, OCTA provides light rail service
(Metrolink). OCTA also operates the State Route 91 Freeway Express lanes.
Bus Service. OCTA operates approximately 77 bus routes in Orange County. Most of the bus riders
are from lower income households. Tables 3-28 and 3-29 present the 2015 OCTA bus fares and a
descriptions of various passes offered to riders.
The OCTA is proposing a service plan for 2016 that includes the elimination of several bus routes.
The proposed changes will affect some of the 16 cities, which are mostly located along the coast and
also in the southern section of Orange County. Some of the key, proposed bus routes or segments
that are planned to be discontinued include:
■ Anaheim: Eliminate a portion of bus line route 30 near the Metrolink station. Eliminate
portion of bus line 167.
■ Buena Park: Eliminate a portion of bus line route 21 from Graham and McFadden to Pacific
Coast Highway.
■ Costa Mesa: Eliminate bus lines 51 and 145 from Santa Ana to Costa Mesa. Eliminate bus
lines 172 and 173 from Huntington Beach to Costa Mesa.
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■ Fullerton: Eliminate portion of express bus line 721 from Fullerton to Los Angeles.
■ Garden Grove: Eliminate portions of bus line 56 from Garden Grove to Orange.
■ Huntington Beach: Eliminate a portion of bus line 35 from Graham and McFadden to Pacific
Coast Highway. Eliminate bus line 76 from Huntington Beach to Newport Beach. Eliminate
bus lines 172 and 173 from Huntington Beach to Costa Mesa. Eliminate bus line 178 from
Huntington Beach to Irvine. Eliminate portion of express bus line 701 from Harbor Gateway
Transit Center to Union Station.
■ La Habra: Eliminate bus line 20 from Imperial and Idaho to Lemon and Main.
Table 3-28: OCTA Bus Fare Structure 2015
Local Routes:
Regular Fare — Local Route
$ 2.00
Customers 6 years and older
Senior Citizen — Local Route
$ 0.75
Customers 60 and older
ACCESS - Local Fare
$ 0.25
Customers with certified disability
Children 5 yrs and younger ride free when riding with paying
Children
Free
passenger. Limit: Three kids per customer
Express Routes:
Regular Fare
$ 6.00
Express Routes: 701, 721 and 794
Additional fare, combined with
any valid OCTA bus pass
$ 4.00
Express Routes: 701, 721 and 794
Seniors (60 & Older), persons
with disabilities and Medicare
cardholders
$ 5.00
Express Routes: 701, 721 and 794
Additional fare, combined with
any valid OCTA bus pass
$ 4.25
Express Routes: 701, 721 and 794
Regular Fare
$ 4.00
Express Routes: 757 and 758
Additional fare, combined with
any valid OCTA bus pass
$ 2.00
Express Routes: 757 and 758
Seniors (60 & Older), persons
with disabilities and Medicare
cardholders
$ 3.50
Express Routes: 757 and 758
Additional fare, combined with
any valid OCTA bus pass
$ 2.75
Express Routes: 757 and 758
Source: OCTA Web Site, December 2015
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Table 3-29: OCTA Cost of Bus Passes 2015
Local Route Passes:
Day Pass
$ 5.00
Only sold on board by coach operators
Day Pass -Seniors
$ 1.50
Seniors (60 and older), persons w/disabilities and Medicare
Pre -Paid Day Pass
$ 4.50
Pre -Paid Day Pass -Seniors
$ 1.35
Seniors (60 and older), persons w/disabilities and Medicare
7 -Day Pass
$ 25.00
7 -Day Pass -Seniors
$ 8.25
Seniors (60 and older), persons w/disabilities and Medicare
30 -Day Pass
$ 69.00
30 -Day Pass -Youth
$ 69.00
Ages 6-18 only
30 -Day Pass -Senior
$ 22.25
Seniors (60 and older), persons w/disabilities and Medicare
5 Rides Pass
$ 9.00
Valid for 5 rides, anytime. Valid for all ages.
Express Route Passes:
Express 30 -Day
$187.50
Unlimited use on all local routs plus 701, 721 and 794
Express Day Pass
$ 12.00
Only sold on board by coach operators, valid until 11:59 p.m.
Express Senior Day Pass
$ 10.00
Seniors (60 and older), persons w/disabilities and Medicare
OC Express 30 -Day
$125.00
Unlimited use on all local routes plus 757 and 758
OC Express Day Pass
$ 8.00
Only sold on board by coach operators, valid until 11:59 p.m.
OC Express Senior Day Pass
$ 7.00
Seniors (60 and older), persons w/disabilities and Medicare
Other Passes:
Unlimited rides for 30 consecutive days between June 1 and
Summer Youth Pass
$ 20.00
Sep 30
30 -Day College Pass
$ 46.00
Students "C -Pass" *
75 -Day Quarter College Pass
$ 116.00
Students "C -Pass" *
120 -Day Semester College Pass
$ 185.00
Students "C -Pass" *
CSUF — University Pass
$ 92.00
"U -Pass" cost for the four-month semester
UC Irvine — University Pass
$ 169.00
"U -Pass" cost for the academic year from July 1 to June 30
Chapman provides a $25 per month subsidy for regular monthly
passes to 28 persons. If there are more than 28 persons that
want the subsidy, Chapman conducts a simple lottery to select
Chapman — University Pass
$ 25.00
28 people that will receive the subsidy for that month.
* C -Pass is available to qualified students at these participating colleges: Career College of California (30 -Day available), Cypress College,
Fullerton College (30 -Day available), Goldenwest College, Irvine Valley College, NOCCCD School of Continuation Education, Orange Coast
College, Saddleback College (30 -Day available), Santa Ana College (30 -Day available), Santiago Canyon College, The Art Institute of California
Source: OCTA Web Site, December 2015
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■ Mission Viejo: Eliminate portion of bus line 85 from Crown Valley and Alicia to Golden
Lantern and Dana Point. Eliminate bus line 191 from Mission Viejo to San Clemente.
■ Newport Beach: Eliminate bus line 76 from Huntington Beach to Newport Beach. Eliminate
portion of bus line 71 from Yorba Linda to Newport Beach.
■ Orange: Eliminate portions of bus line 56 from Garden Grove to Orange.
■ Rancho Santa Margarita: Eliminate bus line 87 from Rancho Santa Margarita to Laguna
Niguel.
■ San Clemente: Eliminate bus line 191 from Mission Viejo to San Clemente. Eliminate bus
line 193.
■ Santa Ana: Eliminate bus lines 51 and 145 from Santa Ana to Costa Mesa. Eliminate express
bus line 757.
Metrolink Service. Metrolink is a system of eight (8) lines that serve the counties of Ventura, Los
Angeles, Orange, Riverside and San Bernardino. It is a network of stations that connect to major
destinations and employment centers. In Orange County, OCTA's Metrolink rail service has three
lines and 13 stations from Buena Park to San Clemente, of which 10 are located within one of the 16
participating cities. OCTA operates the following:
■ OC -Line: The OC Line has stations in the following Orange County cities: Buena Park,
Fullerton, Anaheim, Orange, Santa Ana, Tustin, Irvine, Laguna Niguel/Mission Viejo, San Juan
Capistrano and San Clemente. This line ends in Oceanside.
■ 91 -Line: The 91 line has stations in the following Orange County cities: Buena Park and
Fullerton. This line ends in Riverside.
■ Inland Empire/Orange County (IEOC) Line: The Inland Empire/Orange County (IEOC) Line
has three stations in the following Orange County cities: Anaheim, Orange, Santa Ana, Tustin,
Irvine, Laguna Niguel/Mission Viejo, San Juan Capistrano and San Clemente. This line ends in
Oceanside..
Metrolink fares are based on trip length and it offers many different types of tickets. Seniors and
persons with disabilities receive 50 percent off one-way and round-trip tickets and 25 percent off
monthly and 7 -day passes. Children ages five and under ride free with each fare -paying adult
(limited to three children per adult). Fares, discounts and other related Metrolink items are listed
below:
■ Non-refundable and non -replaceable: Metrolink tickets are sold at ticket -vending machines
on station platforms.
■ One -Way Ticket: Valid for a single one-way trip between the origin and destination stations.
One-way tickets are valid for three hours from time of purchase.
■ Round -Trip Ticket: Valid for a round-trip on the same day between the origin and destination
stations. Travel must begin within three hours from time of purchase and end that same day.
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■ Advance Purchase Ticket: One-way or round-trip tickets can be purchased up to one year in
advance. Unlike a same-day travel ticket, an advance purchase ticket will not include a
printed expiration time.
■ 7 -Day Pass: Good for unlimited trips for seven consecutive days between a set origin and
destination, the 7 -Day Pass is priced at seven one-way trips. Discounts apply for
senior/disabled/Medicare (25% off) and students (10% off). It may not be purchased in
advance.
■ $10 Weekend Day Pass: Available for purchase only on Saturday and Sunday, this pass is
good for unlimited travel throughout the Metrolink system either Saturday or Sunday. The
Weekend Day Pass is accepted for free transfers to connecting transit services, except
Amtrak.
■ Monthly Pass: Valid for unlimited travel between the origin and destination station during
the calendar month printed on the pass. .
■ Metrolink and Amtrak Transfers: Only OCTA buses that directly connect with Metrolink
trains at or near rail stations will honor Metrolink tickets and passes.
The following discounts apply to Metrolink fares and passes:
■ Youth (Ages 6 to 18): 25 percent off Monthly Pass, 7 -Day Pass, One -Way and Round -Trip
tickets
■ Child (Ages 5 and under): Three children ride free with an adult using a valid ticket - each
additional child pays youth fare.
■ Students: 25 percent off Monthly Pass, 7 -Day Pass, One -Way and Round -Trip tickets
■ Short Distance Fares — Starting January 1, 2016: Metrolink is lowering short distance fares
system -wide to $3 for adults/youth/students and only $1.50 for senior/disabled/Medicare
riders for one-way tickets. The short distance fare is offered to encourage local travel on
Metrolink and is good for one station to the next station on any line Metrolink serves.
■ Senior (Ages 65 and over): 25 percent off Monthly Pass and 7 -Day Pass and 50 percent off
One -Way and Round -Trip tickets
■ Persons with Disabilities: 25 percent off Monthly Pass and 7 -Day Pass and 50 percent off
One -Way and Round -Trip tickets. A Personal Care Attendant (PCA) is allowed to accompany a
person with a disability without purchasing a ticket. The PCA must board and detrain with
the person with a disability.
■ Active Military: 10 percent off One -Way and Round -Trip tickets.
Public transit also provides a link between residents and employment centers. Appendix B
includes maps illustrating the location of major employment centers within each city to public
transit routes. According to the 2013 ACS data, approximately three percent of the Orange
County workers age 16 and older use public transit as a means of transportation.
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REGIONAL ANALYSIS OF IMPEDIMENTS
4. Mortgage Lending Practices
An essential aspect of fair housing choice is equal access to credit for the purchase or improvement
of a home. In the past, fair lending practices were not always employed by financial institutions.
Credit market distortions and other activities such as redlining — a practice whereby a lender provides
unequal access to credit or unequal credit terms to a person because of their race, creed, color or
national origin or other characteristic(s) of the residents of the area where the applicant resides or
will reside - prevented some groups from equal access to credit.
The passage of the Community Reinvestment Act (CRA) in 1977 and the Home Mortgage Disclosure
Act (NMDA) in 1979 was designed to improve access to credit for all members of the community.
This section reviews the lending practices of financial institutions, and the access that minorities and
all income groups have to home loans.
A. Lending Laws and Regulations
Community Reinvestment Act
The Community Reinvestment Act (CRA) is intended to encourage regulated financial institutions to
help meet the credit needs of entire communities, including low and moderate -income
neighborhoods. Depending on the type of institution and total assets, a lender may be examined by
different supervising agencies for its CRA performance. A search in the Federal Reserve Board (FRB),
Federal Financial Institutions Examination Council (FFIEC), Federal Deposit Insurance Corporation
(FDIC), Office of the Comptroller of the Currency (OCC), and Office of Thrift Supervision (OTS)
databases was performed.
Home Mortgage Disclosure Act
In tandem with the CRA, the Home Mortgage Disclosure Act (NMDA) requires lending institutions to
make annual public disclosures of their home mortgage lending activity. Under HMDA, lenders are
required to disclose information on the disposition of home loan applications and on the race or
national origin, gender, and annual income of loan applicants.
Detailed HMDA data for conventional and government -backed home purchase and home
improvement loans in Orange County were examined. HMDA data provides some insight into the
lending patterns that exist in a community. However, the HMDA data is used only to indicate the
potential for unfair lending practices; the data cannot be used to reach definite conclusions on
discriminatory practices.
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REGIONAL ANALYSIS OF IMPEDIMENTS
Conventional, Government -Backed Financing
Conventional financing involves market -rate loans provided by private lending institutions such as
banks, mortgage companies, savings and loans, and thrift institutions. To assist lower and moderate
income households that may have difficulty in obtaining home mortgage financing in the private
market due to income and equity issues, several government agencies offer loan products that have
below market rate interests and are insured ("backed") by the agencies. Sources of government -
backed financing include loans insured by the Federal Housing Administration (FHA), the Department
of Veterans Affairs (VA), and the Rural Housing Services/Farm Service Agency (RHA/FSA). Often
government -backed loans are offered to the consumers through private lending institutions. Local
programs such as first time homebuyer and rehabilitation programs are not subject to HMDA
reporting requirements.
Financial Stability Act
The Financial Stability Act of 2009 established the Making Home Affordable Program, which assists
eligible homeowners who can no longer afford their home with mortgage loan modifications and
other options, including short sale or deed -in -lieu of foreclosure. The program is targeted toward
homeowners facing foreclosure, who are unemployed, or who owe more on their mortgage than
their home is worth. The Making Home Affordable Program includes several options for
homeowners in need of assistance:
■ Home Affordable Modification Program: This program reduces a homeowner's monthly
mortgage payment to 31 percent of their verified gross (pre-tax) income to make their
payments more affordable.
■ Second Lien Modification Program: Program offers homeowners a way to lower payments
on their second mortgage.
■ HARP 1.0: The Home Affordable Refinance Program, also known as HARP, is a federal
program of the United States, set up by the Federal Housing Finance Agency in March 2009
to help underwater and near -underwater homeowners refinance their mortgages. Program
assists homeowners whose mortgages are current and held by the Federal National
Mortgage Association (Fannie Mae) or the Federal Home Loan Mortgage Corporation
(Freddie Mac) refinance into a more affordable mortgage. Over 900,000 people have
benefited from this program. In an effort to enable more struggling homeowners to take
advantage of the Home Affordable Refinance Program, the deadline to submit an application
to the program has been extended to December 31, 2016.
■ HARP 2.0: Many people who purchased their home with a down payment of less than 20%
of the purchase price were required to have private mortgage insurance (PMI) a common
practice with Freddie Mac or Fannie Mae loans. Having PMI attached to a loan made that
loan easier to sell on the Wall Street secondary market as a "whole loan." PMI hedged the
risk brought by the high loan -to -value ratio by offering insurance against foreclosure for
whoever owned the "whole loan". Although HARP 2.0 allows homeowners with PMI to apply
through the Making Home Affordable Refinance Program, many homeowners have faced
MORTGAGE LENDING PRACTICES
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REGIONAL ANALYSIS OF IMPEDIMENTS
difficulty refinancing with their original lender. HARP requires the new loan to provide the
same level of mortgage insurance coverage as the original loan. This can be difficult and
time-consuming, especially in the case of lender -paid private mortgage insurance (LPMI). As
a result, many lenders are reluctant to refinance a PMI mortgage. HARP 2.0 enables
homeowners to go to any lender to refinance, so the mortgage holder is not stymied if the
original bank is unwilling to pursue a HARP refinance. HARP 2.0 refinancing is allowed on all
occupancy types: primary residence (owner -occupied), second home, or investment (rental)
property. However, HARP 2.0 refinancing of investment properties by Fannie Mae and
Freddie Mac has higher mortgage rates than for owner -occupied properties. According to
HARP.gov, there are still 430,000 homes that could qualify for HARP 2.0. FHFA, the
organization that oversees HARP, examined homes with loans originated before June 2009
and have little or no equity and meet other requirements. Despite current rates in the low
four percent range, nearly half a million people are still holding onto their mortgages at five
percent, six percent, or even higher.
■ HARP 3.0: In 2012, President Barack Obama outlined a plan to give "every responsible
homeowner the chance to save about $3,000 a year on their mortgage". The plan -
sometimes referred to as "HARP 3 - has not yet passed. HARP 3 is expected to expand
HARP's eligibility requirements to homeowners with non -Fannie Mae and non -Freddie Mac
mortgages, including homeowners with jumbo mortgages and Alt -A mortgages, those whose
original mortgages were stated income, stated asset, or both.
■ Unemployment Program: Program provides eligible homeowners a forbearance period
during which their monthly mortgage payments are reduced or suspended while they seek
re-employment. The minimum forbearance period is three months, although a mortgage
servicer may extend the term depending on applicable investor and regulatory guidelines.
■ Principal Reduction Program: Offers homeowners who are underwater the opportunity to
earn principal reductions over a three-year period by successfully making payments in
accordance with their modified loan terms.
■ Home Affordable Foreclosure Alternatives Program (HAFA): For homeowners who can no
longer afford their homes, but do not want to go into foreclosure, HAFA offers homeowners,
their mortgage servicers, and investors' incentives for completing a short sale or deed -in -lieu
of foreclosure. HAFA enables homeowners to transition to more affordable housing while
being released from their mortgage debt. The program also includes a "cash for keys"
component whereby a homeowner receives financial assistance to help with relocation costs
in return for vacating their property in good condition.
Helping Families Save Their Homes Act
The Helping Families Save Their Homes Act was passed by Congress and signed by the President in
May 2009 and expands the Making Home Affordable Program. This Act includes provisions to make
mortgage assistance and foreclosure prevention services more accessible to homeowners and
increases protections for renters living in foreclosed homes. It also establishes the right of a
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REGIONAL ANALYSIS OF IMPEDIMENTS
homeowner to know who owns their mortgage and provides over two billion dollars in funds to
address homelessness.
The Act targets underwater borrowers by easing restrictions on refinance and requiring principal
write-downs to help these homeowners increase the equity in their homes. The new law also
provides federally guaranteed Rural Housing loans and FHA loans as part of the Making Homes
Affordable Program. In addition to expanding the Making Homes Affordable Program, the Act
extends the temporary increase in deposit insurance, increases the borrowing authority of the FDIC
and National Credit Union Administration (NCUA), and creates a Stabilization Fund to address
problems in the corporate credit union sector. Under this bill, tenants also have the right to stay in
their homes after foreclosure for 90 days or through the term of their lease. Prior to this bill, tenants
were only guaranteed 60 days of notice before eviction and any current lease was considered
terminated in the event of a foreclosure. This Act extends the 60 -day notification period to 90 days
and requires banks to honor any existing lease on a property in foreclosure.
On May 20, 2009, President Obama signed the Homeless Emergency Assistance and Rapid Transition
to Housing (HEARTH) Act into law reauthorizing HUD's Homeless Assistance programs. It was
included as part of the Helping Families Save Their Homes Act of 2009. The HEARTH Act allows for
the prevention of homelessness, rapid re -housing, consolidation of housing programs, and new
homeless categories. In the eighteen months after the bill's signing, HUD must make regulations
implementing this new McKinney program.
Fraud Enforcement and Recovery Act
The Fraud Enforcement and Recovery Act of 2009, or FERA, was enacted May 20, 2009. This federal
law enhanced criminal enforcement of federal fraud laws, especially regarding financial institutions,
mortgage fraud, and securities fraud or commodities fraud. FERA amends the definition of a
financial institution to include private mortgage brokers and non-bank lenders that are not directly
regulated or insured by the federal government, making them liable under federal bank fraud
criminal statutes. The new law also makes it illegal to make a materially false statement or to willfully
overvalue a property in order to manipulate the mortgage lending business. In addition, FERA
includes provisions to protect funds expended under TARP and the Recovery Act and amends the
Federal securities statutes to cover fraud schemes involving commodity futures and options.
Additional funds were also made available under FERA to a number of enforcement agencies in order
to investigate and prosecute fraud.
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REGIONAL ANALYSIS OF IMPEDIMENTS
B. Overall Lending Patterns
Data and Methodology
The availability of financing affects a person's ability to purchase or improve a home. Under HMDA,
lending institutions are required to disclose information on the disposition of loan applications by the
income, gender, and race of the applicants. This applies to all loan applications for home purchases,
improvements, and refinancing, whether financed at market rate or with government assistance.
HMDA data are submitted by lending institutions to the FFIEC. Certain data is available to the public
via the FFIEC site either in raw data format or as pre-set printed reports. The analyses of HMDA data
presented in this Al were conducted using data from Compliance Tech. Compliance Tech's Lending
Patterns on-line database tool that analyzes lending records to produce reports on various aspects of
mortgage lending was used in this report. HMDA data included in this report includes market share,
approval rates, denial rates, low/moderate income lending, and high-cost lending, among other key
lending aspects in the Orange County 16 City study area.
General Overview
A summary of all home purchase loan activities in each of the 16 cities and Orange County, including
loans that went through the complete loan process, and loans approved and denied from 2008 to
2013 are found in Appendix C-1. Included is information on loan outcomes by race/ethnicity. In
addition, Appendix C-2 lists denial rates of purchase loans by race by Census Tract in all 16 cities of
the study area. In 2013, the cities that had the most loan applications — over 2,000 for the year —
included Huntington Beach, Mission Viejo, Orange and Santa Ana. Anaheim had over 3,000
completed purchase home loans. The cities with fewer home loan completions — under 1,000 —
included Buena Park, Fountain Valley and La Habra.
Home purchase loan denial rates varied somewhat by city and from the Orange County average. In
2013 the average home purchase loan denial rate was 15 percent in Orange County. Out of the 16
cities in the study area, the following had denial rates in 2013 less than the Orange County average:
Rancho Santa Margarita (11%), Mission Viejo (12%), San Clemente (12%), Fullerton (13%),
Huntington Beach (13%), Lake Forest (14%) and Orange (14%). Denial rates in La Habra and Newport
Beach were at 15 percent, the County average. On the other hand, the cities with denial rates higher
than the Orange County average included: Anaheim (16%), Costa Mesa (16%), Tustin (16%), Buena
Park (18%), Fountain Valley (18%), Garden Grove (20%) and Santa Ana (20%).
Home loan denial rates have been declining since the peak of the financial crisis in 2008 when the
Orange County denial rate was at 22 percent. Steadily, the denial rate has decreased and stabilized
at 15 percent during the last three years. The same pattern occurred in most of the 16 cities.
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Home Purchase Loans
Home purchase loans were reviewed in the Orange County 16 City study area in 2013, as listed in
Table 4-1. The approved loans included all loans that were originated and applications approved but
not accepted. These loans went through the complete underwriting process. Overall, 85 percent of
purchase loans were approved in Orange County.
Table 41: Status of Home Purchase Loans 2013
...
ApplicationsLoans Approved Loans Denied
lefl� Total
Anaheim 3,655 3,064 84% 591
Buena Park 796 653 82% 143
Costa Mesa 1,471 1,242 84% 2297
Fountain Valley 640 528 83% 112 18%
Ful I erton 1,741 1,521 87% 220 13%
Garden Grove 1,944 1,548 80% 396 20%
Huntington Beach 2,359 2,041 87% 318 13%
La Habra 948 807 85% 141 15%
Lake Forest 2,091 1,796 86% 295 14%
Mission Viejo 2,387 2,091 88% 296 12%
Newport Beach 2,011 1,716 85% 295 15%
Orange 2,355 2,025 86% 330 14%
Rancho Santa Margarita 1,641 1,456 89% 185 11%
San Clemente 1,301 1,142 88% 159 12%
Santa Ana 2,162 1,721 80% 441 20%
Tustin 1,281 1,076 84% 205 16%
OC County 33,742 28,842 85% 4,900 15%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
Note: Approved loans include loans originated and applications approved but not accepted.
Denial Rate based on applications that went through complete underwriting process, and exlude
applications withdrawn or files closed for incompleteness.
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Refinancing Loans
Refinance home loans were also reviewed. (Please see Table 4-2.) Owners will usually refinance
existing home loans for a number of reasons, including better interest rates, consolidating debts,
changing from variable rate to fixed rate loans, or taking equity out of their homes for various
reasons.
The majority of loan applications submitted by Orange County households in 2013 were for home
refinancing - over 100,000 applications. Approximately 80 percent of refinance applications were
approved and 20 percent were denied in 2013. The study area's 16 cities approval and denial rates
were fairly comparable to the countywide figures.
Table 4-2: Status of Home Refinance Loans 2013
Anaheim
10,647
8,388
79%
2,259
21%
Buena Park
2,802
2,185
78%
617
22%
Costa Mesa
4,332
3,434
79%
898
21%
Founta i n Va I I ey
2,451
1,952
80%
499
20%
Fullerton
5,602
4,478
80%
1,124
20%
Garden Grove
6,115
4,721
77%
1,394
23%
Huntington Beach
8,117
6,626
82%
1,491
18%
La Habra
2,538
2,038
80%
500
20%
Lake Forest
4,111
3,343
81%
768
19%
Mission Viejo
7,324
6,022
82%
1,302
18%
Newport Beach
6,159
4,928
80%
1,231
20%
Orange
7,938
6,494
82%
1,444
18%
Rancho Santa Margarita
4,620
3,840
83%
780
17%
San Clemente
4,021
3,243
81%
778
19%
Santa Ana
6,704
5,055
75%
1,649
25%
Tustin
4,351
3,513
81%
838
19%
OC County
100,947
81,026
80%
19,921
20%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
Note: Approved loans include loans originated and applications approved but not accepted.
Denial Rate based on applications that went through complete underwriting process, and exlude
applications withdrawn or files closed for incompleteness.
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Home Improvement Loans
Home improvement loans were also reviewed, and are shown in Table 4-3 below. These types of
loans are used to make necessary repairs and maintenance or to expand the size of a home. Usually,
home improvement loan applications have a higher rate of denial when compared to home purchase
or refinance loans because adding debt may exceed an applicant's maximum level of debt per lender
guidelines. Lowering equity is assessed as riskier by lenders and, for this reason, denial rates are
higher in these types of loans. In 2013, 4,156 applications for home improvement loans were
submitted by Orange County households. The overall approval rate for home improvement loans in
2013 was 74 percent while 26 percent of these applications were denied.
Table 4-3: Status of Home Improvement Loans 2013
W -WIMP. 15-Malvem Loans Approved Loans Denied
Applications mTotal �k,11111=
Anaheim 447 307 69% 140 31%
Buena Park 132 97 73% 35 27%
Costa Mesa 169 120 71% 49 29%
Fountain Valley 118 90 76% 28 24%
Fullerton 239 171 72% 68 28%
Garden Grove 314 218 69% 96 31%
Huntington Beach 340 266 78% 74 22%
La Habra 126 83 66% 43 34%
Lake Forest 141 102 72% 39 28%
Mission Viejo 298 231 78% 67 22%
Newport Beach 213 171 80% 42 20%
Orange 343 259 76% 84 24%
Rancho Santa Margarita 199 143 72% 56 28%
San Clemente 155 124 80% 31 20%
Santa Ana 328 209 64% 119 36%
Tusti n 172 129 75% 43 25%
OC County 4,156 3,060 74% 1,096 26%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRCAssociates, Inc., October2015
Note: Approved loans include loans originated and applications approved but not accepted.
Denial Rate based on applications that went through complete underwriting process, and exlude
applications withdrawn orfiles closed for incompleteness.
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C. Lending Patterns by Race/Ethnicity and Income Level
The federal Fair Housing Act prohibits discrimination in mortgage lending based on race, color,
national origin, religion, sex, familial status or handicap -disability. Thus, it is important to assess not
just overall approval and denial rates for a city, but also whether or not these rates vary by other
factors, such as race/ethnicity.
Loan Applications by Race
Completed home purchase loan applications were also analyzed by race in the Orange County 16 city
study area and compared to the countwide loan approval/denial rates for the 2008-2013 period.
(Please see Tables 4-4 and 4-5). These are the loans that went through the complete underwriting
cycle, which ultimately either led to a loan or denial of loan. In summary, completed application
loans by race countywide included:
■ White (49 percent)
■ Asian (28 percent)
■ Hispanic (10 percent)
■ Black (0.6 percent)
Since 2008, the White population has had a constant share of home loan applications in the County
at figures ranging from 47 to 49 percent. Black application figures have decreased by about half,
from 1.2 percent of all loans in 2008 to 0.6 in 2013. The Asian share of the completed home loan
applications has increased countywide from 23 percent to 28 percent in 2013.
In several cities, the Asian share of home purchase loan applications has increased to over 30
percent, including Anaheim, Buena Park, Fountain Valley, Fullerton, Garden Grove, La Habra, Lake
Forest and Santa Ana.
In contrast, Hispanics evidenced a significant decrease in mortgage loan applications over the past
five years in Orange County. In 2008, Hispanics accounted for 16 percent of all home purchase loan
applications, and this figure has steadily declined to 10 percent in 2013. All of the 16 cities in the
study area have seen a drop in the number of completed Hispanic home purchase loan applications,
including the cities with the largest Hispanic populations (Anaheim, Santa Ana and La Habra).
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REGIONAL ANALYSIS OF IMPEDIMENTS
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Denial rate based on applications that went through the complete underwriting process, and excludes
applications withdrawn or files closed for incompleteness.
MORTGAGE LENDING PRACTICES
69
14-90
Table 4-4:
Status of Home
Purchase Loans
by Applicant Race
- 2013
EE
Anaheim
3,655
1,336
36.55%
31
0.85%
722
19.75%
1,157
31.66%
4
0.11%
21
0.57%
11
0.30%
317
8.67%ME756
1.53%Buena
Park
796
172
21.61%
6
0.75%
143
17.96%
38147.86%
1
0.13%
8
1.01%
3
0.38%
64
8.04%
2.26%Costa
Mesa
1,471
897
60.98%
6
0.41%
90
6.12%
232
15.77%
0.00%
4
0.27%
6
0.41%
211
14.34%
1.70%
Fountain Valley
640
195
30.47%
4
0.63%
24
3.75%
364
56.88%
-
0.00%
4
0.63%
1
0.16%
48
7.50%
-
0.00%
Fullerton
1,741
553
31.76%
14
0.80%
254
14.59%
700
40.21%
3
0.17%
12
0.69%
6
0.34%
181
10.40%
18
1.03%
Garden Grove
1,944
417
21.45%
4
0.21%
257
13.22%
1,110
57.10%
-
0.00%
6
0.31%
7
0.36%
118
6.07%
25
1.29%
Huntington Beach
2,359
1,478
62.65%
10
0.42%
126
5.34%
446
18.91%
3
0.13%
9
0.38%
7
0.30%
260
11.02%
20
0.85%
La Habra
948
316
33.33%
10
1.05%
218
23.00%
315
33.23%
-
0.00%
7
0.74%
1
0.11%
73
7.70%
8
0.84%
Lake Forest
2,091
906
43.33%
9
0.43%
121
5.79%
814
38.93%
3
0.14%
24
1.15%
6
0.29%
205
9.80%
3
0.14%
Mission Viejo
2,387
1,625
68.08%
15
0.63%
133
5.57%
289
12.11%
4
0.17%
19
0.80%
6
0.25%
294
12.32%
2
0.08%
Newport Beach
2,011
1,257
62.51%
4
0.20%
36
1.79%
333
16.56%
4
0.20%
3
0.15%
6
0.30%
321
15.96%
47
2.34%
Orange
2,355
1,236
52.48%
14
0.59%
238
10.11%
589
25.01%
5
0.21%
16
0.68%
9
0.38%
234
9.94%
14
0.59%
Rancho Santa Margarita
1,641
1,113
67.82%
18
1.10%
111
6.76%
175
10.66%
2
0.12%
3
0.18%
8
0.49%
205
12.49%
6
0.37%
San Clemente
1,301
990
76.10%
4
0.31%
50
3.84%
61
4.69%
1
0.08%
7
0.54%
5
0.38%
175
13.45%
8
0.61%
Santa Ana
2,162
587
27.15%
7
0.32%
678
31.36%
670
30.99%
2
0.09%
6
0.28%
8
0.37%
176
8.14%
28
1.30%
Tustin
1,281
654
51.05%
5
0.39%
129
10.07%
329
25.68%
2
0.16%
7
0.55%
4
0.31%
143
11.16%
8
0.62%
Orange County Total
1 33,742
1 16,526
48.98%
201
0.60%
1 3,258
9.66%
1 9,517
28.21%1
41
0.12%
1 170
0.50%
1 123
0.36%
3,607
10.69%
299
0.89%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Denial rate based on applications that went through the complete underwriting process, and excludes
applications withdrawn or files closed for incompleteness.
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REGIONAL ANALYSIS OF IMPEDIMENTS
Table 45: Home Purchase Loans - Completed Loan Applications Percent of Total, 2008 to 2013
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Tusti n
Orange County Total
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Tusti n
Orange County Total
35%
26%
57%
28%
38%
21%
63%
34%
58%
67%
65%
50%
68%
70%
26%
44%
49%
26%
24%
9%
5%
20%
16%
6%
34%
13%
9%
3%
15%
7%
3%
40%
17%
16%
2009 12010
34% 34%
27% 23%
62% 60%
26% 26%
33% 35%
19% 19%
64% 62%
34% 35%
58% 49%
65% 64%
67% 66%
46% 47%
68% 69%
72% 72%
23% 23%
39% 40%
47% 47%
35%
34%
37%
1.8%
1.0%
0.7%
28%
23%
22%
3.1%
1.9%
1.6%
60%
58%
61%
0.6%
0.6%
0.5%
26%
30%
30%
0.7%
0.4%
0.4%
36%
35%
32%
1.6%
1.0%
0.8%
20%
18%
21%
1.1%
0.4%
0.4%
58%
61%
63%
0.6%
0.5%
0.6%
35%
36%
33%
1.1%
1.3%
0.9%
52%
47%
43%
1.2%
0.7%
0.7%
63%
66%
68%
1.1%
1.1%
1.0%
65%
64%
63%
0.3%
0.3%
0.3%
51%
50%
52%
1.3%
0.6%
0.9%
67%
68%
68%
0.9%
1.5%
1.2%
75%
76%
76%
0.2%
0.3%
0.5%
22%
23%
27%
0.9%
0.4%
0.9%
42%
46%
51%
0.8%
0.5%
1.0%
48%
48%
49%
1.2%
0.8%
0.8%
m mm
23%
21%
23%
21%
17%
20%
6%
5%
6%
7%
5%
6%
20%
19%
20%
12%
13%
12%
6%
5%
5%
31%
27%
31%
10%
9%
11%
9%
7%
8%
2%
2%
3%
14%
11%
12%
6%
6%
7%
5%
5%
4%
38%
37%
39%
15%
13%
12%
14%
12%
13%
22%
20%
24%
30%
32%
18%
18%
34%
40%
47%
6%
6%
17%
18%
20%
7%
4%
56%
57%
58%
15%
15%
27%
34%
35%
10%
13%
54%
60%
58%
5%
5%
17%
19%
20%
25%
23%
20%
23%
26%
7%
6%
12%
17%
29%
8%
6%
8%
11%
12%
2%
2%
10%
11%
14%
12%
10%
19%
25%
27%
7%
7%
8%
11%
9%
4%
4%
4%
4%
5%
36%
31%
23%
28%
29%
14%
10%
25%
32%
32%
11%
10%
23%
25%
27%
2011 12012
1.0% 1.1%
1.7% 2.2%
0.7% 0.4%
0.3% 0.2%
0.9% 0.9%
0.7% 0.9%
0.7% 0.4%
1.8% 1.3%
1.1% 1.3%
0.9% 0.8%
0.5% 0.1%
0.9% 1.0%
1.3% 1.1%
0.1% 0.4%
1.1% 0.6%
1.2% 0.5%
0.9% 0.8%
MM
28% 30%
39% 45%
16% 19%
56% 54%
31% 39%
58% 61%
20% 20%
21% 28%
23% 32%
12% 12%
10% 14%
22% 23%
11% 10%
4% 4%
28% 30%
32% 28%
25% 27%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Table includes all applications that went through the complete underwriting process,
and excludes applications withdrawn or files closed for incompleteness.
0.8%
0.8%
0.4%
0.6%
0.8%
0.2%
0.4%
1.1%
0.4%
0.6%
0.2%
0.6%
1.1%
0.3%
0.3%
0.4%
0.6%
32%
48%
16%
57%
40%
57%
19%
33%
39%
12%
17%
25%
11%
5%
31%
26%
28%
MORTGAGE LENDING PRACTICES
70 14-91
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Loan Applicant Representation
Ideally, the applicant pool for mortgage lending should be reflective of the demographics of a
community. When one racial/ethnic group is overrepresented or underrepresented in the total
applicant pool, it could be an indicator of unequal access to housing opportunities. Such a finding
may be a sign that access to mortgage lending is not equal for all individuals. The percentage of
loans completed in each city were compared to the percentage of the city's racial composition and
presented in Tables 4-6, 4-7 and 4-8. All racial/ethnic categories have seen a decline in loan denial
rates since the peak of the financial crisis in 2008. The following provides a summary of completed
purchase loan applications by race compared to the composition of the 16 cities in the study area
and County, is summarized below:
■ White. Throughout Orange County, including most of the 16 cities in the study area, the
White racial group has a similar percentage of loan applications completed compared to the
racial composition of these cities. Whites made up 43 percent of the County in 2013, and 49
percent of the home purchase loan applications were completed by this racial group. Three
cities had a difference of over 10 percent between the loan applications completed and
percentage of this racial category. In Newport Beach, for example, Whites made up 82
percent of the population, yet in 2013, only 63 percent of the loans in Newport Beach were
to Whites. Lake Forest and Fountain Valley also had fewer loans completed by Whites
compared to the racial composition of these cities.
■ Hispanic. Hispanics were severely underrepresented in the home loan market in Orange
County — making up 34 percent of the County's population, compared to just 10 percent of
the home purchase loan applications. The low percentage of loan applications by Hispanics
relative to population figures was significant even in cities with large Hispanic populations.
For example, Anaheim, which has a Hispanic population of 53 percent only had 20 percent of
purchase loan applications being completed by Hispanics. La Habra, which is 60 percent
Hispanic, only had 23 percent of the loan applications completed by Hispanics. And, Santa
Ana — with 79 percent Hispanic population, the most in Orange County — had just 31 percent
of loan applications completed by Hispanics. The relatively low loan figures could be due to
various factors, such as, income, employment history, income -to debt ratio, and knowledge
of the homebuyer process.
■ Asian. In Orange County, 28 percent of the loan applications were completed by Asians,
while this group comprised 18 percent of the population in 2013. The cities that have had
recent significant increases — of over 20 percent in loan applications completed, compared to
percentage of population — include the following: Buena Park, Fountain Valley, La Habra,
Lake Forest and Santa Ana.
■ Black. Blacks make up 1.5 percent of Orange County, and only 0.6 percent of the loan
applications were completed by Blacks. Only two cities had purchase loan applications by
Blacks over 1 percent: La Habra (1.1%) and Rancho Santa Margarita (1.1%). Out of the 16
cities in the study area, the one with the largest percentage of Blacks in 2013 was Buena Park
with 4.3 percent of the population. However, only 0.8 percent of loan applications were
completed by Blacks in this city.
MORTGAGE LENDING PRACTICES
71 14-92
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 4-6: Home Purchase Loans - Comparison, Completed Loan
Applications and Percent of City, 2013
0.8%
2.4%
-1.6%
0.35
Anaheim 36.6% 27.4% 9.2% 1.33
Buena Park
21.6%
26.3%
-4.7%
0.82
0.8%
4.3%
-3.5%
0.18
Costa Mesa
61.0%
51.6%
9.4%
1.18
0.4%
1.2%
-0.8%
0.34
Fountain Valley
30.5%
46.6%
-16.1%
0.65
0.6%
1.2%
-0.6%
0.52
Fullerton
31.8%
36.1%
-4.3%
0.88
0.8%
2.5%
-1.7%
0.32
Garden Grove
21.5%
21.3%
0.2%
1.01
0.2%
1.0%
-0.8%
0.21
Huntington Beach
62.7%
66.1%
-3.4%
0.95
0.4%
0.7%
-0.3%
0.61
La Habra
33.3%
28.7%
4.6%
1.16
1.1%
1.6%
-0.5%
0.66
Lake Forest
43.3%
56.9%
-13.6%
0.76
0.4%
1.6%
-1.2%
0.27
Mission Viejo
68.1%
70.9%
-2.8%
0.96
0.6%
1.5%
-0.9%
0.42
Newport Beach
62.5%
81.6%
-19.1%
0.77
0.2%
0.6%
-0.4%
0.33
Orange
52.5%
45.9%
6.6%
1.14
0.6%
1.0%
-0.4%
0.59
Rancho Santa Margarita
67.8%
66.8%
1.0%
1.02
1.1%
1.1%
0.0%
1.00
San Clemente
76.1%
75.4%
0.7%
1.01
0.3%
0.7%
-0.4%
0.44
Santa Ana
27.2%
9.6%
17.6%
2.83
0.3%
1.1%
-0.8%
0.29
Tustin
51.1%
32.3%
18.8%
1.58
0.4%
2.3%
-1.9%
0.17
Orange County Total
49.0%
43.5%
5.5%
1.13
0.6%
1.5%
-0.9%
0.40
1.11111
Mill!
Anaheim
19.8%
52.6%
-32.8%
0.38
31.7%
15.2%
16.5%
2.08
Buena Park
18.0%
38.5%
-20.5%
0.47
47.9%
27.9%
20.0%
1.72
Costa Mesa
6.1%
35.2%
-29.1%
0.17
15.8%
9.0%
6.8%
1.75
Fountain Valley
3.8%
15.8%
-12.1%
0.24
56.9%
33.7%
23.2%
1.69
Fullerton
14.6%
34.5%
-19.9%
0.42
40.2%
23.8%
16.4%
1.69
Garden Grove
13.2%
36.8%
-23.6%
0.36
57.1%
37.9%
19.2%
1.51
Huntington Beach
5.3%
18.7%
-13.4%
0.29
18.9%
11.0%
7.9%
1.72
La Habra
23.0%
60.3%
-37.3%
0.38
33.2%
7.4%
25.8%
4.49
Lake Forest
5.8%
23.5%
-17.7%
0.25
38.9%
14.1%
24.8%
2.76
Mission Viejo
5.6%
15.8%
-10.2%
0.35
12.1%
7.9%
4.2%
1.53
Newport Beach
1.8%
8.4%
-6.6%
0.21
16.6%
6.9%
9.7%
2.40
Orange
10.1%
38.4%
-28.3%
0.26
25.0%
12.6%
12.4%
1.98
Rancho Santa Margarita
6.8%
18.8%
-12.0%
0.36
10.7%
10.6%
0.1%
1.01
San Clemente
3.8%
17.5%
-13.7%
0.22
4.7%
3.4%
1.3%
1.38
Santa Ana
31.4%
78.5%
-47.1%
0.40
31.0%
9.9%
21.1%
3.13
Tustin
10.1%
39.4%
-29.3%
0.26
25.7%
22.7%
3.0%
1.13
Orange County Total
9.7%
33.8%
-24.1%
0.29
28.2%
18.2%
10.0%
1.55
* Non -Hispanic
Sources: www.lendingpatterns.com, October 2015, US Census, ACS 2009-2013 Table DP05
Tabulations: GRC Associates, Inc., October 2015
1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2 -Table includes all applications that went through the complete underwriting process,
and excludes applications withdrawn or tiles closed tor incompleteness.
MORTGAGE LENDING PRACTICES
72 14-93
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 47: Denied by Race - Home Purchase Loans - 2013
Denied I Denied I Tot. Denied Denied Tot. I Denied I Denied I Tot. I Denied I Denied I Tot. I Denied I C
Apps. % Comp. Apps. / Comp. Apps. % Comp. Apps. % Comp. Apps. L
Anaheim
3,655
591
16.17%
1,336
172
12.87%
31
7
22.58%
722
155
21.47%
1,157
190
16.42%
Buena Park
796
143
17.96%
172
23
13.37%
6
1
16.67%
143
28
19.58%
381
78
20.47%
Costa Mesa
1,471
229
15.57%
897
127
14.16%
6
-
0.00%
90
18
20.00%
232
40
17.24%
Fountain Valley
640
112
17.50%
195
26
13.33%
4
-
0.00%
24
-
0.00%
364
78
21.43%
Fullerton
1,741
220
12.64%
553
56
10.13%
14
1
7.14%
254
35
13.78%
700
98
14.00%
Garden Grove
1,944
396
20.37%
417
55
13.19%
4
2
50.00%
257
50
19.46%
1,110
260
23.42%
Huntington Beach
2,359
318
13.48%
1,478
168
11.37%
10
-
0.00%
126
17
13.49%
446
86
19.28%
La Habra
948
141
14.87%
316
41
12.97%
10
1
10.00%
218
45
20.64%
315
37
11.75%
Lake Forest
2,091
295
14.11%
906
119
13.13%
9
-
0.00%
121
17
14.05%
814
116
14.25%
Mission Viejo
2,387
296
12.40%
1,625
183
11.26%
15
2
13.33%
133
16
12.03%
289
46
15.92%
Newport Beach
2,011
295
14.67%
1,257
184
14.64%
4
1
25.00%
36
4
11.11%
333
49
14.71%
Orange
2,355
330
14.01%
1,236
149
12.06%
14
8
57.14%
238
36
15.13%
589
89
15.11%
Rancho Santa Margarita
1,641
185
11.27%
1,113
115
10.33%
18
4
22.22%
111
12
10.81%
175
24
13.71%
San Clemente
1,301
159
12.22%
990
109
11.01%
4
-
0.00%
50
8
16.00%
61
11
18.03%
Santa Ana
2,162
441
20.40%
587
92
15.67%
7
2
28.57%
678
155
22.86%
670
148
22.09%
Tustin
1,281
205
16.00%
654
97
14.83%
5
-
0.00%
129
26
20.16%
329
44
13.37%
Orange County Total
33,742
4,900
14.52%
16,526
2,036
12.32%
201
36
17.91%
3,258
607
18.63%
9,517
1,536
16.14%
Anaheim
4
1
25.00%
21
1
4.76%
11
4
36.36%
317
58
18.30%
56
3
5.36%
Buena Park
1
-
0.00%
8
1
12.50%
3
1
33.33%
64
11
17.19%
18
-
0.00%
Costa Mesa
-
-
-
4
1
25.00%
6
1
16.67%
211
42
19.91%
25
-
0.00%
Fountain Valley
-
-
-
4
-
0.00%
1
1
100.0%
48
7
14.58%
-
-
-
Fullerton
3
1
33.33%
12
2
16.67%
6
1
16.67%
181
25
13.81%
18
1
5.56%
Garden Grove
-
-
-
6
1
16.67%
7
1
14.29%
118
26
22.03%
25
1
4.00%
Huntington Beach
3
-
0.00%
9
3
33.33%
7
-
0.00%
260
43
16.54%
20
1
5.00%
La Habra
-
-
-
7
2
28.57%
1
-
0.00%
73
13
17.81%
8
2
25.00%
Lake Forest
3
-
0.00%
24
14
58.33%
6
2
33.33%
205
27
13.17%
3
-
0.00%
Mission Viejo
4
-
0.00%
19
6
31.58%
6
2
33.33%
294
41
13.95%
2
-
0.00%
Newport Beach
4
-
0.00%
3
1
33.33%
6
-
0.00%
321
52
16.20%
47
4
8.51%
Orange
5
2
40.00%
16
-
0.00%
9
4
44.44%
234
41
17.52%
14
1
7.14%
Rancho Santa Margarita
2
2
100.0%
3
-
0.00%
8
2
25.00%
205
26
12.68%
6
-
0.00%
San Clemente
1
1
100.0%
7
-
0.00%
5
-
0.00%
175
30
17.14%
8
-
0.00%
Santa Ana
2
2
100.0%
6
2
33.33%
8
2
25.00%
176
36
20.45%
28
2
7.14%
Tustin
2
-
0.00%
7
1
14.29%
4
1
25.00%
143
35
24.48%
8
1
12.50%
Orange County Total
41
7
17.07%
170
30
17.65%
123
22
17.89%
3,607
609
16.88%
299
17
5.69%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Denial rate based on applications that went through the complete underwriting process, and excludes
applications withdrawn or files closed for incompleteness.
MORTGAGE LENDING PRACTICES
73 14-94
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 48: Home Purchase Loans - Denial Rate Percentages, 2008 to 2013
Anaheim
22%
19%
18%
16%
17%
16%
17%
14%
14%
13%
13%
13%
34%
17%
10%
17%
12%
23%
Buena Park
20%
17%
16%
13%
13%
18%
16%
13%
17%
11%
5%
13%
17%
19%
0%
17%
19%
17%
Costa Mesa
24%
18%
16%
16%
17%
16%
24%
16%
16%
16%
15%
14%
14%
29%
0%
29%
0%
0%
Fountain Valley
21%
23%
14%
16%
16%
18%
18%
15%
11%
13%
12%
13%
0%
50%
0%
0%
0%
0%
Fullerton
19%
18%
15%
13%
13%
13%
17%
17%
13%
11%
12%
10%
8%
27%
27%
27%
0%
7%
Garden Grove
22%
21%
19%
19%
20%
20%
19%
13%
13%
14%
14%
13%
18%
29%
0%
10%
14%
50%
Huntington Beach
21%
16%
14%
16%
13%
13%
19%
15%
13%
14%
11%
11%
27%
13%
10%
0%
25%
0%
La Habra
17%
16%
15%
16%
16%
15%
15%
14%
13%
16%
17%
13%
13%
0%
29%
17%
0%
10%
Lake Forest
18%
16%
15%
12%
14%
14%
16%
15%
14%
10%
12%
13%
33%
0%
22%
18%
21%
0%
Mission Viejo
19%
15%
15%
15%
12%
12%
18%
14%
14%
13%
11%
11%
21%
14%
20%
6%
25%
13%
Newport Beach
24%
22%
19%
17%
16%
15%
23%
20%
19%
17%
16%
15%
0%
100%
0%
33%
0%
25%
Orange
20%
15%
15%
13%
14%
14%
19%
13%
14%
11%
13%
12%
24%
8%
12%
25%
25%
57%
Rancho Santa Margarita
19%
14%
14%
12%
11%
11%
17%
12%
13%
11%
10%
10%
10%
12%
14%
7%
29%
22%
San Clemente
22%
17%
18%
13%
12%
12%
20%
16%
16%
13%
11%
11%
50%
0%
0%
0%
0%
0%
Santa Ana
28%
24%
25%
20%
21%
20%
23%
19%
19%
15%
15%
16%
32%
18%
5%
25%
45%
29%
Tustin
22%
15%
16%
13%
15%
16%
20%
13%
17%
11%
13%
15%
17%
0%
21%
13%
17%
0%
Orange County Total
22%
18%
16%
15%
15%
15%
19%
15%
14%
14%
12%
12%
25%
15%
16%
15%
14%
18%
Anaheim
30%
23%
25%
19%
19%
21%
18%
18%
16%
17%
20%
16%
Buena Park
25%
20%
22%
12%
16%
20%
17%
15%
13%
14%
16%
20%
Costa Mesa
24%
19%
28%
21%
19%
20%
20%
19%
13%
16%
21%
17%
Fountain Valley
31%
45%
18%
17%
20%
0%
21%
23%
14%
18%
16%
21%
Fullerton
23%
23%
18%
16%
17%
14%
16%
16%
13%
12%
12%
14%
Garden Grove
35%
24%
31%
21%
25%
19%
18%
22%
16%
20%
21%
23%
Huntington Beach
30%
19%
21%
15%
19%
13%
19%
17%
12%
17%
18%
19%
La Habra
22%
19%
16%
14%
17%
21%
12%
15%
13%
15%
15%
12%
Lake Forest
31%
20%
23%
19%
20%
14%
13%
13%
11%
10%
14%
14%
Mission Viejo
31%
20%
18%
23%
21%
12%
14%
14%
14%
17%
17%
16%
Newport Beach
31%
22%
19%
20%
9%
11%
26%
28%
19%
19%
20%
15%
Orange
29%
19%
28%
18%
15%
15%
14%
13%
14%
11%
15%
15%
Rancho Santa Margarita
43%
21%
21%
17%
15%
11%
15%
18%
13%
13%
14%
14%
San Clemente
34%
24%
17%
2%
15%
16%
27%
18%
34%
15%
22%
18%
Santa Ana
33%
27%
32%
23%
22%
23%
21%
21%
20%
19%
24%
22%
Tustin
32%
20%
24%
20%
21%
20%
17%
13%
11%
11%
14%
13%
Orange County Total
30%
23%
25%
19%
19%
19%
18%
17%
14%
15%
17%
16%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Denial rate based on applications that went through the complete underwriting process,
and excludes applications withdrawn orfiles closed for incompleteness.
MORTGAGE LENDING PRACTICES
74 14-95
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Additional analysis was completed on loans denied by race/ethnicity. Loan denials at the Census
Tract level by minority percentage were also analyzed. Table 4-9 and Figure 4-1 show the number
and percent of purchase loans denied by minority category at the Census Tract level by city and
County. Appendix C-2 shows the details, listing all Census Tracts and figures. In general, Overall, the
lower the percentage of minority residents within a Census Tract, lower the denial rate.
Table 49: Home Purchase Loans -Denied by Race/Ethnicity- Per Census Tract - 2013
Anaheim
3,655
591
16.17%
0
- -
0
-
-
0
-
-
534
62
11.61%
481
55
11.43%
Buena Park
796
143
17.96%
0
- -
0
-
-
0
-
-
0
-
-
0
-
-
Costa Mesa
1,471
229
15.57%
0
- -
91
13
14.29%
434
57
13.13%
200
29
14.50%
254
49
19.29%
Fountain Valley
640
112
17.50%
0
- -
0
-
22
0
-
-
180
28
15.56%
53
5
9.43%
Fullerton
1,741
220
12.64%
0
- -
0
-
-
0
-
-
217
28
12.90%
388
35
9.02%
Garden Grove
1,944
396
20.37%
0
- -
0
-
-
93
6
6.45%
122
13
10.66%
39
7
17.95%
Huntington Beach
2,359
318
13.48%
0
- -
121
22
18.18%
1,319
169
12.81%
638
73
11.44%
24
3
12.50%
La Habra
948
141
14.87%
0
- -
0
-
-
0
-
-
0
-
-
252
43
17.06%.
Lake Forest
2,091
295
14.11%
0
- -
0
-
-
260
32
12.31%
193
19
9.84%
1,221
179
14.66%
Mission Viejo
2,387
296
12.40%
0
- -
247
37
14.98%
1,156
127
10.99%
598
63
10.54%
215
43
20.00%
Newport Beach
2,011
295
14.67%
63
3 4.76%
885
133
15.03%
484
53
10.95%
106
22
20.75%
446
81
18.16%
Orange
2,355
330
14.01%
0
- -
0
-
-
213
33
15.49%
435
56
12.87%
780
96
12.31%
Rancho Santa Margarita
1,641
185
11.27%
0
-
286
38
13.29%
404
34
8.42%
784
96
12.24%
167
17
10.18%
San Clemente
1,301
159
12.22%
0
- -
530
74
13.96%
695
71
10.22%
49
9
18.37%
0
-
-
Santa Ana
2,162
441
20.40%
0
- -
0
-
-
0
-
-
0
-
-
77
9
11.69%
Tustin
1,281
205
16.00%
0
- -
0
-
14.49%
201
29
14.43%
191
34
17.80%
335
43
12.84%
Orange County Total
33,742
4,900
14.52%
63
3 4.76%
3,201
450
14.06%
5,953
687
11.54%
6,426
832
12.95%
6,074
829
13.65%
Anaheim
251
51
20.32%
619
91
14.70%
735
116
15.78%
869
173
19.91%
166
43
25.90%
- - #DIV/01
Buena Park
55
17
30.91%
417
64
15.35%
252
42
16.67%
72
20
27.78%
0
-
-
0 - -
Costa Mesa
209
33
15.79%
69
12
17.39%
157
29
18.47%
57
7
12.28%
0
-
-
0 -
Fountain Valley
104
22
21.15%
120
16
13.33%
89
19
21.35%
94
22
23,40%
0
-
-
0 - -
Fullerton
66
12
18.18%
434
60
13.82%
362
39
10.77%
274
46
16.79%
0
-
-
0 - -
Garden Grove
10
1
10.00%
198
39
19.70%
449
94
20.94%
887
201
22.66%
146
35
23.97%
0 - -
Huntington Beach
147
22
14.97%
32
11
34.38%
78
18
23.08%
-
-
-
0
-
-
0 - -
La Habra
236
29
12.29%
169
22
13.02%
166
22
13.25%
125
25
20.00%
0
-
-
0 -
Lake Forest
99
16
16.16%
318
49
15.41%
-
-
-
-
-
0
-
-
0 -
Mission Viejo
171
26
15.20%
0
-
-
-
-
-
-
-
-
0
-
-
0 -
Newport Beach
0
-
-
27
3
11.11%
-
-
-
-
-
-
0
-
-
0 - -
Orange
284
35
12.32%
517
92
17.79%
103
14
13.59%
23
4
17.39%
0
-
0 - -
RanchoSantaMargarita
0
-
-
0
-
-
-
-
-
-
-
-
0
-
-
0 - -
San Clemente
27
5
18.52%
0
-
-
-
-
-
-
-
0
-
0 - -
Santa Ana
218
34
15.60%
194
39
20.1%
302
55
18.21%
439
85
19.36%
932
219
23.50%
0 -
Tustin
204
27
13.24%
-
-
-
281
55
19.57%
41
6
14.63%
28
11
39.29%
0 - -
Orange County Total
2,642
395
14.95%
3,272
474
14.49%
2,315
404
17.45%
2,635
543
20.61%
1,155
281
24.33%
6 2 33.33%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Denial rate based on applications that went through the complete underwriting process, and excludes
applications withdrawn or files closed for incompleteness.
MORTGAGE LENDING PRACTICES
75 14-96
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Figure 4-1
Minority population - purchase Loan Denials
By Census Tracts 2013
U Census Tracts with 56% Minority Population
(5671c represent Countywide Minority Population)
Census Tracts with 17-32% Minority Loan C
(17316 represents Countywide Minority Loan Denials
® Census Tracts with 33% or Greater Minority
MORTGAGE LENDING PRACTICES
76
14-97
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Income Level - Applicants
In addition to analyzing loans by race, loans by income were also reviewed. Table 4-10 lists each of
the Orange County 16 Cities' home purchase loans in 2013 by the following income categories: Low
(<50% of AMI), Moderate (50-79% of AMI), Middle (80-119% of AMI) and Upper (>120% of AMI). The
income levels used in the HMDA analysis is different than the definitions used by HUD to determine
low and moderate areas.
Given the relatively expensive housing market in Orange County, it is reasonable to note that over
half of the purchase loans (61 percent) were made to applicants in the Upper income category.
Table
410:
Status of Home
Purchase Loans
by Applicant Income
2013
Anaheim
3,655
199
5.44%7136
19.04%
1,068
29.22%
1,539
42.11%
153
4.19%
Buena Park
796
37
4.65%
17.09%
266
33.42%
318
39.95%
39
4.90%
Costa Mesa
1,471
24
1.63%
113
7.68%
279
18.97%
999
67.91%
56
3.81%
Fountain Valley
640
12
1.88%
90
14.06%
159
24.84%
353
55.16%
26
4.06%
Fullerton
1,741
59
3.39%
230
13.21%
516
29.64%
875
50.26%
61
3.50%
Garden Grove
1,944
153
7.87%
482
24.79%
572
29.42%
653
33.59%
84
4.32%
Huntington Beach
2,359
34
1.44%
220
9.33%
437
18.52%
1,612
68.33%
56
2.37%
La Habra
948
54
5.70%
171
18.04%
265
27.95%
417
43.99%
41
4.32%
Lake Forest
2,091
34
1.63%
206
9.85%
408
19.51%
1,383
66.14%
60
2.87%
Mission Viejo
2,387
42
1.76%
196
8.21%
490
20.53%
1,614
67.62%
45
1.89%
Newport Beach
2,011
10
0.50%
42
2.09%
140
6.96%
1,684
83.74%
135
6.71%
Orange
2,355
37
1.57%
212
9.00%
505
21.44%
1,518
64.46%
83
3.52%
Rancho Santa Margarita
1,641
31
1.89%
154
9.38%
334
20.35%
1,085
66.12%
37
2.25%
San Clemente
1,301
14
1.08%
59
4.53%
150
11.53%
1,052
80.86%
26
2.00%
Santa Ana
2,162
172
7.96%
576
26.64%
648
29.97%
683
31.59%
83
3.84%
Tustin
1,281
46
3.59%
149
11.63%
264
20.61%
792
61.83%
30
2.34%
Orange County Total
33,742
978
2.90%
3,789
11.23%
7,128
21.13%
20,661
61.23%
1,186
3.51%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Denial rate based on applications that went through the complete underwriting process, and excludes
applications withdrawn or files closed for incompleteness.
Income Categories: Low (<50% AMI), Moderate (50-79% AMI), Middle (80-119% AMI) & Upper (>120% AMI)
AMI =Area Median Income
MORTGAGE LENDING PRACTICES
77 14-98
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Loan denial rates by income category of applicants were also reviewed. (Please see Table 4-11.)
Lower income applicants had significantly higher denial rates, most likely due to lending institutions'
strict underwriting standards, which have toughened since the financial/housing bubble problems of
the mid 2000's. As noted earlier, on average, the purchase loan denial rate in Orange County was 15
percent in 2013. In Orange County, the overall denial rates by income level in 2013 were:
■ Low Income: 37 percent
■ Moderate Income: 20 percent
■ Middle Income: 15 percent
■ Upper Income: 12 percent
MORTGAGE LENDING PRACTICES
78 14-99
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
NEWMEWMEMM
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Table 411: Denied Home Purchase Loans by Applicant Income 2013
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ms
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m r.
Anaheim
3,655
591
16.17%
199
74
37.19%
696
141
20.26%
1,068
162
15.17%
1,539
190
12.35%
153
24
15.69%
Buena Park
796
143
17.96%
37
15
40.54%
136
24
17.65%
266
37
13.91%
318
63
19.81%
39
4
10.26%
Costa Mesa
1,471
229
15.57%
24
10
41.67%
113
23
20.35%
279
56
20.07%
999
135
13.51%
56
5
8.93%
Fountain Valley
640
112
17.50%
12
5
41.67%
90
20
22.22%
159
36
22.64%
353
47
13.31%
26
4
15.38%
Fullerton
1,741
220
12.64%
59
23
38.98%
230
38
16.52%
516
58
11.24%
875
93
10.63%
61
8
13.11%
Garden Grove
1,944
396
20.37%
153
62
40.52%
482
103
21.37%
572
111
19.41%
653
101
15.47%
84
19
22.62%
Huntington Beach
2,359
318
13.48%
34
19
55.88%
220
37
16.82%
437
70
16.02%
1,612
186
11.54%
56
6
10.71%
La Habra
948
141
14.87%
54
14
25.93%
171
36
21.05%
265
40
15.09%
417
45
10.79%
41
6
14.63%
Lake Forest
2,091
295
14.11%
34
10
29.41%
206
47
22.82%
408
65
15.93%
1,383
152
10.99%
60
21
35.00%
Mission Viejo
2,387
296
12.40%
42
12
28.57%
196
26
13.27%
490
61
12.45%
1,614
186
11.52%
45
11
24.44%
Newport Beach
2,011
295
14.67%
10
3
30.00%
42
10
23.81%
140
38
27.14%
1,684
221
13.12%
135
23
17.04%
Orange
2,355
330
14.01%
37
8
21.62%
212
40
18.87%
505
72
14.26%
1,518
194
12.78%
83
16
19.28%
Rancho Santa Margarita
1,641
185
11.27%
31
9
29.03%
154
17
11.04%
334
35
10.48%
1,085
118
10.88%
37
6
16.22%
San Clemente
1,301
159
12.22%
14
3
21.43%
59
16
27.12%
150
16
10.67%
1,052
121
11.50%
26
3
11.54%
Santa Ana
2,162
441
20.40%
172
70
40.70%
576
138
23.96%
648
117
18.06%
683
100
14.64%
83
16
19.28%
Tustin
1,281
205
16.00%
46
20
43.48%
149
41
27.52%
264
39
14.77%
792
99
12.50%
30
6
20.00%
Orange County Total
33,742
4,900
14.52%
978
361
36.91%
3,789
764
20.16%
7,128
1,092
15.32%
20,661
2,473
11.97%
1,186
210
17.71%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications.
2 - Denial rate based on applications that went through the complete underwriting process, and excludes
applications withdrawn orfiles closed for incompleteness.
Income Categories: Low (<50% AMI), Moderate (50-79% AMI), Middle (80-119% AMI) & Upper (>120% AMI)
AMI =Area Median Income
MORTGAGE LENDING PRACTICES
79
14-100
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
D. Lending Patterns by Census Tract Characteristics
Income Level by Census Tract
Loan denial rates based on residents income was reviewed by Census Tract in the Orange County 16
City study area. The purpose of this analysis was to identify differences in loan activities by
geographic area. Table 4-12 lists loans by city per income level of Census Tract. The vast majority of
census tracts in Orange County are considered middle or upper income. Over half of the 16 cities in
the study area did not have any loans completed in low-income Census Tracts, most likely due to the
fact that low-income Census Tracts were almost non-existent in these cities. The denial rates by
income level per Census Tract in 2013 were:
■ Low Income: 22 percent
■ Moderate Income: 19 percent
■ Middle Income: 15 percent
■ Upper Income: 13 percent
MORTGAGE LENDING PRACTICES
80 14-101
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Denial rate based on applications that went through the complete underwriting process, and excludes
applications withdrawn or files closed for incompleteness.
MORTGAGE LENDING PRACTICES
81
14-102
Table 412: Home Purchase Loans - Denied by Income - Per Census Tract - 2013
Anaheim
3,655
591
16.17%
331
62 18.73%
1,415
258 18.23%
1,031
176 17.07%
873
95 10.88%
5 0.00%
Buena Park
796
143
17.96%
29
13 44.83%
228
34 14.91%
539
96 17.81%
0
- -
- -
Costa Mesa
1,471
229
15.57%
18
1 5.56%
466
86 18.45%
795
117 14.72%
192
25 13.02%
Fountain Valley
640
112
17.50%
0
- -
217
28 12.90%
253
50 19.76%
170
34 20.00%
Fullerton
1,741
220
12.64%
43
12 27.91%
395
43 10.89%
1,027
141 13.73%
276
24 8.70%
Garden Grove
1,944
396
20.37%
63
17 26.98%
1,041
220 21.13%
743
145 19.52%
97
14 14.43%
Huntington Beach
2,359
318
13.48%
0
- -
268
35 13.06%
810
119 14.69%
1,281
164 12.80%
La Habra
948
141
14.87%
0
271
50 18.45%
551
82 14.88%
126
9 7.14%
Lake Forest
2,091
295
14.11%
0
74
23 31.08%
574
90 15.68%
1,255
165 13.15%
188 17 9.04%
Mission Viejo
2,387
296
12.40%
0
72
10 13.89%
667
100 14.99%
1,648
186 11.29%
- - -
Newport Beach
2,011
295
14.67%
0
236
48 20.34%
155
22 14.19%
1,620
225 13.89%
Orange
2,355
330
14.01%
0
300
54 18.00%
626
84 13.42%
1,429
192 13.44%
Rancho Santa Margarita
1,641
185
11.27%
0
-
- -
385
44 11.43%
1,256
141 11.23%
San Clemente
1,301
159
12.22%
0
85
9 10.59%
414
58 14.01%
802
92 11.47%
Santa Ana
2,162
441
20.40%
178
40 22.47%
1,257
273 21.72%
671
122 18.18%
56
6 10.71%
Tustin
1,281
205
16.00%
18
8 44.44%
215
48 22.33%
411
62 15.09%
637
87 13.66%
Orange County Total
33,742
4,900
14.52%
696
151 21.70%
6,047
1,134 18.75%
10,574
1,567 14.82%
16,226
2,029 12.50%
199 19 9.55%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1- Includes conventional and government -assisted (FHA, FSA/RHS and VA) home purchase applications.
2- Denial rate based on applications that went through the complete underwriting process, and excludes
applications withdrawn or files closed for incompleteness.
MORTGAGE LENDING PRACTICES
81
14-102
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
E. lending Performance by Lender
General Overview
Table 4-13 shows the top 10 lenders by city and Orange County in 2013. Wells Fargo is the top
lender in all of the cities in the 16 cities and the County. The next two larger banks are Bank of
America and JP Morgan Chase Bank. Table 4-13 also shows denial rates by mortgage lending
institution by city and County. Most cities have the same lenders, with few exceptions at the lower
end of the top 10 lenders. Notable is the fact that Wells Fargo has a denial rate of 19 percent
countywide. Though, by city, the denial rate ranges from a low of 14 percent in Lake Forest and
Newport Beach, to a high of 30 percent in Santa Ana. A few lenders had very low denial rates in
some cities, such as Flagstar Bank, Quicken Loans and Chicago Mortgage Solutions, LLC.
MORTGAGE LENDING PRACTICES
82 14-103
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Total
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
County Total
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 4-13: Top 10 Lenders - All Home Loan Applications, 2013
14,749
2,990
20.27%
Wells
1,497
346 23.11%
BofA
1,002
221 22.06%
JPM
863
225 26.07% Flag.
625
63 10.08%
Cash
3,730
795
21.31%
Wells
382
98 25.65%
JPM
275
62 22.55%
BofA
228
48 21.05% Flag.
149
14 9.40%
Citi
5,978
1,176
19.67%
Wells
642
134 20.87%
BofA
337
80 23.74%
Flag.
327
44 13.46% IPM
326
79 24.23%
Citi
3,209
639
19.91%
Wells
316
66 20.89%
BofA
216
48 22.22%
Flag.
193
21 10.88% School.
146
14 9.59%
JPM
7,582
1,412
18.62%
Wells
807
170 21.07%
BofA
522
94 18.01%
JPM
442
103 23.30% Flag.
351
40 11.40%
Scho
8,373
1,886
22.52%
Wells
709
201 28.35%
BofA
592
117 19.76%
JPM
464
112 24.14% Flag.
447
67 14.99%
PMA
10,816
1,883
17.41%
Wells
1,370
264 19.27%
BofA
710
123 17.32%
JPM
657
164 24.96% Flag.
596
53 8.89%
Cash
3,612
684
18.94%
Wells
428
93 21.73%
B&A.
234
51 21.79%
JPM
232
53 22.84% Flag.
143
12 8.39%
Cash
6,343
1,102
17.37%
Wells
875
121 13.83%
BofA
362
59 16.30%
Flag.
314
37 11.78% JPM
256
60 23.44%
Nati(
10,009
1,665
16.64%
Wells
1,129
205 18.16%
BofA
664
120 18.07%
Flag.
524
52 9.92% IPM
465
128 27.53%
Cash
8,383
1,568
18.70%
Wells
1,383
197 14.24%
BofA
782
160 20.46%
JPM
527
135 25.62% Union
489
116 23.72%
Citi
10,636
1,858
17.47%
Wells
1,211
235 19.41%
BofA
712
130 18.26%
JPM
589
136 23.09% Flag.
542
49 9.04%
Cash
6,460
1,021
15.80%
Wells
720
128 17.78%
BofA
356
62 17.42%
Flag.
347
38 10.95% JPM
275
63 22.91%
Quic
5,477
968
17.67%
Wells
844
131 15.52%
BofA
347
53 15.27%
Flag.
246
30 12.20% JPM
229
68 29.69%
Cash
9,194
2,209
24.03%
Wells
955
290 30.37%
BofA
811
179 22.07%
JPM
551
172 31.22% School.
427
97 22.72%
Flag.
5,804
1,086
18.71%
Wells
637
122 19.15%
BofA
404
88 21.78%
JPM
298
91 30.54% Flag.
293
33 11.26%
Cash
138,845
25,917
18.67%
Wells
16,700
3,186 19.08%
BofA
9,553
1,795 18.79%
JPM
7,465
1,895 25.39% Flag.
6,806
772 11.34%
Cash
lick.
ag.
pick.
Ish
lick.
ti
526 100 19.01% Citi 442 105 23.76% Quick. 394 57 14.47% Nation. 331 121 36.56% Chicago 273
125 35 28.00% Cash 117 39 33.33% Nation. 94 37 39.36% Green. 94 41 43.62% Stearns 83 * x
182 50 27.47% School 165 20 12.12% Chicago 151 * * Quick. 148 23 15.54% Univ. 133
116 35 30.17% Citi 108 29 26.9% JMAC 102 * * Quick. 89 13 14.61% PMAC 87 42 48.28%
254 80 31.50% Citi 248 64 25.81% Quick. 183 19 10.38% Nation. 177 69 38.98% Chicago 157
318 28 8.81% School 309 51 16.50% Citi 303 76 25.08% Cash 261 82 31.42% Quick. 211 41 19.43%
356 76 21.35% School 351 41 11.68% Quick. 312 52 16.67% Chicago 242 * * Stearns 233
110 21 19.09% Quick. 89 9 10.11% School 85 11 12.94% Nation. 85 36 42.35% Broker 67 9 13.43%
209 67 32.06% Quick. 190 27 14.21% Citi 169 31 18.34% School 160 37 23.13% Stearns 151
342 46 13.45% Citi 299 79 26.42% School 282 45 15.96% Chicago 281 22 7.83% Nation 238 93 39.08%
292 42 14.38% Quick. 229 37 16.16% US 205 64 31.22% Cash 176 57 32.39% Chicago 153
361 74 20.50% School 335 42 12.54% Citi 325 78 24.00% Chicago 255 * * Stearns 229
212 48 22.64% Chicago 189 * * Stearns 159 * * Citi 157 39 24.84% School. 149 19 12.75%
172 24 13.95% Citi 164 38 23.17% Chicago 152 14 9.21% US 148 43 29.05% Union 122 26 21.31%
312 79 25.32% Nation. 214 86 40.19% Quick. 214 44 20.56% Cash 214 72 33.64% PMAC 175 73 41.71%
194 23 11.86% Citi 189 36 19.05% Quick. 185 27 14.59% Chicago 138 * * Stearns 113
4,206 1,032 24.54% Quick. 4,061 653 16.08% School 4,041 671 16.60% Chicago 3,112 * * Nation 2,847 1,051 36.92%
Loans by these financial institutions
were out of the top 15 fi na nci a I
institutions denying loans. FinanciaI Institutions:
Wells
=Wells Fargo Bank
Citi =Citibank
Univ.
=Universal American Mortgageof CA
BofA
=Bank of America
Quick. =Quicken Loans, Inc.
JMAC
=JMAC Lending, Inc.
JPM
=JPMorgan Chase Bank
Nation = Nationstar Mortgage, LLC
PMAC
= PMAC Lending, Inc.
Flag.
=Flagstar Bk FSB
Chicago =Chicago Mortgage Solutions LLC
Broker
= Broker Solutions, Inc.
Cash
=Cashcall, Inc.
Green =Greenlight Financial Services
Union
=Union Bank
School.
=Schoolfirst FCU
Stearns = Stea rns Lendi ng, l nc.
Us
=US Bank
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
Denial rate based on applications that went through the complete underwriting process, and exclude applications withrawan or files closed for incompleteness.
MORTGAGE LENDING PRACTICES
83
14-104
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Disposition by Loan Applicants Income
Additional research was completed on mortgage lending institutions by income and minority
applicants. Table 4-14 lists the top 10 lenders by city and County with the market share of each
financial institution and percent of loans going to applicants with low and moderate incomes and
percent minority. Some key findings include:
■ Wells Fargo has a 12 percent share of the home loan market. In some cities like Newport
Beach, Wells Fargo has a large share of the market at almost 17 percent. While in another
city, Wells Fargo has around eight percent of the market (Garden Grove).
■ Minority applicants typically have a third of the market share of loans. However, in some
cities, minority applicants make up a much bigger share of the market for some lenders.
PMAC Lending, Inc., which is favored by Asian applicants, makes 99 percent of their loans to
minorities in Fountain Valley, 95 percent to minorities in Garden Grove and 94 percent to
minorities in Santa Ana.
MORTGAGE LENDING PRACTICES
84 14-105
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Loans bythese financial institutions were out ofthe top 15 financial
institutions denying loans. Financial Institutions:
Table
4-14: Top
30 Lenders
- Market
Share
and
Income
and Minority
Categories
-
All Home
Loan
Applications,
2013
Chicago = Chicago Mortgage Solutions LLC
Broker
= Broker Solutions, Inc.
Cash=Cashcall, Inc.
Green = Greenlight Financial Services
Union
=Union Bank
School.=Schoolfirst FCU
Stearns = Stearns Lending, Inc.
US
=US Bank
Minority Category includes Asian, Black and Hispanic. Low =%of AMI
and Mod =%of AMI
Source: www.lendi ngpatterns.com, October 2015
Anaheim
Wells
10.15%
27%
44%
BofA
6.79%
41%
50%
JPM
5.85%
39%
42%
Flag.
4.24%
26%
48%
Cash
3.72%
Buena Park
Wells
30.24%
28%
57%
JPM
7.37%
41%
48%
BofA
6.11%
44%
51%
Flag.
3.99%
25%
59%
Citi
3.59%
40%
46%
Costa Mesa
Wells
30.74%
12%
18%
BofA
5.64%
19%
27%
Flag.
5.47%
11%
27%
JPM
5.45%
25%
18%
Citi
3.31%
27%
20%
Fountain Valley
Wells
9.85%
21%
55%
BofA
6.73%
40%
52%
Flag.
6.01%
17%
52%
School.
4.55%
24%
23%
JPM
4.39%
28%
47%
Fullerton
Wells
10.64%
23%
48%
BofA
6.88%
34%
48%
JPM
5.83%
37%
42%
Flag.
4.63%
15%
50%
School.
3.75%
26%
34%
Garden Grove
Wells
8.47%
35%
59%
BofA
7.07%
48%
62%
JPM
5.54%
41%
51%
Flag.
5.34%
35%
64%
PMAC
3.97%
51%
95%
Huntington Beach
Wells
12.67%
12%
19%
BofA
6.56%
21%
23%
JPM
6.07%
24%
19%
Flag.
5.51%
16%
25%
Cash
3.76%
16%
16%
La Habra
Wells
11.85%
22%
50%
BofA
6.48%
31%
52%
JPM
6.42%
33%
41%
Flag.
3.96%
16%
48%
Cash
3.46%
23%
23%
Lake Forest
Wells
13.79%
12%
38%
BofA
5.71%
25%
30%
Flag.
4.95%
13%
40%
JPM
4.04%
23%
25%
Nation
3.72%
12%
39%
Mission Viejo
Wells
11.28%
12%
18%
BofA
6.63%
22%
18%
Flag.
5.24%
11%
22%
JPM
4.65%
21%
15%
Cash
3.43%
14%
15%
Newport Beach
Wells
16.50%
3%
14%
BofA
9.33%
7%
12%
JPM
6.29%
8%
10%
Union
5.83%
2%
3%
Citi
3.57%
13%
14%
Orange
Wells
11.39%
13%
27%
BofA
6.69%
21%
29%
JPM
5.54%
20%
30%
Flag.
5.10%
10%
39%
Cash
3.97%
14%
23%
Rancho Santa Margarita
Wells
11.15%
12%
16%
BofA
5.51%
17%
16%
Flag.
5.37%
11%
21%
JPM
4.26%
18%
15%
Quick.
3.64%
12%
14%
San Clemente
Wells
15.41%
9%
6%
BofA
6.34%
15%
9%
Flag.
4.49%
7%
11%
JPM
4.18%
16%
9%
Cash
3.34%
14%
14%
Santa Ana
Wells
10.39%
37%
63%
BofA
8.82%
51%
70%
JPM
5.99%
48%
57%
School.
4.64%
41%
60%
Flag.
3.74%
34%
62%
Tustin
Wells
10.98%
15%
30%
BofA
6.96%
21%
36%
JPM
5.13%
22%
28%
Flag.
5.05%
12%
42%
Cash
3.69%
18%
16%
Orange County Total
Wells
12.03%
15%
30%
BofA
6.88%
26%
33%
JPM
5.38%
26%
31%
Flag.
4.90%
16%
39%
Cash
3.30%
18%
20%
Anaheim
School.
3.57%
31%
43%
Citi
3.00%
40%
44%
Quick.
2.67%
23%
30%
Nation.
2.24%
29%
37%
Chicago
1.85%
24%
42%
Buena Park
School.
3.35%
39%
40%
Cash
3.14%
30%
36%
Nation.
2.52%
37%
49%
Green.
2.52%
33%
39%
Stearns
2.23%
39%
49%
Costa Mesa
Cash
3.04%
15%
15%
School
2.76%
27%
12%
Chicago
2.53%
11%
21%
Quick.
2.48%
16%
13%
Univ.
2.22%
15%
44%
Fountain Valley
Cash
3.61%
21%
40%
Citi
3.37%
36%
34%
JMAC
3.18%
21%
85%
Quick.
2.77%
18%
30%
PMAC
2.71%
38%
99%
Fullerton
Cash
3.35%
27%
30%
Citi
3.27%
40%
44%
Quick.
2.41%
15%
30%
Nation.
2.33%
27%
34%
Chicago
2.07%
17%
36%
Garden Grove
JMAC
3.80%
39%
92%
School
3.69%
40%
42%
Citi
3.62%
50%
56%
Cash
3.12%
30%
29%
Quick.
2.52%
27%
37%
Huntington Beach
Citi
3.29%
32%
15%
School
3.25%
19%
11%
Quick.
2.88%
11%
17%
Chicago
2.24%
14%
17%
Stearns
2.15%
21%
21%
La Habra
Citi
3.05%
39%
49%
Quick.
2.46%
19%
31%
School
2.35%
22%
31%
Nation.
2.35%
24%
33%
Broker
1.85%
25%
37%
Lake Forest
Cash
3.29%
15%
16%
Quick.
3.00%
17%
21%
Citi
2.66%
31%
28%
School
2.52%
21%
24%
Stearns
2.38%
17%
31%
Mission Viejo
Quick.
3.42%
15%
16%
Citi
2.99%
24%
17%
School
2.82%
21%
17%
Chicago
2.81%
12%
14%
Nation
2.38%
15%
21%
Newport Beach
Flag.
3.48%
9%
27%
Quick.
2.73%
5%
10%
US
2.45%
5%
8%
Cash
2.10%
11%
15%
Chicago
1.83%
8%
19%
Orange
Quick.
3.39%
11%
21%
School
3.15%
16%
22%
Citi
3.06%
25%
31%
Chicago
2.40%
11%
31%
Stearns
2.15%
13%
23%
Rancho Santa Margarita
Cash
3.28%
10%
14%
Chicago
2.93%
12%
16%
Stearns
2.46%
16%
13%
Citi
2.43%
15%
17%
School.
2.31%
15%
15%
San Clemente
Quick.
3.14%
10%
9%
Citi
2.99%
16%
7%
Chicago
2.78%
13%
9%
US
2.70%
8%
6%
Union
2.23%
4%
2%
Santa Ana
Citi
3.39%
51%
57%
Nation.
2.33%
50%
51%
Quick.
2.33%
38%
41%
Cash
2.33%
30%
37%
PMAC
1.90%
49%
94%
Tustin
School.
3.34%
24%
25%
Citi
3.26%
25%
30%
Quick.
3.19%
10%
20%
Chicago
2.38%
17%
28%
Stearns
1.95%
20%
25%
Orange County Total
Cit!
3.03%
31%
31%
lQuick.
2.92%
15%
21%
1 School
2.91%
25%
26%
1 Chicago
2.24%
15%
29%
Nation
2.05%
22%
30%
Loans bythese financial institutions were out ofthe top 15 financial
institutions denying loans. Financial Institutions:
Wells =Wells Fargo Bank
Citi =Citibank
Univ.
=Universal American Mortgage of CA
BofA =Bank of America
Quick. = Quicken Loans, Inc.
JMAC
= JMAC Lending, Inc.
JPM=JPMorgan Chase Bank
Nation = Nationstar Mortgage, LLC
PMAC
= PMAC Lending, Inc.
Flag.=Flagstar Bk FSB
Chicago = Chicago Mortgage Solutions LLC
Broker
= Broker Solutions, Inc.
Cash=Cashcall, Inc.
Green = Greenlight Financial Services
Union
=Union Bank
School.=Schoolfirst FCU
Stearns = Stearns Lending, Inc.
US
=US Bank
Minority Category includes Asian, Black and Hispanic. Low =%of AMI
and Mod =%of AMI
Source: www.lendi ngpatterns.com, October 2015
Tabulations: GRCAssociates, Inc., October2015
Denial rate based on applications that went through the complete underwriting
process, and exclude applications
withrawan
or files closed for incompleteness.
MORTGAGE LENDING PRACTICES
85
14-106
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
F. Sub -Prime Lending Market
The subprime lending market in 2011 and 2013 was analyzed. In most cases, the best or prime loans
are offered to applicants with good credit history, employment and income. Applicants who do not
possess acceptable credit may be offered subprime loans. However, HMDA data does not identify
specifically whether a loan is prime or subprime. The best that HMDA provides is whether a loan has
a "Rate Spread". Table 4-15 lists the Rate Spread loans for 2011 and 2013. An HMDA Rate Spread
occurs when a loan's interest rate exceeds a FFIEC defined "threshold". HMDA provides the
following definition about Rate Spread: "For a home purchase loan, a refinancing, or a dwelling -
secured home improvement loan that you originated, report the spread (difference) between the
annual percentage rate (APR) and the applicable average prime offer rate if the spread is equal to or
greater than 1.5 percentage points for first -lien loans or 3.5 percentage points for subordinate -lien
loans."
Table 4-15:
Home Purchase Loans
- Rate Spread, 2011
to 2013
Anaheim
2.58%
5.28
5.52%
3.41
2.94%
(1.87)
Buena Park
0.95%
3.60
4.18%
2.07
3.23%
(1.53)
Costa Mesa
1.31%
5.18
2.64%
3.26
1.33%
(1.92)
Fountain Valley
0.91%
5.49
1.48%
2.46
0.57%
(3.03)
Fullerton
2.04%
3.64
2.83%
3.90
0.79%
0.26
Garden Grove
1.64%
6.08
3.83%
3.22
2.19%
(2.86)
Huntington Beach
2.32%
5.25
3.11%
3.47
0.79%
(1.78)
La Habra
4.74%
6.66
6.33%
4.24
1.59%
(2.42)
Lake Forest
2.73%
3.29
3.02%
2.49
0.29%
(0.80)
Mission Viejo
1.41%
3.03
2.87%
2.04
1.46%
(0.99)
Newport Beach
1.65%
3.57
1.36%
2.83
-0.29%
(0.74)
Orange
1.47%
3.77
2.81%
2.94
1.34%
(0.83)
Rancho Santa Margarita
0.81%
1.80
3.11%
1.97
2.30%
0.17
San Clemente
1.26%
3.34
1.53%
1.95
0.27%
(1.39)
Santa Ana
2.85%
4.19
5.98%
2.88
3.13%
(1.31)
Tustin
1.53%
4.79
2.11%
2.52
0.58%
(2.27)
Orange County Total
1.79%
4.27
3.08%
2.77
1.29%
(1.50)
Source: www.lendingpatterns.com, November 2015
Tabulations: GRC Associates, Inc., November 2015
1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2 - Includes applications thatwent through the complete underwriting process,
and excludes applications withdrawn or files closed for incompleteness.
3- A HMDA Rate Spread occurs when a loan's interest rate exceeds a FFIEC defined "threshold".
HMDA definition of "Rate Spread": For a home purchase loan, a refinancing, or a dwelling -
secured home improvement loan thatyou originated, report the spread (difference) between the
annual percentage rate (APR) and the applicable average prime offer rate if the spread is equal
to or greater than 1.5 percentage points for first -lien loans or 3.5 percentage points for
subordinate -lien loans.
MORTGAGE LENDING PRACTICES
86 14-107
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
In 2011, less than two percent of loans had Rate Spreads (or had rates high enough that may be
considered subprime). The average increase above a prime interest rate was 4.27. By 2013 the
number of loans with high rates had increased to about three percent; however, the spread had
decreased to 2.77. Thus, it appears lenders are getting more aggressive by providing loans to high-
risk applicants and, at the same time, lowering the rates on these types of loans. This type of lending
has the effect of both extending fair housing choice to a broader group of people, who would not
qualify for regular mortgage lending programs. However, if there are too many of these types of
loans, there may be an increase in foreclosures - a situation that occurred during the recent
recession.
The Rate Spread loans of top lenders for 2011 and 2013 were tabulated. Listed in Table 4-16 are the
market share figures of the top lenders with the percentage of loans they make having a Rate
Spread. For the most part, the top lenders have had very few of these type of loans. However, there
is one lender that appears to make a significant amount of Rate Spread loans - 21s' Mortgage which
has 16 percent of their loans being Rate Spread loans and with an average spread of 8.53 in 2013.
Source: www.1endingpatterns.com, November 2015
Tabulations: GRC Associates, Inc., November 2015
1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2 - Includes applications that wentthrough the complete underwriting process,
and excludes applications withdrawn or files closed for incompleteness.
3- A HMDA Rate Spread occurs when a loan's interest rate exceeds a FFIEC defined "threshold". HMDAdefinition of"Rate
Spread": For a home purchase loan, a refinancing, or a dwelling -secured home improvement loan that you originated,
reportthe spread (difference) between the annual percentage rate (APR) and the applicable average prime offer rate if the
spread is equal to or greater than 1.5 percentage points for first -lien loans or 3.5 percentage points for subordinate -lien
loans.
MORTGAGE LENDING PRACTICES
87 14-108
Table 4-16: Home
Purchase Loans - Rate Spread
- Top Orange County Lenders,
2011 & 2013
NoW M,
mm -M.'11111111
1
Wells Fargo
15.9%
0.40% 1.97
1
Wells Fargo
13.5%
0.20%
1.59
2
Bank of America
11.0%
0.10% 1.52
2
Flagstar
5.1%
0.60%
1.75
3
Flagstar Bank
4.6%
0.50% 1.68
3
Bank of America
4.0%
0.10%
1.57
4
JP Morgan
2.3%
0.20% 1.96
4
JP Morgan
3.7%
0.30%
1.55
5
Metlife Bank
2.2%
0.00% -
5
Stearns
2.3%
1.40%
1.70
6
PMC Corp
2.0%
0.00% -
6
21st Mortgage
1.9%
15.70%
8.53
7
Pacific Union
1.9%
2.50% 1.77
7
imortgage.com
1.9%
3.00%
1.95
8
Paramount Financial
1.8%
0.20% 1.51
8
Primelending
1.8%
1.50%
1.86
9
Primelending
1.6%
0.50% 1.56
9
Union Bank
1.7%
0.00%
-
10
Stearns Lending
1.5%
0.00% -
10
Broker Solutions, Inc.
1.7%
5.30%
1.71
11
21st Mortgage
1.5%
27.20% 7.79
11
PMAC Lending
1.6%
0.50%
1.91
12
Pinnacle Capital
1.4%
0.30% 4.03
12
East W. Bank
1.6%
0.20%
1.51
13
Kiencta FCU
1.3%
0.00% -
13
Sierra Pacific
1.5%
0.20%
1.62
14
imorrgage.com
1.3%
0.80% 1.81
14
Paramount Residential
1.4%
5.80%
1.71
15
JMAC Lending
1.3%
0.00% -
15
Pacific Union
1.4%
5.20%
1.78
Orange County Total
100.0%
1.79% 4.27
Orange County Total
100.0%
3.08%
2.77
Source: www.1endingpatterns.com, November 2015
Tabulations: GRC Associates, Inc., November 2015
1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2 - Includes applications that wentthrough the complete underwriting process,
and excludes applications withdrawn or files closed for incompleteness.
3- A HMDA Rate Spread occurs when a loan's interest rate exceeds a FFIEC defined "threshold". HMDAdefinition of"Rate
Spread": For a home purchase loan, a refinancing, or a dwelling -secured home improvement loan that you originated,
reportthe spread (difference) between the annual percentage rate (APR) and the applicable average prime offer rate if the
spread is equal to or greater than 1.5 percentage points for first -lien loans or 3.5 percentage points for subordinate -lien
loans.
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G. Predatory Lending
The potential of predatory lending occurrences in the Orange County 16 City study area was also
reviewed. Predatory lending occurs when applicants are targeted with abusive practices, such as
higher fees, hidden costs and other related practices. The HMDA database identifies HOEPA or "high
cost" loans. As defined by HMDA "HOEPA" loans include: "HOEPA Status. Report whether each loan
you originated or purchased is covered by the Home Ownership and Equity Protection Act of 1994
(HOEPA), as implemented in Regulation Z (12 C.F.R. § 1026.32). Coverage under HOEPA, which
requires special disclosures and regulates the terms of covered loans, is determined by comparing a
loan's APR and its points and fees to triggers specified in the regulation. See 12 C.F.R. § 1026.32(a)
and (b)." Table 4-17 lists the HOEPA loans in the study area and Orange County. Based on the HMDA
database, there are very few in any of these types of loans.
Table 4-17: All Types of Loans - High Cost Loans (HOEPA), 2011 to 2013
•Chang, 2011 to
2013
Cities• • ..
Anaheim - 1
1
Buena Park - -
-
Costa Mesa -
Fountain Valley - -
-
Fullerton - 1
1
Garden Grove - -
-
Huntington Beach 1
(1)
La Habra -
-
Lake Forest
Mission Viejo
Newport Beach
Orange 1
(1)
Rancho Santa Margarita -
-
San Clemente -
Santa Ana -
Tusti n - -
Orange County Total 2 2
Source: www.lendingpatterns.com, November 2015
Tabulations: GRC Associates, Inc., November 2015
1 -Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2 -Includes applications that went through the complete underwriting process,
and excludes applications withdrawn or files closed for incompleteness.
3- HMDAdefinition of HOEPA Loans: HO EPA Status: Report whether each loan you originated or
purchased is covered by the Home Ownership and Equity Protection Act of 1994 (HO EPA), as
implemented in Regulation Z (12 C.F.R. § 1026.32). For further guidance, see Appendix A (I.G.3). Coverage
under HOEPA, which requires special disclosures and regulates the terms of covered loans, is
determined by comparing a loan's APR and its points and fees to triggers specified in the regulation. See
12 C.F.R. § 1026.32(a) and (b).
MORTGAGE LENDING PRACTICES
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H. Foreclosures
Foreclosure data has been gathered for each of the 16 cities in the study area and countywide. The
foreclosure process begins when owner(s) stop making mortgage payments and it can be stopped
when the owner(s) makes all payments and becomes current with the lender. If owner(s) and lender
do not agree on how to resolve the situation of missed mortgage payments, then the lender has the
right to use the foreclosure process in court to take over the home and get its loan funds back. Table
4-18 shows the number of homes that are in various states of foreclosure in the 16 cities of the study
area. As can be noted, there are few homes in foreclosure — less than one percent.
Table 4-18: Foreclosures, September 2015
Foreclosure Distr•
% of Total
nomm Stock
Housing
Anaheim 230 246 90 566 0.5%
Buena Park 69 14 69 152 0.6%
Costa Mesa 49 49 28 127 0.3%
Fountain Valley 8 25 21 55 0.3%
Fullerton 135 39 48 222 0.5%
Garden Grove 105 70 47 222 0.5%
Huntington Beach 206 147 44 396 0.5%
La Habra 55 71 39 165 0.8%
Lake Forest 100 62 50 212 0.8%
Mission Viejo 100 67 67 234 0.7%
Newport Beach 68 54 14 135 0.3%
Orange 125 105 20 249 0.6%
Rancho Santa Margarita 81 107 - 188 1.1%
San Clemente 47 20 40 107 0.4%
Santa Ana 243 196 93 532 0.7%
Tusti n 33 72 26 131 0.5%
Orange County Total 2,922 2,654 1,299 6,875 0.6%
Sources: RealtyTrack and Department of Finance, November 2015
Tabulations: GRC Associates, Inc., November 2015
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Foreclosure and market sales prices in the 16 cities and countywide for the years 2014 and 2015
were gathered and are listed in Table 4-19. The housing market has been increasing at very good
rates, while the foreclosure market has stabilized. Home prices have increased about five percent in
Orange County within the past year. The following cities have had increases of more than double the
five percent Orange County figure at 10 percent or more: Fountain Valley (15 percent), La Habra (11
percent), Lake Forest (11 percent), San Clemente (14 percent) and Santa Ana (10 percent).
Table 4-19: Foreclosure and Market Sales Prices, September 2014 & 2015
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Ful I erton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Justin
Orange County Total
$ 443,000 $ 446,500
429,000 439,500
578,250 585,500
504,000 555,000
476,000 479,500
429,000 432,500
559,500 587,750
475,000 475,000
227,014 320,000
583,000 588,000
1,392,500 1,712,500
545,000 545,000
574,980 580,000
755,050 810,000
368,000 373,500
282,000 425,500
$ 520,000 $ 520,000
$ 468,500 $ 485,000
463,500 462,500
667,500 700,000
600,000 687,500
473,500 507,000
451,000 475,000
655,000 719,000
425,000 470,000
587,000 650,000
587,000 605,000
1,550,000 1,475,000
541,000 566,000
478,250 455,000
752,500 860,000
405,000 445,000
531,250 572,500
$ 584,000 $ 615,000
250
53
93
53
124
111
231
64
98
125
102
130
64
73
167
74
3,193
3.5%
-0.2%
4.9%
14.6%
7.1%
5.3%
9.8%
10.6%
10.7%
3.1%
-4.8%
4.6%
-4.9%
14.3%
9.9%
7.8%
5.3%
* All recorded home sales include sales of all single family residences and condominiums
Sources: RealtyTrack and Core Logic, November 2015
Tabulations: GRC Associates, Inc., November 2015
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REGIONAL ANALYSIS OF IMPEDIMENTS
5. Public Policies and Practices
Public policies may affect the pattern of housing development, availability of housing choices, as well
as access to housing. This section of the Al reviews the various public policies that may impact fair
housing choice in Orange County, including:
■ General Plan Policies Affecting Housing Development
■ Zoning Ordinance
■ Building Codes and Occupancy Standards
■ Affordable Housing Development
■ Other Land Use Policies, Programs and Controls
■ Zoning Regulations and Practices for Persons with Disabilities
■ Local Housing Authorities
■ Community Representation and Participation
A. General Plan Policies Affecting Housing Development
General Plan Housing Element
The Housing Element is one of seven state -mandated Elements of the General Plan. California
housing element law, originally enacted in 1969, requires that local governments adequately plan to
meet the existing and projected housing needs of all economic segments of their community. The
most recent housing element for jurisdictions in the Southern California Association of Governments
(SCAG) region, of which Orange County is a part, covers the 2014-2021 planning period.
Among the 16 cities participating in this Al, 14 have an adopted 2014-2021 Housing Element that has
been found in compliance with state housing element statutes by the State Department of Housing
and Community Development (HCD). Important criteria for State HCD approval of any housing
element include a determination that the local jurisdiction's policies do not unduly constrain the
maintenance, improvement, and development of a variety of housing choices for all income levels.
The following summarizes the status of the housing element in the two participating jurisdictions
whose elements have not been found in compliance by HCD.
■ The City of Fullerton adopted it 2014-2021 Housing Element on May 5, 2015. HCDs review
letter indicated that while the Element met most statutory requirements, the Element could
not be found in full compliance until the City completed Policy Action 1.1 to establish
minimum densities and identify site capacity for 41 lower income units. Compliance was also
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contingent upon Policy Action 4.4 to amend the Zoning Code to eliminate constraints to the
provision of emergency shelters. In early 2016, the City was informed by HCD that they had
met the statutory requirements and the Element was found in compliance.
■ The City of San Clemente adopted a Housing Element for the prior, 2008-2014 Housing
Element cycle on July 5, 2011 which was found in compliance by HCD. The City is in the
process of updating its Housing Element for the 2014-2021 planning period consistent with
the City's new General Plan, and submitted a draft for HCD review in February 2016.
Element adoption is targeted for spring of 2016.
California "no net loss" zoning law requires a local government to make a finding that a density
reduction, rezoning, or downzoning is consistent with its Housing Element prior to requiring or
permitting a reduction of density of a parcel below the density used in determining Housing Element
compliance. The legislation also allows courts to award attorneys' fees and costs if the court
determines that the density reduction or downzoning was made illegally.
General Plan Land Use Element
The General Plan Land Use Element serves as the foundation for all land use controls within a
jurisdiction, and identifies the location, distribution and density/intensity of permitted land uses. As
it applies to residential land uses, the Land Use Element establishes a range of residential, and
oftentimes mixed use, land use categories; defines densities for each category (typically expressed in
dwelling units per acre [du/ac]); and describes the housing types which typify each land use category.
Numerous factors, both market and governmental, affect the supply and cost of housing in a
community. The governmental factor that most directly influences these market conditions is the
allowable density range of residentially designated land. In general, higher densities allow developers
to take advantage of economies of scale, reduce the per-unit cost of land and improvements, and
reduce developments costs associated with new housing construction. Reasonable density standards
ensure the opportunity for higher -density residential uses to be developed within a community,
increasing the feasibility of producing affordable housing, and facilitating the provision of a greater
range of housing types to address community needs.
Table 5-1 presents a summary of allowable densities by land use type for the 16 participating Orange
County jurisdiction. While most jurisdictions have Land Use Elements that allow a range of single-
family and higher density multi -family residential uses, several cities do not accommodate multi-
family uses at a density greater than 25 units per acre without a density bonus or other incentive for
affordable housing. Cities that limit densities within residential neighborhoods include: Buena Park,
Costa Mesa, Orange, Rancho Santa Margarita, Santa Ana and Tustin. Most of these cities have
instead chosen to direct higher density housing into areas designated for residential/commercial
mixed use. For example, the City of Santa Ana eliminated the high density residential land use
designation that supported its R-3 and R-4 zoning districts in an effort to facilitate long term
neighborhood stabilization; the City's Land Use Element now directs higher density housing and
mixed use development in proximity to transit services within District Centers and Urban
Neighborhood areas. Just two jurisdictions - Fountain Valley and Ranch Santa Margarita - do not
include provisions for commercial/residential mixed use in their Land Use Element or Zoning Codes.
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Source: General Plan Land Use Elements for Orange County jurisdictions.
Note: Table represents a summary of typical land use categories by density category, and does not represent a specific jurisdiction's General Plan Land Use designations. Instead, these
categories are meant to provide an overview of the type of residential land uses and densities permitted in that jurisdiction.
PUBLIC POLICIES AND PRACTICES
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Table 5-1: Typical
Residential
Land
Use Designations
General
Land Use
Density
Range
(units/
Typical
Category
Estate/ Very
<2
Residential Type
Large lot, single-family, often in
Low Density
hillside or semi -rural setting X
X
X
X
Residential
Low Density
0-7
Detached single-family dwellings,
Residential
typically constructed in
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
subdivisions
Low
7-15
Includes small lot single-family,
Medium
duplexes, townhomes, mobile
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Density
home parks, and lower intensity
apartments and condominiums.
Medium
15-25
Multi -family apartments and
Density
condominiums, typically 2-3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
stories
High Density
>25
Large multi -story apartment and
X
X
X
X
X
X
X
X
X
X
X
condominium complexes
Mixed Use
30+
Apartments, condominiums, live -
work units, flats and artist -style
X
X
X
X
X
X
X
X
X
X
X
X
X
X
lofts integrated with commercial
uses
Source: General Plan Land Use Elements for Orange County jurisdictions.
Note: Table represents a summary of typical land use categories by density category, and does not represent a specific jurisdiction's General Plan Land Use designations. Instead, these
categories are meant to provide an overview of the type of residential land uses and densities permitted in that jurisdiction.
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REGIONAL ANALYSIS OF IMPEDIMENTS
B. Zoning Ordinance
The Zoning Ordinance implements the General Plan Land Use and Housing Elements by establishing
zoning districts and development standards that correspond with General Plan land use designations.
To supplement review of the Zoning Ordinance, staff from each of the 16 participating jurisdictions
completed HUD's recommended Zoning Survey, which reviews Zoning and Planning Codes to identify
land use and zoning regulations, practices and procedures that may result in the creation or
perpetuation of an impediment to fair housing choice. The survey has a particular focus on practices
that can act as barriers to the provision of housing for individuals with disabilities, and also touches
on areas that may affect fair housing choice for families with children, or otherwise serve as
impediments to full fair housing choice.
The completed HUD checklist Review of Public Policies and Practices for each participating
jurisdiction is included in the Appendix to the Al. In summary, jurisdictions did not identify any public
sector impediments to fair housing choice. Several jurisdictions did however identify actions to
further fair housing, such as adding a definition of "disability" to the Municipal Code consistent with
the Fair Housing Act. These specific actions are included in the Fair Housing Action Plan matrices
provided in Chapter VIII of the Al.
Aspects of the zoning ordinance that may affect a person's access to housing or limit the range of
housing choices available are further discussed below.
Variety of Housing Types
To ensure fair housing choice in a community, a community's Zoning Ordinance should provide
opportunities for a variety of housing types to promote diversity to meet the needs of its residents.
This includes zoning provisions for single and multi -family housing, secondary dwelling units, mobile
and manufactured homes, licensed residential care facilities, supportive and transitional housing,
emergency shelters, and single room occupancy units (SROs). Table 5-2 provides a summary of each
jurisdiction's Zoning Ordinance as it relates to providing for these various housing types, and
indicates if a given use is permitted or conditionally permitted in at least one zone district in the City.
Secondary Dwelling Units. Second units are attached or detached dwelling units that provide
complete independent living facilities for one or more persons including permanent provisions for
living, sleeping, cooking and sanitation. Second units may provide an alternative source of affordable
housing for lower income households, particularly for seniors, persons with disabilities, and students,
and typically rent for less than apartments of comparable size. These units can also assist older
homeowners to remain in their homes, providing housing for caregivers and extended family
members, and generating income for units used as rentals.
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P = Permitted Use PD =Planned Development Permit MUP =Minor Use Permit C= Conditional Use Permit
1For transitional and supportive housing, "permitted" means the jurisdiction treats these as residential uses under zoning, and only subject
to the same provisions as other residential uses of the same type in the some zone.
2The Buena Park Zoning Code does not currently contain provisions for SROs. The City's 2013-2021 Housing Element includes an action to
amend the Code within one year of adoption of the Housing Element to specifically address the provision of SRO units.
3The Fountain Valley Zoning Code does not currently specify provisions for transitional or supportive housing, but the City is in the process of
amending the Code to treat as a residential use, as required under SB 2.
4The Garden Grove Zoning Code does not specify provisions for SROs. The City's 2014-2021 Housing Element indicates SROs are conditionally
permitted as a boarding or lodging facility in R-2 and R-3 zones consistent with established development standards.
5The Huntington Beach Zoning Code currently requires a CUP for multi family projects with more than 4 units (5-9 units - Zoning
Administrator, 10+ units - Planning Commission). The City's 2013-2021 Housing Element includes an action to evaluate permit streamlining
to include increasing the threshold for units in a project to be permitted by right, and increasing the threshold for projects requiring review
by the Planning Commission.
6The Mission Viejo Zoning Code requires a planned development permit for single- and multi family projects, except for projects in the
RPD30a zone (Residential Planned Development By Right) which include 15-20% lower income units, as specified in the Housing Element.
7The Newport Beach Zoning Code limits occupancy of accessory dwelling units to persons age 55 and above. Licensed residential care
facilities with 6 or fewer residents are a permitted use in residential zones, whereas as unlicensed facilities are subject to a CUP. SROs are
classified under the Visitor Accommodation zoning classification.
8The City of Orange Zoning Code permits transitional and supportive housing with six or fewer occupants by -right in residential zones,
whereas these housing types with more than seven residents are subject to a CUP. The City's Zoning Code does not currently contain
provisions for SRO units.
9The San Clemente Zoning Code requires a CUP for multi family projects with more than 4 units.
10 The Santa Ana Zoning Code does not currently contain provisions for SRO units.
11 The Tustin Zoning Code does not currently contain provisions for SRO units, but are conditionally permitted as boarding houses.
PUBLIC POLICIES AND PRACTICES
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Table
5-2:
MINN
Zoning
for a Variety
of
Housing
Types
NN.
Anaheim
P
P
P
C
P
P
C
P
P
P
C
Buena Park
P
P
P
P
P
P
C
P
P
P
-Z
Costa Mesa
P
P
P
C
P
P
C
P
P
P
C
Fountain Valley
P
C
P
C
P
P
C
- 3
- 3
P
C
Fullerton
P
P
P
P
P
P
C
P
P
P
C
Garden Grove
P
P
P
P
P
P
C
P
P
P
C4
Huntington Beach
P
P/C,
P
C
P
P
C
P
P
P
C
La Habra
P
P
P
P
P
P
C
P
P
P
C
Lake Forest
P
P
P
C
P
P
C
P
P
P
C
Mission Viejo
PD/P6
PD/P6
P
PD
PD
P
C
P
P
P
C
Newport Beach
P
P
MUP7
P
P
P/C'
C
P
P
P
C
Orange
P
P
P
C
P
P
C
P/C,
P/C,
P
-8
Rancho Santa Margarita
P
P
P
C
P
P
C
P
P
P
P
San Clemente
P
P/C,
P
C
P
P
C
P
P
P
P
Santa Ana
P
P
P
P
P
P
C
P
P
P
--10
Tustin
P
P
P
C
P
P
C
P
P
P
C11
P = Permitted Use PD =Planned Development Permit MUP =Minor Use Permit C= Conditional Use Permit
1For transitional and supportive housing, "permitted" means the jurisdiction treats these as residential uses under zoning, and only subject
to the same provisions as other residential uses of the same type in the some zone.
2The Buena Park Zoning Code does not currently contain provisions for SROs. The City's 2013-2021 Housing Element includes an action to
amend the Code within one year of adoption of the Housing Element to specifically address the provision of SRO units.
3The Fountain Valley Zoning Code does not currently specify provisions for transitional or supportive housing, but the City is in the process of
amending the Code to treat as a residential use, as required under SB 2.
4The Garden Grove Zoning Code does not specify provisions for SROs. The City's 2014-2021 Housing Element indicates SROs are conditionally
permitted as a boarding or lodging facility in R-2 and R-3 zones consistent with established development standards.
5The Huntington Beach Zoning Code currently requires a CUP for multi family projects with more than 4 units (5-9 units - Zoning
Administrator, 10+ units - Planning Commission). The City's 2013-2021 Housing Element includes an action to evaluate permit streamlining
to include increasing the threshold for units in a project to be permitted by right, and increasing the threshold for projects requiring review
by the Planning Commission.
6The Mission Viejo Zoning Code requires a planned development permit for single- and multi family projects, except for projects in the
RPD30a zone (Residential Planned Development By Right) which include 15-20% lower income units, as specified in the Housing Element.
7The Newport Beach Zoning Code limits occupancy of accessory dwelling units to persons age 55 and above. Licensed residential care
facilities with 6 or fewer residents are a permitted use in residential zones, whereas as unlicensed facilities are subject to a CUP. SROs are
classified under the Visitor Accommodation zoning classification.
8The City of Orange Zoning Code permits transitional and supportive housing with six or fewer occupants by -right in residential zones,
whereas these housing types with more than seven residents are subject to a CUP. The City's Zoning Code does not currently contain
provisions for SRO units.
9The San Clemente Zoning Code requires a CUP for multi family projects with more than 4 units.
10 The Santa Ana Zoning Code does not currently contain provisions for SRO units.
11 The Tustin Zoning Code does not currently contain provisions for SRO units, but are conditionally permitted as boarding houses.
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California law requires local jurisdictions to adopt ordinances that establish the conditions under
which second units are permitted (Government Code Section 65852.2). No local jurisdiction can
adopt an ordinance precluding second units in residential zones unless the ordinance contains
findings acknowledging that prohibiting second units may limit housing opportunities in the region
and result in adverse impacts on public health, safety, and welfare. An amendment to the State's
second unit law in 2003 requires local governments to use a ministerial review process for second
units, defined as a review and approval process that does not require public notice, public hearing or
discretionary approval. Jurisdictions are permitted to impose standards on second units addressing
issues such as building size, parking, height, setbacks and lot coverage.
As summarized in Table 5-2, 15 of the 16 participating Orange County jurisdictions have amended
their Zoning Ordinances to permit second units by right in single-family residential zones. The City of
Newport Beach, however, does not provide for second units within single-family zones in its Zoning
Ordinance, but does allow for "granny units" (accessory, age -restricted units) in single-family zones.
More specifically, the City's Code specifies that accessory units are intended for the sole occupancy
of one or two adult persons who are fifty-five (55) years of age or older, do not exceed six hundred
forty (640) square feet, and are subject to Zoning Administrator approval of a Minor Use Permit. The
City's age -restrictions on accessory dwelling units, combined with the requirement for discretionary
approval, may serve to impede housing choice for lower income individuals in Newport Beach.
Mobile Homes/Manufactured Housing. The manufacturing of homes in a factory is typically less
costly than the construction of individual homes on-site thereby lowering overall housing costs. State
law requires local governments to permit manufactured or mobile homes meeting federal safety and
construction standards on a permanent foundation in single-family residential zones (Section 65852.3
of the California Government Code). State law also declares a mobile home park to be a permitted
land use on any land planned and zoned for residential use, and prohibits requiring the average
density in a new mobile home park to be less than that permitted by the Municipal Code. A city or
county may, however, require use permits for mobile home parks. As presented in Table 5-2, all 16
Orange County cities comply with these State requirements. While the City of Mission Viejo requires
a planned development permit for manufactured housing, this is consistent with the City's
requirement for all market rate single- and multi -family developments.
Residential Care Facilities. The Lanterman Developmental Disabilities Services Act ("Lanterman Act"
- Sections 5115 and 5116 of the California Welfare and Institutions Code) is that part of California law
that sets out the rights and responsibilities of persons with developmental disabilities. The
Lanterman Act impacts local zoning ordinances by requiring the use of property for the care of six or
fewer disabled persons to be classified as a residential use under zoning. More specifically, a State -
authorized, certified or licensed family care home, foster home, or a group home serving six or fewer
disabled persons or dependent and neglected children on a 24 -hour -a -day basis is considered a
residential use that is to be permitted in all residential zones. No local agency can impose stricter
zoning or building and safety standards on these homes. Due to the unique characteristics of larger
(more than six persons) community care facilities, most jurisdictions require a Use Permit to ensure
neighborhood compatibility in the siting of these facilities.
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According to the California Department of Social Services, Community Care Licensing Division, there
are 672 State licensed assisted living residential care facilities for the elderly, 258 adult residential
facilities, 22 adult day care facilities, 49 children's residential group homes, and 10 residential small
family homes in the 16 Orange County cities participating in this Al. As depicted in previous Table 3-
28, which presents the numbers of residential care facilities by the 16 cities, the following cities have
the highest numbers of residential care facilities by type:
■ Assisted living residential care for the elderly located in Mission Viejo with 147 facilities,
followed by Anaheim with 97 facilities;
■ Adult residential facilities in Anaheim with 96 and eight adult day care facilities;
■ Children's residential group homes in Orange with 11 homes, followed by Costa Mesa with 9
homes; and,
■ Residential small family home for children with special needs in the City of Huntington Beach
four homes.
All but one of the 16 participating jurisdictions have at least a dozen or more licensed community
care facilities, with Rancho Santa Margarita currently having no such facilities. As presented in Table
5-2, all 16 cities have provided by -right zoning for licensed residential care facilities with six or fewer
residents, treating these facilities as a single-family residential use. All cities also specify one or more
zone districts where residential care facilities with seven or more residents may be permitted, subject
to a conditional use permit; operators of care facilities may also pursue a reasonable accommodation
to locate in additional zone districts. While the City of Newport Beach requires a use permit for
unlicensed facilities regardless of size, requirements for by -right residential zoning under the
Lanterman Act are only applicable to State licensed facilities.
Single Room Occupancy (SRO). Single Room Occupancy (SRO) residences are small, one room units
occupied by a single individual, and may either have shared or private kitchen and bathroom
facilities. SROs are rented on a monthly basis typically without rental deposit, and can provide an
entry point into the housing market for extremely low income individuals, formerly homeless and
disabled persons.
California Housing Element law requires jurisdictions to address the provision of housing for
extremely low income (30% AMI) households, including SROs. The majority of the 16 Orange County
cities either contain specific provisions for SRO units in their Zoning Ordinances, or have clarified in
their Housing Elements how SROs are provided for under other zoning classifications. For example,
the Housing Elements for Garden Grove and Tustin clarify that SROs are conditionally permitted
through zoning as boarding houses. However, as indicated in the footnotes to Table 5-2, the cities of
Buena Park, Orange and Santa Ana do not explicitly provide for SROs in their Zoning Codes, or clarify
in their Housing Elements how such uses would be provided for, though the City of Buena Park has
indicated SROs could be accommodated through a development agreement. Lack of clarity on
provisions for SROs can serve to limit housing choice to extremely low income households, including
persons with disabilities and veterans.
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Emergency Shelters. An emergency shelter is a facility that provides temporary shelter and feeding
of indigents or disaster victims, operated by a public or non-profit agency. State law requires
jurisdictions to identify adequate sites for housing which will be made available through appropriate
zoning and development standards to facilitate and encourage the development of a variety of
housing types for all income levels, including emergency shelters and transitional housing (Section
65583(c)(1) of the Government Code). Recent changes in State law (SB 2) require that local
jurisdictions make provisions in the Zoning Ordinance to permit emergency shelters by right in at
least one zoning district where adequate capacity is available to accommodate at least one year-
round shelter. Local jurisdictions may, however, establish standards to regulate the development of
emergency shelters.
All 16 participating Orange County cities have complied with the requirement to permit emergency
shelters by right within at least one zoning district. On November 17, 2015, the County Board of
Supervisors approved the purchase of a warehouse in the City of Anaheim to build the county's first
year-round, permanent emergency shelter for the homeless. The multi -service center is expected to
house up to 200 people and act as a triage center where health, job and housing social workers
would help homeless clients find permanent housing.
Transitional and Supportive Housing. State law (AB 2634 and SB 2) requires local jurisdictions to
address the provisions for transitional and supportive housing. Under Housing Element law,
transitional housing means buildings configured as rental housing developments, but operated
under program requirements that require the termination of assistance and re -circulating of the
assisted unit to another eligible program recipient at a predetermined future point in time that shall
be no less than six months from the beginning of the assistance (California Government Code Section
65582(h)).
Supportive housing means housing with no limit on length of stay, that is occupied by the target
population, and that is linked to an onsite or offsite service that assists the supportive housing
resident in retaining the housing, improving his or her health status, and maximizing his or her ability
to live and, when possible, work in the community. Target population means persons with low
incomes who have one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or
other chronic health condition, or individuals eligible for services provided pursuant to the Lanterman
Developmental Disabilities Services Act (Division 4.5 (commencing with Section 4500) of the Welfare
and Institutions Code) and may include, among other populations, adults, emancipated minors,
families with children, elderly persons, young adults aging out of the foster care system, individuals
exiting from institutional settings, veterans, and homeless people (California Government Code
Sections 65582(f) and (g)).
In summary, State law establishes transitional and supportive housing as a residential use and
prohibits local governments from treating it differently from other similar types of residential uses
(e.g., requiring a use permit when other residential uses of similar type in the same zone do not
require a use permit). The majority of the 16 participating jurisdictions have amended their Zoning
Codes to define and regulate transitional and supportive housing as a residential use as specified
under State law. The City of Orange Zoning Code, however, only addresses transitional and
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supportive housing structured in the form of group housing (which is permitted by right in all
residential zones with 6 or fewer persons, conditionally permitted in R-3 and R-4 zones with seven or
more persons); the Code does not specifically address transitional or supportive housing structured
as an apartment building (which is permitted by right in multi -family zones). The City of Fountain
Valley Zoning Code contains a definition of supportive housing, but does not currently specify how
such uses are to be regulated; the City is in the process of amending the Code to treat transitional
and supportive housing as a residential use, consistent with State requirements.
Definition of Family
A community's Zoning Ordinance can potentially restrict access to housing for relations failing to
qualify as a "family" by the definition specified in the Zoning Ordinance. Even if the code provides a
broad definition, deciding what constitutes a "family" should be avoided by cities to prevent
confusion or give the impression of restrictiveness. Particularly, when Zoning Ordinance uses terms
such as "single-family" homes, defining family in too detailed conditions may be viewed by some as
restricting access to housing for certain segments of the population. According to California Housing
Element Law, one of the ways communities can promote fair housing is to remove definitions of
family that are restrictive.
Although a recent federal court case upheld the definition of a family in the zoning code, California
court cases have ruled that an ordinance that defines a "family" as (a) an individual, (b) two or more
persons related by blood, marriage or adoption, or (c) a group of not more than a certain number of
unrelated persons as a single housekeeping unit, is invalid. California court rulings stated that
defining a family does not serve any legitimate or useful objective or purpose recognized under the
zoning and land planning powers of the city, and therefore violates rights of privacy under the
California Constitution. A zoning ordinance also cannot regulate residency by discrimination between
biologically related and unrelated persons.
None of the participating cities' Zoning Codes define the word "family" in a way that appears to have
restrictive or discriminating effect, and place no limitations on how members of the family are
related or the maximum number of member in the households. Several jurisdictions have removed
the definition of family from their Zoning Codes entirely.
C. Building Codes and Occupancy Standards
Building codes were created to ensure the safety of buildings and residential structures. Many codes
put in place were in response to the loss of life or property due to poor construction techniques or
natural disasters (e.g., earthquakes or fires) from the past. It is unlikely that cities will relax housing
codes; however, most of the 16 participating Orange County cities have housing rehabilitation
programs that can assist lower income households ensure their homes are compliant with housing
and building codes. In addition, each City implements a code enforcement program which works to
correct code violations and respond to complaints from residents. Code enforcement is a critical
component of retaining quality neighborhoods and residential structures.
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Each of the participating cities have adopted the State Uniform Building and Housing Codes. These
codes are considered to be the minimum necessary to protect the public health, safety, and welfare.
No local amendment has either been initiated or approved that directly affects housing standards or
processes. Each of the cities' building codes requires that new residential construction comply with
the American with Disabilities Act (ADA) per federal law. ADA regulations include requirements for a
minimum percentage of units in new developments to be fully accessible to the physical disabled.
Section 504 of the Rehabilitation Act of 1973 adds an additional layer of accessibility requirements
for projects receiving federal funds, such as HOME or CDBG. In federally assisted new construction or
substantially rehabilitated housing with five or more units, five percent of the units, or at least one
unit, must be accessible for persons with mobility disabilities. An additional two percent of the
dwelling units, or at least one unit, must be accessible for persons with hearing or visual disabilities.
These units must be constructed in accordance with the Uniform Federal Accessibility Standards
(UFAS), or a standard that is equivalent or stricter. UFAS generally defines an accessible housing unit
as a unit located on an accessible route that can be approached, entered and used by individuals
with disabilities.
Occupancy Standards
Local occupancy standards more stringent than those established by the State have been deemed
unconstitutional by the courts; none of the 16 participating cities contain residential occupancy
standards more stringent than the State. California jurisdictions are mandated to follow the
minimum occupancy standards established under the State Uniform Housing Code (UHC). The UHC
requires that every dwelling, except studio apartments, have at least one room with a minimum of
120 square feet of floor area. Two persons are permitted to use a room for sleeping purposes if it
has a total area of not less than 70 square feet. When more than two persons occupy a room, the
required floor area must be increased by 50 square feet per occupant. There is nothing in the
Housing Code that prevents occupants from sleeping in the living or dining rooms, provided these
rooms have an operable window or door meeting California building code requirements for
emergency egress. The UHC is based on health and safety considerations, and is not intended to
discriminate based on familial status.
Occupancy in housing receiving public funds, such as Section 8 rental assistance, is typically further
regulated based on the number of bedrooms. Under the "two -plus -one" rule, maximum occupancy
is based on two persons per bedroom plus one additional person.
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D. Affordable Housing Development
Siting of Affordable Housing
Market rents are generally well above the level of affordability to lower income households in
Orange County. Table 5-3 below summarizes the number of rent -restricted units in each of the 16
Orange County cities, and calculates the proportion of rent -restricted housing to each community's
total stock of rental housing. As shown, while the number of affordable rental units varies
significantly by jurisdiction, the proportion relative to each city's total rental housing is relatively
consistent at between five and six percent. Just two cities fall below this percentage - Newport
Beach (3.4%) and La Habra (4.0%). Thus, affordable rental opportunities are generally well dispersed
within the 16 cities relative to each city's size.
Source: Rent restricted units derived from each City's Housing Element and Consolidated Plan, as updated by City staff.
Number of rental units derived from 2008-2012 American Community Survey, rounded to the nearest 100.
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Table 5-3: Affordable
Rent Restricted
Rental Units
Total Rental
% Rental Housing
Cities
Anaheim
Units
3,333
Units
50,800
Rent Restricted
6.6%
Buena Park
608
9,700
6.3%
Costa Mesa
1,436
24,000
6.0%
Fountain Valley
306
5,300
5.8%
Fullerton
1,164
20,500
5.7%
Garden Grove
1,321
20,100
6.6%
Huntington Beach
1,726
29,500
5.9%
La Habra
328
8,300
4.0%
Lake Forest
453
7,900
5.7%
Mission Viejo
369
7,400
5.0%
Newport Beach
579
17,200
3.4%
Orange
1,404
16,900
8.3%
Rancho Santa Margarita
242
4,600
5.3%
San Clemente
497
8,400
5.9%
Santa Ana
2,508
38,400
6.5%
Tustin
813
12,100
6.7%
Source: Rent restricted units derived from each City's Housing Element and Consolidated Plan, as updated by City staff.
Number of rental units derived from 2008-2012 American Community Survey, rounded to the nearest 100.
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Development Fees/Assessments
Local jurisdictions collect various fees on new residential development to recover the cost of permit
processing, the costs of providing public services to the development, and to mitigate certain
development impacts. Such fees typically include plan check and building permit fees, water meter
fees, sewer connection fees, recreation taxes and school facilities fees. Multi -family development
may also be subject to charges for various administrative or discretionary reviews, environmental
review, and impact mitigation. When projects require multiple planning permit applications, such as
a variance and conditional use permit, most cities place a cap on the combined fees.
Planning fees for the 16 participating Orange County cities are summarized in Table 5-4, and vary by
the needs of each jurisdiction. Each city conducts periodic assessments of fees to ensure they reflect
the actual cost of providing services.
Table 5-4: Development Fees
Cities General Plan Conditional
Amendment Permit
Anaheim $181/hr; $12,000 $181/hr; $10,000 $181/hr; $10,000
deposit deposit deposit
Buena Park
$1,400
$1,600
$525
Costa Mesa
$4,560
Minor: $1,050
$1,685
Major: $1,550
Fountain Valley
$9,265
$3,455
$2,960
Fullerton
$3,110
$3,110
$3,110
Garden Grove
$1,950
$2,100
Existing SF: $500
Other: $1,675
Huntington Beach
Minor: $24,890
ZA: $4,550
$4,230
Major: $46,580
PC: $9,990
La Habra
$4,000
$3,200
$3,200
Lake Forest
$10,000 deposit
$6,500 deposit
$6,000 deposit
Mission Viejo
$5,000 deposit
$2,500
$4,500
$183/hr;
ZA: $2,420
$183/hr;
Newport Beach
$7,500 deposit
PC: $5,000 deposit;
$5,000 deposit
$183/hr
Orange'
FBHR +$3,000 deposit
FBHR +$1,000 deposit
FBHR +$1,000 deposit
Rancho Santa Margarita
$6,700 deposit
Minor: $3,650 deposit
$8,000 deposit
Major: $7,300 deposit
San Clemente2
Deposit + 28% GP
)eposit + 28% GP Update
Deposit + 28% GP
Update Fee
Fee
Update Fee
Santa Ana
$8,250
$4,900
$4,750
Tustin$2,985
(text and map)
Minor: $665
Minor: $380
Major: $3,000 deposit
Major: $3,000 deposit
Source: Housing Elements for Orange County jurisdictions, as updated by City staff.
1 FBHR: Fully Burdened Hourly Rate
'Deposit determined by City Planner, with actual hourly costs consisting of time, materials, and overhead.
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E. Other Land Use Policies, Programs and Controls
Land use policies, programs, and controls can impede or facilitate housing development and can
have implications for fair housing choice in a community. Density bonus and inclusionary housing
policies can facilitate the provision of new affordable housing, whereas growth management
programs and Article 34 of the California Constitution can impede new affordable housing
development. The following section discusses land use policies, programs, and controls that may
affect housing development and fair housing choice within the 16 participating Orange County cities.
Programs/Incentives to Develop Affordable Housing
Density Bonus and Other Incentives for Affordable Housing. California Government Code Section
65915 requires jurisdictions to grant a density bonus in exchange for the provision of affordable
housing. In summary, applicants of residential projects of five or more units may apply for a density
bonus and additional concession/incentive(s) if the project provides for construction of one of the
following:
■ 10 percent of units in a housing project for lower income households; or
■ 5 percent of units in a housing project for very low income households; or
■ A senior citizen housing development, or mobile home park that limits residency based on
age requirements for housing for older persons; or
■ 10 percent of units in a common interest development for moderate income households,
provided that all units in the development are offered to the public for purchase.
The amount of density bonus to which the applicant is entitled ranges from 20-35 percent above the
specified General Plan density, based on the percentage and affordability of units provided. In
addition, eligible projects may receive one to three additional development concessions/incentives,
based on the applicant demonstrating that it is not financially feasible to build the project without
the concessions. The number of concessions a project may be eligible for is based upon a
combination of the level of affordability and the percentage of affordable units, as presented in Table
5-5:
Table 5-5: Density Bonus Concessions
Level of Affordability % Affordable Development
Units Incentives
Very Low Income
At least 5%
1
At least 10%
2
At least 15%
3
Low Income
At least 10%
1
At least 20%
2
At least 30%
3
Moderate Income
At least 10%
1
(for -sale condo or planned
At least 20%
2
development)
At least 30%
3
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State density bonus law also specifies alternative parking standards which may be utilized at the
request of the developer; use of these standards does not count towards a project's development
incentives/concessions. These reduced parking standards are inclusive of guest parking and
handicapped parking, may be tandem and/or uncovered, and are applicable to the entire
development project.
■ Zero to one bedroom: one on-site parking space
■ Two to three bedrooms: two on-site parking spaces
■ Four or more bedrooms: two and one-half on-site parking spaces
AB 2222 (effective January 2015), has made important changes to State density bonus law in an
effort to help address potential displacement of existing tenants. Specifically, AB 2222 now prohibits
an applicant from receiving a density bonus (and related incentives and waivers) unless the proposed
housing development or condominium project would, at a minimum, maintain the number and
proportion of affordable housing units within the proposed development, including affordable
dwelling units that have been vacated or demolished in the five-year period preceding the
application. AB 2222 also increases the required affordability from 30 years or longer to 55 years or
longer for all affordable rental units that qualified an applicant for a density bonus, and requires
replacement rental units to be subject to a recorded affordability restriction for at least 55 years. If
the units that qualified an applicant for a density bonus are affordable ownership units, they must be
subject to an equity sharing model rather than a resale restriction.
AB 744, signed into law in October 2015, further amends density bonus law to provide additional by -
right reductions in parking for density bonus projects. Specifically, for density bonus projects which
include the maximum percentage of low income or very low income units (20% and 11%,
respectively) and located within one-half mile of a major transit stop with "unobstructed access"",
upon the request of the developer, the jurisdiction shall not impose a vehicular parking ratio,
inclusive of handicapped and guest parking, that exceeds 0.5 spaces per bedroom. Senior rental
housing (as defined in Sections 51.2 and 51.3 of the Civil Code) and housing for special needs
populations (as defined in Section 51312 of the Health and Safety Code) also qualify for by -right
parking reductions when either paratransit service is provided, or unobstructed access to a fixed bus
route service that operates at least eight times per day is available within one-half mile.
All 16 cities have adopted local density bonuses which implement state density bonus law. With the
recent addition of anti -displacement provisions under AB 2222 and modified parking standards for
transit -accessible projects under AB 744, all jurisdictions should update their ordinances to reflect
these new State requirements.
1 A development is defined as having unobstructed access to a major transit stop if a resident is able to access the major
transit stop without encountering natural or constructed impediments.
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Inclusionary Housing Programs. Inclusionary zoning is a tool that can be used by cities to integrate
affordable units within market rate developments. One-third of cities and counties in California have
adopted some form of inclusionary zoning, including ten in Orange County, requiring a stated
percentage (typically 10 to 20%) of affordable units to be provided within newly constructed housing
projects. The majority of these regulations allow for payment of a housing in -lieu fee as an
alternative to providing the required affordable units on-site. The goal of inclusionary housing
programs is to increase the supply of affordable housing proportionate to market -rate development,
and to disperse affordable units throughout the community.
Among the 16 participating Orange County cities, the following currently have in place inclusionary
zoning requirements to help address local affordable housing needs and contribute towards Housing
Element production requirements:
■ Huntington Beach. The City's Zoning Ordinance requires projects with three or more units to
provide at least 10 percent of the total units for low to moderate income households.
Affordable units are permitted to be provided at an off-site location (unless otherwise
outlined as part of a specific plan project), and may be new construction, substantial
rehabilitation, or preservation of assisted rental housing at -risk of conversion or mobile
homes. Projects up to 30 units in size are permitted to pay an in -lieu fee.
■ Lake Forest. The City has adopted Affordable Housing Implementation Plans (AHIPs) for four
"New Neighborhoods" created from the rezoning of vacant business/industrial land. Each of
the New Neighborhoods' land owners/developers has entered into a development
agreement with the City which encompasses the AHIP, and reflects the City's policy to
incorporate a minimum of 15 percent affordable units in new developments.
■ San Clemente. Inclusionary Housing Program, adopted in 1980, requires developers of six or
more units to set aside four percent of the total number of units for very low income
households. This affordable requirement can be provided either on-site, off-site, or through
the payment of an in -lieu fee or provision of land. In addition, the City established an
Affordable Housing Overlay Zone along the EI Camino Real commercial corridor in 2006,
allowing for senior housing or mixed income housing with a minimum of 51 percent
affordable to very low income households.
■ Santa Ana. The City's Housing Opportunity Ordinance requires eligible housing development
projects of 5 or more units to include at least 15 percent of the units as affordable to lower
income households (rental) and at least 15 percent as affordable to moderate income
households (ownership). The inclusionary requirement is triggered by: a request to increase
the permitted density above that permitted in the zone, conversion of commercial or
industrial land to residential uses, conversion of rental units to condominiums, and various
other conditions.
Financial Assistance for Affordable Housing. The 16 participating Orange County cities have access
to a number of financial resources which can provide critical gap financing in support of affordable
housing development. As entitlement jurisdictions, the federal government provides annual
allocations of Community Development Block Grant (CDBG), and for most jurisdictions, HOME funds.
The State of California administers the Proposition 1C Housing Bond funds for a variety of
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competitive housing programs. The State also administers federal tax credits and housing bonds
allocated competitively throughout the state.
The primary local source of funds for affordable housing has traditionally been each Redevelopment
Agency's Low- and Moderate -Income Housing Fund. With the passage of Assembly Bill (AB)1X 26,
redevelopment agencies across California have been eliminated as of February 1, 2012, removing the
primary local tool for creating affordable housing. However, with the passage of AB 1484 in June
2012, the Supplemental Educational Revenue Augmentation Funds (SERAF) borrowed by the State
from Redevelopment Agencies Low and Moderate Income Housing Funds are to be repaid, and will
be deposited into each Successor Agency's Housing Asset Fund (pursuant to Health and Safety Code
Section 34191.4(b)(2)(B) and (C)).
Growth Management
Growth management programs facilitate well-planned development and ensure that the necessary
services and facilities for residents are provided. However, a growth management program may act
as a constraint if it prevents a jurisdiction from addressing its housing needs, which could indirectly
impede fair housing choice. Among the 16 participating Orange County cities, only the City of
Newport Beach currently has any form of growth control in place.
The Newport Beach City Charter (Section 423) requires voter approval of any project that increases
density, intensity, or peak hour trip, above that provided for in the General Plan. Significance is
quantified as 100 or more dwelling units, over 100 peak hour trips, or 40,000 or more square feet of
nonresidential floor area. It is important to note, however, that Charter Section 423 does not have
any impact on the allowed density established for the sites identified to meet the City's Regional
Housing Needs Allocation (RHNA) in its 2014-2021 Housing Element, including affordable units.
A Growth Management Initiative was approved by the voters in San Clemente in 1986 which limited
residential construction to 500 units per year and established a competitive allocation process. The
Growth Management Ordinance expired on December 31, 2006 and was not extended.
Article 34
Article 34 of the State Constitution requires a majority vote of the electorate to approve the
development, construction, or acquisition by a public body of any "low rent housing project" within
that jurisdiction. In other words, for any projects to be built and/or operated by a public agency
where at least 50 percent of the occupants are low income and rents are restricted to affordable
levels, the jurisdiction must seek voter approval known as "Article 34 authority" to authorize that
number of units.
In the past, Article 34 may have prevented certain projects from being built. In practice, most public
agencies have learned how to structure projects to avoid triggering Article 34, such as limiting public
assistance to 49 percent of the units in the project. Furthermore, the State legislature has enacted
Sections 37001, 37001.3, and 37001.5 of the Health and Safety Code to clarify ambiguities relating to
the scope of the applicability of Article 34 which now exist.
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F. Zoning Regulations for Persons with Disabilities
Review of each city's zoning standards, policies and practices has not identified anything
discriminatory against persons with disabilities, or that impedes the availability of housing for these
individuals. Examples of the ways in which the cities facilitate housing for persons with disabilities
include:
■ Each City defines "family" or "single housekeeping unit" in such a way that does not have the
effect of discriminating against unrelated individuals, or individuals with disabilities who
reside together in a congregate or group living arrangement.
■ Zoning Codes do not distinguish housing for persons with disabilities who are residing in a
single housekeeping unit from any other residential use in which individuals are residing as a
single housekeeping unit.
■ Through reasonable accommodations, and in certain instances use permits, Zoning Codes
permit disabled individuals not living as a single housekeeping unit to reside in residential
zones where all other groups not living as a single housekeeping unit are prohibited.
■ Each City's Building Code requires new residential construction to comply with the American
with Disabilities Act (ADA) per federal law. ADA regulations include requirements for a
minimum percentage of units in new developments to be fully accessible to the physical
disabled.
Reasonable Accommodation
Both the federal Fair Housing Act and the California Fair Employment and Housing Act impose an
affirmative duty on local governments to make reasonable accommodations in their zoning and
other land use regulations when such accommodations may be necessary to afford disabled persons
an equal opportunity to use a dwelling. Jurisdictions must grant variances and zoning changes if
necessary to make new construction or rehabilitation of housing for persons with disabilities feasible,
but are not required to fundamentally alter their Zoning Ordinance. For example, it may be a
reasonable accommodation to allow covered ramps in the setbacks of properties that have already
been developed to accommodate residents with mobility impairments.
If specific reasonable accommodation policies and procedures are not adopted by a jurisdiction, if a
public hearing or discretionary action is required, or if a fee is charged to process a reasonable
accommodation request, this may present an impediment to equal access to housing for residents
with disabilities. The majority of the 16 participating Orange County cities have adopted formal
procedures in their Municipal Code to process Reasonable Accommodation requests; the City of San
Clemente currently considers such requests as they are made, and includes a program action in its
Housing Element to adopt a formal reasonable accommodation ordinance by 2016. Three cities
charge a fee (Anaheim, Tustin and La Habra), and one city requires a public hearing (Newport Beach).
The Al includes recommended actions for each of these jurisdictions to modify these current
practices to better facilitate housing opportunities to persons with disabilities
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G. Local Housing Authorities
Orange County's four housing authorities provide rental assistance through the Housing Choice
Voucher Program (HCVP) to an estimated 16,486 households'. Thus, the authorities' fair housing
policies affect the well-being of a significant number of renter households, most of whom are very
low- and low-income families. The assisted tenant's are informed about fair housing rights and the
services provided by the Fair Housing Council of Orange County (FHCOC), and the Fair Housing
Foundation (FHF).
The housing authorities' policies contribute to attaining HUD's mandate to affirmatively further fair
housing. If this mandate were not effectively carried out it would adversely impact thousands of very
low and low income renter households. All four housing authorities are performing well, however.
For example, HUD evaluates the performance of housing authorities through the Section 8
Management Assessment Program (SEMAP). This program measures the performances of public
housing agencies (PHAs) that administer the HCVP in 14 key areas, including "Expand housing choice
outside areas of poverty or minority concentration." All four housing authorities have received a
"high performance rating" with SEMAP scores of 90 percent or greater. The Orange County Housing
Authority has consistently received bonus points in SEMAP for de -concentration.
The paragraphs below summarize key fair housing policies of the housing authorities.
Anaheim Housing Authority (AHA)
The AHA 5 -Year Plan for the Housing Choice Voucher Program contains a goal to expand housing
opportunities by completing a survey of Section 8 landlords to establish an inventory of units that are
accessible to the disabled. Another important goal is to ensure equal opportunity and affirmatively
further fair housing by ensuring accessible housing to persons with all varieties of disabilities
regardless of unit size required.
The Administrative Plan contains policies promoting fair housing and equal opportunity. Policies are
established for nondiscrimination, for persons with disabilities, and improving access to services for
persons with limited English speaking proficiency.
As noted in the Administrative Plan, Federal regulations prohibit discrimination against certain
protected classes. State and local requirements, as well as PHA policies, prohibit discrimination
against additional classes of people. The PHA shall not discriminate because of race, color, sex,
religion, familial status, age, disability or national origin (called "protected classes").
Anaheim PHA Policy:
The PHA will not discriminate on the basis of marital status or sexual orientation.
2 This estimated figure includes approximately 6,263 household receiving HCVP assistance from the Orange County Housing
Authority, 2,300 households from the Garden Grove Housing Authority, 1,761 households from the Santa Ana Housing
Authority and 6,162 households receiving Section 8 or Project -Base Voucher Program assistance from the Anaheim Housing
Authority
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The PHA will not use any of these factors to:
■ Deny to any family the opportunity to apply for housing, nor deny to any qualified applicant
the opportunity to participate in the housing choice voucher program
■ Provide housing that is different from that provided to others
■ Subject anyone to segregation or disparate treatment
■ Restrict anyone's access to any benefit enjoyed by others in connection with the housing
program
■ Treat a person differently in determining eligibility or other requirements for admission
■ Steer an applicant or participant toward or away from a particular area based any of these
factors
■ Deny anyone access to the same level of services
■ Deny anyone the opportunity to participate in a planning or advisory group that is an integral
part of the housing program
■ Discriminate in the provision of residential real estate transactions
■ Discriminate against someone because they are related to or associated with a member of a
protected class
■ Publish or cause to be published an advertisement or notice indicating the availability of
housing that prefers or excludes persons who are members of a protected class
Garden Grove Housing Authority (GGHA)
It is the policy of the Housing Authority to comply fully with all Federal, State, and local
nondiscrimination laws and with the rules and regulations governing protected classes of the Fair
Housing Act and Equal Opportunity in Housing and Employment.
The GGHA shall not deny any family or individual the equal opportunity to apply for or receive
assistance under the HCVP on the basis of race, color, sex, religion, creed, national or ethnic origin,
age, familial or marital status, handicap or disability, or sexual orientation.
To further its commitment to full compliance with applicable Civil Rights laws, the GGHA will provide
Federal/State/local information to voucher holders regarding unlawful discrimination and any
recourse available to families who believe they are victims of a discriminatory act. Such information
will be made available during the family briefing session and all applicable Fair Housing Information
and Discrimination Complaint forms will be made a part of the voucher holder's briefing packet. They
also will be available upon request at the front desk.
All Housing Authority staff will be informed of the importance of affirmatively furthering fair housing
and providing equal opportunity to all families; including providing reasonable accommodations to
persons with disabilities as a part of the overall commitment to quality customer service.
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Fair Housing posters are posted in the Housing Authority office lobby and the equal opportunity logo
will be used on specific outreach materials. When available, staff will attend local Fair Housing
update training sessions sponsored by HUD and other local organizations to keep current with new
developments.
Santa Ana Housing Authority (SAHA)
The SAHA's Annual Plan states that it will take affirmative measures to ensure equal opportunity and
affirmatively further fair housing. These measures include:
■ Undertake affirmative measures to ensure access to assisted housing regardless of race,
color, religion, national origin, sex, familial status, and disability.
■ Undertake affirmative measures to provide a suitable living environment for families living in
assisted housing, regardless of race, color, religion, national origin, sex, familial status, and
disability.
■ Undertake affirmative measures to ensure accessible housing to persons with all varieties of
disabilities regardless of unit size required.
Among the action steps taken to implement these measures are the following:
■ Provide referrals to the Fair Housing Council of Orange County when the Housing Authority
receives complaints of possible housing discrimination.
■ Invite the Fair Housing Council of Orange County to make presentations to Authority staff
regarding equal opportunities for fair housing (at least one presentation per year).
■ Include fair housing information in all tenant briefing packets.
■ Provide fair housing information and materials at all landlord training sessions.
Other activities to affirmatively further fair housing include:
■ Counsel Section 8 tenants as to location of units outside areas of poverty or minority
concentration and assist them to locate those units.
■ Market the Section 8 program to owners outside of areas of poverty/minority
concentrations.
■ Awareness training will be provided to staff by representatives of the Fair Housing Council of
Orange County.
Orange County Housing Authority (OCHA)
OCHA furthers the HUD strategic goal of ensuring equal opportunity for all Americans by undertaking
affirmative measures to provide access to a suitable living environment in assisted housing regardless
of race, color, religion, national origin, sex, familial status, or disability, in any bedroom size unit.
Examples of specific affirmative measures are given below:
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OCHA undertakes affirmative measures, initially at program briefings and again during annual re -
certifications, to keep participant and applicant families advised of their civil rights regarding access
to assisted housing regardless of race, color, religion, national origin, sex, familial status, and
disability. In addition, OCHA networks with over 180 community organizations and 31 participating
cities to ensure awareness of and enforcement of fair housing laws. OCHA's Annual Plan is also
consistent with Orange County's Consolidated Plan in furthering these objectives.
OCHA includes a Fair Housing brochure in all Briefing Packets, advising applicants and participants on
how to file a fair housing complaint. The brochure includes the toll-free number for the Housing
Discrimination Hotline: 1-800-669-9777, and the Federal Information Relay Service number: 800-877-
8339. In addition, Fair Housing posters are printed in three Languages; English, Spanish and
Vietnamese and are placed in OCHA's lobby for distribution.
OCHA affirmatively furthers fair housing by certifying to HUD that it will:
■ Examine OCHA's programs and proposed programs
■ Identify any impediments to fair housing choice within those programs
■ Address those impediments in a reasonable fashion in view of the resources available
■ Work with local jurisdictions to implement any of the jurisdiction's initiatives to affirmatively
further fair housing that requires OCHA's involvement
■ Maintain records reflecting these analyses and actions
Additionally, OCHA implements the following policies for persons with disabilities:
■ In accordance with rent reasonableness requirements, approve higher rents to owners that
provide accessible units with structural modifications for persons with disabilities.
■ Provide technical assistance, through referrals to the Fair Housing Council of Orange County,
to owners interested in making reasonable accommodations or units accessible to persons
with disabilities.
OCHA's Administrative Plan further explains its role in implementing laws and HUD regulations
requiring OCHA to affirmatively further civil rights and fair housing in all federally -assisted housing
programs. The letter and spirit of these laws are implemented through consistent policy and
processes. The responsibility to further nondiscrimination pertains to all areas of OCHA's Housing
Choice Voucher (HCV) operations. The Administrative Plan Fair Housing and Equal Opportunity rules
and policies include:
■ Nondiscrimination: Laws and regulations governing the responsibilities of OCHA regarding
nondiscrimination.
■ Policies Related to Persons with Disabilities: Rules and policies of the HCVP related to
reasonable accommodation for persons with disabilities. These rules and policies are based
on the Fair Housing Act (42.U.S.C.) and Section 504 of the Rehabilitation Act of 1973, and
incorporate guidance from the Joint Statement of The Department of Housing and Urban
Development and the Department of Justice (DOJ), issued May 17, 2004.
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■ Prohibition of Discrimination Against Limited English Proficiency Persons: Obligations of
OCHA to ensure meaningful access to the HCVP and its activities by persons with limited
English proficiency (LEP). This part incorporates HUD and DOJ's Notice of Guidance,
published December 19, 2003 in the Federal Register.
H. Community Representation and Participation
It is important to provide residents various opportunities to express their concerns about fair
housing issues through community involvement and representation. Information from the
public provides first hand information on impediments to fair housing choice. As part of the
community outreach for this Al, residents, community organizations, housing advocates, fair housing
and social service providers, and City staff had numerous opportunities to voice concerns and receive
information on fair housing. This was through community fair housing workshops, fair housing
surveys, monthly Al Working Group meetings, and interviews with various organization and agencies.
In addition, each city offers a variety of ways to receive public input regarding housing issues.
Residents can express their concerns through the following:
■ City Level: City residents are given opportunities to provide their housing concerns at city
councils and commissions, and in some cities, housing advisory boards have been
established. Table 5-6 presents, some of the key public input opportunities by city.
■ County: Orange County, through its Housing and Community Development Division
encourages citizen involvement throughout the housing development process, from
planning to implementation. Orange County's community participation process promotes
involvement from residents of all income levels, persons with disabilities, homeless, minority
groups, non-English speaking residents, and from different geographic areas within the
County. The County hosts public meetings on a regular basis and provides timely notification
and information regarding the purpose of these housing meetings in order to allow for full
public participation.
■ Fair Housing Foundation: Eleven of 16 participating cities contract with the Fair Housing
Foundation (FHF) to address housing discrimination and other issues. According to the
Foundation (in addition to providing services to address discrimination) the FHF conducts a
comprehensive, extensive education and outreach program. The purpose of the program is
to educate tenants, landlords, owners, Realtors and property management companies on
fair housing laws. FHF conducts training sessions with tenants, provide staff booths at public
events, and conduct community presentations.
■ Fair Housing Council of Orange County: The Fair Housing Council of Orange County (FHCOC)
provides fair housing services to five of the 16 participating cities. FHCOC provides
comprehensive community education, individual counseling, mediation, advocacy and other
services to try to eliminate housing discrimination.
Even though there are a variety of ways for the community to identify impediments to fair housing
choice, there may be a need for improvement. Results of the Al housing surveys, shown in the
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Chapter 2 Community Participation, indicate that many residents did not know where to go or who
to contact regarding housing discrimination. Over one half (57%) of the respondents indicated that
they encountered discrimination, mostly by landlord/property managers (88%). However, one-third
of these respondents did not know what to do or where to go when discrimination occurs.
Therefore, more information to the public and more opportunities for community involvement will
further improve opportunities for fair housing choice.
Table 5-6: Community Outreach by Cities
Cities Key Outreach Task
Anaheim
Anaheim has 4 Neighborhood Councils that assist in soliciting citizen input.
Buena Park
City has a Citizen's Advisory Committee to obtain input
Costa Mesa
Public meetings are regularly scheduled for the public
At least three public meetings are held each year at different times by the Housing
Fountain Valley
Division of the City. Housing and Community Development Advisory Board
encourages public participation
Fullerton
Minimum of two public hearings are held per year to respond to proposal and
questions.
Garden Grove
Public workshops on housing include inviting service providers to help residents,
including those with special needs
Huntington Beach
HB established the Citizen Participation Advisory Board to represent diverse views
on various issues
La Habra
Established the Citizen Participation Committee to outline strategies and ensure
citizen participation
Lake Forest
City contracts with the Fair Housing Council to work with the community on
housing discrimination issues
Mission Viejo
Surveys, public meetings, hearings, and two commissions that address housing
issues
Newport Beach
City has nearly 40 active boards, commissions and committees, including the
Affordable Housing Task Force
Orange
City contracts with the FHF to assist in providing fair housing services.
Rancho Santa Margarita
City participation is welcome at regularly scheduled meetings, hearings and/or
workshops
San Clemente
The Las Palmas Leadership Group has had results in obtaining input from
underserved residents
Santa Ana
Regular public meetings are scheduled and encouraged at existing
boards/commissions and ad hoc committees
Tustin
City's Citizen Participation Committee holds regularly scheduled public meetings
and makes recommendations to City Council
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6. Fair Housing Profile
Chapter 6 provides an overview of the institutional structure of the housing industry with regard to
fair housing practices. In addition, this section discusses the fair housing services available to
residents, as well as the nature and extent of fair housing complaints received by the City. Typically,
fair housing services encompass the investigation and resolution of housing discrimination
complaints, discrimination, auditing/testing, education and outreach, including the dissemination of
fair housing information. Tenant/landlord counseling services are usually offered by fair housing
service providers but are not considered fair housing.
A. Fair Housing Practices in the Homeownership Market
In 1996, HUD and the National Association of Realtors (NAR) entered into a Fair Housing Partnership.
Article VII of the HUD/NAR Fair Housing Partnership Resolution provides that HUD and the NAR
develop a Model of Affirmative Fair Housing Marketing Plan for use by members of the NAR to satisfy
HUD's Affirmative Fair Housing Marketing regulations. Even so, discrimination still occurs in the
housing market.
Homeownership Process
One of the main challenges in owning a home versus renting a home is the process. Buying a house
takes considerably more time and effort than finding a home to rent. The major legal and financial
implications surrounding the process also intimidate potential buyers. People can be overwhelmed
by the unique terminologies, the number of steps required, and the financial considerations involved.
The process is costly and fair housing issues could surface at any time during this process.
Real Estate Associations and Practices
National Association of Realtors
The NAR has developed a Fair Housing Program to provide resources and guidance to Realtors in
ensuring equal professional services for all people. The term Realtor identifies a licensed
professional in real estate who is a member of the NAR, however, not all licensed real estate brokers
and salespersons are members of the NAR.
Article 10 of the NAR Code of Ethics provides that "Realtors shall not deny equal professional services
to any person for reasons of race, color, religion, sex, handicap, familial status, or national origin.
Realtors shall not be a party to any plan or agreement to discriminate against any person or persons
on the basis of race, color, religion, sex, handicap, familial status, or national origin." A Realtor
pledges to conduct business in keeping with the spirit and letter of the Code of Ethics. Article 10
imposes obligations on realtors and is a firm statement of support for equal opportunity in housing.
A realtor who suspects discrimination is instructed to call the local Board of Realtors. Local Boards of
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Realtors will accept complaints alleging violations of the Code of Ethics filed by a home seeker who
alleges discriminatory treatment in the availability, purchase or rental of housing. Local Boards of
Realtors have a responsibility to enforce the Code of Ethics through professional standards,
procedures, and corrective action in cases where a violation of the Code of Ethics is proven to have
occurred.
In addition, Standard of Practice Article 10-1 states that "REALTORS® shall not volunteer information
regarding the racial, religious, or ethnic composition of any neighborhood and shall not engage in any
activity which may result in panic selling. REALTORS® shall not print, display, or circulate any
statement or advertisement with respect to the selling or renting of a property that indicates any
preference, limitations, or discrimination based on race, color, religion, sex, handicap, familial status,
or national origin."
Realtor Fair Housing Declaration. In accordance with the Code of Ethics, each Realtor signs the
following pledge, developed in 1996 as a result of the HUD -NAR agreement.
The Realtor agrees to:
■ Provide equal professional service without regard to race, color, religion, sex, handicap,
familial status, or national origin of any prospective client, customer, or of the residents of
any community.
■ Keep informed about fair housing law and practices, improving clients' and customers'
opportunities and his/her business.
■ Develop advertising indicating that everyone is welcome and no one is excluded, expanding
his/her clients' and customers' opportunities to see, buy or lease property.
■ Inform clients and customers about their rights and responsibilities under the Fair Housing
Laws by providing brochures and other information.
■ Document efforts to provide professional service, which will assist him/her in becoming a
more responsive and successful Realtor.
■ Refuse to tolerate non-compliance.
■ Learn about those who are different and celebrate those differences.
■ Take a positive approach to fair housing practices and aspire to follow the spirit, as well as
the letter, of the law.
■ Develop and implement fair housing practices for his/her firm to carry out the spirit of this
declaration.
NAR also provides training on working with a diverse population. NAR's training program At Home
With Diversity offers information about conducting business in culturally competent ways. It
includes updated statistics, fair housing laws, business plan development, and business etiquette. At
Home With Diversity addresses the topics of diversity, fair housing and business planning
development, and teaches REALTORS' how to:
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■ Assess and understand attributes of diversity in local markets and their impact on the real
estate industry
■ Build a business plan and selling strategy to successfully service all client profiles
■ Understand basic competencies to earn the confidence of potential buyers and sellers,
regardless of race, ethnicity, religion, gender, handicaps, familial status, or national origin
California Association of Realtors
The California Association of Realtors (CAR) is a trade association of nearly 170,000 Realtors
statewide. As members of this organization, Realtors subscribe to a strict code of ethics. Over the
years, CAR's membership better reflects the changing demographics of a diverse state. Through its
Leadership Summit meetings, it has grown to include the African American Economic Development
Association of REALTORS® and Affiliates (AAEDARA), California Association of Real Estate Brokers
(CAREB), National Association of Hispanic Real Estate Professionals (NAHREP), Asian Real Estate
Association of America (AREAA), Chinese-American Real Estate Association (CAREA), Chinese Real
Estate Association of America (CREAA), Chinese American Real Estate Professionals Association
(CAREPA), Filipino American Real Estate Professionals Association (FAREPA), South Asian Real Estate
Association of America (SAREAA), Korean Real Estate Brokers Association of Southern California
(KREBA), Korean Association of REALTORS° and Lenders (KARL) and the Multicultural Alliance.
CAR has three meetings per year, which include sessions on fair housing issues. CAR directs outreach
efforts Southern California area to underserved communities, State -licensed brokers, and sales
persons who are not CAR members.
California Department of Real Estate (DRE)
The California Department of Real Estate (DRE) is the licensing authority for real estate brokers and
salespersons. As noted earlier, not all licensed brokers and salespersons are members of the
national or California Association of Realtors.
DRE has adopted education requirements that include courses in ethics and fair housing. To renew a
real estate license, each licensee is required to complete 45 hours of continuing education, including
three hours in each of four mandated areas: Agency, Ethics, Trust Fund and Fair Housing. The fair
housing course contains information that will enable an agent to identify and avoid discriminatory
practices when providing real estate services to clients.
For the initial renewal on or after January 1, 1996, the law requires, as part of the 45 hours of
continuing education, completion of four mandatory three-hour courses in Agency, Ethics, Trust Fund
Handling and Fair Housing. These licensees will also be required to complete a minimum of 18
additional hours of courses related to consumer protection. The remaining hours required to fulfill
the 45 hours of continuing education may be related to either customer service or consumer
protection, at the option of the licensee.
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Orange County Associations of Realtors
The Orange County Association of Realtors is generally the first line of contact for real estate agents
who need continuing education courses, legal forms, career development and other daily work
necessities. The frequency and availability of courses varies among these associations, and local
association membership is generally determined by the location of the broker for which an agent
works.
Complaints involving agents or brokers may be filed with this association. The monitoring of services
by these associations is difficult as statistics on the education/services that the agencies provide or
statistical information pertaining to the members is rarely available. Offices of the Orange County
Association of Realtors are located at:
Laguna Hills
25552 La Paz Road
Laguna Hills 92653
Tel: (949) 586-6800
Fax: (949) 586-0382
http://www.ocar.org/#
Huntington Beach
8071 Slater Avenue, Ste. 240
Huntington Beach 92647
Tel: (714) 375-9313
Fax: (714) 375-9322
Pacific West Association of Realtors
The Pacific West Association of Realtors serves realtors in communities from Long Beach to northern
Orange County. They provide many continuing education opportunities to members, including
courses on the topics of ethics and professional conduct, trust funds, fair housing, and real estate
agency. The Association also has trained mediators on staff that provide extensive mediation
services for unresolved issues relating to financial disputes and fair housing issues. Realtors with fair
housing questions, or who are in need of additional information, are usually referred to the California
Association of Realtors. The Pacific West Association of Realtors also provides resource information
on ethics and standards of practice.
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B. Fair Housing Practices in the Rental Market
Similar to the homeownership market, a major challenge to ensuring fair housing in the rental
market is the complexity of the process. There are several stages in the process of renting a home or
apartment: 1) the advertising and outreach stage, 2) pre -application inquiries and responses, 3) the
criteria for acceptance, 4) the lease and 5) administration of the lease. This section discusses these
phases of the rental process. Although a potential homebuyer might face discriminatory practices
primarily during the process of purchasing a home, a renter could confront housing discrimination
not only during the process of renting but also throughout the tenancy.
Rental Process
Although the process of renting an apartment may be less expensive and burdensome up -front than
the home -buying process, it may still be just as time-consuming. Potential renters might still face
discrimination during the various stages of the rental process.
Advertising. The main sources of information are the internet, the realtor through the MLS,
classified advertisements in local newspapers, word of mouth, and signs. The same types of
discriminatory language previously described under the Homeownership Process may be used by
landlords or apartment managers to exclude "undesirable elements."
Compliance with fair housing laws is difficult to monitor among the large number of small property
owners. Outreach to this group is also difficult because many of these owners may not belong to the
Apartment Owners or Apartment Managers associations, or do not actively participate in
events/trainings offered by these associations. Advertising by small property owners may not always
comply with the fair housing laws. For example, rental ads in local Spanish-language newspapers do
not always appear in the English-language newspapers, as required by law.
Viewing the Unit. Viewing the unit is the most obvious place where potential renters could
encounter discrimination because landlords or managers might discriminate based on race or
disability, or judge on appearance whether a potential renter is reliable or might violate any of the
rules. For example, a participant at a fair housing workshop conducted for this Al, indicated that a
manager frowning on the presence of young children accompanying a viewer. Discrimination against
families with children and people with disabilities is even more prevalent than racial discrimination.
Credit/Income Check. Landlords may ask potential renters to provide credit references, lists of
previous addresses and landlords, and employment history/salary. The criteria for tenant selection,
if any, are typically not known to those seeking to rent. Many landlords often use credit history as an
excuse when trying to exclude certain groups. Recent legislation provides for applicants to receive a
copy of the report used to evaluate applications. In addition, applicants may also request a copy of
their credit report (for a fee) to verify that the information used to approve/deny their application is
accurate.
Lease. Most apartments are rented under either a lease agreement or a month-to-month rental
agreement. A lease is favorable from a tenant's point of view for two reasons: the tenant is assured
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the right to live there for a specific period of time and the tenant has an established rent during that
period. Most other provisions of a lease protect the landlord. Information written in a lease or
rental agreement includes the rental rate, required deposit, length of occupancy, apartment rules
and termination requirements.
In a tight housing market, when a landlord can "financially afford" to choose tenants, the tendency is
to offer shorter lease terms. In this case, a landlord might simply ask the "not -so -desirable" tenant
to leave with a 60 -day Notice to Vacate. Short-term leases also allow the landlord to raise rent more
frequently.
Typically, the lease or rental agreement is a standard form completed for all units within the same
building. However, the enforcement of the rules contained in the lease or agreement might not be
standard for all tenants. A landlord might act in a discriminatory way and choose strict enforcement
of the rules for certain tenants based on arbitrary factors, such as race, presence of children or
disability. Because of the recent escalation of housing prices throughout California, complaints
regarding tenant harassment through strict enforcement of lease agreements as a means of evicting
tenants have increased.
Security Deposit. A security deposit is typically required to rent a housing unit. To deter "less -than -
desirable" tenants, a landlord might ask for a security deposit higher than usual. Tenants could also
face differential treatment when vacating the units. The landlord might choose to return a smaller
portion of the security deposit to some tenants, claiming excessive wear and tear. A landlord might
require that persons with disabilities with service animals pay an additional pet rent, a monthly
surcharge for pets or a deposit, which is also a discriminatory act.
During the Tenancy. During tenancy, the most common forms of discrimination a tenant could face
are based on familial status, race, national origin, sex or disability. Usually these types of
discrimination appear in differential enforcement of rules, overly strict rules for children, excessive
occupancy standards, and refusal to make a reasonable accommodation for handicapped access,
refusal to make necessary repairs, eviction, notices, illegal entry, rent increases or harassment. These
actions may be used as a way to force undesirable tenants to move on their own without the
landlord having to make an eviction.
Rental Associations and Practices
California Apartment Association. The California Apartment Association (CAA) is the country's
largest statewide trade association for rental property owners and managers. The CAA was
incorporated in 1941 to serve rental property owners and managers throughout California. The CAA
represents rental housing owners and professionals who manage more than 1.5 million rental units.
Under the umbrella agency, various apartment associations cover specific geographic areas.
The CAA has developed the California Certified Residential Manager (CCRM) program to provide a
comprehensive series of courses geared toward improving the approach, attitude and professional
skills of onsite property managers and other interested individuals. The CCRM program consists of
31.5 hours of instruction that includes training on fair housing and ethics issues.
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The CAA supports the intent of all local, state and federal fair housing laws for all residents without
regard to color, race, religion, sex, marital status, mental or physical disability, age, familial status,
sexual orientation or national origin. Members of the CAA agree to abide by the following provisions
of the organization's Code for Equal Housing Opportunity:
■ We agree that in the rental, lease, sale, purchase, or exchange of real property, owners and
their employees have the responsibility to offer housing accommodations to all persons on an
equal basis,
■ We agree to set and implement fair and reasonable rental housing rules and guidelines and
will provide equal and consistent services throughout our residents' tenancy;
■ We agree that we have no right or responsibility to volunteer information regarding the
racial, creed, or ethnic composition of any neighborhood, and we do not engage in any
behavior or action that would result in steering; and
■ We agree not to print, display, or circulate any statement or advertisement that indicates any
preference, limitations, or discrimination in the rental or sale of housing.
C. Fair Housing Services
Fair housing services include the investigation and resolution of housing discrimination complaints,
discrimination auditing/testing, and education and outreach, including the dissemination of fair
housing information such as written material, workshops, and seminars. Landlord/tenant counseling
services involves informing landlords and tenants of their rights and responsibilities under the
California Civil Code and mediating conflicts between tenants and landlords.
There are two private non-profit organizations that provide fair housing programs and services to
Orange County residents. The Fair Housing Council of Orange County (FHCOC) and the Fair Housing
Foundation (FHF) are the primary organizations providing fair housing services.
Fair Housing Council of Orange County
The Fair Housing Council of Orange County, which was established in 1965, provides fair housing
service to the cities of Fountain Valley, La Habra, Lake Forest, Rancho Santa Margarita, and Santa
Ana. Fair housing services include discrimination counseling, intake, investigation, and resolution,
landlord/tenant fair housing counseling, mediations and training, certificate management training,
community outreach, and fair housing education to cities. As part of the FHCOC's education and
counseling service, its team provides one-on-one education, mediation, and counseling for
individuals and families throughout Orange County and is a HUD Approved Housing Counseling
Agency.
Fair Housing Council of Orange County
1516 Brookhollow Drive, Suite A
Santa Ana, CA 92705
714.569-0823 or 800.698.FAIR
FAX: 714.835-0281
http://www.fairhousingoc.org/
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Fair Housing Foundation
The Fair Housing Foundation has provided programs and services for the elimination of housing
discrimination, general housing assistance, and education and outreach activities to cities since 1964.
Among the 16 cities participating in this Al, FHF provides fair housing services to the cities of
Anaheim, Buena Park, Costa Mesa, Fullerton, Garden Grove, Huntington Beach, Mission Viejo,
Newport Beach, Orange, San Clemente, and Tustin.
The objective of FHF is to affirmatively further fair housing in the City through a program comprised
of services formulated to address the issues specific to their service cities. Those components
include but are not limited to:
■ General Housing counseling, mediations, unlawful detainer assistance, and referrals to
tenants, landlords, managers, and rental property owners
■ Discrimination counseling, complaint intake, in-depth testing, and resolution
■ Audits of housing practices based on areas of concern uncovered through counseling and
testing
■ Education and Outreach services target specific areas and concerns. Education and training
to Housing Consumers, and Housing Providers
■ Workshops and presentations designed to educate the public on fair housing laws and issues
■ Tester and other volunteer training
■ Promoting media interest in eliminating housing violations
The FHF has two office locations:
Fair Housing Foundation
3605 Long Beach Boulevard, Suite 302
Long Beach, CA 90807
562-989-1206
800-446-3247
FAX 562-989-1836
http://www.fairhousingfoundation.com/
Fair Housing Foundation
600 W. Santa Ana Boulevard, Suite 214A
Santa Ana, CA 92701
714-918-8001
800-446-3247
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D. Fair Housing Statistics and Trends
A key service provide by both the Fair Housing Council of Orange County and the Fair Housing
Foundation is the handling of fair housing complaints filed by residents in their service cities. The
following discussion summarizes the results of fair housing services provided by both organizations
to each city in the Regional Al. Table 6-1 displays the number and type of fair housing cases for fiscal
years 2012/13, 2013/14 and 2014/15.
As presented in Table 6-1, during the last three fiscal years, there were 254 discrimination cases in
the 16 cities participating in the Regional Al. The City of Tustin, with a population of about 80,000,
had the highest number of discrimination cases at 32, which represents 12.6 percent of the total
discrimination cases in the 16 cities. This was closely followed by Garden Grove and Huntington
Beach, both at 31 cases or 12.2 percent of the total cases. The City of Anaheim had 29 cases during
the same three-year period and accounted for 11.4 percent of the total. Rancho Santa Margarita had
no discrimination cases during the last three years.
A comparison of the types of discrimination cases shows that over one-half (53.9%) of the total cases
were related to a person's disability -- including both mental and physical disabilities. The next
highest number of discrimination cases were related to familial status, which includes the presence
of children under age of 18 and pregnant women, comprising 21.2 percent of the total 254 cases.
National origin and race were also frequent bases for alleged discrimination, representing 11.6
percent and 7.5 percent of all cases, respectively. As the table shows, there were no discrimination
cases based on age or religion.
Of the 254 fair housing cases opened by the Fair Housing Foundation and Fair Housing Council of
Orange County within the 16 cities during fiscal years 2012/13 to 2014/15, approximately 38 percent
were found by investigation that discrimination did in fact occur. In slightly fewer cases (34.7%), the
fair housing provider did not find sufficient evidence to indicate potential fair housing violations.
Another one-quarter of the cases were inconclusive, with 2.8 percent pending an outcome.
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Source: Fair Housing Council of Orange County and Fair Housing Foundation
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Table 6-1:
Discrimination Cases by Protected Class: 2012/13 - 2014/15
I- Source
Familial National of
Disability Origin •Income
Age Arbitrary M
Emi
Anaheim
0
0
12
6 0 0 4 4 0
3
0
29
11.4%
Buena Park
0
0
10
2 0 0 0 3 0
1
0
16
6.3%
Costa Mesa
2
0
12
4 1 0 4 2 0
0
0
25
9.8%
Fountain Valley
0
0
2
1 0 0 0 0 0
0
0
3
1.2%
Fullerton
0
0
14
3 0 2 3 2 0
0
0
24
9.4%
Garden Grove
0
0
15
6 0 0 5 4 0
0
1
31
12.2%
Huntington Beach
0
0
23
6 1 0 0 0 0
0
1
31
12.2%
La Habra
0
0
3
4 0 0 1 1 0
0
0
9
3.5%
Lake Forest
0
0
1
0 0 0 0 0 0
0
0
1
0.4%
Mission Viejo
0
0
4
1 0 0 1 0 0
0
0
6
2.4%
Newport Beach
0
0
4
1 0 0 1 1 0
0
0
7
2.8%
Orange
0
0
6
3 0 0 3 0 0
0
0
12
4.7%
Rancho Santa
Margarita
0
0
0
0 0 0 0 0 0
0
0
0
0.0%
San Clemente
0
0
3
2 0 0 3 0 0
0
0
8
3.1%
Santa Ana
0
1
11
3 0 0 4 1 0
0
0
20
7.9%
Tustin
0
1
17
11 0 1 1 1 0
0
0
32
12.6%
Total
2
2
137
53 2 3 30 19 0
4
2
254
100.0%
Source: Fair Housing Council of Orange County and Fair Housing Foundation
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E. Tenant -Landlord Services
In addition to services directly related to fair housing, the Fair Housing Foundation (FHF) and Fair
Housing Council of Orange County (FHCOC) provide services related to general landlord/tenant
issues. Both landlords and tenants contact the FHF and FHCOC regarding a multitude of issues, such
as lease terms, repairs and unlawful detainers. Each organizations' Housing Counselors resolve
general housing inquiries through a variety of methods:
■ Counsel and resolve: Well over 80 percent of all landlord or tenant calls are resolved
without further referrals. Many client issues can be resolved through counseling by
informing them of the law, civil codes, rights and responsibilities, and the remedies available
to them
■ Unlawful Detainer Assistance: Clients receiving Unlawful Detainers can contact the fair
housing provider in their city, make appointments and receive assistance with completing
their paperwork. Although FHF and FHCOC staff will not represent the client in court, agency
staff will attend the Unlawful Detainer hearing and speak as a witness when requested.
■ Mediations: The fair housing agencies also use mediations to resolve disputes. In
mediation, agency staff acts as a neutral third party to facilitate dispute resolution between
two disagreeing parties. In order to mediate, both parties must want the mediation and
agree to enter into good faith resolution agreements.
■ Referrals: Many clients contact their fair housing agency for problems not related to fair
housing or general housing issues or require services not provided by the agency such as on-
site health department reviews. In these cases, the agency provides referrals to other
resources for assistance.
Table 6-2 provides a breakdown of the number of residents and landlords in the 16 participating
cities provided with general housing counseling, mediation, unlawful detainer assistance and referral
services over the past three years (2012/13 - 2014/15). Combined, the FHF and FHCOC handled over
24,000 complaints or requests for assistance, with the most prevalent issues as follows:
■ Lease Terms - 25%
■ Notices - 21%
■ Repairs and Maintenance - 13%
■ Security Deposits - 7%
■ Unlawful Detainer - 6%
■ Harassment and Retaliation - 5%
■ General Information - 5%
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Table 6-2: Tenant/Landlord Complaints and Inquiries 2012/13 - 2014/15
Lease Terms
6,013
2,546
24
63
109
57
295
391
117
135
35
Notices
5,174
1,494
141
253
67
243
111
430
104
96
54
Repairs, Maintenance
3,264
1,101
112
174
63
196
225
333
59
28
52
Security Deposit
1,600
414
53
70
39
94
106
179
31
25
27
Unlawful Detainer
1,345
441
25
32
20
45
54
94
33
23
12
Harassment/Retaliation
1,310
336
35
58
21
57
63
101
20
10
17
Other, General Information
1,171
215
57
64
13
102
103
87
14
14
21
Rentlncrease
673
164
24
44
7
51
48
47
8
10
7
Self -Help Eviction, Relocation
582
83
28
48
6
57
72
49
2
3
11
Nuisance
501
117
13
26
6
22
32
47
22
7
4
Entry by Landlord
459
147
9
6
12
18
5
48
8
10
4
Disability Accommodation
449
72
16
33
5
36
41
73
5
2
13
Reimbursement/Receipts
325
169
15
26
7
4
Lockout
251
99
1
2
7
5
2
16
6
10
1
Utilities
234
46
8
10
7
13
18
19
6
6
Discrimination
168
40
11
7
3
11
7
15
1
5
3
Late Fees
140
40
3
2
8
7
7
4
2
Housing Assistance Info
140
41
4
5
2
1
12
17
3
3
1
Pets
130
47
3
6
2
8
9
15
2
4
Parking
128
48
1
5
3
4
4
2
2
4
Abandonment
92
20
6
6
4
3
14
4
2
2
Guests and Subtenants
78
31
3
5
1
Personal Belongings
77
37
1
5
2
2
Total
24,304
7,748
524
914
1 401
1,030
1,2281
2,012
456
400
273
Source: Fair Housing Council of Orange County Quarterly Reports, Fair Housing Foundation Annual Reports. Compiled by Karen Warner Associates, Inc.
Data missing for cities for the following quarters: Anaheim (QI 2013114), La Habra (Q1 - Q4 2014115)
74
270
109
92
325
40
85
215
21
60
101
38
4
79
8
25
76
14
62
79
14
25
63
13
27
39
3
8
38
9
13
33
21
34
29
2
22
5
8
3
2
19
5
5
14
17
1
10
1
4
15
2
3
9
1
7
2
3
9
1
5
1
8
2
527
1,473
358
27
1,702
59
90
1,498
136
49
755
96
41
266
56
14
449
12
18
413
46
33
217
76
23
110
29
32
88
34
13
128
9
4
113
8
11
43
34
77
91
3
65
7
6
23
17
2
47
6
6
16
8
19
2
46
1
13
4
32
20
373
6,231
639
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F. Hate Crimes
Hate crimes are committed because of a bias against race, religion, sexual orientation, ethnicity,
disability, gender, and gender identity. In an attempt to determine the scope and nature of hate
crimes, the Federal Bureau of Investigation's (FBI) Uniform Crime Reporting Program collects
statistics on these incidents. Hate crimes provide insight into the context of discrimination occurring
in a jurisdiction.
As presented in Table 6-3, based on the most recent five years of FBI hate crime statistics (2010-
2014), all the 16 Al participating cities reported some level of hate crime. In total, 169 incidents of
hate crime were reported in the 16 -city Al region. Of the types of hate crimes (bias motivation), 57
incidents were related to race, 38 to religion, 37 to sexual orientation, 33 to ethnicity, and 2 to
disability and 2 to gender identity. The Orange county Human Relations Commission reports that
race/ethnicity continues to be the most common motivation for hate crimes (37%), followed by
religion (29%). During the five year period, nearly 60 percent of the total 169 hate crimes in the 16
participating cities occurred within the following four jurisdictions: Huntington Beach (36 incidents),
Santa Ana (31 incidents), Newport Beach (18 incidents), and Garden Grove (15 incidents).
Services for Hate Crime Victims
Both the State and County have programs providing assistance to hate crime victims. The Office of
Attorney General has established an Office of Victims' Services that provides advocacy, support,
educational and referral services. The aims of this Office are to help victims and their families
understand their rights, help them get the support they need, and to guide them through the
criminal justice system. The Office of Attorney General also has a Hate Crime Prevention Program
Manager.
In 1991 the Orange County Human Relations Commission formed the Hate Crime Network to bring
together representatives from law enforcement, community organizations, and the Orange County
District Attorney, California Attorney General and the United States Attorney General's offices to
facilitate the sharing of current hate crime issues. The Network is dedicated to creating a united
voice against hate, developing resources for victims of hate, and building an appreciation of diversity
in the community. Some of its objectives are:
■ To Increase immediate and effective assistance to victims of hate.
■ To address the under -reporting of hate crimes and hate incidents in our communities
■ To build and develop collaborations between community organizations and law enforcement
■ To educate communities about roots and trends of hate crimes and hate incidents
Periodic meetings of the Network are held and open to the public, listed on the OC Human Relations
Calendar of Events http://www.ochumanrelations.org/hatecrime/hate-crime-victim-assistance-
partnership/#sthash.0il5GUKh.dpuf
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The Orange County Human Relations Commission collects hate crime and incident data from law
enforcement agencies, prosecutors, community organizations, and hate crime and incident victims.
The data is then analyzed and compiled into an annual report, which is broadly disseminated to
policy -makers, law enforcement agencies, community groups and educators throughout Orange
County. The information presented in these reports allows all parties to better understand hate
crime and incident trends; measure the outcome of their work; and, direct prevention campaigns in
their communities or schools. The reports also serve to advise policy decisions and inform the
development of services for victims of hate.
Source: F81 Uniform Crime Report, 2010-2014 Hate Crime Statistics
' 2013 was the first year F81 began tracking hate crimes based on gender identity.
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Table 6-3:
FBI Hate Crime Statistics 2010-2014
ims
Number of Incidents per
Anaheim
3
1 2 1 -
7
Buena Park
2
- 3 3 -
8
Costa Mesa
2
2 2 2 -
8
Fountain Valley
2
1 2 - 1
6
Fullerton
-
- 1 - -
1
Garden Grove
6
2 3 4 - -
15
Huntington Beach
15
9 4 7 - 1
36
La Habra
5
1 1 - -
7
Lake Forest
3
- 1 1 - 1
6
Mission Viejo
3
2 - 2 - -
7
Newport Beach
-
12 3 3 -
18
Orange
3
3 1 2
9
Rancho Santa Margarita
1
1 - - -
2
San Clemente
1
1 1 1
4
Santa Ana
10
2 13 5 1
31
Tustin
1
1 - 2 - -
4
Total
57
38 37 33 2 2
169
Source: F81 Uniform Crime Report, 2010-2014 Hate Crime Statistics
' 2013 was the first year F81 began tracking hate crimes based on gender identity.
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7. Progress Since 2010
This chapter summarizes private and public sector impediments identified in the prior Al and the
region's progress in implementing actions to address these impediments. The continued existence of
these impediments, along with the appropriateness of identified actions to be carried forward in the
2016-2020 Al are also evaluated.
The following two Als are evaluated:
■ Orange County Regional Analysis of Impediments to Fair Housing Choice 2010-2015
■ Cities of Costa Mesa, Mission Viejo, San Clemente, and Tustin Analysis of Impediments to Fair
Housing Choice 2010-2015
A. Status of 2010-2015 Orange County Regional Al Actions
The 2010-2015 Orange County Regional Analysis of Impediments to Fair Housing Choice (AI)
identified the following private sector impediments:
■ Housing Discrimination
■ Discriminatory Advertising
■ Denial of Reasonable Accommodation
■ Hate Crimes
■ Unfair Lending
These regional impediments have not been eliminated, and have thus been carried over into the 16
Orange County Cities Regional Analysis of Impediments for the 2015-2020 period. The following
section summarizes the actions identified in the 2010-2015 Orange County Regional Al to address
identified impediments, and the progress made by the Orange County Fair Housing Council in
implementing these actions.
Housing Discrimination
Housing discrimination, especially in the rental housing market, is an impediment to fair housing
choice. The Fair Housing Council of Orange County (FHCOC) opens an average of 50 cases on an
annual basis for allegations of housing discrimination.
Actions to be Taken
1. Continue to process housing discrimination complaints filed by city and county residents.
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2. Conduct testing of housing provider practices to determine whether there are differences in
treatment based on a protected class.
3. Revise FHCOC website to provide direct access to a housing discrimination complaint form
and provide an explanation of the process for investigating and resolving a complaint.
4. Revise FHCOC website to add more information on how residents can detect whether they
have been victims of unlawful housing discrimination.
5. Publish a quarterly report on the FHCOC website summarizing the remedies pertaining to
filed housing discrimination complaints.
6. Ensure that all jurisdictions provide a link to the FHCOC website.
7. Compile an Annual Report on housing discrimination complaints filed with the FHCOC, the
DFEH and HUD, and transmit to participating jurisdictions.
Progress
■ During the 2011/12 - 2014/15 period, the Fair Housing Council of Orange County (FHCOC)
opened a total of 236 case files for allegations of housing discrimination in its client cities and
the County.
■ During the same time period, the FHCOC addressed housing -related inquiries from 15,137
unduplicated clients. These inquiries were screened for possible issued of housing
discrimination and clients were provided counseling on their fair housing rights, obligations
and remedies.
■ During 2011/12 - 2014/15, FHCOC conducted 561 paired, on-site, systemic tests for
discriminatory housing practices in both for -sale real estate brokerage transactions and
rental housing transactions.
■ FHCOC's website currently has an on-line contact form that can be used housing
discrimination complaint reporting. The tool generates an e-mail to FHCOC. It is often used
for complaints for other, non-discrimination, housing -related issues.
■ FHCOC has received a grant under the HUD Fair Housing Initiatives Program (FHIP), Education
and Outreach Initiative (EOI) that included $14,000 in funding for web site improvements.
Work has begun and will include the improvements identified in the Al. These will include
upgrades to help further differentiate between discrimination and non-discrimination
complaints. Also, information regarding the process of investigating and resolving
complaints will be added.
Discriminatory Advertising
Rental housing ads that state "no pets" or indicate rental discounts for seniors are impediments to
fair housing choice because they make housing unavailable to disabled persons and the non -elderly.
"No Section 8" ads may become an impediment to fair housing choice because they could make
housing unavailable disproportionately to a protected class such as persons with disabilities.
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Actions to be Taken
1. Encourage the Orange County Register to publish a Fair Housing Notice in the for rent
classified ad section and to identify the FHCOC as an agency that can respond to fair housing
questions. Encourage apartment rental websites to display more prominently their Fair
Housing Notice.
2. Encourage the Los Angeles Times and Orange County Register to publish a "no pets"
disclaimer that indicates rental housing owners must provide reasonable accommodations,
including "service animals" and "companion animals" for disabled persons.
3. Support an amendment to the Communications Decency Act of 1996 to state no provider or
user of an interactive computer service shall be treated as the publisher or speaker of any
information provided by another information content provider, except for notices,
statements, or advertisements with respect to the sale, rental, financing or insuring, or any
other service of a dwelling that violate the Fair Housing Act.
4. Periodically review for rent and for sale ads published in the print media.
5. Prepare a summary of the accomplishments each year and transmit to the Urban County and
participating cities.
Progress
■ FHCOC periodically reviewed rental advertisements in the LA Times, the OC Register and
other local weekly newspapers. This review did not find any overtly discriminatory
advertisements, although ads were observed statements possibly presenting impediments,
including stating 'no pets' without distinguishing that assistance animals would be allowed,
or the use of phrases like 'active senior living' in advertising for senior housing that could
discourage individuals with a disability. Additionally, many ads lacked any affirmative
marketing language or symbols, such as the use of the phrase 'equal housing opportunity' or
the display of HUD's 'equal housing' logo.
■ FHCOC also periodically reviewed advertising for Orange County rentals listed on Craigslist
for discriminatory content. Any discriminatory ads were either flagged as prohibited,
responded to in order to inform the poster of possible discriminatory content, brought to the
attention of Craigslist, or referred to FHCOC investigators for possible enforcement action.
Problematic postings indicated restrictions with regard to children under the age of 18 or
improper preference for seniors or 'older adults' for housing opportunities that did not
appear to qualify as housing for older persons.
■ Additional issues of potentially discriminatory content were found in postings in the
roommates/shared listings. These typically dealt with religious, national origin, race or
sexual orientation preferences or limitations. Given recent court decisions holding that such
preferences might be permissible in shared housing situations, attempting to obtain
correction or removal was a low priority of the FHCOC.
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Denial of Reasonable Accommodation
Denial of a reasonable modification or reasonable accommodation is an impediment to fair
housing choice because they account for almost one-fifth of all alleged discriminatory acts.
Actions to be Taken
1. Provide education and information on why this practice is unlawful to the owners and
managers of apartment complexes and homeowner associations.
2. Provide information on the unlawful practice of denying reasonable modifications/
reasonable accommodations at fair housing seminars conducted by the Apartment
Association of Orange County.
Progress
■ FHCOC responded to inquiries regarding reasonable accommodations and modifications, and
directly assisted numerous clients to request and receive a reasonable accommodation or
permission for a reasonable modification. In instances where clients were denied or
effectively denied their requested accommodation, FHCOC assisted in them in filing an
administrative housing discrimination complaint with the Fair Housing and Equal Opportunity
(FHEO) Office of the U.S. Department of Housing and Urban Development.
■ FHCOC provided training to rental property owners and managers through training seminars
which addressed requirements for reasonable accommodations.
■ FHCOC conducted fair housing seminars in cooperation with the Apartment Association of
Orange County. The curriculum included discussion of reasonable accommodations and
modifications.
Hate Crimes
Hate crimes committed at a residence are an impediment to fair housing choice because they impact
the lives of 20-30 households per year. Almost one-half of all hate crime events in Orange County
had an anti -Black or anti -Latino bias motivation.
Actions to be Taken
1. Coordinate with the Orange County Human Relations Commission, Center OC and the
Orange County Victim Assistance Partnership.
2. Provide affected residents — when needed - with referrals to hate crime victim resources.
Progress
■ On the rare occasion FHCOC is contacted by a victim of a hate crime occurring at their
residence, the FHCOC refers them to the O.C. Human Relations Commission, while still
possibly taking their fair housing complaint.
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Unfair Lending
Disparities in the loan denial rates experienced by Hispanic and Black/African applicants create an
impediment to fair housing choice as they have loans denied at rates 1.5 to 2.0 times greater than
White applicants.
Actions to be Taken
1. Monitor the HMDA data annually using the 2008 HMDA analysis as a benchmark.
2. Complete a HMDA analysis of the top 10 lenders in Orange County to compare and contrast
loan denial rates.
3. Conduct a follow-up analysis of loan denial rates at the neighborhood level to determine to
what extent, if any, redlining may exist in Orange County. This follow-up will be completed
when Census 2010 data are available on minority populations at the census tract level. The
Census 2010 data will enable an analysis of loan activity and minority population
characteristics for the same time period.
4. Conduct outreach to cultural, ethnic and minority organizations to potentially increase
interest and readiness in home purchases.
5. Provide homebuyer education programs in neighborhoods with high denial rates, high
minority population concentrations and limited English speaking proficiency to help increase
loan approval rates.
Progress
■ As part of its outreach efforts FHCOC informs individuals and organizations of its services,
which include housing counseling for individuals seeking to become ready for a home
purchase. FHCOC participates in numerous education and/or outreach activities, reaching a
culturally and ethnically diverse audience, in which they inform participants of fair housing
laws and of their counseling services.
ACTIONS TAKEN BY FHCOC TO AMELIORATE PUBLIC SECTOR IMPEDIMENTS
As part of the Fair Housing Action Plan developed in conjunction with the Regional Al, FHCOC will
provide technical assistance to cities that have identified public sector impediments in the following
areas:
■ Family definition inconsistent with fair housing laws
■ Lack of a definition of disability
■ Lack of a reasonable accommodation procedure
■ Lack of zoning regulations for special needs housing
■ Lack of a fair housing discussion in zoning and planning documents
■ Compliance with HUD AFFH requirements
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The most common public sector impediments are:
■ The zoning regulations do not define "disability".
■ The zoning regulations do not define "supportive" and "transitional housing" as required by
Government Code Section 65583(a)(5).
■ Some cities have not adopted a reasonable accommodation procedure.
■ The zoning regulations do not discuss housing for "special needs" populations.
■ The zoning regulations do not discuss fair housing.
a. Definition of Disability
Question #3 asks: Does the code or any policy document define 'disability, if at all, at least as
broadly as the federal Fair Housing Act?
Almost all cities do not define "disability." Those cities with an adopted reasonable
accommodation procedure define disability in the procedure.
b. Supportive Housing
Question #5 asks: Does the code limit housing opportunities for disabled individuals through
restrictions on the provision of on-site supportive services?
Government Code Section 65583(a)(5) requires local zoning to treat supportive and transitional
housing as a residential use and subject only to those restrictions that apply to other residential
uses of the same type in the same zone. For example, if transitional housing is a multifamily use
proposed in a multifamily zone, zoning should treat transitional housing the same as other
multifamily uses proposed in the zone. The purpose of Government Code Section 65583(a)(5) is
to address the need for housing for the disabled.
The population to be served by supportive and transitional housing is people with different kinds
of disabilities. Actions by the entitlement cities and Urban County to provide zoning regulations
will eliminate a potential impediment to the development of such housing.
c. Reasonable Accommodation Procedure
Question #7 asks: Does the jurisdiction have, either by ordinance or policy, a process by which persons
with disabilities can request reasonable accommodations (modifications or exceptions) to the
jurisdiction's codes, rules, policies, practices, or services, necessary to afford persons with disabilities
an equal opportunity to use or enjoy a dwelling?
Many cities have not yet adopted a reasonable accommodation procedure. Cities without an
adopted procedure have stated in their housing elements that they intend to enact such a
procedure pursuant to the requirements of state law.
d. Special Needs Zoning
Question #20 asks: Does the zoning code or other planning document address housing for "special
needs" populations.
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Most cities answered this question in the affirmative. However, the documents addressing special
needs housing was typically a housing element and not the zoning code. Consequently, most cities do
not have zoning regulations that describe development standards for special needs populations such
as: homeless people, victims of domestic violence, people with disabilities, and people living with
HIV/AIDS, all of whom have direct fair housing implications.
Entitlement cities and the Urban County should consider enacting special needs housing zoning
regulations.
e. Fair Housing Discussion
Question 24 asks: Does the zoning ordinance or other planning or policy document include a
discussion affair housing?
Most cities answered this question in the affirmative. However, the document discussing fair housing
was typically a housing element and not the zoning code. Consequently, most cities do not have
zoning regulations that discuss fair housing.
Entitlement cities and the Urban County should consider enacting fair housing zoning
regulations.
ACTIONS TO BE TAKEN BY THE FHCOC AND CITY TO AMELIORATE OR ELIMINATE PUBLIC
SECTOR IMPEDIMENTS.
a. Actions to be Taken by the FHCOC
The FHCOC will provide technical assistance to cities that have identified public sector impediments
in the following areas:
■ Family definition inconsistent with fair housing laws
■ Lack of a definition of disability
■ Lack of a reasonable accommodation procedure
■ Lack of zoning regulations for special needs housing
■ Lack of a fair housing discussion in zoning and planning documents
■ Compliance with HUD AFFH requirements
The technical assistance will consist of providing background information on the above
impediments and model ordinances or regulations that adequately address the fair housing
concerns posed by the impediments.
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B. Status of 2010-2015 Sub -Regional Al Actions
(Cities of Costa Mesa, Mission Viejo, San Clemente, and Tustin)
Identified Impediments
The Sub -Regional Al identified the following impediments to fair housing choice in the four cities:
■ Areas of racial/ethnic concentrations in each City indicate that residential patterns are
evident; however, they do not indicate the reasons behind the patterns. Given that many of
the ethnically concentrated areas do not overlap the low- and moderate -income areas, the
trends are likely related to other factors. Each of the Cities may need to target these areas
with fair housing services, education/outreach, and/or additional testing to ensure that these
patterns are related to individual preferences and not a discriminatory force within the
market.
■ Residents who speak Spanish at home represented the majority of linguistically isolated
households in each jurisdiction. These language barriers may prevent residents from
accessing services, information, housing, and may also affect educational attainment and
employment needed to earn higher incomes.
■ Analyzing tenure by race indicates that minorities are significantly underrepresented in the
ownership market.
■ When looking at overcrowding by race and ethnicity, the 2000 Census shows that the
percentage of overcrowded households is significantly higher for Hispanic households,
though it is unclear if this is a cultural preference, result of socio-economic status, or
intentional discrimination.
■ Housing designated for persons living with AIDS is scarce and many of these people
encounter discrimination (based on interviews with service providers). In addition,
complaints involving bias against persons with disabilities, denial of reasonable
accommodations, and the availability of accessible housing is a growing concern.
■ The housing stock contains a significant amount of older units that may potentially contain
lead-based paint. In addition, lower income households tend to live in the older housing
stock since it is more affordable. While there were relatively few cases of elevated blood
levels reported during the last five years, all of the cases involved children of Hispanic
ethnicity. Given this group also reported earning lower incomes, outreach and education
efforts may need to be expanded to include Hispanics and residents in the low- and
moderate -income areas.
■ Given the demographics of each City, Asians appear underrepresented as there were no
complaints received by the fair housing service providers from this group in any of the four
Cities (with the exception of one complaint from San Clemente). Yet, it is difficult to
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determine the significance of this trend, because of the large number of complaints that
declined to state their race/ethnicity in each City.
■ Discrimination based on Disability (physical and mental), Race, and Familial Status
constituted the majority of complaints received by the fair housing service provides within
each City. These categories also represented the majority of protected classes of cases filed
with HUD, FHEO, and DFEH. Moreover, there was a consistent pattern of the top three
allegations including eviction, denial of a reasonable accommodation and unequal terms.
These topics may need to be emphasized in outreach efforts and/or targeted to landlords
through literature. Bias against physical and mental disability, familial status, sex, race, and
retaliation should also receive focus in education and outreach materials.
■ Bias against race and/or ethnicity appears to be the biggest motivator of hate crimes within
each of the four Cities.
■ While each City has tried to provide for the accommodation of affordable housing, residents
have sought to block affordable housing developments due to not in my backyard (NIMBY)
sentiments; several of which involved Homeowner's Associations (HOAs).
■ While most of the impediments listed in previous AI's do not appear to still exist in each of
the four Cities, fair lending and education and outreach services pertaining to fair housing
laws (especially to immigrant populations) does continue to be a need in each jurisdiction.
■ The disparate impact of credit scoring and loan approval rates (since the use of credit scores
are still widely used in lending) also appears to remain a concern since the last Al.
■ The pattern of Whites having higher approval rates than minority groups has not changed
since the last Al and Hispanics represented a significant portion of loan applications received
with substantially lower approval rates in each City.
■ Lack of advertising by lenders in particular neighborhoods is one area which may be of
concern due to the lack of home purchase loan applications received by African Americans
and Hispanics.
■ The current housing market has resulted in many new concerns that were not present during
the last Al, which may provide opportunities for additional incidents of discrimination
including: foreclosures, loan modifications, short sales, and real estate owned (REO)
properties that have flooded the market.
Proposed Actions to Address Identified Impediments
The following actions were proposed in the Sub -Regional Al to address identified impediments to fair
housing choice. A summary of the Fair Housing Foundation and the four partner cities progress
made in implementing these actions is identified after each.
Action 1: Each City should consider providing a Housing Page on its website that provides links to the
fair housing service provider and other agencies that provide related services. Access to program
information in Spanish should also be provided or links to agencies that provide information in
Spanish, such as OCAR's link to agents who speak various languages, DRE's Spanish webpage, and
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HUD's Spanish webpage. [This will address impediments involving language barriers, access to
information, racial disparity in the ownership and lending markets, NIMBYism, and disproportionate
complaints.]
Timeframe: By the end of FY 2010-11, and annually thereafter.
Progress: The Cities of Tustin, San Clemente, Costa Mesa, and Mission Viejo have updated their
websites to provide information regarding education opportunities and links to the Fair Housing
Foundation (FHF). Information was also provided in Spanish in Costa Mesa. The FHF has reported
that during this Consolidated Plan period, 17,754 hits to their website have been received, and as of
current, they have 187 Facebook, and 65 Twitter followers.
Action 2: Each City should explore ways to collaborate with local lenders (especially the top ten), real
estate agents, and special networks for Hispanic, African American and Asian professionals within
these groups to develop and expand marketing efforts for services provided by each group within
each of the low- and moderate -income and racial/ethnic concentrated areas. Collaborative efforts
should ensure that various racial/ethnic groups have access and knowledge of City programs,
supportive services, and provide for networking opportunities with these groups such as a housing
fair or similar event. Services providers for those with special needs, especially the disabled and
those living with HIV/AIDS, should also be included. [This will address impediments involving
language barrier, access to information, racial disparity in the ownership and lending markets, and
problems faced by those with special needs.]
Timeframe: By the end of FY 2010-11, and annually thereafter.
Progress: FHF has provided fair housing trainings throughout the sub -region and currently provides
trainings for landlords, managers, realtors, and other housing providers on a regular basis. The FHF
regularly reaches out to real estate boards, property owner associations, and offers fair housing
trainings for their members. The general types of trainings conducted for housing providers are:
Landlord Workshops - A two-hour training geared toward property owners and managers that covers
the Federal and State Fair Housing Laws, the rental process, selection criteria, rental agreements,
rules and regulations, obligations and guidelines regarding late fees, security deposits, rent increases,
and termination. The training also covers specific concerns regarding families with children,
occupancy standards and reasonable accommodations and modifications.
Certificate Management Trainings — A four-hour intensive training geared towards property owners,
managers, management companies and real estate professionals that covers a detailed overview of
the Fair Housing Laws, general guidelines, families with children, lead disclosure, occupancy limits,
reasonable regulations of facilities, people with disabilities, sexual harassment, advertising
guidelines, prohibited practice and hate crimes. A question and answer session follows the training.
Disability Policy Workshop- A two-hour training geared towards housing providers, which covers the
basics of what needs to be addressed in a property's disability policy. The training discusses property
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accessibility, reasonable accommodations and modifications, accessibility policies, and disability
discrimination.
Action 3: Each City should continue to collaborate with their fair housing service provider and include
testing/audits within the contractual work scope of each agreement. In addition, each City should
review their agreements annually to make sure that increased and comprehensive services are being
provided each year, and that education and outreach efforts are expanded and affirmatively
marketed in the low- and moderate income and racial/ethnic concentrated areas. [This will address
impediments involving racial disparities, discrimination complaints, and unexplained trends in
residential patterns.]
Timeframe: By the end of FY 2010-11, and annually thereafter.
Progress:
■ Through counseling and case management, the Fair Housing Foundation has identified that
in addition to complaints on familial status, more prevalent in the sub -region are complaints
regarding disability, specifically in the form of denying reasonable accommodations for
perspective tenants with physical disabilities. While provisions for audit services were not
always available to address this issue, the Fair Housing Foundation did open nearly 100
bonafide discrimination cases within the sub -region since 2010 which were investigated
through on site testing, document review, and surveys. Most complainants were in place
tenants, of lower income, and Latino.
■ When there was provision for audits and testing, or when the number of cases opened and
investigated fell short of the annual performance goal, the FHF conducted discrimination and
educational audits and workshops to address the most common concerns found in the
housing industry. For Mission Viejo specifically, the FHF conducted 7 audits on physical
disability and reasonable accommodations and concluded that one of the seven audits had
evidence to support the discrimination allegation.
■ Educational audits were conducted by randomly selecting housing providers and asking them
to complete questionnaires based on the three most alleged protective classes: Disability,
Race, and Familial Status. Of the 15 housing providers who participated in the educational
audit, most were knowledgeable in all areas of the questionnaire.
■ The Fair Housing Foundation held several Accommodation & Modification 101 workshops for
housing providers. The workshop covered the following topics:
13 Overview of protected classifications
13 Definition of disability, life activities, and impairments
Modifications and accommodations
Examples of common accommodations and modifications
Important data needed o verification forms
Approval notices
Denial of request for accommodations/modifications
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Construction requirements and accessibility
Hoarding
Action 4: Several entities exist in Orange County that assist with fair housing and related issues,
including, but not limited to: Orange County Human Relations, the Public Law Center, Legal Aid
Society, and the Center Orange County. Each City should consider increasing collaborative efforts
with these and similar groups to expand education and outreach efforts and increase the diversity of
services provided. [This will address impediments involving racial disparities, discrimination
complaints, and unexplained trends in residential patterns.]
Timeframe: By the end of FY 2010-11, and annually thereafter.
Progress: Due to a lack of funding, the four cities in the sub -region did not have an opportunity to
collaborate with the Orange County Human Relations, the Public Law Center, Legal Aid Society, or
the Center Orange County. However, the cities contracted with the Fair Housing Foundation to
provide education and outreach to both housing providers and consumers in their cities. A
component of these services is providing referrals, when necessary, to these organizations, as well as
to the California Department of Fair Employment and Housing and HUD.
Action 5: Each City should increase education and outreach efforts related to the home buying
process to increase knowledge of how credit history, debt -to -income ratios, collateral, and cash
needed to close affect a person's ability to successfully qualify for a loan. Information on down -
payment assistance programs available should be included as well. Given that Hispanics are the
group most affected in each of the cities and represent the second largest proportion of each City's
population, information should be made available in Spanish. [This will address impediments
involving language barriers, access to information, impediments involving racial disparities in the
ownership and lending markets.]
Timeframe: By the end of FY 2010-11, and annually thereafter.
Progress: Due to the loss of significant revenue (e.g., redevelopment) and continued reductions in
HUD funding, three of the four cities in the sub -region did not carry out any education or outreach
efforts related to home buying or down payment assistance. In past years, education and outreach
efforts had been conducted in conjunction with the City's redevelopment -funded homebuyer
assistance program. The City of Tustin, however, did provide education to 46 households that
received down payment assistance from nonfederal funds since 2010.
Action 6: Each City should continue to affirmatively market their first-time homebuyer and housing
rehabilitation programs if already doing so, and/or expand their efforts to include programs available
through the County and private sector to residents in the low and moderate -income and
racial/ethnic concentrated areas. In addition, outreach efforts should be expanded to include
Hispanics, elderly, large, and disabled households, as they represented a significant proportion of
households reporting problems. [This will address impediments involving racial disparities and
housing problems.]
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Timeframe: By the end of FY 2010-11, and annually thereafter.
Progress: Each city's ability to fund and hence, affirmatively market, affordable housing programs,
such as a first-time homebuyer or housing rehabilitation program has been limited due to the
elimination of Redevelopment Agencies in California which provided leverage funding for these
programs. Continual annual reductions in HOME entitlement funds, also make it challenging to
effectively administer these programs. However, the sub -region had these accomplishments to
report for Action 6:
■ Costa Mesa affirmatively marketed their HOME -funded owner -occupied rehabilitation
program and assisted 108 households of diverse ethnicity, age, size, and physical ability since
2010.
■ Since 2010, Mission Viejo affirmatively marketed their owner -occupied rehabilitation
program and was successful at funding 62 loans and grants to eligible households.
■ Since 1994, the City of San Clemente has marketed and operated a CDBG-funded single-
family rehabilitation loan program. The program, offering up to $15,000 to owners for home
improvements, is advertised in the City's quarterly magazine, which is mailed to over 31,000
residents and businesses in the city, and is publicly noticed in the city's local newspaper.
■ The City of Tustin assumed responsibility for marketing 262 affordable rental units at Tustin
Legacy to low and moderate income households. Tustin also collaborates with the Orange
County Housing Authority to provide 347 senior, disabled, and lower income households
with housing assistance vouchers through the County's Section 8 program.
Action 7: Each City should continue to collaborate or expand efforts with various property
management companies, mobile home parks, and Homeowner Associations (HOA's) to ensure that
each is knowledgeable of fair housing laws, services, education opportunities, and City -funded
programs. Emphasis on discrimination toward the categories of Disability (mental, physical, and
persons living with HIV/AIDS), Race, and Familial Status (single parents, children, and issues with
lead-based paint) should be included as well as discriminatory acts of eviction, denial of a reasonable
accommodation, and unequal terms. [This will address impediments involving racial disparities,
discrimination complaints, housing problems faced by those with special needs, and NIMBYism. It will
also get more groups involved in the fair housing process.]
Timeframe: By the end of FY 2010-11, and annually thereafter.
Progress: Each city in the sub -region contracts with the Fair Housing Foundation to offer a
comprehensive fair housing program to their residents. FHF provides fair housing trainings
throughout the City and currently provides trainings for landlords, managers, realtors, and other
housing providers on a regular basis. There are several types of trainings offered including landlord
workshops, Certificate Management Training Seminars and Realtor trainings.
■ Landlord Workshops - A two-hour training geared toward property owners and managers
that covers the Federal and State Fair Housing Laws, the rental process, selection criteria,
rental agreements, rules & regulations, obligations & guidelines regarding late fees, security
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deposits, rent increase, termination, etc. The training also covers specific concerns regarding
families with children, occupancy standards and reasonable accommodations and
modifications.
■ Certificate Management Trainings —A four-hour intensive training geared towards property
owners, managers, management companies and real estate professionals that covers a
detailed overview of the Fair Housing Laws, general guidelines, families with children, lead
disclosure, occupancy limits, reasonable regulations of facilities, people with disabilities,
sexual harassment, advertising guidelines, prohibited practice and hate crimes. This training
also includes a "What would you do?" session with specific Fair Housing scenarios discussed
in a group forum.
■ Realtor Trainings — A four-hour training geared towards Realtors that covers a summary of
the Fair Housing Laws, general guidelines, policies and practices, equal treatment needs and
examples and guidelines to showing properties.
Additionally, the FHF has conducted and continues to offer a Fair Housing 101 and Reasonable
Accommodations and Modifications workshops, and conducts educational surveys and audits in the
areas of the most common protected classes: Disability, Familial Status, and Race.
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8. Fair Housing Plan
The Orange County 16 City Analysis to Fair Housing Choice (AI) evaluates a wide range of private and
public sector housing issues and potential barriers to fair housing. This chapter builds upon the
previous analysis, summarizes conclusions and presents a list of recommendations to help address
the impediments. The Fair Housing Action Plan (Table 8-1) is provided at the end of this Chapter:
only those actions pertinent to a specific jurisdiction are included in each city's individual Fair
Housing Action Plan. Periodically, during the Consolidated Plan Annual Action Plan and
Consolidated Annual Performance Evaluation Report (CAPER) processes, individual jurisdictions may
adjust their Fair Housing Action Plan depending on funding availability and progress and
effectiveness in implementing the actions.
A. Regional, Private Sector Impediments Carried Over
from 2010 Regional and Subregional Al
1. Housing Discrimination
Impediment A-1: Housing discrimination continues to exist throughout Orange County, as
evidenced by the number of complaints and fair housing cases opened by the Fair Housing
Foundation and Fair Housing Council of Orange County. An average of 85 cases were opened in the
participating cities over the past three years, with the leading bias based on disability (physical and
mental), followed by familial status, national origin and race.
Recommendations for All Jurisdictions:
■ In partnership with each city's fair housing provider, conduct multi -faceted fair housing
outreach to tenants, landlords, property owners, realtors, and property management
companies. Methods of outreach should include workshops, informational booths at
community events, presentations to civic leaders and community groups, staff trainings, and
distribution of multi-lingual fair housing literature.
■ Conduct focused outreach and education to small property owners/landlords on fair
housing, and race, reasonable accommodation and familial status issues in particular.
Conduct property manager trainings on a regular basis, targeting managers of smaller
properties, and promote fair housing certificate training offered through the fair housing
providers.
■ Provide general counseling and referrals to address tenant -landlord issues through each
city's fair housing contractor, and provide periodic tenant -landlord walk-in clinics at City
Halls and other community locations.
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■ Include testing/audits within the scope of work for each city's fair housing provider. Support
enforcement activity and publicize outcomes of fair housing litigation as a means to deter
discriminatory practices and to encourage reporting.
2. Racial and Ethnic Segregation
Impediment A-2: Residential segregation refers to the degree in which groups live separately from
one another. Within the County there are areas of racial/ethnic concentrations, such as in Santa Ana
where over three-quarters of the population is Hispanic and ten percent Asian. Approximately ten
percent of households in the County are considered to be limited English-speaking households.
Recommendations for All Jurisdictions:
■ Coordinate with fair housing providers to focus fair housing services, education/outreach,
and/or additional testing in identified areas of racial/ethnic concentrations.
■ Offer a variety of housing opportunities to enhance mobility among residents of all races
and ethnicities. Facilitate the provision of affordable housing throughout the community
through: 1) available financial assistance; 2) flexible development standards; 3) density
bonuses; and 4) other zoning tools.
■ Promote equal access to information on the availability of affordable housing by providing
information in multiple languages, and through methods that have proven successful in
outreaching to the community, particularly those hard -to -reach groups.
■ Affirmatively market first-time homebuyer and/or housing rehabilitation programs to low
and moderate income areas, and areas of racial/ethnic concentration.
■ Work collaboratively with local housing authorities to ensure affirmative fair marketing
plans and de -concentration policies are implemented.
3. Denial of Reasonable Modifications/ Reasonable Accommodations
Impediment A-3: Denial of reasonable modification or reasonable accommodation is a continuing
impediment to fair housing choice, and represents over one-half of alleged discriminatory acts in the
16 participating jurisdictions.
Recommendations for All Jurisdictions:
■ Through each city's fair housing contractor, continue to provide fair housing education and
information to apartment managers and homeowner associations on why denial of
reasonable modifications/accommodations is unlawful.
■ Provide information on the unlawful practice of denying reasonable modifications/
accommodations at fair housing seminars conducted by the Apartment Association of
Orange County.
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4. Discriminatory Advertising
Impediment A-4: Regionally, there were incidents of discriminatory advertising that have the
potential to discourage a certain type of renter or buyer from pursuing a housing opportunity. Ads
indicating a preference for a certain type of tenant or buyer, such as "no pets", "no children", or
"Ideal for single adult" have the effect of housing discrimination.
Recommendations for All Jurisdictions:
■ Through each city's fair housing contractor, periodically monitor local newspapers and
online media outlets to identify potentially discriminatory housing advertisements. When
identified, make contact with the individual or firm and provide fair housing education.
■ Take steps to encourage both the Los Angeles Times and Orange County Register to
publish a Fair Housing Notice and a "no pets" disclaimer that indicates rental housing
owners must provide reasonable accommodations, including "service animals" and
"companion animals" for disabled persons.
5. Hate Crimes
Impediment A-5: Hate crimes committed at a residence are an impediment to fair housing choice
because they impact the lives of an average of 35 households per year in the 16 participating Orange
County cities. Of the total 169 hate crime incidents reported between 2010 and 2014, 57 incidents
were related to race, 38 to religion, 37 to sexual orientation, 33 to ethnicity, 2 to disability and 2 to
gender identity. Nearly 60 percent of these incidents occurred within the following four
jurisdictions: Huntington Beach (36 incidents), Santa Ana (31 incidents), Newport Beach (18
incidents), and Garden Grove (15 incidents).
Recommendations for All Jurisdictions:
■ Continue to monitor FBI data to determine if any hate crimes are housing related and if
there are actions that may be taken by the City or its fair housing service provider to address
potential discrimination linked to the bias motivations of hate crimes.
■ Continue to coordinate with various City and County housing, building and safety, health
and sanitation, law enforcement and legal aid offices to maintain a comprehensive referral
list of support services for victims of hate crimes or other violent crimes — inclusive of
housing resources.
6. Unfair Lending
Impediment A-6: Disparities in the home purchase loan denial rates experienced by Hispanic and
Black/African American applicants within the 16 Orange County cities creates an impediment to fair
housing choice as they have loans denied at rates 1.5 to 1.6 times greater than White applicants. In
addition, Hispanic residents, which comprise 34 percent of Orange County's population, account for
just 10 percent of applications for home purchase loans. Examples of the disparity between
Hispanic residents and Hispanic applicants for home purchase loans include: Anaheim has a 53
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percent Hispanic population, with 20 percent of purchase loan applicants comprised of Hispanics; La
Habra has a 60 percent Hispanic population, with 23 percent Hispanic mortgage loan applicants; and
Santa Ana has a 79 percent Hispanic population, with just 30 percent of home purchase loan
applications made by Hispanics. In addition, the proportion of Hispanics to the total pool of
mortgage loan applicants in the 16 Orange County cities has decreased in each of the past five years,
from 16 percent in 2008 to 10 percent in 2013.
Recommendations for All Jurisdictions:
■ As resources permit, monitor HMDA data annually using the 2013 HMDA analysis as a
benchmark.
■ As resources permit, monitor the top 10 lenders in Orange County to compare and contrast
loan denial rates and percentage of loans completed to minority populations.
■ Both of the Orange County fair housing service contractors should assist in identifying
potential issues regarding redlining, predatory lending and other illegal lending activities. In
addition, each city should review their agreements annually to make sure that increased and
comprehensive services are being provided, and that education and outreach efforts are
expanded and affirmatively marketed in low and moderate income and racial concentrated
areas.
■ Each city should explore ways to collaborate with local lenders and support lenders' efforts
to work with community groups to help minority households purchase their homes.
Collaborative efforts should ensure that minority groups have access and knowledge of City
programs, supportive services, and provide for networking opportunities with these groups.
■ Coordinate with local lenders to expand outreach efforts to first time homebuyers in
minority neighborhoods.
■ Affirmatively market first-time homebuyer and/or housing rehabilitation programs in
neighborhoods with high denial rates, high minority population concentrations and limited
English speaking proficiency to help increase loan approval rates.
B. Public Sector Impediments
1. Housing Element Compliance
Impediment 13-1: According to HCD, of the 16 participating jurisdictions, 15 Housing Elements were
in compliance, and San Clemente had submitted a draft Housing Element for the current 2014-2021
period in early 2016.
Recommendations for Specific Jurisdictions:
■ San Clemente should pursue State certification of its Housing Element.
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2. Housing for Persons with Disabilities
Impediment 13-2: Disability is the greatest cited basis for discrimination, comprising over half of the
fair housing cases opened by the Orange County Fair Housing Council and Fair Housing Foundation
in the 16 cities over the past three years. With the exception of the City of San Clemente, all
participating jurisdictions have adopted formal policies and procedures in the Municipal Code to
reasonably accommodate the housing needs of disabled residents. However, three cities charge a
fee (Anaheim, Tustin and La Habra), and one city requires a public hearing (Newport Beach).
Imposing a fee or a requirement for a public hearing could serve as an impediment to persons with
disabilities seeking reasonable accommodation.
Recommendations for Specific Jurisdictions:
■ The City of San Clemente should adopt formal Reasonable Accommodations policy and
procedure in 2016.
■ The cities of Anaheim, Tustin and La Habra should consider eliminating the processing fee
for reasonable accommodation requests.
■ The City of Newport Beach should consider amending its Reasonable Accommodation
procedures to eliminate the requirement for a public hearing, and to approve
administratively.
3. Zoning Regulations
Impediment 13-3: The analyses of the land use controls and zoning codes identified the following
potential issues:
■ Second Units: The City of Newport Beach does not currently provide for second units in its
Zoning Code for single-family zoned properties, but does allow for "granny units" (accessory,
age -restricted units) subject to Zoning Administrator approval of a Minor Use Permit. The
City's age restrictions, combined with the requirement for non -ministerial approval, may
serve to impede housing choice.
■ Single -Room Occupancy Housing: The majority of the 16 participating cities either contain
specific provisions for SROs in their Zoning Ordinances, or have clarified in their Housing
Elements how SROs are provided for under other zoning classifications. The cities of Buena
Park, Orange and Santa Ana, however, do not currently specify zoning for SROs, or
otherwise clarify how such uses would be provided for, though Buena Park has indicated
SROs could currently be accommodated through a development agreement. Buena Park
and Orange both include programs in their 2014-2021 Housing Elements to amend the
Zoning Code to specifically address the provision of SRO units. Lack of clarity on provision
for SROs can serve to limit housing choice to extremely low income households, including
persons with disabilities and veterans.
■ Transitional/Supportive Housing: In all participating jurisdictions, with the exception of the
cities of Fountain Valley and Orange, transitional and supportive housing is permitted in the
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REGIONAL ANALYSIS OF IMPEDIMENTS
manner prescribed by State law, regulated as a residential use and subject to the same
permitting and standards as similar residential uses of the same type in the same zone. The
City of Orange Zoning Code currently only addresses transitional and supportive housing
structured in the form of group housing, and the City of Fountain Valley Zoning Code
contains a definition of supportive housing but doesn't specify how such uses are to be
regulated.
Recommendations for Specific Jurisdictions:
■ The City of Newport Beach should consider pursuing a Zoning Code amendment to eliminate
the current age restriction on second units and establish a ministerial review process.
■ The cities of Buena Park, Orange and Santa Ana should amend their Zoning Codes to specify
provisions for SRO units.
■ The cities of Fountain Valley and Orange should amend their Zoning Codes to regulate
transitional and supportive housing as a residential use, subject to the same standards as
other residential uses of the same type in the same zone.
4. Density Bonus Incentives
Impediment B-4: All 16 jurisdictions have adopted local density bonus ordinances which implement
state density bonus law, providing density and other development incentives and concessions for
the provision of affordable housing. However, with the recent addition of anti -displacement
provisions under AB 2222, and modified parking standards for transit -accessible projects under AB
744, jurisdictions should update their density bonus ordinances to reflect these new State
requirements.
Recommendations for All Jurisdictions:
■ All 16 jurisdictions should amend the Zoning Code to reflect current State density bonus law.
FAIR HOUSING PLAN
147
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20
Impediment Actions Time Frame
A. Regional, Private Sector Impediments Carried Over from 2010 Regional and Subregional Al
A-1. Housing
Data indicates housing discrimination
a) Conduct multi -faceted fair housing outreach to tenants,
Discrimination
continues to exist throughout Orange
landlords, property owners, realtors, and property
County, as evidenced by the number of
management companies. Methods of outreach should
complaints and fair housing cases opened
include workshops, informational booths,
by the Fair Housing Foundation and Fair
presentations to civic leaders and community groups,
Housing Council of Orange County. An
staff trainings, and distribution of multi-lingual fair
average of 85 cases were opened in the
housing literature.
participating cities over the past three
b) Conduct focused outreach to small property owners/
years, with the leading bias based on
landlords; conduct property manager trainings on a
Ongoing
disability (physical and mentals followed by
regular basis; promote fair housing certificate training.
2015/16 -2019/20
familial status, national origin and race.
c) Provide general counseling and referrals to address
tenant -landlord issues, and provide periodic tenant -
landlord walk-in clinics at City Halls and other
community locations.
d) Include testing/audits within the scope of work for each
city's fair housing provider. Support enforcement
activity and publicize outcomes of fair housing
litigation.
A-2. Racial and Ethnic
Residential segregation refers to the degree
a) Coordinate with fair housing providers to focus fair
Segregation
in which groups live separately from one
housing services, education/outreach, and/or additional
another. As presented within the
testing in areas of racial/ethnic concentrations.
Community Profile, there are areas of
b Offer a varietyof housing opportunities to enhance
) g pp
Ongoing
racial/ethnic concentrations in the County.
mobility among residents of all races and ethnicities.
2015/16 -2019/20
Approximately ten percent of households
Facilitate affordable housing throughout the
are considered to be limited English-
community through: 1) available financial assistance; 2)
speaking households.
flexible development standards; 3) density bonuses;
and 4) other zoning tools.
FAIR HOUSING PLAN
148
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20
Impediment Actions Time Frame
c) Promote equal access to information on the availability
of affordable housing by providing information in
multiple languages, and through methods that have
proven successful in outreaching to the community,
particularly those hard -to -reach groups.
d) Affirmatively market first-time homebuyer and/or
housing rehabilitation programs to low and moderate
income areas, and areas of racial/ethnic concentration.
e) Work collaboratively with local housing authorities to
ensure affirmative fair marketing plans and de -
concentration policies are implemented.
A-3. Denial of
Denial of reasonable modification or
a) Through each city's fair housing contractor, continue to
Reasonable
reasonable accommodation is a continuing
provide fair housing education and information to
Modifications/
impediment to fair housing choice, and
apartment managers and homeowner associations on
Reasonable
represents over one-half of alleged
why denial of reasonable modifications/
Accommodations
discriminatory acts in the 16 participating
accommodations is unlawful.
Ongoing
jurisdictions.
2015/16 -2019/20
b) Provide information on the unlawful practice of denying
reasonable modifications/accommodations at fair
housing seminars conducted by the Apartment
Association of Orange County.
A-4. Discriminatory
Regionally, there were incidents of
a) Through each city's fair housing contractor, periodically
Advertising
discriminatory advertising that have the
monitor local newspapers and online media outlets to
potential to discourage a certain type of
identify potentially discriminatory housing
renter or buyer from pursuing a housing
advertisements. When identified, make contact with
Ongoing
opportunity. Ads indicating a preference
the individual or firm and provide fair housing
2015/16 - 2019/20
for a certain type of tenant or buyer, such
education.
as "no pets", "no children", or "Ideal for
b) Take steps to encourage both the Los Angeles Times
single adult" have the effect of housing
and Orange County Register to publish a Fair Housing
discrimination.
Notice and a "no pets" disclaimer that indicates rental
FAIR HOUSING PLAN
149
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20
Impediment Actions Time Frame
housing owners must provide reasonable
accommodations, including "service animals" and
"companion animals" for disabled persons.
A-5. Hate Crimes
Hate crimes committed at a residence are
a) Continue to monitor FBI data to determine if any hate
an impediment to fair housing choice
crimes are housing related and if there are actions that
because they impact the lives of an average
may be taken by the City or its fair housing service
of 35 households per year in the 16
provider to address potential discrimination linked to
participating Orange County cities. Of the
the bias motivations of hate crimes.
total 169 hate crime incidents reported
b) Continue to coordinate with various City and County
Ongoing
2015/16 -2019/20
between 2010 and 2014, 57 incidents were
housing, building and safety, health and sanitation, law
related to race, 38 to religion, 37 to sexual
enforcement and legal aid offices to maintain a
orientation, 33 ethnicity, 2 to disability
comprehensive referral list of support services for
and 2 to gender identity.
i
victims of hate crimes or other violent crimes —inclusive
of housing resources.
A-6. Unfair Lending
Disparities in the home purchase loan
a) As resources permit, monitor HMDA data annually using
Annually
denial rates experienced by Hispanic and
the 2013 HMDA analysis as a benchmark.
Black/African American applicants within
b) As resources permit, monitor the top 10 lenders in
2017
the 16 Orange County cities creates an
Orange County to compare and contrast loan denial
impediment to fair housing choice as they
rates and percentage of loans completed to minority
have loans denied at rates 1.5 to 1.6 times
populations.
greater than White applicants. In addition,
Hispanic residents, which comprise 34
c) Both of the Orange County fair housing service
Ongoing
percent of Orange County's population,
contractors should assist in identifying potential issues
2015/16 -2019/20
account for just 10 percent of home
regarding redlining, predatory lending and other illegal
purchase loans, and the percentage of
lending activities. Each city should review their
completed mortgage loans by Hispanics has
agreements annually to make sure that increased and
decreased in each of the past five years.
comprehensive services are being provided, and that
education and outreach efforts are expanded and
affirmatively marketed in low and moderate income
and racial concentrated areas.
FAIR HOUSING PLAN
150
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20
Impediment Actions Time Frame
d) Each city should explore ways to collaborate with local
2017
lenders and support lenders' efforts to work with
community groups to help minority households
purchase their homes. Collaborative efforts should
ensure that minority groups have access and knowledge
of City programs, supportive services, and provide for
networking opportunities with these groups.
e) Coordinate with local lenders to expand outreach
2017
efforts to first time homebuyers in minority
neighborhoods.
f) Affirmatively market first-time homebuyer and/or
2016
housing rehabilitation programs in neighborhoods with
high denial rates, high minority population
concentrations and limited English speaking proficiency
to help increase loan approval rates.
B. Public Sector Impediments (Only actions pertinent to Newport Beach identified)
B-2. Housing for
Disability is the greatest cited basis for
Jurisdiction -Specific Actions:
Persons with Disabilities
discrimination, comprising over half of the
c) The City of Newport Beach should consider amending its
fair housing cases in the 16 cities over the
Reasonable Accommodation procedures to eliminate
2017
past three years. With the exception of San
the requirement for a public hearing, and to approve
Clemente, all participating jurisdictions
administratively.
have adopted formal policies and
procedures to reasonably accommodate
the housing needs of disabled residents.
However, three cities charge a fee
(Anaheim, Tustin and La Habra), and one
city requires a public hearing (Newport
Beach). Imposing a fee or a requirement
for a public hearing could serve as an
impediment to persons with disabilities.
FAIR HOUSING PLAN
151
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Table 8-1: City of Newport Beach Fair Housing Action Plan 2015/16 - 2019/20
Impediment I Actions Time Frame
B-3. Zoning Regulations
The analyses of the land use controls and
zoning codes identified the following
Jurisdiction -Specific Actions:
potential issues:
Second Units: Newport Beach does not
a) Second Units: The City of Newport Beach should
2017
currently provide for second units in its
consider pursuing a Zoning Code amendment to
Zoning Code for single-family zoned
eliminate the current age restriction on second units
properties, but does allow for "granny
and establish a ministerial review process.
units" subject to Zoning Administrator
approval of a Minor Use Permit. The City's
age restrictions, combined with the
requirement for non -ministerial approval,
may serve to impede housing choice.
B-4. Density Bonus
All 16 jurisdictions have adopted local
a) All 16 jurisdictions should amend their Zoning Codes to
2016
Incentives
density bonus ordinances which implement
reflect current State density bonus law.
state density bonus law, providing density
and other development incentives and
concessions for the provision of affordable
housing. However, with the recent addition
of anti -displacement provisions under AB
2222, and modified parking standards for
transit -accessible projects under AB 744, all
16 jurisdictions should update their density
bonus ordinances to reflect these new
State requirements.
FAIR HOUSING PLAN
152
14-173
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Appendix A: Community Participation
APPENDIX A-1: Fair Housing Workshops
APPENDIX A-2: Fair Housing Surveys
APPENDIX A-3: Public Review Notices
APPENDIX
A
14-174
We invite you to participate in one of five Fair Housing Workshops hosted by a group of
16 Orange County cities.* These workshops are aimed at tenants, landlords, social
service providers, housing professionals and anyone who has concerns about fair
housing in their community. Your input will help develop the federally -required
Analysis of Impediments to Fair Housing Choice — the planning document for providing
equal housing opportunities.
Anaheim
Tuesday, September 22, 2015
6:00 PM -7:30 PM
Assembly Hall, Downtown Anaheim
Community Center
250 E. Center Street, Anaheim
r—
Tustin
Wednesday, September 23, 2015
6:00 PM -7:30 PM
Professional Training Center
Tustin Library
345 E. Main Street, Tustin
Fountain Valley
Thursday, September 24, 2015
6:00 PM -7:30 PM
City Hall Council Chambers
10200 Slater Avenue, Fountain Valley
Santa Ana
Wednesday, September 30, 2015
6:00 PM -7:30 PM
Santa Ana Police Community Room
60 Civic Center Plaza, Santa Ana
Fair Housing issues to be discussed include:
❖ Housing affordability/availability
❖ Tenant/landlord relations
❖ Accessibility to persons with disabilities
❖ Real estate and mortgage lending practices
❖ Public policies affecting fair housing choice
For more information, please contact:
John Oshimo at 626.331.6373 or
joshimo@grcassoc.com
Please take our brief Fair Housing Survey online:
English https.11www.surveymonkey.com/r/OC-
A1160tiesSurvey ENGLISH
Spanish https://www.surveymonkey.com/r/OC-
A116CitiesSurvey SPANISH
Vietnamese https://www.surveVmonkeV.com/r/OC-
A1160tiesSurvey VIETNAMESE
Korean https://www.surveymonkey.com/r/OC-
A116CitiesSurvev KOREAN
Lake Forest
Thursday, October 1, 2015
6:00 PM -7:30 PM
City Hall, Community Room
25550 Commercentre Drive, Lake Forest
Le invitamos a participar en uno de los cinco Talleres de Equidad de Viviendas organizada por
un grupo de 16 ciudades del Condado de Orange.* Estos talleres estan dirigidos a inquilinos,
propietarios, proveedores de servicios sociales, profesionales de viviendas y cualcluier
persona clue tenga inquietudes sobre la equidad de viviendas en su comunidad. Su
contribuci6n ayudara a desarrollar el informe requerido por el gobierno federal, Analisis de
Impedimentos de Elecci6n de Vivienda Justa (Analysis of Impediments to Fair Housing Choice)
— el documento de planificaci6n para proporcionar igualdad de oportunidades de viviendas.
Anaheim
Martes, 22 de septiembre 2015
6:00 PM -7:30 PM
Assembly Hall, Downtown Anaheim
Community Center
250 E. Center Street, Anaheim
Tustin
Miercoles, 23 de septiembre 2015
6:00 PM -7:30 PM
Professional Training Center
Tustin Library
345 E. Main Street, Tustin
Fountain Valley
Jueves, 24 de septiembre 2015
6:00 PM -7:30 PM
City Hall Council Chambers
10200 Slater Avenue, Fountain Valley
Santa Ana
Miercoles, 30 de septiembre 2015
6:00 PM -7:30 PM
Santa Ana Police Community Room
60 Civic Center Plaza, Santa Ana
Cuestiones de equidad de vivienda que se
consideraran incluyen:
❖ Disponibilidad / Asequibilidad de Viviendas
❖ Las relaciones de inquilino / propietario
❖ Accesibilidad a las personas con discapacidad
❖ Las practicas de prestamos de bienes raices e hipotecas
❖ Las politicas publicas que afectan a la elecci6n de
vivienda justa
Para obtener mas informaci6n, p6ngase en contacto:
Robert G. Vasquez at 626.331.6373 o
rvasquez@grcassoc.com
Por favor tome nuestra breve encuesta de
Vivienda Justa en linea :
Ingles https://www.surveymonkey.com/r/OC
A1160tiesSurvey ENGLISH
Espanol https://www.surveymonkey.com/r/OC-
A116CitiesSurvey SPANISH
Vietnamita https://www.surveymonkey.com/r/OC-
A1160tiesSurvey VIETNAMESE
Coreano https://www.surveymonkey.com/r/OC-
A116Citiessurvey KOREAN
Lake Forest
Jueves, 01 de octubre 2015
6:00 PM -7:30 PM
City Hall, Community Room
25550 Commercentre Drive, Lake Forest
14-176
Kfnh md! quy vj tham dg m8t trong ndm buai H$l Th'ao v6 Ung Bung Gia Cr,
dugc dang td ch0c b8i 16 thdnh pha thu6c QuAn Cam.* Cdc bu$i h6i thho
ndy ddnh cho nha7ng ngudi thud nhd, chu nhd, cdn sit xd h6i, chuydn vidn
va gia cLIvd bat ca3 ai c6 quan tdm don van da cling bang gia cLitrong c$ng
d$ng c6a hp. l( kion d6ng g6p cua qug vi sd giaa p fch cho vioc phdn tfch cdc
ydu cau cua Lidn bang va nh�7ng tib ng4ki trong Fair Housing Choice— Cdc
tdi IiQu ka hooch cho vioc sung carp nht7ng cd hoi trg cap gia cal mot cdch
cSng binh.
Anaheim
Thi, Ba, 22 thong 9 ndim 2015
6:00 PM -7:30 PM
Assembly Hall, Downtown Anaheim
Community Center
250 E, Center Street, Anaheim
Tustin
Thi, TV, 23 thdng 9 n6m 2015
6:00 PM -7:30 PM
Professional Training Center
Tustin Library
345 E. Main Street, Tustin
Fountain Valley
Thif N6m, 24 thong 9 nom 2015
6:00 PM -7:30 PM
City Hall Council Chambers
10200 Slater Avenue, Fountain Valley
Nhitng v5n dfi Ung BAng Gla Cu
s6 duglc birn b6c bao g6m:
# Nha $ gia phdi chdng/ co son
4� Quan h6 thud nhd / chu nhd
• 1-6i vdo nhd ddnh cho ngudi
khuyat tot
• Cdc phucng thuc cho vay bat
dung shn va nha dot
• Chfnh sdch cling c8ng dnh
huizing d6n skf IkIa chgn trong
cling bang gia cu
Dd bi6t th6m chi ti6t, An 116n I4c:
Jahn Oshimo at 626.331.6373 or
joshimo@gmassoc.com
I Xin mdi than gia cu�c khio sdt
ngan g9n va Cdng Bang Gia Cu
Santa Ana trdn website:
Thi, Tal, an th6ng 9 nAm 2015
6:00 PM -7:30 PM
Santa Ana Police Community Room
60 Civic Center Plaza, Santa Ana
Lake Forest
Thi, N6m, 1 th6ng 10 ndm 2016
6:00 PM -7:30 PM
City Hall, Community Room
25550 Commercentre Drive, Lake Forest
English
haps.!/www.surve ymonke y.cum/r/OC-
A116Cit1esSurvey ENGLISH
Spanish
hsurveymonkey.com/��`/0C-
A116GHesSurvey SPANISH
Vietnamese
https://www surve ymonkey cnm/r/OC-
A1I60tlesSurvev VIETNAMESE
Korean
httns4llwww.surveymonkey.com/r/0C-
A1160desSurve ry_KOREW
* 16 thdnh ph6 d$ng tham gia baa g6m: Anaheim, Buena Park, Costa
Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach,
La Habra, Lake Forest, Mission Viejo, Orange, Newport Beach,
Rancho Santa Margarita, San Clemente, Santa Ana, and Tustin
14-177
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September 23, 2015
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14-180
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September 24, 2015
Fountain Valley
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Fair Housing Workshop
October 1. 2015
Lake Forest
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14-184
Fifth Fair Housing
Workshop
Lake Forest
City Hall,
Community Room
25550 Commercentre Drive,
Lake Forest
Regional Analysis of
Impediments to Fair
Housing Choice
14-185
■ Jurisdictions receiving federal funds must certify
that they are affirmatively promoting fair housing.
Certification means:
Prepare an Analysis of Impediments to Fair Housing
Choice (AI) every 5 years
Take actions to eliminate identified impediments
Maintain fair housing records reflecting the actions taken
16 Orange County Cities have elected to prepare
Regional All
14-186
Anaheim ■ lake Forest
Buena Park Mission Viejo
Costa Mesa ■ Newport Beach
Fountain Valley Orange
Fullerton Rancho Santa Margarita
Garden Grove San Clemente
Huntington Beach Santa Ana
La Habra Tustin
14-187
)rest
ober 1, 2015
;30 PM
unity Room
Drive, Lake Forest
14-188
0
Fair housing describes a condition in which
individuals of similar income levels in the same
housing market have a similar range of choices
available to them regardless of a protected class
status
Prohibits discrimination in housing choice because
of one's:
✓ Race or color
✓ Religion
✓ Sex
Marital or familial status
National origin
✓ Disability
Gender
Gender identity and expression
Sexual orientation
Source of income
14-189
■ Any actions, omissions, or decisions that restricts
the availability of housing choice on account of
one's protected class status
■ Communities must work to remove impediments
to fair housing choice
14-190
■ Regional and Community Profiles
Demographic and socioeconomic
Household and housing characteristics
Employment
` Special needs
Public assisted housing
Access to public transportation
Mortgage Lending Practices
Lending patterns by race/ethnicity and income levels
Lending performance by lenders
14-191
■ Public Policies and Practices (General Plans/Zoning/
Building Codes)
Land use policies/development standards
Reasonable accommodations
Housing for special needs (disabled, seniors, homeless, etc)
Residential development fees
Fair Housing Practices
Rental and homeownership market
Fair housing services
Trends in discrimination cases
14-192
Status of Actions from the 2010-2015 Al
Were the actions implemented and were they successful?
Should the actions be continued in the 2015-2020 Al?
r Findings and Recommendations
Identify potential impediments to fair housing choice
Recommendations /actions to address impediments
14-193
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
Lake Forest
Mission Viejo Rancho Santa San Clemente Orange County
2 Races
NH -Black
NH -Asian
Hispanic
NH -White
Margarita
14-194
Source: American Community Survey 2009-2013
■ Dependent Population
About one-quarter (24%) of total County population under the
age of 18 years
12% over the age of 65 years
Persons with Disability
8% of total County population include persons with a disability
or 237,000 residents
Of the population 65 years and over, almost one-third (32%)
persons with disability
14-195
Source: American Community Survey 2009-2013
Anaheim
Anaheim Assembly Hall, Downtown
Tuesday Anaheim Community Center
Sept. 22 250 E. Center St., Anaheim
Tustin
Professional Training Center,
7Fe
Tustin Library
Tu st i n 345 E. Main St., Tustin
Wednesday
Sept. 23
Fountain Valley
Regional City Hall Council Chambers
10200 Slater Ave., Fountain Valley
Santa Ana
Santa Ana Police Community Rm.
® 60 Civic Center Plaza, Santa Ana
Santa Ana Fountain
Valley Lake Forest
Wednesday Thursday City Hall, Community Rm.
Sept. 30 Sept. 24 25550 Commercentre Dr., Lake
Forest
14-196
■ Key Questions of the Survey
Have you encountered discrimination?
Who discriminated against you?
Where did the discrimination occur?
What was the basis for the discrimination?
Did you report the incident?
Have you been denied "reasonable accommodation"?
How well inform are you on your fair housing rights?
What would you do if you encounter discrimination?
Do you believe housing discrimination occurs in Orange County?
14-197
Online Fair Housing Survey on City Websites
English: https://www.surveymonkey.com/r/OC-AI16CitiesSurveV ENGLISH
Spanish: https://www.surveymonkey.com/r/OC-AI16CitiesSurveV SPANISH
Vietnamese: https://www.surveymonkey.com/r/OC-Al16CitiesSurveV VIETNAMESE
Korean: https://www.surveymonkey.com/r/OC-AI16CitiesSurveV KOREAN
Hardcopy Fair Housing Survey
City Halls and libraries
Mailed to housing and social service providers
County Fair Housing Workshops
14-198
M
Outreach
Effort
Community
Outreach
Notices
01
M
Workshops:
9/22 Anaheim
9/23 Tustin
9/24 Fountain
Valley
9/30 Santa Ana
10/1 Lake
Forest
Needs Surveys
Ci
M
M
Working
Draft Al
Results of Group
available
» Workshops Study
at City
Halls
» Public
and Needs Session on
libraries
Hearings
Survey Screen
and City
Draft Al
Websites
i � �
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■ What are the Most Important Fair Housing
Issues and Needs?
■ What Actions can the City, Fair Housing Service
Providers, and Community Stakeholders Pursue
to Address These Fair Housing Needs?
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■ Provide programs and services for the elimination
of discrimination, general housing (tenants and
landlords) service and education to cities
Fair Housing Foundation (800) 446-3247
Housing service to Anaheim, Buena Park, Costa Mesa,
Fullerton, Garden Grove, Huntington Beach, Mission Viejo,
Newport Beach, Orange, San Clemente, and Tustin
Fair Housing Council of Orange County
(714) 569-0823
Housing service to Fountain Valley, La Habra, Lake Forest,
Rancho Santa Margarita, and Santa Ana
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If you have additional questions or comments
after this workshop, please contact:
John Oshirno or Robert Vasquez
GRC Associates
626-331-6373 or
bshimo
frcassoc. com
rvasquez pgrcassoc. com
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Appendix A-1
Compiled List of Workshop Outreach from 16 cities
City of Anaheim
All Workshop Outreach_FY 15/16 HUD Subrecipients
Allyson Crosby
acrosby@ifhomeless.org
Alycia Capone
alycia.capone@pathwaysofhope.us
Ann Trovada
atrovada@anaheimymca.org
Ashley Spindler
aspindler@lestonnacfreeclinic.org
Audrey Mcintosh
meg@grandmashouseofhope.org
Barbara Jennings
Barbara.Jennings@pathwaysofhope.us
Bradford Jones
dmassethjones@ywcanoc.org
Bradford Jones
dmassethjones@yweanoc.org
Bryon Reliford
breliford@anaheimymca.org
Carol Anne Williams
carol@intervalhouse.org
Carol McKinny
cmckinney@mariposacenter.org
Cyndee Albertson
Cyndee@ThomasHouseShelter.org
Diana Meier
dmeier@ocasf.org
Diana Stalter
dstalter@healinghomelessness.org
Diane Messeth-Jones
DianeMassethjones@ywcanoc.org
Dr. Brad Fieldhouse
bfieldhouse@citynet.org
Dr. Cynthia Smith, MT -BC
creativeidentityanaheim@yahoo.com
Dr. Krista Driver, LMFT
kdriver@mariposacenter.org
Evette Nadolny
enadolny@anaheimymca.org
Gracelene Gracia
ggracia@anaheimymca.org
Janeth Velazquez
jvelazquez@seniorserv.org
John Kim
jkim@ifhomeless.org
John Machiaverna
jmac@theboysandgirlsclub.org
Julie Durte
jduarte@acacia-services.ort
Karen B. Williams
kwilliams@211oc.org
Kathleen Weidner
kweidner@coaoc.org
Laura Bates
laura.bates@learninglight.org
Mailory Vega
mvega@acacia-services.org
Maria Mazzenga-Avellaneda
maria.mazzenga@pathwaysofthope.uc
Marytza Rubio
MRubio@ifhomeless.org
Mayra Mejia Gille
mmejia@211oc.org
Megan Hartman
MHartman@bigbrooc.org
Michael Baker
mike@theboysandgirlsclub.org
Michael Shephard
michael@grandmashouseofhope.org
Michaela Lemelin
Michaela.lemelin@learninglight.org
Nahla Kayali
nkayali@accesscal.org
Odezza Larida
odezza@grandmashouseofhope.org
Paul Cho
PCho@ifhomeless.org
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Penelope Agosta
penelope@hope4arts.org
Philip Yaeger
pyaeger@acasf.org
Ray Harper
rharper@coaoc.org
Roseann Peters
rpeters@lestonnacfreeclinic.org
Sharon Wie
accounting@intervalhouse.org
Sofia Burns
sburns@211oc.org
Suhail Mulla
smulla@accesscal.org
Susan Contreras
scontreras@mariposacenter.org
SuzAnne Mathai
smathai@hopeu.org
Tatiana Caicedo
tcaicedo@seniorserv.org
Willian O'Connell
coletteschildren@aol.com
City of Buena Park
Al Workshop mailing list/Outreach Summary
The City of Buena Park used the non-profit lists from their Finance Department's Business License
Division. The City mailed out approximately 25 from the list and 6 were returned as no longer in
business. Additionally, the City sent out the survey to six of their CDBG subrecipients. To the City's
knowledge, two of the subrecipients replied. Additionally, the City posted the survey on their website.
City of Costa Mesa
Meeting/Survey Distribution
Mercy House Transitional Living Center — Homeless/at risk
Fair Housing Foundation — Landlord and Tenants
City of Costa Mesa Senior Center — Seniors
Elwyn California — Disabled Adults
Project Independence — Disabled Adults
Alzheimer's Family Services Center — Adults with dementia
Community SeniorSery - Seniors
Women Helping Women — Low/Mod and homeless persons
Serving People In Need — Homeless/substance recovery
Council on Aging, Orange County — Seniors living in managed care
Orange Coast Interfaith Shelter — Homeless families
Human Options — Victims of domestic violence
Working Wardrobes — Low/mod and homeless persons
Families Forward — Homeless and at risk families
Colette's Children's Home —Transitional housing
City of Costa Mesa website
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City of Fountain Valley
Community Care Health Centers
Council on Aging of Orange Co
Community Senior Sery
Women's Transitional Living Center
Fair Housing Council of Orange Co
Wico Dinro
Better Vision for Children
Assistance League of Garden Grove
Mercy House
Homeless Veterans Outreach
Sweet Success Ext Program SSEP
City of Fullerton
Boys & Girls Clubs of Huntington Valley
Interval House Crisis Shelters
Alzheimer's Family Services
Community Service Programs
California Elwyn, Inc
nART
2-1-1
Lutheran Program
Supreme Court OC/Central Justice Ctr
Mental Health Association of Orange Co
Fair Housing Foundation
Mailed notices to over 600 community groups and multi -family apartments (including the City's 17
affordable housing projects) and management companies. Placed a community meeting notice in the
local paper (Fullerton News Tribune) in the September 10, 2015 edition. Noticed on the City's website
homepage including a direct link to survey money.
City of Garden Grove
Agency contact list:
Mercy House
Assistance League of Garden Grove
Fair Housing Foundation
College of Optometry
Interval House
HPP Cares
Child Abuse Prevention Center
Thomas House
Mental Health Assoc. of Orange County
Dayle Macintosh Center
Community SeniorSery
Fletcher House, DBA Halfway Homes
Legal Aid Society of Orange County
Rebuilding Together O.C.
H.0.P.E.
Orange County Superior Court, Central Justice Center
Hospital Assoc. of Southern California
OC Partnership
Family Support Network
Women's Transitional Living Center
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Illumination Foundation
Jamboree Housing Corporation (CHDO — Non Profit Developer)
Veterans First
Acacia Adult Day Services
AIDS Services Foundation
Jamboree Housing
International Crusade of the Penny
American Lung Association
Lutheran Social Services of So. Cal.
Breast Cancer Angels
Illumination Foundation
Public Law Center
Community Health Care Centers
Interval House
Garden Grove United Methodist Church
The Syriac Charitable Society of America
American Family Housing
Vietnamese Community of Orange County
Boat People SOS
Salvation Renovation
St. Anselm Cross Cultural Community Center
211 Orange County
Colette's Children's Home
Workshop invitations to 80 property managers of apartment buildings in Garden Grove
and invited City's 7 NI Commissioners.
City of La Habra
Delivered or placed the flyers in all of the following places:
1. City's website
2. Community Services Center which provides notification of City Events to: Community Groups, Block
Clubs, Faith -Based and Social Organizations
3. City Hall — Public Counters
4. Public Library
5. Community Services Commission members
6. City Council members
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City of Lake Forest
For the Al Workshop, city advertised it via our monthly electronic newsletter, on our website, and emails
to our subrecipients and local non -profits. The surveys and meeting notice (in different languages) was
sent to the following agencies. Also, the City posted notice and links to survey/meeting notice on the
City's website and the City's Econ Dev website. Additionally, info was sent via e -newsletter to
approximately 4,000 businesses in the City.
Saddleback Valley Unified School District
Childcare services
Vocational Visons
Disabled services
Human Options
Domestic violence services
Families Forward
Low/Mod & at -risk families services
Age Well Senior Services
Senior services
Camino Health Center
Health care services
Boys & Girls Club of Laguna Beach
Youth services
South County Outreach
Low/Mod & at -risk families services
City of Mission Viejo
Vocational Visions
Disabled Services
Age Well Senior Services
Senior Services
Camino Health Center
Health Care Services
Saddleback Valley USD
Childcare Services
Families Forward
L/M Services
South County Outreach
L/M Services
Council on Aging - OC
Senior Services
Birth Choice Health Clinic
Health Care Services
Fair Housing Foundation
Fair Housing Services
City of Newport Beach
The City published the attached flyer approximately 10 days in advance of the first community meeting
in the Daily Pilot, a newspaper of general circulation in the Costa Mesa and Newport Beach area. The
flyer was also emailed to a community interest email list with over 700 email addresses for residents,
businesses and other community stakeholders.
City of Rancho Santa Margarita
Information regarding Fair Housing Survey and Al workshops was emailed to current and past public
service grant recipients — see list below:
Vocational Visions
South County Outreach
Laura's House
Families Forward
Dayle McIntosh
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Age Well
Santiago Seniors Club
Saddleback Valley Unified School District
City of San Clemente
Advertised on the City's homepage and we passed out flyers/surveys at the Boys and Girls Club, all
public schools, ten churches, library, City Hall, and social service providers including Family Assistance
Ministries and OC Human Relations.
City of Santa Ana
The City posted workshop flyers and surveys on the City's website, released an email notification to
approximately 14,339 subscribers of the City's Nixle notification system
(https://local.nixle.com/alert/5499002/), and emailed information to local community centers and
nonprofits.
Flyer and Surveys distributed through:
Santa Ana Housing Authority
Santa Ana WORK Center
Santa Ana Public Library
Santa Ana Senior Center
Santa Ana South West Senior Center
Santa Ana Police Athletic and Activities League
Santa Ana Youth Council
Garfield Community Center
Fair Housing Council of Orange County
America on Track
Boys and Girls Club of Santa Ana
Community SeniorSery
Council on Aging
Delhi Center
Human Options
KidWORKS
Public Law Center
Orange County Children's Therapeutic Arts Center
The Cambodian Family
WISE Place
City of Tustin
Mailed flyers to over 80 agencies and 400 property managers/realtors.
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Appendix A-1
Public Comments
For
Fair Housing Workshops
Analysis Of Impediments — Group Of 16 Orange County Cities
14-209
Public Fair Housing Workshop # 1
Northern Orange County Subregion: Anaheim, Buena Park, Fullerton, La Habra
September 22, 2015 - 6:00 to 7:30 pm
City of Anaheim Assembly Hall - Community Center
Public Comments
• Who can educate property managers/leasing agents about fair housing issues? (The
Orange County Fair Housing Council and the Fair Housing Foundation both provide these
services. Each city contracts with one of these fair housing providers).
• Spanish-speaking resident brought up her situation about landlord that may be
discriminating against large families. (She took various copies of Spanish fair housing
survey and said she would ask residents in her apartment complex to complete).
• Concerns about housing affordability were brought up by resident.
• Question about how property managers can be tracked.
• Concern over current, very high rents. Landlords are asking for $1,450 for a two-
bedroom unit that was recently rented at $1,200 for the same unit.
• It is not possible for some residents on Social Security to qualify for apartments now
because property owners are requiring them to earn 2, or 2.5 times the income as
compared to their required rent
• Workshop participant wanted to get a copy of the actions required in the Al for the
previous Al five years ago. (2010-2015 Orange County Regional Al with actions is
available on-line @ http://www.newportbeachca.gov/home/showdocument?id=10768
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Public Fair Housing Workshop # 2
Central Orange County Subregion: Garden Grove, Orange, Santa Ana, Tustin
September 23, 2015 - 6:00 to 7:30 pm
City of Tustin Library — Professional Training Center
Public Comments
• Can property owners discriminate against anyone? For example, can owners limit
people renting a room in their homes to single women only?
• Various issues regarding housing affordability were raised. Resident stated that some
housing complexes that are "affordable" have asking rents that are nearly the same as
non -restricted, market rate housing.
• There is a lack of housing opportunities for disabled people.
• Rents are increasing quickly and there are no vacancies. A property manager from
Tustin Villas said that she takes a monthly survey of rents of nearby apartment
complexes and all are 100% occupied and rents are increasing. Currently asking $1,600
to $1,800 per month for a 2 -Bedroom, $1,395 to $1,420 for a 1 -Bedroom unit and a
studio is going for $1,295 per month. Rents are being paid on time and the waiting list is
"real".
Comment was made that "strawberry pickers" or seasonal farm workers are crowding
into some units, with two or three families per apartment unit.
Overcrowding was discussed at length. Residents wanted to know how to address this
big issue. Property manager mentioned that the key is to have good on-site
management.
A resident brought up question about what can be done for veterans regarding housing
options. Some of the responses included that there were specific mortgages for
veterans, housing complexes targeting veterans, programs by HUD (HUD-VASH)
specifically for veterans, programs to assist homeless veterans and specific local projects
for veterans were identified (Village of Hope).
Services of the Fair Housing Council of OC were presented and referral information
provided to workshop participants.
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Public Fair Housing Workshop # 3
Western Orange County Subregion: Costa Mesa, Fountain Valley, Huntington Beach,
Newport Beach
September 24, 2015 - 6:00 to 7:30 pm
Fountain Valley City Hall, Council Chambers
Public Comments
• Comments were made that residents do not know who to call about discrimination
issues.
• Some residents do not know they are being discriminated against and it was
commented that lack of education on housing discrimination may be an impediment.
• Workshop attendees were informed that City websites have information on housing
programs and resources that may be useful. Some cities, like Huntington Beach, also
provide information on housing resources available through Orange County.
• A comment was made about how some struggling people do not have good access to
computers, may have issues with literacy, and face other barriers which limit their
access to housing resources. Many are close to being homeless once they have dropped
down various rungs on the housing/economic ladder.
• There is not enough funding to help everyone.
• Some cities have walk-in hours open to the public for fair housing assistance scheduled
each month at their city halls.
• Some cities, like Fountain Valley, have programs to help residents purchase a home.
Education on the buying process is necessary for many.
• Housing affordability issue was brought up. Cities would prefer to have affordable units
mixed in with market rate units.
• Retired police officer who is now volunteering with a non-profit property management
group explained her organization's goals. In essence, they want to expand to other
areas (North OC and others). She also stated that the biggest housing needs that her
non-profit is noticing are housing for seniors and single parents.
• Resident requested PowerPoint presentation available and it was agreed that it would
be put on website in the near future.
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Public Fair Housing Workshop # 4
City of Santa Ana
September 30, 2015 - 6:00 to 7:30 pm
Santa Ana Police Community Room
Public Comments
• A resident said that there was discrimination against families with children. Asked who
could be contacted regarding specific issues. (Referred to Fair Housing Council of Orange
County. Three staff from the Fair Housing Council were present at the workshop).
• Person discussed situation where families with disabled children have difficulties finding
apartments that do not have stairs.
• Some attendees were unclear which classes of people were protected against
discrimination.
• Seniors have a difficult time finding housing they can afford as rents are too high
relative to their fixed incomes.
• Single parent families have a hard time finding housing.
• Disabled seniors (wheelchair bound) do not know where to obtain housing.
• Affordable housing is a major issue in Santa Ana and Orange County as a whole. (Issue
was raised numerous times)
• Residents discussed that they do not know where to go with discrimination problems.
• Resident asked about specific things that Fair Housing Council can do to help, and if they
offered legal services.
• Some said that residents need help with foreclosure situation.
• Some residents feel overwhelmed by the documentation required by landlords to rent
an apartment.
• The need for educational workshops on fair housing was brought up by a resident.
• There is the need to properly notify the public about the importance of housing
workshops. (Consultant responded that the Fair Housing Council offers
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workshops/services and let the attendees know that there were representatives from
Fair Housing present at this public workshop meeting.)
• Resident asked about programs to assist them in their housing needs. (They were
informed that cities have rehab programs and that they can find specific information on
the cities' websites).
• Some landlords now have waiting lists for rental units. A resident commented that she
would like to see the specific waiting list information as she thinks the waiting list is
used to exclude applicants.
• A resident asked if Al report will cover the need for additional housing. (She was
informed that other documents address this specific information- the cities' Housing
Elements, Consolidated Plans, etc.)
• A question was asked about the draft Al being available for public review. (The draft Al
will be made available on city websites and in hard copy at City Halls).
• Landlord requirements that were onerous to some tenants came up.
• Non-profit property manager mentioned that some tenants break rules (pets,
overcrowding and others) and then expect owners not to enforce rules.
• Non-profit property manager said survey was one sided towards tenants and that
landlords also have rights.
• The services of both the Fair Housing Council of Orange County, and the Fair Housing
Foundation are important in Santa Ana to provide residents and landlords more
choice/help with housing issues.
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Public Fair Housing Workshop # 5
Southern Orange County Subregion: Lake Forest, Mission Viejo, Rancho
Santa Margarita, San Clemente
October 1, 2015 - 6:00 to 7:30 pm
Lake Forest City Hall — Community Room
Public Comments
• Motel Issue: Many residents use motels as apartments. In Costa Mesa there are various
motels that are being converted to luxury condominiums. Does the Al report address
motels? (Other related reports, such as Housing Element address motel conversion
issue).
• Since apartment vacancies are so low, several attendees questioned if perhaps landlords
were being too picky to the point of discrimination.
• If tenants discover they are being discriminated against — can they go to the police?
• There were 35 written surveys completed in San Clemente that were submitted at this
public workshop.
• There were questions about how the Al will be implemented, and if 16 individual
reports would be completed or one regional report.
• One of the goals of the Al Report is to show progress. A resident asked if a city has a
poor record of addressing housing discrimination, is it possible to assess progress before
the end of the five year period. (Resident was informed that policies/actions would be
addressed prior to the five year period, since many of these policies are also in the
Housing Element. There is a yearly Action Plan, also CAPER, Consolidated Plan and other
reports required by HUD that would ensure that there would be close scrutiny on cities'
housing activities. If a city does not make the needed corrections, they may lose HUD
funding. All cities have the similar goal to provide fair housing to all).
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Appendix A-2
Fair Housing Survey for Orange County Residents
A group of 16 Orange County cities' is conducting a study to evaluate fair housing conditions in
their communities, and is interested in gathering information from residents on any experience
they may have had with housing discrimination. Your input is greatly needed to provide a clear
picture of the situation within these areas, which will in turn assist the group in developing a plan
to improve equal and fair housing choice for all residents. Please take a few minutes to fill out
this survey. Your answers will be kept confidential. You can also respond to the survey on-line at
https://www.surveymonkey.com/r/OC-AI16CitiesSurvey ENGLISH. For additional information,
please contact: Robert G. Vasquez, GRC Associates, Inc., (626) 331-6373,
rvasquez@grcassoc.com.
1. Please identify the ZIP code of your residence.
2. Have you ever encountered any form of housing
discrimination in one of the 16 Orange County cities?
O YES City name
O NO
O NOT SURE
(If YES or NOT SURE, proceed to questions 3-7.
If NO, skip to question 8)
3. If yes, which of the following best describes the
person responsible for discriminating against you?
O A landlord/property manager
O A real estate agent
O A lending institution
O A City staff person
O Other:
Examples of discrimination include:
➢ A rental advertisement that says,
"Perfect for couples or singles without
children" or "No Pets" without an
exception for service animals.
➢ A real estate agent "steers" you to
houses in neighborhoods different
than the ones you have requested and
think you can afford.
Y A landlord refuses to let you install a
ramp in your shower (at your own
expense) to accommodate your
disability.
4. Which of the following best describes the location where the act of discrimination occurred?
O An apartment complex O A trailer or mobile home park
O A single-family neighborhood O A subsidized housing project
O A condominium development O When applying for City programs
O When applying for a loan
5. Please explain how you believe you were discriminated against.
1 The following 16 cities are participating in the regional Analysis of Impediments to Fair Housing Choice: Anaheim,
Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, La Habra, Lake Forest,
Mission Viejo, Orange, Newport Beach, Rancho Santa Margarita, San Clemente, Santa Ana, and Tustin.
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6. On what basis do you believe you were discriminated against? Check all that apply.-
0
pply.
O
Race
O Disability
O
Color
O Ancestry
O
National Origin
O Sexual Orientation
O
Gender
O Marital Status
O
Age
O Source of Income (i.e. welfare)
O
Religion
O Other:
O
Family Status (e.g. due to children)
Z Did
you report the incident?
O
YES - If Yes, who did you contact?
O
NO - If No, why not?
O Don't know where to report
O Afraid of retaliation
O Too much trouble
O Don't believe it makes any difference
O Other:
8. Have you ever been denied "reasonable accommodation" (flexibility) in rules, policies, or
practices that you required to accommodate a disability related to housing?
O YES
O NO
If YES, what was your request?
9. How well informed do you feel yourself to be about housing discrimination laws?
O Very well informed O A little informed
O Somewhat informed O Not informed at all
10. What would you do if you encountered housing discrimination?
O Tell the person you believe they are discriminating O Report it
O Do nothing and seek other housing options O Wouldn't know what to do
11. Do you believe there is housing discrimination occurring in Orange County and, if so,
what types of discrimination problems do you think are the worst?
Your input is greatly appreciated!
Please return the survey by October 15, 2015 to:
Robert G. Vasquez, GRC Associates, Inc., 858 Oak Park Road, Suite 280, Covina, CA 91724
(626) 331-6373 (phone), (626) 331-6375 (fax), rvasquez@grcassoc.com
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Appendix A-2
Encuesta de Vivienda Justa para los Residentes del Condado de Orange
Un grupo de 16 ciudades del Condado de Orange' esta Ilevando a cabo un estudio para evaluar las
condiciones de equidad de vivienda en sus comunidades y estan interesados en recompilar informacion
de los residentes acerca de cualquier experiencia discriminatoria que hayan tenido relacionada con
viviendas. Su ayuda es necesaria para proporcionar una imagen clara de la situacion dentro de estas
areas, que a su vez ayudara al grupo en el desarrollo de un plan para mejorar la eleccion justa y
equitativa de viviendas para todos los residentes. Por favor tome unos minutos para Ilenar esta
encuesta. Sus respuestas seran confidenciales. Tambien puede responder a la encuesta en linea en el
sitio web https://www.surveymonkey.com/r/OC-Al16CitiesSurvey SPANISH. Para obtener
informacion adicional, por favor pongase en contacto con Robert G. Vasquez, GRC Associates, Inc.,
(626) 331-6373, rvasquez@grcassoc.com.
1. Por. favor identifique el codigo postal de su hogar.
2
2. Aiguna vez ha tenido alguna forma de discriminacion de
viviendas en una de las 16 ciudades del Condado de Orange?
0 Si Nombre de Ciudad
0 NO
0 NO ESTOY SEGURO(A)
(Si "SI" o "NO ESTOY SEGURO(A)", continue con las
preguntas 3-7. Si "NO", pase a la pregunta 8)
2
3. En caso afirmativo, cual de las siguientes opciones describe
mejor la persona responsable de discriminar en contra de
usted?
0 Un administrador o manejador de la propiedad
0 Un agente de buenas raices
0 Una institucion de credito
0 Personal de Ciudad
0 Otro:
Ejemplos de discriminaci6n incluyen:
➢ Un anuncio de alquiler que dice,
"Perfecto para parejas o solteros sin
hijos " o " no mascotas", sin una
excepcion para los animales de
servicio.
➢ Un agente de bienes raices que to
"dirige" a casas en barrios diferentes
que las que usted habia requerido y
podria pagar.
➢ Un propietario le niega a usted de
instalar una rampa en el baro (a su
propio costo) para ayudarle con su
discapacidad.
2
4. Cual de las siguientes opciones describe mejor el lugar donde ocurrio el acto de discriminacidn?
0 Un apartamento 0 Un Remolque o complejo de casas moviles
0 Un barrio de casas 0 Un complejo de viviendas subsidiadas
0 Un proyecto de condominios 0 Al solicitar programas de la Ciudad
0 Al solicitar un prestamo
5. Por favor, explique cdmo usted cree que fue discriminado:
1 Las siguientes 16 ciudades estan participando en un estudio, el Analisis Regional de los Impedimentos para
la Justa Seleccion de Viviendas: Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden
Grove, Huntington Beach, La Habra, Lake Forest, Mission Viejo, Orange, Newport Beach, Rancho Santa
Margarita, San Clemente, Santa Ana, and Tustin.
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z
6. Sobre que base usted cree que fue discriminado? Marque todo to que corresponda:
0 Raza 0 Discapacidad
0 Color 0 Linaje
0 Origen Nacional 0 Orientacion Sexual
0 Genero 0 Estado Civil (Matrimonio)
0 Edad 0 Fuente de ingresos (ejemplo el
0 Religion bienestar)
0 Estado Familiar (e.g. debido a los ninos) 0 Otro:
2
7. Denuncio o reporto el incidente??
0 SI — En caso afirmativo, ?A quien contacto?
0 NO — En caso negativo, Por que no?
0 No sabia a quien contactar 0 Miedo de represalia
0 Demasiados problemas 0 No crei que haria ninguna diferencia
0 Otro:
2
S. Alguna vez se le ha negado " ajustes razonables " (flexibilidad) en las reglas, politicas, o pr6cticas que se
requieren para dar cabida a una discapacidad de usted relacionada con viviendas?
0 SI
0 NO 7
Si afirmativo, cual era su peticion?
9. Que tan bien informado to sientes a ti mismo ser acerca de las leyes de discriminacion de vivienda?
0 Muy bien informado 0 Informado un poco
0 Algo informado 0 No informado en ninguna manera
10. Que haria usted si usted encontrara discriminacion de viviendas?
0 Le diria a la persona que yo creo que ellos estan discriminando 0 Reportarlo
0 No haria nada y buscaria otras opciones de viviendas 0 No sabria que hacer
11. tree usted que est6 ocurriendo discriminacion de viviendas en el Condado de Orange y, si es asi, que
dpos de problemas de discriminacion cree usted que son los peores?
Sus respuestas son muy apreciadas!
Por favor devuelva esta encuesta para el 15 de Octubre de 2015 para:
Robert G. Vasquez, GRC Associates, Inc., 858 Oak Park Road, Suite 280, Covina, CA 91724
(626) 331-6373 (phone), (626) 331-6375 (fax), rvasquez@grcassoc.com
14-219
Appendix A-2
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Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, La
Habra, Lake Forest, Mission Viejo, Orange, Newport Beach, Rancho Santa Margarita, San Clemente,
Santa Ana, and Tustin.
14-220
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[HoH CHEEoI o'Af=d'LICH.
2015 vA 10 iz 15 ' Oil 14 p 3'--A}-Kik V-4 - �' Al —0:
Robert G. Vasquez, GRC Associates, Inc., 858 Oak Park Road, Suite 280, Covina, CA 91724
(626) 331-6373 (phone), (626) 331-6375 (fax), rvasquez@grcassoc.com
14-221
Appendix A-2
Khao Sat Ve Cong Bang Gia Cu' Cho Cu' Dan Orange County
Mub'i sau thanh pho trong Quan Cam' (Orange County) dang titin hanh mot cuoc khao sat de tim Neu ve
van de tong bang gia cLr (fair housing) trong tong long. Cac vien chk c6a cuoc khao sat se thu thap
thong tin c6a cu• dan lien quan den viec ky thi trong van de nha 6. Chung toi rat can cac y kien d6ng g6p
c6a quy vi de tim Neu them van de nay, tU d6 ho tra cho cac thanh pho phac thao ke hoach cai titin
quyen binh dang va tong bang ve nha & cho cu' da"n. Xin vui Ibng danh ra vai phut de lien vao ban khao
sat dLr&i day. Cau tra V c6a quy vi se du'ac giix kin. Quy vi cung c6 the lien vao ban khao sat tren mang
tai dia chi: https://www.surveymonkey.com/r/OC-Al16CitiesSurvey VIETNAMESE. Won biet them chi
tiet, Anlien lac: Robert G. Vasquez, GRC Associates, Inc., (626) 331-6373, rvasquez@grcassoc.com.
1. Cho biet ma so vung noxi cu' ngu c6a quj vi (ZIP Code).
2. Cd bao gi& quj vi bi ky thi ve nhd 6,tai mot trong 16
thdnh pho 6, Orange County?
O CO Ten thanh pho"
O KHONG
O KHONG CHAC
(Neu cau tra lai la CO hoac KHONG CHAC,
tra IM tiep tU cau 3 den cau 7. Neu cau tra
IM la KHONG, tiep tuc tra lai cau so 8)
3. Ne -u da tirng bi kk th% quk vi nghT rang nhirng
ngLrai/cling ty/to chtrc ndo dir&i d6y da kk thi quk vi?
O Chu nha /ngLfdi quan ly khu gia cu' (property
manager)
O Chuyen vien dia oc
O Nai cho vay na
O Nhan vien Thanh Pho
O NgLrai/cong ty/to chtk khong de cap & tren:
4. Viet kk thi da dien ra tai dia die"'m ndo dudi day?
O Khu chung cLr
O Khu nha dun (single-family neighborhood)
O Khu nha condo
O Khi quy vi nop dun xin vay mot khoan nor
5. Giai thich tai sao quj vi tin rang minh da bi kk thi:
Vi du ve phan biet d6i xir bao gom:
➢ Mau rao vat ghi: "Thich hap cho va
thong hoac ngLr&i doc than khong co
con nh6" hoac "Khong nhan thu nu6i"
Mau rao vat khong de cap den trLr&ng
hap ngoai le cho phep cac loai cho
giup da cho ngLr&i tan tat (service
animals).
➢ Chuyen vien dia oc ter chuyen hu'ang
kiem nha cua quy vi sang mot khu vu'c
khac - khong phai khu vLrc ma quy vi
yeu cau. Chuyen vien dia oc nghT rang
b khu vuc khac quy vi moi co kha nang
tai chinh de mua nha.
➢ Chu nha tU cho "i khong cho phep quy
vi, ngLrai bi tan tat, lap dat "ramp"
trong phbng tam (v&i chi phi do quy vi
ter tra). ["Ramp" - tam not 2 vi tri vai
2 do cao khac nhau, giup ngLr&i tan tat
di chuyen de clang -]
O Khu mobile home/trailer
O Trong mot chLrang trinh tra cap gia cu'
O Khi quy vi nop dun cho mot chLrang trinh c6a
Thanh Pho
(1) Danh sach 16 thanh pho tham gia cuoc khao sat ve cong bang gia cir Analysis of Impediments to Fair Housing Choice:
Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, La Habra, Lake
Forest, Mission Viejo, Orange, Newport Beach, Rancho Santa Margarita, San Clemente, Santa Ana, and Tustin.
14-222
6. Quy vi nghi rang minh dd bi kk thi b6,i yeu to neto dLr6,i day? Danh ddu veto tdt ca nhCrng yeu to ma
quy vi cho la bi kk thi:
0 Chungtoc
0 Mau da
0 Qu6c gia
0 Giai tinh
0 Tubi tac
0 Ton giao
0 Tinh trang gia dinh (vi du: do co con nh6)
0 Tan tat
0 To titin
0 Xu hLrang tinh duc (Sexual Orientation)
0 Tinh trang hon nhan
0 Ngu6n lai Uuc (vi du: do lanh try cap xa h6i)
0 Bi ky thi b&i cac yeu to khac, ghi ra:
7. Quy vi co bao cao trirang hap bi kk thi khong?
O CO — Neu CO, quy vi bio cao cho ai?
0 KHONG — Neu KHONG, tai sao khong bio cao?
0 Kh6ng biet bao cao cho ai? 0 Lo sq bi tra thu
0 Cam thay phien phLrc qua 0 Cho rang bao cao cung kh6ng lam du'ac gi
0 Ly do khac:
8. Co bao gia quy vi bi tir chdi khong du'ac "Trg, Giup Hap Ly" ("Reasonable Accommodation") —
Reasonable Accommodation let mot su' uye'n chuye'n vet thay ddi ve chinh sach, luat le, quy dinh
nham giup cho ngu'6,i bi tetn tat hu'odng du'ac quyen loi tong bang ve gia cu:
O CO
0 KHONG
Neu CO, de nghi An try pup cua quy vi la gi?
9. Quy vi nghi rang minh dd du'oc thong bao ve cac luat lien quan den vdn de kk thi gia cu' 6, muc
neto?
0 Dayc th6ng bao day du 0 Du'gc thong bao khong day du
0 Duyc thong bao rat it 0 Kh6ng ducc thong bio
10. Quy vi se lam gi neu bi ky thi ve nhet 6,?
0 Cho ngLr&i d6 biet ho Bang ky thi minh 0 Bao cao
0 Kh6ng lam gi ca, di kiem nha khac 0 Kh6ng biet phai lam gi
11. Quy vi co nghi rang co tinh trang kk thi gia cLr tai Orange County. Neu co, theo quy vi, hinh thirc kk
thi nbo Id toi to nhdt?
Cam an quy vi da danh thi gia cho cuoc khao sat nay!
Vui long g&i lai ban khao sat truck ngay 15 thang Mueyi, 2015 cho chung t6i den dia chi sau:
Robert G. Vasquez, GRC Associates, Inc., 858 Oak Park Road, Suite 280, Covina, CA 91724
14-223
r,rbidi
•.
LA
HABRA
BUENA
PARK FULLERTON
f ANAHEIM 1�
F
ORANGE
t
gEN
N E VkPORT
BEACH
Fair Housing
Survey Results
/ LAKE
FCRES
IISSION
VIEJO
RANCHO
SANTA
MARGARITA
SAN
MENTE
14-224
Total
English
Spanish
Vietnamese
Korean
188
76
110
2
0
•
Top 10 Zip Codes
of Respondents' Residences
Num.
Zip Code
#
1
92701
54
2
92672
23
3
92703
19
4
92706
13
5
92673
9
6
92705
9
7
92704
7
8
92707
7
9
92708
6
10
92801
4
Total
151
82%
14-225
14-226
Total %
Total
English
Spanish
Vietnamese
36.3%
66
39
27
0
NO
7.1%
13
9
4
0
NOT SURE
56.6%
103
25
77
1
ES
100.0%
182
73
108
1
Total
14-226
14-227
Total %
Total
English
Spanish
Vietnamese
landlord/property
87.5%
98
30
67
1
manager
real estate agent
5.4%
6
0
6
0
lending institution
1.8%
2
0
2
0
City staff person
1.8%
2
1
1
0
Other:
3.6%
4
1
3
0
�otal
100.0%
112
321
791
1
14-227
Options
Total %
Response
English
Spanish
Vietnamese
Count
80.2%
89
23
66
0
An apartment complex
10.8%
12
7
5
0
single-family neighborhood
0.9%
1
1
0
0
condominium development
1.8%
2
0
2
0
When applying for a loan
4.5%
5
1
3
1
trailer or mobile home park
0.0%
0
0
0
0
subsidized housing project
1.8%
2
1
1
0
When applying for City programs
100.0%
111
33
77
1
�otal
14-228
14-229
j
Total
English
Spanish
Vietnamese
105
Answered question
27
77
1
83
Skipped question
49
33
1
188
Total
76
110
2
14-229
j
Options
Total %
Response
Count
English
Spanish
Vietnamese
Race
42.9%
48
13
34
1
Color
29.5%
33
5
28
0
National Origin
35.7%
40
4
35
1
Gender
13.4%
15
4
11
0
Age
4.5%
5
2
3
0
Religion
0.0%
0
0
0
0
Family Status (e.g. due to
children
50.9%
57
12
45
0
Disability
12.5%
14
4
10
0
ncestr
0.9%
1
1
0
0
Sexual Orientation
0.9%
1
1
0
0
Marital Status
9.8%
11
2
9
0
Source of Income (i.e.
welfare)
35.7%
40
9
31
0
Other leasespecify)
10.7%
12
9
3
0
Total
112
32
79
1
14-230
14-231
Source: 2007-2011 CHAS
A
Response
Answer
Total %
Count
English
Spanish
Vietnamese
9.2%
10
4
6
0
YES
90.8%
99
29
69
1
NO
100.0%
109
29
69
1
Total
14-231
Source: 2007-2011 CHAS
A
Answer
Total %
Total
English
Spanish
Vietnamese
14.0%
23
8
15
0
ES
86.0%
141
58
82
1
NO
100.0%
164
66
97
1
Tota
14-232
Answer
Total %
Total
English
Spanish
Vietnamese
Very well informed
10.7%
18
16
2
0
Somewhat
15.4%
26
17
9
0
informed
little informed
33.7%
57
16
41
0
Not informed at all
40.2%
68
15
52
1
Tota 1
100.0%
169
64
104
1
14-233
Answer
Total %
Total
English
Spanish
Vietnamese
Tell the person you believe they are
14.6%
24
11
13
0
discriminating
17.7%
29
8
21
0
Do nothing and seek other housing options
34.8%
57
28
29
0
Report it
32.9%
54
16
37
1
Wouldn't know what to do
100.0%
164
63
100
1
�otal
14-234
1
Answer
Total %
Total
English
Spanish
Vietnamese
Answered
76.1 %
143
Question
46
97
0
Skipped Question
23.9%
45
30
13
2
Total
100.0%
188
76
110
2
14-235
14-236
Mm Thu Hai mdoi UI ..
S6 bdo 7643
Thu Ba a-3-16
I a 0 j4rj�����
Th6' nB
g aa .Cong C6.g
16 #hanh P. 6 trong Qufih Cam du' thio phin tich
4 tr4 ngai doi Edi cac Lt>' Cho Ong Bang Gia Ct(
Medi sau ihanh phd Qu4n.Cam da tham:gia trotig du 1h o, pkat trim cac phan
tich.trong gt4n hat cua cac DA Chon &ig-Bing Gia Cir(Al) 16`th nh phi
than] gia bao gbm: :.
Anaheim Huntington Beach. Orange
Buena Park La Habra Rancho.Santa Margarita
CostaMesa Lake Forest Sanclemente
Fountain Valley MissipnViejo Santa Ana
Fullerton. Newport Beach Tustin
Carden Grove
Muc Bich cua hp ghi Al la xa.c M va nh etc tri n aa.tierrt ging 01 0i
icha n ng cua in&t ngoi `dai vdi sit lata c 0 riot cu trig .cua hg m1kh rig cb ski
phan bid Chung tot, va khuy n kb ch nli ing hanh dung nh�.m xac dinh cite tr6
ngai"nay. Dpi Chao Al cung c9p:
1) Mot caM nhin`tdng quit ve lint phap, nh(mg quy Binh, chinh sash va cac
thu tyc hanh;chinh;
2} ;M$t d�nh gid nh�ig'pFiucliig ;each ma lint phap iinh hung den riof chSn,
su sin e6 vel each tip cin gia cit; .
3) :M0 danh gia.Y� cAc dr�u ]air,, cahai khu v�tc cang c9� va i�t�h�n cb
an,huun d,n sr.lichpn c8iag b�bng gia ciz.
Ban sao cua du thio Al Hang co An de cling chGrrg.xein xet'tai Vats Phnng c6
City Clerk tai m8i thanh ph$ c6 tham gia va .tran ming di�ri _tu cda cac thanh
phs d6, C6 thbi giat) 30 ngay de cling chung xem xet lai bin du the o Al. b6.t da.0
W ngay 9 thing 3 va chem &rt vao ngay 7 thing 4, 20,16. Xan qui vi vui l6ng
nop nhCMg ban g6p y:viet tay v$ hAn dot thio Al dente chin GRC Associates;
nhfri g nha hrvan dang'trq giftp c gt.hanh ph6 chuan b}'cfi6 AI'.tai dia chi 'sau
day: .
GRC Associates
8060 Florence Avenue, Suite 303
Downey, CA 90240
Neu quy A cb thac;mk ve Dtr Th o sq
Al, xin gqi Robert Vauez hg6c. John
Oshimo thu¢c GRC Associates tai so di@n"thoai 626-331-6373.
14-237
24 1 LaOphd6n MARTES 8 MARZO 2016
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duct0 0 Servicio.
regulares $180, se
Publicandose en los
trabajan estandar,
Clasificados
Grua Gratis
de
323-231-2786
La Opinion
Avisos Legales
Avisos Legales
Aviso de Opinion Hiblica
16 Ciudades del Condado de Orange
Analisis Regional de Impedimentos
para la Elecci6n Justa de Viviendas
Dieciseis ciudades del Condado de Orange han participado en el desarrollo del analisis regional de
impedimentos para la elecci6n justa de viviendas (AI). Las 16 ciudades participantes incluyen:
Anaheim Huntington Beach Orange
Buena Park La Habra Rancho Santa Margarita
Costa Mesa Lake Forest San Clemente
Fountain Valley Mission Viejo Santa Ana
Fullerton Newport Beach Tustin
Garden Grove
EI objetivo del Al es identificar y evaluar los posibles obstaculos o impedimentos de personas para
elegir sus residencias libre de discriminaci6n, y recomendar acciones que aborden tales impedi-
mentos. EI Al ofrece: 1) una vision general de las leyes, reglamentos, politicas administrativas y
procedimientos; 2) una evaluaci6n de c6mo estas leyes afectan la ubicaci6n, la disponibilidad y
accesibilidad de las viviendas; y 3) una evaluaci6n de las condiciones, tanto p6blicas tomo priva-
das, que afectan a la elecci6n justa de viviendas.
Copias del Borrador Al estan disponibles para consulta p6blica en la Oficina del Secretario de la
Ciudad (Office of the City Clerk) de Cada Ciudad participante y en el sitio web de la Ciudad. EI
periodo de revision p6blica de 30 dias para el Borrador Al comienza 9 de marzo y termina el 7
de abril de 2016. Por favor, envie sus comentarios por escrito sobre el Borrador Al a GRC
Associates, los consultores que asisten a las ciudades para preparar el Al, a la siguiente direction:
GRC Associates
8060 Florence Avenue, Suite 303
Downey, CA 90240
Si tiene alguna pregunta con respecto al Al, por favor Ilame a Roberto G. Vasquez o John Oshimo
de GRC Associates al 626-331-6373.
41DEMPO1 TEM'S
It FUTBOL
D iscusibn sobre C117
ymessi t
tragedia en India
Nigerian de
24 anos es
asesinado
por su amigo
EFE
BOMBAY, INDIA
Un hombre mato a uno de
sus amigos durante una
discusi6n sobre quien es
mejor futbolista, si el por-
tugues Cristiano Ronaldo o
el argentino Lionel Messi,
en la fiesta de cumpleafios
de la victima en la Ciudad
india de Bombay, informo
una fuente policial.
Los dos jovenes, de na-
cionalidad nigeriana, Ile-
vaban desde el sabado ce-
lebrando el 34 cumpleanos
de uno de ellos en su apar-
tamento en Nalasopara, a
las afueras de la metropolis
(oeste), cuando en la mafia-
na del domingo la disputa
sobre las estrellas del Real
Madrid y del FC Barcelo-
na desencadeno la pelea.
WIL
La pasi6n futbolera por Cristiano Ronaldo y Lionel Messi Ileg6
all extremo en India, donde murj6 un joven. /GETTY IMAGES
Segun explico un inspector
La policia lleg6 al lugar tras
de la policia local, Kiran Ka-
ser avisada por los vecinos,
badi, el joven que celebraba
que escucharon la disputa, y
el cumpleafios, identificado
arresto al joven nigeriano por
como Obinna y seguidor de
el cargo de asesinato, conclu-
Ronaldo, lanz6 un vaso con-
yo el agente.
tra el fan de Messi, Nwabu,
El deporte hegem6nico en
de 24 afios, pero fall6 y el ob-
la India es el criquet, aunque
jeto impacto contra la pared.
el n6mero de seguidores del
Entonces el fan del argen-
futbol aumenta alio tras alio
tino agarr6 uno de los cris-
de manera exponencial y el
tales del vaso roto y degollo
interes por las competiciones
a su amigo, que muri6 des-
europeas es masivo. •
angrado en el apartamento.
laopinion.com
Vela se da una
escapadita
Todo sea por ver a Chris
Brown. La Real Sociedad ya
le prepara un expediente
disciplinario a Carlos Vela por
ausentarse del entrenamiento
matutino de ayer. La noche del
domingo, el mexicano realiz6
un viaje relampago a Madrid
para asistir a un concierto de
Brown, cantante de rap. EI
mexicano debia presentarse
ayer por la manana en el
conn lejo deportivo de
Zubieta, donde el equipo
hizo trabajo regenerativo.
De acuerdo a informes,
el delantero mexicano
justific6 su ausencia por una
gastroenteritis. /REFORMA
14-238
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Appendix 6: Public Transit and Major
Employment Centers
APPENDIX
14-239
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Appendix B
Public Transit and Major Employment Centers
LPL q,e SGrtuIly
❑ram)e couty
Top 10 Employment Centers
North
Tustin
APPENDIX B: PUBLIC TRANSIT AND EMPLOYMENT CENTERS
B-1 14-240
Top
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Appendix B
Public Transit and Major Employment Centers
APPENDIX B: PUBLIC TRANSIT AND EMPLOYMENT CENTERS
B-2
14-241
Tol
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Appendix 6
Public Transit and Major Employment Centers
APPENDIX B: PUBLIC TRANSIT AND EMPLOYMENT CENTERS
B-3
14-242
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Appendix B
Public Transit and Major Employment Centers
0
Top 10 Employment Centers
Rancho Santa Margarita
74i,�d
APPENDIX B: PUBLIC TRANSIT AND EMPLOYMENT CENTERS
B-4 14-243
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Appendix C: Mortgage Lending Practices
APPENDIX C-1: Home Purchase Loan Activities 2008-
2013
APPENDIX C-2: Percent Of Denied Purchase Loans - By
Census Tract - Applicant Race/Ethnicity
APPENDIX
C
14-244
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Tustin
Orange County Total
Anaheim
Buena Park
Costa Mesa
Fountain Valley
Fullerton
Garden Grove
Huntington Beach
La Habra
Lake Forest
Mission Viejo
Newport Beach
Orange
Rancho Santa Margarita
San Clemente
Santa Ana
Tustin
Orange County Total
Appendix C-1
Home Purchase Loans - Completed Loan Applications Percent of Total
2008-2013
2008 1 2009 1 2010 1 2011 1 2012 1 2013 1 2008 1 2009 1 2010 1 2011 1 2012 1 2013
35%
34%
34%
35%
34%
37%
1.8%
1.0%
0.7%
1.0%
1.1%
0.8%
26%
27%
23%
28%
23%
22%
3.1%
1.9%
1.6%
1.7%
2.2%
0.8%
57%
62%
60%
60%
58%
61%
0.6%
0.6%
0.5%
0.7%
0.4%
0.4%
28%
26%
26%
26%
30%
30%
0.7%
0.4%
0.4%
0.3%
0.2%
0.6%
38%
33%
35%
36%
35%
32%
1.6%
1.0%
0.8%
0.9%
0.9%
0.8%
21%
19%
19%
20%
18%
21%
1.1%
0.4%
0.4%
0.7%
0.9%
0.2%
63%
64%
62%
58%
61%
63%
0.6%
0.5%
0.6%
0.7%
0.4%
0.4%
34%
34%
35%
35%
36%
33%
1.1%
1.3%
0.9%
1.8%
1.3%
1.1%
58%
58%
49%
52%
47%
43%
1.2%
0.7%
0.7%
1.1%
1.3%
0.4%
67%
65%
64%
63%
66%
68%
1.1%
1.1%
1.0%
0.9%
0.8%
0.6%
65%
67%
66%
65%
64%
63%
0.3%
0.3%
0.3%
0.5%
0.1%
0.2%
50%
46%
47%
51%
50%
52%
1.3%
0.6%
0.9%
0.9%
1.0%
0.6%
68%
68%
69%
67%
68%
68%
0.9%
1.5%
1.2%
1.3%
1.1%
1.1%
70%
72%
72%
75%
76%
76%
0.2%
0.3%
0.5%
0.1%
0.4%
0.3%
26%
23%
23%
22%
23%
27%
0.9%
0.4%
0.9%
1.1%
0.6%
0.3%
44%
39%
40%
42%
46%
51%
0.8%
0.5%
1.0%
1.2%
0.5%
0.4%
49%
47%
47%
48%
48%
49%
1.2%
0.8%
0.8%
0.9%
0.8%
0.6%
2008 12009 12010 12011 12012 12013 12008 12009 12010 12011 12012 12013
26%
23%
21%
23%
22%
20%
24%
30%
32%
28%
30%
32%
24%
21%
17%
20%
18%
18%
34%
40%
47%
39%
45%
48%
9%
6%
5%
6%
6%
6%
17%
18%
20%
16%
19%
16%
5%
7%
5%
6%
7%
4%
56%
57%
58%
56%
54%
57%
20%
20%
19%
20%
15%
15%
27%
34%
35%
31%
39%
40%
16%
12%
13%
12%
10%
13%
54%
60%
58%
58%
61%
57%
6%
6%
5%
5%
5%
5%
17%
19%
20%
20%
20%
19%
34%
31%
27%
31%
25%
23%
20%
23%
26%
21%
28%
33%
13%
10%
9%
11%
7%
6%
12%
17%
29%
23%
32%
39%
9%
9%
7%
8%
8%
6%
8%
11%
12%
12%
12%
12%
3%
2%
2%
3%
2%
2%
10%
11%
14%
10%
14%
17%
15%
14%
11%
12%
12%
10%
19%
25%
27%
22%
23%
25%
7%
6%
6%
7%
7%
7%
8%
11%
9%
11%
10%
11%
3%
5%
5%
4%
4%
4%
4%
4%
5%
4%
4%
5%
40%
38%
37%
39%
36%
31%
23%
28%
29%
28%
30%
31%
17%
15%
13%
12%
14%
10%
25%
32%
32%
32%
28%
26%
16%
14%
12%
13%
11%
10%
23%
25%
27%
25%
27%
28%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2 - Table includes all applications that went through the complete underwriting process,
and excludes applications withdrawn or files closed for incompleteness.
14-245
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black
Hispanic
Applicant Race
Asian I Haw. Nat. Am.
Multi I
Unk/NA
I
Total
Min.
%
Anaheim
0116.02
Low
25%
n/a
33%
33%
n/a
n/a
n/a
0%
28%
33%
Anaheim
0117.14
Low
0%
n/a
n/a
0%
n/a
n/a
n/a
n/a
0%
0%
Anaheim
0117.20
Low
n/a
n/a
25%
0%
n/a
n/a
n/a
33%
18%
14%
Anaheim
0117.22
Middle
38%
0%
0%
33%
n/a
n/a
n/a
n/a
27%
11%
Anaheim
0218.07
Upper
9%
n/a 1
33%
29%
0%
n/a
n/a 1
25%
16%
29%
Anaheim
0218.12
Middle
12%
n/a
15%
14%
n/a
n/a
n/a
29%
14%
15%
Anaheim
0218.13
Unk/NA
0%
n/a
n/a
n/a
n/a
n/a
n/a
n/a
0%
0%
Anaheim
0218.21
Middle
25%
0%
25%
15%
n/a
n/a
100%
0%
21%
21%
Anaheim
0218.26
Upper
6%
n/a
0%
0%
n/a
n/a
n/a
0%
3%
0%
Anaheim
0219.03
Middle
9%
n/a
14%
20%
n/a
n/a
n/a 1
50%
14%
17%
Anaheim
0219.05
Upper
0%
n/a
22%
6%
n/a
n/a
n/a
13%
7%
11%
Anaheim
0219.12
Upper
6%
n/a
17%
15%
0%
n/a
n/a
0%
8%
15%
Anaheim
0219.15
Upper
7%
n/a
0%
19%
n/a
n/a
100%
0%
10%
18%
Anaheim
0219.16
Upper
12%
n/a 1
43%
17%
n/a
n/a
0%
0%
15%
29%
Anaheim
0219.19
Middle
10%
n/a
0%
14%
n/a
n/a
n/a
20%
12%
11%
Anaheim
0219.20
Upper
15%
n/a
20%
10%
n/a
n/a
n/a
17%
14%
12%
Anaheim
0219.21
Upper
12%
n/a
0%
24%
n/a
n/a
0%
17%
16%
21%
Anaheim
0219.22
Upper
12%
0%
0%
6%
0%
n/a
0%
0%
8%
4%
Anaheim
0219.23
Upper
15%
100%
14%
9%
0%
n/a
n/a
0%
13%
11%
Anaheim
0219.24
Upper
0%
n/a
0%
7%
n/a
n/a
n/a
0%
2%
6%
Anaheim
0758.13
Upper
6%
0%
0%
9%
n/a
n/a
n/a
10%
7%
6%
Anaheim
0761.01
Middle
22%
n/a
13%
0%
n/a
n/a
n/a
67%
20%
10%
Anaheim
0761.02
IMod
0%
100%
0%
0%
n/a
n/a
n/a
0%
5%
8%
Anaheim
0762.02
Middle
13%
0%
14%
14%
0%
n/a I
n/a
40%
15%
13%
Anaheim
0863.01
Mod
20%
n/a
17%
7%
0%
n/a
n/a
0%
14%
13%
Anaheim
0863.03
Mod
0%
100%
8%
6%
n/a
n/a
n/a
0%
5%
10%
Anaheim
0863.04
Middle
8%
n/a
9%
13%
0%
n/a
n/a
0%
8%
9%
Anaheim
0863.05
IMiddle
13%
0%
0%
13%
0%
n/a
n/a
25%
11%
7%
Anaheim
0863.06
Middle
0%
n/a
0%
0%
n/a
n/a
n/a
50%
4%
0%
Anaheim
0864.02
Mod
8%
50%
7%
0%
n/a
n/a
n/a
25%
9%
8%
Anaheim
0864.04
Mod
25%
n/a
42%
0%
n/a
0%
n/a
33%
25%
24%
Anaheim
0864.05
Mod
11%
n/a
25%
0%
n/a
n/a
n/a
0%
15%
17%
Anaheim
0864.06
Mod
0%
n/a
20%
25%
n/a
n/a I
n/a
25%
16%
22%
Anaheim
0864.07
Mod
8%
n/a
17%
20%
n/a
n/a
n/a
33%
16%
19%
Anaheim
0865.01
Mod
19%
n/a
38%
20%
n/a
n/a
n/a
43%
29%
33%
Anaheim
0865.02
Mod
0%
n/a
31%
38%
n/a
n/a
n/a
25%
29%
33%
Anaheim
0866.01
Low
n/a
n/a
25%
8%
n/a
n/a
n/a
22%
17%
15%
Anaheim
0866.02
Mod
33%
0%
20%
17%
n/a
n/a I
n/a
0%
21%
18%
Anaheim
0867.01
Mod
7%
n/a
12%
9%
0%
n/a
n/a
0%
9%
10%
Anaheim
0867.02
Mod
0%
n/a
30%
9%
n/a
n/a
n/a
25%
16%
19%
Anaheim
0868.01
Middle
44%
0%
33%
38%
0%
n/a
n/a
33%
36%
33%
Anaheim
0868.02
Mod 1
0%
0%
0%
0%
n/a
n/a
n/a
50%
4%
0%
Page 1 of 14
14-246
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic
Applicant Race
Asian I Haw. Nat. Am. I
Multi I
Unk/NA
I
Total
Min.
%
Anaheim
0868.03
Mod
11%
0%
10%
11%
n/a
n/a
n/a
0%
9%
10%
Anaheim
0869.01
Mod
0%
0%
0%
14%
0%
n/a
n/a
0%
8%
12%
Anaheim
0869.02
Mod
11%
n/a
20%
0%
n/a
n/a
n/a
17%
10%
8%
Anaheim
0869.03
Mod
0%
n/a
0%
0%
n/a
n/a
n/a
n/a
0%
0%
Anaheim
0870.01
Mod
40%
n/a 1
13%
7%
n/a
n/a
n/a 1
20%
16%
9%
Anaheim
0870.02
Mod
11%
n/a
36%
27%
n/a
100%
n/a
25%
28%
35%
Anaheim
0871.01
Mod
0%
n/a
0%
0%
n/a
n/a
100%
0%
7%
17%
Anaheim
0871.02
Mod
11%
n/a
18%
23%
n/a
n/a
n/a
100%
23%
21%
Anaheim
0871.03
Middle
0%
0%
36%
17%
n/a
n/a
0%
29%
18%
21%
Anaheim
0871.05
Mod
14%
n/a
0%
14%
n/a
n/a
n/a 1
0%
11%
13%
Anaheim
0871.06
Low
20%
n/a
0%
27%
n/a
n/a
0%
10%
16%
18%
Anaheim
0872.00
Mod
21%
n/a
18%
9%
n/a
n/a
n/a
29%
19%
14%
Anaheim
0873.00
Low
12%
n/a
45%
17%
n/a
n/a
n/a
27%
20%
23%
Anaheim
0874.01
Middle
14%
0%1
23%
5%
n/a
n/a
0%
29%
13%
11%
Anaheim
0874.03
Mod
33%
100%
50%
67%
n/a
n/a
n/a
33%
50%
60%
Anaheim
0874.04
Low
0%
0%
0%
0%
n/a
n/a
n/a
#DIV/0!
0%
0%
Anaheim
0874.05
Low
0%
n/a
67%
29%
n/a
n/a
n/a
0%
22%
40%
Anaheim
0875.03
Mod
21%
n/a
17%
50%
n/a
n/a
n/a
33%
32%
40%
Anaheim
0875.04
Low
0%
n/a
50%
50%
n/a
n/a I
n/a
14%
28%
50%
Anaheim
0875.05
Low
9%
0%
n/a
20%
n/a
n/a
n/a
0%
13%
18%
Anaheim
0876.01
IMod
14%
n/a
0%
27%
0%
n/a
n/a
0%
15%
23%
Anaheim
0876.02
Middle
13%
n/a
27%
19%
0%
n/a
n/a
0%
17%
21%
Anaheim
0877.01
Mod
33%
n/a
33%
17%
n/a
n/a
n/a
50%
29%
25%
Anaheim
0877.03
Mod
0%
0%
40%
20%
n/a
n/a I
n/a
17%
18%
24%
Anaheim
0877.04
Middle
7%
n/a
18%
17%
100%
0%
n/a
50%
17%
19%
Anaheim
0878.01
Mod
0%
0%
8%
23%
n/a
0%
n/a
0%
11%
17%
Anaheim
0878.02
Mod
36%
0%
40%
36%
0%
n/a
n/a
0%
31%
34%
Anaheim
0878.03
Low
50%
n/a
0%
0%
n/a
n/a
n/a
20%
13%
0%
Anaheim
0878.05
Mod
50%
100%
33%
28%
n/a
n/a
n/a
50%
36%
320o
Anaheim
0878.06
Low
20%
n/a
18%
20%
n/a
n/a
n/a
0%
16%
19%
Anaheim
0883.02
Middle
13%
n/a
17%
26%
n/a
n/a
n/a
50%
24%
25%
Anaheim
0884.02
Mod
0%
n/a
0%
10%
n/a
n/a
n/a
0%
7%
9%
Anaheim
0884.03
Mod
14%
0%
36%
19%
n/a
n/a
n/a
20%
21%
23%
Anaheim
1102.01
Mod
6%
n/a
40%
10%
0%
n/a
0%
0%
14%
18%
Anaheim
1102.02
Mod
0%
n/a
20%
23%
n/a
n/a
n/a
11%
17%
22%
Anaheim
1102.03
Middle
20%
n/a
25%
48%
n/a
n/a
n/a
0%
31%
39%
Anaheim
1104.01
Middle
13%
n/a
17%
0%
n/a
n/a
n/a
0%
8%
9%
Anaheim
1104.02
Middle
15%
100%
9%
14%
0%
n/a
n/a
0%
14%
15%
Anaheim
9800.00
Unk/NA
0%
n/a
n/a
0%
n/a
n/a
n/a
n/a
0%
0%
Anaheim
Total
13%
23%
21%
16%
5%
25%
36%
16%
16%
18%
Buena Park
0018.01
Mod
0%
n/a 1
40%
13%
n/a
n/a
n/a
0%
14%
23%
Page 2 of 14
14-247
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic
Applicant Race
Asian I Haw. Nat. Am. I
Multi I
Unk/NA
I
Total
Min.
%
Buena Park
0868.01
Middle
44%
0%
33%
38%
0%
n/a
n/a
33%
36%
33%
Buena Park
0868.03
Mod
11%
0%
10%
11%
n/a
n/a
n/a
0%
9%
10%
Buena Park
1101.02
Middle
0%
n/a
0%
19%
n/a
n/a
n/a
14%
14%
16%
Buena Park
1101.10
Mod
0%
n/a
17%
27%
0%
n/a
n/a
0%
21%
24%
Buena Park
1102.01
Mod
6%
n/a 1
40%
10%
0%
n/a
0%
0%
14%
18%
Buena Park
1102.02
Mod
0%
n/a
20%
23%
n/a
n/a
n/a
11%
17%
22%
Buena Park
1102.03
Middle
20%
n/a
25%
48%
n/a
n/a
n/a
0%
31%
39%
Buena Park
1103.01
Middle
0%
n/a
0%
10%
0%
n/a
n/a
25%
7%
6%
Buena Park
1103.02
Middle
20%
n/a
25%
25%
0%
0%
n/a
38%
25%
23%
Buena Park
1103.03
Middle
17%
n/a
11%
13%
n/a
n/a
n/a 1
67%
17%
12%
Buena Park
1103.04
Middle
17%
n/a
14%
18%
0%
n/a
n/a
0%
15%
17%
Buena Park
1104.01
Middle
13%
n/a
17%
0%
n/a
n/a
n/a
0%
8%
9%
Buena Park
1104.02
Middle
15%
100%
9%
14%
0%
n/a
n/a
0%
14%
15%
Buena Park
1105.00
Mod
0%
0%1
17%
14%
n/a
n/a
n/a
0%
10%
14%
Buena Park
1106.03
Low
50%
0%
50%
50%
100%
n/a
n/a
0%
45%
50%
Buena Park
1106.04
Middle
0%
n/a
0%
19%
n/a
n/a
50%
20%
16%
19%
Buena Park
1106.06
Mod
50%
0%
0%
29%
n/a
n/a
n/a
50%
31%
22%
Buena Park
1106.07
Middle
0%
n/a
0%
15%
n/a
n/a
n/a
n/a
11%
14%
Buena Park
Total
13%
17%
20%
20%
13%
0%1
33%
13%
18%
20%
Costa Mesa
0626.10
Mod
14%
n/a
33%
24%
0%
n/a
n/a
31%
19%
24%
Costa Mesa
0631.01
Mod
31%
n/a
n/a
25%
n/a
n/a
n/a
20%
28%
25%
Costa Mesa
0631.02
IMiddle
12%
n/a 1
13%
0%
n/a
n/a
n/a
19%
13%
8%
Costa Mesa
0631.03
Upper
19%
n/a
0%
n/a
n/a
n/a
0%
0%
15%
0%
Costa Mesa
0632.01
Middle
14%
n/a
100%
0%
n/a
n/a
n/a
13%
15%
50%
Costa Mesa
0632.02
Middle
12%
0%
0%
0%
n/a
n/a
n/a
0%
8%
0%
Costa Mesa
0633.01
Middle
6%
n/a
n/a
n/a
n/a
n/a
100%
0%
8%
100%
Costa Mesa
0633.02
jUpper
14%
n/a 1
50%
0%
n/a
n/a 1
0%
13%
14%
17%
Costa Mesa
0636.01
Middle
13%
n/a
0%
0%
n/a
n/a
n/a
25%
14%
0%
Costa Mesa
0636.03
Middle
17%
n/a
0%
0%
n/a
n/a
n/a
8%
14%
0%
Costa Mesa
0636.04
Mod
11%
n/a
0%
n/a
n/a
n/a
n/a
0%
7%
0%
Costa Mesa
0636.05
Low
0%
0%
0%
0%
n/a
n/a
n/a
20%
6%
0%
Costa Mesa
0637.01
Mod
0%
n/a I
n/a
0%
n/a
n/a
n/a
0%
0%
0%
Costa Mesa
0637.02
Mod
18%
0%
20%
14%
n/a
n/a
n/a
31%
20%
15%
Costa Mesa
0638.02
Upper
11%
n/a
n/a
0%
n/a
n/a
n/a
0%
8%
0%
Costa Mesa
0638.03
Middle
11%
n/a
0%
0%
0%
n/a
0%
20%
10%
0%
Costa Mesa
0638.05
Upper
8%
n/a
0%
14%
n/a
n/a
n/a
50%
12%
13%
Costa Mesa
0638.06
Middle
16%
n/a
n/a
0%
n/a
n/a
n/a
33%
19%
0%
Costa Mesa
0638.07
Middle
20%
n/a
0%
0%
n/a
n/a
n/a
0%
15%
0%
Costa Mesa
0638.08
Mod
20%
n/a
38%
33%
n/a
n/a
n/a
0%
24%
36%
Costa Mesa
0639.02
Middle
6%
n/a
67%
17%
n/a I
n/a
n/a
33%
17%
33%
Costa Mesa
0639.03
Mod
7%
n/a 1
20%
100%
n/a I
n/a
n/a 1
20%
17%
50%
Page 3 of 14
14-248
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic
Applicant Race
Asian I Haw. Nat. Am.
Multi I
Unk/NA
I
Total
Min.
%
Costa Mesa
0639.04
Mod
0%
n/a
0%
13%
0%
n/a
n/a
40%
11%
10%
Costa Mesa
0639.05
Middle
0%
0%
0%
0%
n/a
n/a
n/a
50%
3%
0%
Costa Mesa
0639.06
Mod
13%
n/a
25%
0%
n/a
n/a
0%
20%
16%
21%
Costa Mesa
0639.07
Middle
18%
0%
50%
38%
n/a
n/a
n/a
11%
21%
36%
Costa Mesa
0639.08
Middle
25%
n/a 1
0%
0%
n/a
n/a
n/a 1
17%
16%
0%
Costa Mesa
0755.15
Middle
20%
n/a
20%
16%
100%
n/a
n/a
18%
18%
18%
Costa Mesa
0992.40
Upper
17%
n/a
0%
0%
n/a
n/a
0%
14%
15%
0%
Costa Mesa
Total
14%
0%
20%
17%
25% n/a
17%
18%
16%
18%
Fountain Valley
0992.02
Mod
0%
n/a
0%
15%
0%
n/a
n/a 1
25%
13%
13%
Fountain Valley
0992.03
Middle
29%
n/a
0%
37%
n/a
n/a
n/a
#DIV/0!
33%
34%
Fountain Valley
0992.04
Middle
40%
n/a
0%
44%
n/a
n/a
n/a
100%
44%
42%
Fountain Valley
0992.23
Mod
13%
n/a
0%
25%
n/a
n/a
n/a
100%
23%
24%
Fountain Valley
0992.24
Upper
0%
n/a
0%
36%
n/a
n/a
n/a
0%
24%
33%
Fountain Valley
0992.25
Upper
0%
n/a
n/a
35%
n/a
n/a
n/a
0%
27%
35%
Fountain Valley
0992.26
Middle
0%
n/a
n/a
38%
n/a
n/a
n/a
0%
24%
38%
Fountain Valley
0992.27
IMod
16%
0%
0%
14%
0%
n/a
n/a
0%
13%
12%
Fountain Valley
0992.29
Middle
33%
0%
0%
13%
n/a
n/a
n/a
0%
18%
11%
Fountain Valley
0992.30
Middle
14%
n/a
0%
6%
n/a
n/a
n/a
0%
9%
5%
Fountain Valley
0992.31
Upper
6%
n/a
0%
26%
n/a
n/a
n/a
8%
15%
24%
Fountain Valley
0992.32
Upper
15%
n/a
0%
31%
n/a
n/a
n/a
0%
21%
27%
Fountain Valley
0992.33
Middle
0%
n/a
0%
0%
n/a
n/a I
n/a
50%
7%
0%
Fountain Valley
0992.34
Middle
0%
n/a
n/a
6%
n/a
n/a
n/a
25%
7%
6%
Fountain Valley
0992.50
Middle
0%
n/a
n/a
20%
n/a
n/a
n/a
50%
22%
20%
Fountain Valley
0992.51
Mod
0%
n/a
0%
12%
0%
n/a
100%
0%
11%
13%
Fountain Valley
Total
13%
0%
0%
21%
0% n/a
100%
15%
18%
20%
Fullerton
0014.04
Mod
0%
n/a
38%
50%
n/a
n/a
n/a
50%
30%
42%
Fullerton
0015.03
Middle
10%
100%
0%
8%
0%
n/a
0%
25%
11%
10%
Fullerton
0015.05
Middle
17%
n/a
0%
12%
n/a
0%
0%
33%
15%
10%
Fullerton
0016.01
Middle
9%
n/a
11%
14%
n/a
n/a I
n/a
0%
10%
13%
Fullerton
0016.02
Upper
4%
n/a
0%
17%
n/a
n/a
n/a
14%
11%
15%
Fullerton
0017.04
Middle
0%
0%
33%
18%
n/a
n/a
n/a
10%
16%
19%
Fullerton
0017.05
Middle
13%
n/a
0%
0%
n/a
n/a
n/a
29%
11%
0%
Fullerton
0017.06
jUpper
21%
n/a
0%
15%
n/a
0%
n/a 1
0%
13%
14%
Fullerton
0017.07
Upper
6%
n/a
0%
6%
0%
n/a
n/a
20%
6%
6%
Fullerton
0017.08
Middle
7%
n/a
0%
5%
67%
n/a
n/a
0%
9%
12%
Fullerton
0018.01
Mod
0%
n/a
40%
13%
n/a
n/a
n/a
0%
14%
23%
Fullerton
0018.02
Mod
0%
n/a
11%
10%
n/a
n/a
n/a
17%
8%
11%
Fullerton
0019.01
IMiddle
0%
0%
50%
0%
n/a
n/a I
n/a I
n/a
25%
33%
Fullerton
0019.02
Mod
0%
n/a
0%
0%
n/a
n/a
n/a 1
0%1
25%
0%
Fullerton
0019.03
IMiddle 1
25%
n/a
0%
45%
n/a I
n/a
n/a 1
0%
0%1
31%
Page 4 of 14
14-249
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic I
Applicant Race
Asian I Haw. Nat. Am.
Multi I
Unk/NA
I
Total
Min.
%
Fullerton
0110.00
Middle
5%
0%
22%
10%
0%
n/a
n/a
0%
7%
13%
Fullerton
0111.01
Middle
13%
0%
40%
0%
n/a
n/a
n/a
0%
12%
13%
Fullerton
0111.02
Middle
11%
0%
6%
29%
0%
n/a
n/a
0%
13%
16%
Fullerton
0112.00
Middle
0%
0%
8%
17%
n/a
n/a
n/a
0%
5%
10%
Fullerton
0113.00
Middle
30%
n/a 1
0%
29%
0%
n/a
n/a 1
40%
29%
26%
Fullerton
0114.01
Upper
8%
n/a
n/a
0%
n/a
n/a
n/a
0%
6%
0%
Fullerton
0114.02
Upper
0%
n/a
0%
20%
n/a
n/a
0%
0%
5%
11%
Fullerton
0114.03
Mod
4%
0%
18%
10%
0%
n/a
n/a
13%
9%
13%
Fullerton
0115.02
Mod
13%
0%
0%
29%
n/a
n/a
n/a
25%
15%
13%
Fullerton
0115.03
Upper
0%
n/a I
n/a
0%
n/a
n/a I
n/a
50%
5%
0%
Fullerton
0115.04
Mod
20%
n/a
0%
0%
0%
n/a
n/a
60%
19%
0%
Fullerton
0116.01
Mod
18%
n/a
7%
13%
n/a
100%
0%
14%
14%
12%
Fullerton
0116.02
Low
25%
n/a
33%
33%
n/a
n/a
n/a
0%
28%
33%
Fullerton
0117.07
Middle
8%
n/a
13%
0%
n/a
n/a
n/a
0%
5%
3%
Fullerton
0117.08
Middle
13%
n/a 1
0%
31%
n/a
n/a
n/a
17%
18%
25%
Fullerton
0117.11
Mod
20%
n/a
0%
9%
n/a
n/a
n/a
0%
10%
6%
Fullerton
0117.12
Middle
13%
n/a
0%
22%
n/a
n/a
n/a
20%
14%
13%
Fullerton
0867.01
IMod
7%
n/a
12%
9%
0%
n/a
n/a
0%
9%
10%
Fullerton
0868.01
Middle
44%
0%
33%
38%
0%
n/a
n/a
33%
36%
33%
Fullerton
0868.02
Mod
0%
0%
0%
0%
n/a
n/a
n/a
50%
4%
0%
Fullerton
1104.01
Middle
13%
n/a
17%
0%
n/a
n/a
n/a
0%
8%
9%
Fullerton
1106.04
Middle
0%
n/a
0%
19%
n/a
n/a
50%
20%
16%
19%
Fullerton
1106.05
Middle
0%
n/a
n/a
10%
n/a
n/a
n/a
67%
12%
10%
Fullerton
Total
10%
7%
14%
14%
17%
33%
17%
13%
13%
14%
Garden Grove
0761.03
Mod
0%
n/a
20%
22%
n/a
n/a
n/a
50%
17%
21%
Garden Grove
0875.03
Mod
21%
n/a
17%
50%
n/a
n/a
n/a
33%
32%
40%
Garden Grove
0876.02
Middle
13%
n/a
27%
19%
0%
n/a
n/a
0%
17%
21%
Garden Grove
0878.06
Low
20%
n/a
18%
20%
n/a
n/a
n/a
0%
16%
19%
Garden Grove
0879.01
Middle
17%
n/a
38%
15%
0%
n/a
n/a
33%
24%
23%
Garden Grove
0879.02
Mod
0%
n/a
29%
33%
n/a
n/a
n/a
0%
28%
32%
Garden Grove
0880.01
Middle
0%
n/a
0%
31%
n/a
n/a
n/a
25%
22%
27%
Garden Grove
0880.02
Middle
20%
n/a
50%
29%
n/a
n/a
n/a
0%
27%
30%
Garden Grove
0881.01
Middle
0%
0%1
25%
27%
n/a
n/a
0%
0%
16%
24%
Garden Grove
0881.04
Mod
27%
n/a
0%
25%
n/a
n/a
n/a
n/a
23%
20%
Garden Grove
0881.05
Mod
33%
n/a
0%
16%
n/a
n/a
100%
0%
18%
17%
Garden Grove
0881.06
Mod
8%
n/a
0%
31%
n/a
n/a
n/a
14%
17%
22%
Garden Grove
0881.07
Mod
0%
n/a
n/a
29%
n/a
n/a
n/a 1
0%
24%
29%
Garden Grove
0882.01
Mod
0%
n/a
0%
19%
n/a
n/a
0%
0%
10%
17%
Garden Grove
0882.02
Middle
13%
n/a
0%
23%
n/a
n/a
n/a
0%
14%
17%
Garden Grove
0882.03
Mod 1
0%
n/a
25%
19%
n/a
n/a
n/a
0%
16%
19%
Garden Grove
0883.01
Middle 1
40%
n/a
50%
22%
n/a
n/a
n/a
20%
28%
25%
Page 5 of 14
14-250
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic
Applicant Race
Asian I Haw. Nat. Am.
Multi I
Unk/NA
Total
Min.
Garden Grove
0883.02
Middle
13%
n/a
17%
26%
n/a
n/a
n/a
50%
24%
25%
Garden Grove
0884.01
Middle
25%
n/a
9%
35%
n/a
n/a
n/a
n/a
26%
26%
Garden Grove
0884.02
Mod
0%
n/a
0%
10%
n/a
n/a
n/a
0%
7%
9%
Garden Grove
0884.03
Mod
14%
0%
36%
19%
n/a
n/a
n/a
20%
21%
23%
Garden Grove
0885.01
Mod
33%
n/a 1
20%
14%
0%
n/a
n/a 1
33%
19%
14%
Garden Grove
0885.02
Mod
0%
n/a
33%
30%
0%
n/a
0%
100%
27%
29%
Garden Grove
0886.01
Mod
11%
n/a
13%
13%
n/a
n/a
n/a
25%
13%
13%
Garden Grove
0886.02
Middle
25%
n/a
25%
32%
n/a
n/a
n/a
0%
26%
30%
Garden Grove
0887.01
Mod
33%
n/a
33%
3%
n/a
n/a
n/a
33%
12%
6%
Garden Grove
0887.02
Mod
0%
n/a
50%
31%
n/a
n/a
I n/a
n/a
31%
32%
Garden Grove
0888.01
Mod
18%
n/a
100%
21%
n/a
n/a
n/a
100%
24%
24%
Garden Grove
0888.02
Mod
33%
n/a
60%
27%
n/a
n/a
n/a
50%
34%
33%
Garden Grove
0889.01
IMod
25%
n/a
0%
27%
n/a
n/a
0%
67%
31%
26%
Garden Grove
0889.02
Mod
100%
n/a
0%
15%
n/a
n/a
n/a
100%
22%
14%
Garden Grove
0889.03
Mod
n/a
n/a
0%
37%
n/a
n/a
0%
n/a
32%
32%
Garden Grove
0889.04
Mod
50%
n/a
n/a
47%
n/a
n/a
n/a
n/a
47%
47%
Garden Grove
0890.01
Mod
n/a
n/a
0%
4%
n/a
n/a
n/a
0%
3%
4%
Garden Grove
0890.03
IMod
0%
n/a 1
0%
28%
n/a
n/a
n/a
0%
23%
26%
Garden Grove
0891.02
Mod
14%
n/a
16%
19%
n/a
n/a
n/a
0%
16%
18%
Garden Grove
0891.04
Low
0%
n/a
30%
11%
n/a
n/a
n/a
0%
18%
21%
Garden Grove
0891.06
Low
n/a
n/a
100%
75%
n/a
n/a
n/a
100%
80%
78%
Garden Grove
0891.07
Middle
0%
n/a
18%
23%
n/a
n/a
n/a
50%
23%
22%
Garden Grove
0992.03
IMiddle
29%
n/a 1
0%
37%
n/a
n/a
I n/a
n/a
33%
34%
Garden Grove
0998.01
Mod
0%
n/a
25%
18%
n/a
n/a
n/a
50%
19%
19%
Garden Grove
0999.02
Middle
0%
n/a
0%
20%
n/a
n/a
n/a
100%
14%
17%
Garden Grove
0999.03
Mod
0%
n/a
0%
14%
n/a
n/a
n/a
0%
11%
13%
Garden Grove
0999.05
Middle
14%
n/a
n/a
0%
n/a
n/a
n/a
n/a
10%
0%
Garden Grove
0999.06
jUpper
6%
n/a 1
0%
33%
n/a
n/a
I n/a
0%
12%
24%
Garden Grove
1100.01
Middle
9%
n/a
0%
25%
100%
n/a
n/a
0%
13%
27%
Garden Grove
1100.03
Middle
6%
n/a
0%
0%
n/a
n/a
n/a
0%
4%
0%
Garden Grove
1100.04
Middle
13%
100%
0%
0%
n/a
n/a
0%
0%
8%
8%
Garden Grove
1100.05
Middle
0%
n/a
0%
20%
0%
n/an/a
0%
3%
10%
Garden Grove
1100.10
Upper
19%
n/a 1
33%
19%
n/a
n/a
n/a
0%
18%
21%
Garden Grove
Total
13%
50%
19%
23%
17%
n/a
14%
19%
20%
23%
Huntington Beach
0992.12
IMod
10%
n/a I
n/a
25%
n/a
n/a
I n/a
33%
17%
25%
Huntington Beach
0992.14
Middle
15%
n/a
0%
0%
n/a
n/a
n/a
0%
11%
0%
Huntington Beach
0992.15
Middle
14%
0%
13%
0%
0%
n/a
0%
0%
9%
4%
Huntington Beach
0992.16
Middle
6%
n/a
0%
0%
n/a
n/a
0%
60%
12%
0%
Huntington Beach
0992.17
Middle
23%
n/a
n/a
0%
n/a
n/a
n/a 1
0%
21%
0%
Huntington Beach
0992.20
Middle
14%
0%
25%
6%
0%
n/a
I n/a 1
30%
14%
9%
Huntington Beach
0992.35
Mod
0%
n/a 1
0%
22%
n/a
n/a
I n/a 1
14%
7%
18%
Page 6 of 14
14-251
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
I Income
White
Black I
Hispanic I
Applicant Race
Asian I Haw. Nat. Am.
Multi
Unk/NA
Total
Min.
Huntington Beach
0992.37
Upper
0%
n/a
0%
11%
n/a
n/a
n/a
0%
3%
10%
Huntington Beach
0992.38
Upper
6%
n/a
0%
20%
n/a
n/a
n/a
50%
11%
17%
Huntington Beach
0992.39
Upper
8%
n/a
0%
13%
n/a
n/a
n/a
13%
9%
10%
Huntington Beach
0992.40
Upper
17%
n/a
0%
0%
n/a
n/a
0%
14%
15%
0%
Huntington Beach
0992.41
Middle
14%
n/a 1
0%
27%
n/a
n/a
n/a
n/a
22%
25%
Huntington Beach
0992.42
Middle
0%
n/a
50%
22%
n/a
n/a
0%
0%
11%
25%
Huntington Beach
0992.43
Upper
9%
0%
0%
60%
n/a
n/a
0%
29%
13%
27%
Huntington Beach
0992.44
Middle
13%
n/a
0%
20%
n/a
0%
n/a
50%
13%
11%
Huntington Beach
0992.45
Upper
13%
n/a
0%
40%
n/a
n/a
n/a
0%
17%
33%
Huntington Beach
0992.46
Upper
10%
0%
0%
17%
n/a
n/a I
n/a
17%
12%
14%
Huntington Beach
0993.05
Mod
15%
n/a
0%
0%
n/a
n/a
n/a
20%
14%
0%
Huntington Beach
0993.06
Middle
8%
n/a
50%
31%
n/a
n/a
n/a
18%
14%
33%
Huntington Beach
0993.07
Upper
13%
n/a
25%
67%
n/a
n/a
n/a
14%
19%
43%
Huntington Beach
0993.08
Upper
3%
n/a
50%
16%
n/a
n/a
n/a
6%
7%
22%
Huntington Beach
0993.09
Upper
17%
n/a 1
0%
29%
n/a
0%
n/a
17%
17%
17%
Huntington Beach
0993.10
Upper
13%
n/a
0%
38%
n/a
n/a
n/a
0%
14%
33%
Huntington Beach
0993.11
jUpper
14%
n/a
40%
25%
100%
n/a
n/a
13%
19%
33%
Huntington Beach
0994.02
IMod
10%
n/a
0%
0%
n/a
n/a
n/a
25%
10%
0%
Huntington Beach
0994.04
jUpper
0%
0%
0%
0%
n/a
0%
n/a
0%
18%
0%
Huntington Beach
0994.05
IMiddle
12%
n/a 1
0%
0%
n/a
n/a
n/a
0%
0%
0%
Huntington Beach
0994.06
IMiddle
5%
n/a
33%
0%
n/a
n/a
n/a
0%
6%
9%
Huntington Beach
0994.07
lUpper
24%
n/a
0%
0%
n/a
n/a
n/a
33%
19%
0%
Huntington Beach
0994.08
jUpper
5%
0%
0%
0%
n/a
n/a
n/a
20%
5%
0%
Huntington Beach
0994.10
IMod
20%
n/a
n/a
0%
n/a
n/a
n/a
100%
15%
0%
Huntington Beach
0994.11
IMod
9%
0%
0%
17%
n/a
n/a
n/a
20%
12%
14%
Huntington Beach
0994.12
jUpper
16%
n/a
33%
0%
n/a
n/a
n/a
0%
13%
11%
Huntington Beach
0994.13
jUpper
13%
0%
0%
13%
0%
n/a
0%
29%
13%
8%
Huntington Beach
0994.15
lUpper
4%
n/a
n/a
27%
n/a
n/a
n/a
0%
11%
27%
Huntington Beach
0994.16
IMod
19%
n/a 1
0%
0%
n/a
n/a
n/a
17%
16%
0%
Huntington Beach
0994.17
lUpper
13%
n/a
0%
36%
0%
n/a
n/a
26%
19%
27%
Huntington Beach
0995.08
Middle
12%
n/a
50%
50%
n/a
n/a
n/a
0%
16%
50%
Huntington Beach
0995.13
Upper
25%
n/a
0%
38%
n/a
n/a
n/a
0%
24%
25%
Huntington Beach
0995.14
Upper
3%
n/a
0%
18%
n/a
n/a
n/a
7%
7%
16%
Huntington Beach
0996.02
Middle
0%
n/a
25%
0%
n/a
n/a
n/a
50%
13%
8%
Huntington Beach
0996.03
jUpper
6%
n/a
38%
7%
0%
n/a
n/a
20%
12%
17%
Huntington Beach
0996.04
lUpper
13%
n/a
0%
0%
n/a
n/a
n/a
0%
8%
0%
Huntington Beach
0996.05
Middle
6%
n/a
n/a
15%
100%
n/a
n/a
0%
10%
21%
Huntington Beach
0997.02
Middle
40%
0%
0%
25%
50%
n/a
n/a 1
33%
28%
24%
Huntington Beach
0997.03
Middle
18%
n/a
50%
47%
n/a
n/a
n/a 1
0%1
34%
47%
Huntington Beach
Total
11%
0%1
13%
19%
33%
0%
0%1
16%
13%
18%
La Habra 1 0011.01 IMiddle 1 13%1 0%1 10%1 9%1 n/a I n/a I n/a 1 25%1 11%1 9%
Page 7 of 14
14-252
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic I
Applicant Race
Asian I Haw. Nat. Am.
Multi I
Unk/NA
I
Total
Min.
La Habra
0011.02
Mod
8%
0%
11%
0%
n/a
n/a
n/a
20%
8%
5%
La Habra
0011.03
Mod
0%
0%
17%
0%
0%
n/a
n/a
0%
8%
13%
La Habra
0012.01
Mod
23%
n/a
15%
14%
n/a
n/a
n/a
0%
17%
15%
La Habra
0012.02
Middle
14%
0%
20%
20%
n/a
n/a
n/a
0%
17%
19%
La Habra
0013.01
Middle
7%
50%
23%
14%
n/a
n/a
n/a 1
0%
15%
21%
La Habra
0013.03
Mod
25%
n/a
32%
5%
0%
n/a
n/a
25%
22%
20%
La Habra
0013.04
Mod
17%
n/a
33%
17%
n/a
n/a
n/a
0%
21%
24%
La Habra
0014.01
Mod
29%
0%
15%
29%
0%
n/a
n/a
0%
21%
18%
La Habra
0014.02
Middle
0%
n/a
0%
40%
n/a
n/a
n/a
17%
15%
25%
La Habra
0014.03
Upper
10%
n/a
10%
0%
n/a
n/a I
n/a
0%
9%
9%
La Habra
0014.04
Mod
0%
n/a
38%
50%
n/a
n/a
n/a
50%
30%
42%
La Habra
0015.01
Middle
17%
0%
33%
22%
n/a
n/a
0%
38%
24%
26%
La Habra
0016.01
Middle
9%
n/a
11%
14%
n/a
n/a
n/a
0%
10%
13%
La Habra
0017.05
Middle
13%
n/a
0%
0%
n/a
n/a
n/a
29%
11%
0%
La Habra
0017.07
Upper
6%
n/a
0%
6%
0%
n/a
n/a
20%
6%
6%
La Habra
0017.08
Middle
7%
n/a
0%
5%
67%
n/a
n/a
0%
9%
12%
La Habra
Total
13%
10%
21%
12%
29% n/a
0%
19%
15%
15%
Lake Forest
0320.14
Mod
11%
n/a
22%
30%
85%
n/a I
n/a
40%
31%
44%
Lake Forest
0320.27
Middle
11%
n/a
31%
15%
75%
0%
100%
0%
16%
31%
Lake Forest
0320.29
Upper
9%
n/a
22%
18%
0%
n/a
n/a
20%
13%
18%
Lake Forest
0320.47
IMiddle
11%
n/a
11%
0%
n/a
n/a
n/a
0%
8%
6%
Lake Forest
0524.04
Unk/NA
9%
n/a
0%
7%
0%
n/a
n/a
43%
9%
7%
Lake Forest
0524.08
Upper
13%
n/a
0%
0%
0%
n/a
n/a
33%
11%
0%
Lake Forest
0524.10
Middle
13%
n/a
0%
15%
n/a
n/a
0%
0%
12%
13%
Lake Forest
0524.11
Middle
19%
0%
0%
13%
n/a
n/a
n/a
17%
16%
8%
Lake Forest
0524.15
Upper
14%
0%1
17%
20%
0%
n/a
n/a
8%
14%
18%
Lake Forest
0524.16
Middle
14%
0%
29%
33%
0%
n/a
0%
13%
17%
26%
Lake Forest
0524.22
Upper
7%
n/a
20%
10%
n/a
n/a
n/a
0%
7%
13%
Lake Forest
0524.23
Middle
21%
n/a
17%
31%
n/a
n/a
n/a
0%
23%
29%
Lake Forest
0524.24
Middle
19%
0%
14%
0%
n/a
n/a
n/a
50%
18%
5%
Lake Forest
0524.25
Middle
14%
n/a
0%
10%
0%
n/a
n/a
0%
10%
6%
Lake Forest
0524.26
Upper
13%
0%
0%
15%
n/a
0%
33%
11%
14%
15%
Lake Forest
0524.27
Upper
19%
0%
0%
8%
n/a
n/a
n/a
0%
12%
7%
Lake Forest
0524.28
Upper
10%
0%
0%
13%
n/a
n/a
n/a
20%
11%
11%
Lake Forest
Total
13%
0%
14%
14%
58%
0%
33%
13%
14%
15%
Mission Viejo
0320.02
Middle
10%
n/a
20%
0%
n/a
n/a
n/a
11%
10%
9%
Mission Viejo
0320.03
Upper
20%
n/a
0%
0%
0%
n/a
0%
25%
18%
0%
Mission Viejo
0320.12
Upper
11%
0%
0%
0%
n/a
n/a
n/a
0%
9%
0%
Mission Viejo
0320.13
Middle
15%
n/a
50%
0%
n/a
n/a
n/a
0%
14%
25%
Mission Viejo
0320.15
Upper
8%
n/a 1
0%1
13%
n/a
n/a
0%
0%
6%
8%
Page 8 of 14
14-253
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic
Applicant Race
Asian I Haw. Nat. Am.
Multi I
Unk/NA
I
Total
Min.
Mission Viejo
0320.20
Upper
7%
n/a
25%
14%
0%
n/a
n/a
9%
9%
17%
Mission Viejo
0320.22
Mod
10%
0%
17%
14%
n/a
n/a
n/a
33%
14%
13%
Mission Viejo
0320.27
Middle
11%
n/a
31%
15%
75%
0%
100%
0%
16%
31%
Mission Viejo
0320.28
Middle
14%
n/a
40%
20%
100%
n/a
n/a
11%
18%
29%
Mission Viejo
0320.30
Upper
12%
0%
0%
17%
n/a
n/a
n/a 1
29%
13%
8%
Mission Viejo
0320.31
Upper
7%
n/a
0%
25%
0%
n/a
n/a
0%
7%
13%
Mission Viejo
0320.32
Upper
7%
n/a
n/a
0%
n/a
n/a
n/a
20%
9%
0%
Mission Viejo
0320.33
Middle
15%
n/a
14%
29%
n/a
0%
n/a
22%
18%
20%
Mission Viejo
0320.34
Upper
3%
0%
0%
8%
n/a
n/a
n/a
20%
6%
6%
Mission Viejo
0320.35
Upper
26%
n/a 1
0%
40%1
100%
0%
n/a
0%
24%
25%
Mission Viejo
0320.36
Upper
9%
n/a
0%
0%
n/a
n/a
n/a
0%
7%
0%
Mission Viejo
0320.37
Middle
7%
100%
0%
44%
n/a
n/a
n/a
8%
11%
38%
Mission Viejo
0320.38
Upper
14%
n/a
0%
20%
n/a
n/a
n/a
19%
15%
15%
Mission Viejo
0320.39
Upper
8%
0%
11%
14%
0%
0%
n/a
25%
11%
12%
Mission Viejo
0320.40
Upper
9%
n/a 1
0%
50%
0%
n/a
n/a
0%
10%
25%
Mission Viejo
0320.47
Middle
11%
n/a
11%
0%
n/a
n/a
n/a
0%
8%
6%
Mission Viejo
0320.48
jUpper
7%
0%
0%
13%
0%
n/a
n/a
10%
8%
9%
Mission Viejo
0320.49
Upper
10%
0%
0%
0%
0%
n/a
n/a
6%
7%
0%
Mission Viejo
0320.58
Upper
10%
0%
0%
16%
50%
n/a
0%
17%
12%
14%
Mission Viejo
0320.61
Upper
19%
n/a
0%
0%
n/a
n/a
n/a
7%
16%
0%
Mission Viejo
0423.15
Upper
10%
50%
0%
11%
n/a
n/a
100%
18%
13%
21%
Mission Viejo
0423.28
Upper
10%
n/a
0%
0%
n/a I
n/a
n/a 1
67%
20%
0%
Mission Viejo
0423.33
Upper
16%
0%
n/a
0%
0%
n/a
n/a
18%
14%
0%
Mission Viejo
0524.23
Middle
21%
n/a
17%
31%
n/a
n/a
n/a
0%
23%
29%
Mission Viejo
0524.28
Upper
10%
0%
0%
13%
n/a
n/a
n/a
20%
11%
11%
Mission Viejo
Total
1
11%
13%
12%
16%
32%
0%
33%
14%
12%
15%
Newport Beach
0626.04
Upper
17%
n/a
25%
15%
n/a
n/a
n/a
23%
17%
16%
Newport Beach
0626.10
Mod
14%
n/a
33%
24%
0%
n/a
n/a
31%
19%
24%
Newport Beach
0626.14
Middle
17%
0%
0%
33%
n/a
n/a
n/a
0%
17%
20%
Newport Beach
0626.42
jUpper
16%
n/a
n/a
0%
100%
n/a
n/a
10%
14%
14%
Newport Beach
0626.43
Upper
9%
0%
0%
11%
n/a
0%
n/a
21%
12%
10%
Newport Beach
0626.44
Upper 1
16%
0%
0%
0%
n/a
n/a
n/a
12%
13%
0%
Newport Beach
0626.45
Upper
11%
n/a
0%
12%
n/a
n/a
n/a
29%
14%
11%
Newport Beach
0627.01
Upper
20%
n/a
n/a
50%
n/a
n/a
n/a
11%
18%
50%
Newport Beach
0627.02
Upper
16%
n/a
0%
0%
n/a
n/a
0%
17%
15%
0%
Newport Beach
0628.00
jUpper
23%
n/a
n/a
29%
0%
n/a
0%
14%
20%
20%
Newport Beach
0629.00
Upper
5%
n/a
n/a
n/a I
n/a
n/a
n/a
0%
4%
#DIV/0!
Newport Beach
0630.04
Upper
12%
n/a
25%
0%
n/a
0%
n/a
8%
11%
11%
Newport Beach
0630.05
Upper
0%
n/a
n/a
0%
n/a
n/a
n/a
0%
18%
0%
Newport Beach
0630.06
Upper
8%
n/a
n/a
0%
n/a
n/a
n/a
0%
0%
09/0
Newport Beach
1 0630.07
Upper 1
5%
n/a
0%
7%
n/a I
n/a I
n/a
5%
5%
5%
Page 9 of 14
14-254
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
I Income
White
Black
Hispanic I
Applicant Race
Asian Haw. Nat. Am.
Multi
Unk/NA
I
Total
Min.
%
Newport Beach
0630.08
Upper
20%
n/a
n/a
0%
n/a
n/a
n/a
0%
17%
0%
Newport Beach
0630.09
Upper
14%
n/a
n/a
17%
n/a
n/a
n/a
18%
16%
17%
Newport Beach
0630.10
Upper
19%
n/a
0%
20%
n/a
n/a
0%
9%
16%
11%
Newport Beach
0631.01
Mod
31%
n/a
n/a
25%
n/a
n/a
n/a
20%
28%
25%
Newport Beach
0631.03
Upper
19%
n/a
0%
n/a
n/a
n/a
0%
0%
15%
0%
Newport Beach
0633.02
Upper
14%
n/a
50%
0%
n/a
n/a
0%
13%
14%
17%
Newport Beach
0634.00
Upper
10%
n/a
0%
20%
n/a
0%
n/a
13%
10%
14%
Newport Beach
0635.00
Upper
22%
100%
n/a
0%
n/a
0%
n/a
22%
20%
9%
Newport Beach
0636.01
Middle
13%
n/a
0%
0%
n/a
n/a
n/a
25%
14%
0%
Newport Beach
0636.03
Middle
17%
n/a 1
0%
0%
n/a
n/a I
n/a
8%
14%
0%
Newport Beach
0636.04
Mod
11%
n/a
0%
n/a
n/a
n/a
n/a
0%
7%
0%
Newport Beach
Total
15%
25%
11%
15%
33%
0%
0%
15%
15%
14%
City of Orange
0219.12
Upper
6%
n/a
17%
15%
0%
n/a
n/a
0%
8%
15%
City of Orange
0219.13
Middle
16%
100%
17%
20%
n/a
n/a
n/a
0%
17%
22%
City of Orange
0219.14
Upper
22%
n/a
0%
10%
n/a
0%
n/a
0%
12%
6%
City of Orange
0219.15
jUpper
7%
n/a
0%
19%
n/a
n/a
100%
0%
10%
18%
City of Orange
0219.17
Upper
13%
n/a
0%
40%
n/a
n/a
n/a
20%
16%
25%
City of Orange
0219.18
Upper
7%
n/a
36%
22%
0%
n/a
0%
0%
12%
25%
City of Orange
0219.20
Upper
15%
n/a 1
20%
10%
n/a
n/a
n/a
17%
14%
12%
City of Orange
0219.23
Upper
15%
100%
14%
9%
0%
n/a
n/a
0%
13%
11%
City of Orange
0219.24
jUpper
0%
n/a
0%
7%
n/a
n/a
n/a
0%
2%
6%
City of Orange
0524.19
Upper
14%
n/a
0%
17%
n/a
n/a
n/a
29%
16%
13%
City of Orange
0524.20
Upper
15%
n/a
46%
12%
0%
n/a
0%
29%
16%
14%
City of Orange
0756.04
Upper
17%
n/a 1
0%
12%
n/a
0%
100%
31%
18%
14%
City of Orange
0756.05
Upper
11%
n/a
56%
14%
0%
n/a
n/a
43%
18%
29%
City of Orange
0758.05
Middle
13%
n/a
17%
0%
n/a
n/a
n/a
0%
10%
11%
City of Orange
0758.06
Middle
4%
n/a
13%
38%
n/a
n/a
n/a
33%
13%
25%
City of Orange
0758.07
Middle
0%
n/a
0%
22%
n/a
n/a
100%
0%
8%
23%
City of Orange
0758.08
Upper
14%
n/a 1
0%
10%
n/a
n/a
n/a
0%
9%
7%
City of Orange
0758.09
Upper
6%
n/a
n/a
0%
n/a
n/a
n/a
14%
7%
0%
City of Orange
0758.10
Upper
5%
n/a
0%
18%
n/a
n/a
n/a
0%
8%
15%
City of Orange
0758.11
Mod
14%
n/a
0%
50%
0%
n/a
n/a
50%
23%
25%
City of Orange
0758.12
Mod
0%
75%
0%
0%
0%
n/a
0%
0%
8%
20%
City of Orange
0758.13
Upper
6%
0%
0%
9%
n/a
n/a
n/a
10%
7%
6%
City of Orange
0758.14
Upper
25%
n/a
50%
13%
n/a
n/a
0%
0%
19%
18%
City of Orange
0758.15
Middle
10%
n/a
14%
11%
n/a
n/a
n/a
25%
14%
13%
City of Orange
0758.16
Middle
14%
50%
33%
20%
n/a
n/a
n/a
0%
18%
25%
City of Orange
0759.01
Mod
24%
0%
0%
50%
n/a
n/a
100%
0%
24%
40%
City of Orange
0759.02
Mod
9%
n/a
33%
50%
n/a
n/a
n/a
0%
14%
38%
City of Orange
0760.00
Mod 1
25%
100%
0%1
26%
0%
100%
n/a
259/o
25%
24%
City of Orange
0761.01
Middle 1
22%
n/a
13%
0%
n/a
n/a
n/a 1
67%
20%
10%
Page 10 of 14
14-255
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic
Applicant Race
Asian I Haw. Nat. Am. I
Multi I
Unk/NA
I
Total
Min.
%
City of Orange
0761.02
Mod
0%
100%
0%
0%
n/a
n/a
n/a
0%
5%
8%
City of Orange
0761.03
Mod
0%
n/a
20%
22%
n/a
n/a
n/a
50%
17%
21%
City of Orange
0762.01
Middle
8%
0%
0%
22%
0%
0%
n/a
23%
13%
15%
City of Orange
0762.02
Middle
13%
0%
14%
14%
0%
n/a
n/a
40%
15%
13%
City of Orange
0762.04
Mod
17%
n/a 1
13%
0%
0%
n/a
n/a 1
25%
15%
11%
City of Orange
0762.05
Middle
8%
n/a
0%
0%
n/a
n/a
n/a
17%
8%
0%
City of Orange
0762.06
Middle
14%
n/a
0%
40%
0%
n/a
n/a
33%
17%
29%
City of Orange
0762.08
Middle
9%
n/a
13%
13%
n/a
n/a
0%
0%
9%
12%
City of Orange
Total
12%
57%
15%
15%
0%
40%
44%
17%
14%
16%
Rancho SM
0320.34
Upper
3%
0%
0%
8%
n/a
n/a
n/a
20%
6%
6%
Rancho SM
0320.37
Middle
7%
100%
0%
44%
n/a
n/a
n/a
8%
11%
38%
Rancho SM
0320.38
Upper
14%
n/a
0%
20%
n/a
n/a
n/a
19%
15%
15%
Rancho SM
0320.41
Upper
11%
n/a
0%
0%
n/a
n/a
n/a
0%
6%
0%
Rancho SM
0320.42
Upper
16%
n/a
0%
0%
n/a
n/a
n/a
20%
15%
0%
Rancho SM
0320.43
Upper
9%
0%
0%
22%
n/a
n/a
n/a
0%
9%
18%
Rancho SM
0320.44
jUpper
12%
0%
9%
32%
n/a
100%
0%
14%
15%
24%
Rancho SM
0320.45
Upper
8%
n/a
0%
0%
n/a
n/a
0%
0%
6%
0%
Rancho SM
0320.48
Upper
7%
0%
0%
13%
0%
n/a
n/a
10%
8%
9%
Rancho SM
0320.49
Upper
10%
0%
0%
0%
0%
n/a
n/a
6%
7%
0%
Rancho SM
0320.50
Upper
12%
50%
0%
0%
n/a
n/a
0%
23%
12%
6%
Rancho SM
0320.51
IMiddle
7%
67%
8%
11%
n/a
100%
n/a
0%
10%
20%
Rancho SM
0320.53
Upper
12%
0%
23%
0%
n/a
n/a
67%
12%
13%
14%
Rancho SM
0320.54
Middle
13%
0%1
25%
0%
n/a
n/a
0%
33%
14%
10%
Rancho SM
0320.55
Middle
9%
n/a
33%
20%
n/a
n/a
n/a
11%
11%
25%
Rancho SM
0320.56
Upper
13%
n/a
9%
20%
n/a
n/a
n/a
10%
13%
15%
Rancho 5M
Total
10%
22%
11%
14%
0%
100%
25%
12%
11%
14%
San Clemente
0320.23
Upper
7%
0%
10%
17%
0%
n/a
0%
12%
8%
12%
San Clemente
0421.03
Upper
14%
n/a
33%
n/a
0%
n/a
0%
8%
13%
17%
San Clemente
0421.06
Middle
6%
n/a
33%
n/a
n/a
n/a
n/a
0%
10%
33%
San Clemente
0421.07
Mod
20%
n/a
0%
n/a
n/a
n/a
n/a
17%
19%
0%
San Clemente
0421.08
IMiddle
18%
n/a 1
0%
0%
n/a
100%
n/a
17%
18%
20%
San Clemente
0421.09
Middle
6%
n/a
0%
0%
0%
n/a
n/a
8%
6%
0%
San Clemente
0421.11
Upper
11%
n/a
0%
33%
n/a
n/a
n/a
20%
13%
25%
San Clemente
0421.12
Upper
8%
0%
0%
29%
n/a
n/a
n/a
12%
9%
20%
San Clemente
0421.13
Middle
5%
n/a
20%
0%
n/a
n/a
n/a
50%
12%
17%
San Clemente
0421.14
IMod
5%
n/a 1
33%
25%
n/a
n/a
n/a
0%
7%1
29%
San Clemente
0422.01
Middle
25%
n/a
33%
0%
n/a
n/a
n/a
27%
24%
14%
San Clemente
0422.03
Upper
16%
0%
18%
9%
0%
n/a
0%
24%
16%
12%
San Clemente
0422.05
Middle
9%
n/a
0%
33%
n/a
n/a
0%
17%
12%
23%
San Clemente
0422.06
Middle
10%
n/a
0%
0%
n/a I
/a I
n/a
30%
13%
0%
Page 11 of 14
14-256
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic
Applicant Race
Asian I Haw. Nat. Am.
Multi I
Unk/NA
I Min.
Total %
San Clemente
Total
11%
0%
16%
18%
0%
100%
0%
16%
12% 16%
Santa Ana
0740.03
Middle
40%
n/a
67%
10%
n/a
n/a
n/a
0%
36% 37%
Santa Ana
0740.04
Middle
25%
n/a
33%
17%
n/a
n/a
n/a
0%
22% 24%
Santa Ana
0740.05
Mod
14%
n/a 1
0%
7%
n/a
n/a
n/a 1
20%
9% 5%
Santa Ana
0740.06
Mod
13%
0%
8%
14%
n/a
n/a
n/a
67%
15% 10%
Santa Ana
0741.02
Mod
33%
n/a
20%
20%
n/a
n/a
n/a
100%
24% 20%
Santa Ana
0741.03
Middle
0%
n/a
16%
0%
n/a
n/a
n/a
0%
10% 12%
Santa Ana
0741.06
Mod
7%
n/a
13%
40%
n/a
n/a
n/a
0%
17% 26%
Santa Ana
0741.07
Middle
17%
0%
38%
14%
n/a
n/a
50%
33%
22% 24%
Santa Ana
0741.08
Mod
50%
n/a
31%
15%
n/a
n/a
n/a
0%
23% 23%
Santa Ana
0741.09
Mod
0%
n/a
20%
22%
n/a
n/a
n/a
50%
22% 21%
Santa Ana
0741.10
Middle
50%
n/a
0%
31%
n/a
n/a
0%
50%
23% 16%
Santa Ana
0741.11
Mod
0%
n/a 1
17%
0%
n/a
n/a
n/a
n/a
5% 7%
Santa Ana
0742.00
Mod
13%
n/a
27%
33%
n/a
n/a
n/a
33%
26% 28%
Santa Ana
0743.00
Mod
20%
n/a
28%
33%
n/a
n/a
n/a
0%
25% 29%
Santa Ana
0744.03
Low
n/a
n/a
17%
n/a
n/a
n/a
n/a
0%
14% 17%
Santa Ana
0744.05
Low
0%
n/a
0%
0%
n/a
n/a
n/a
0%
19% 0%
Santa Ana
0744.06
Mod
0%
n/a
33%
0%
n/a
n/a I
n/a
100%
0% 29%
Santa Ana
0744.07
Low
45%
n/a
75%
0%
n/a
n/a
n/a
0%
44% 50%
Santa Ana
0745.01
Low
100%
n/a
0%
60%
n/a
n/a
n/a
0%
36% 33%
Santa Ana
0745.02
Mod
0%
n/a
40%
38%
n/a
n/a
n/a
0%
35% 39%
Santa Ana
0746.01
Mod
31%
n/a
11%
22%
n/a
n/a
n/a
17%
20% 15%
Santa Ana
0746.02
Mod
0%
n/a
4%
20%
n/a
n/a I
n/a
14%
8% 7%
Santa Ana
0747.01
Mod
0%
n/a
32%
21%
0%
n/a
n/a
0%
25% 27%
Santa Ana
0747.02
Mod
0%
n/a
42%
0%
n/a
n/a
n/a
0%
32% 38%
Santa Ana
0748.01
Mod
0%
n/a
20%
20%
n/a
n/a
n/a
0%
15% 20%
Santa Ana
0748.02
Mod
0%
n/a
21%
25%
n/a
n/a
n/a
n/a
20% 22%
Santa Ana
0748.03
Mod
33%
n/a
27%
24%
n/a
n/a
100%
75%
31% 27%
Santa Ana
0748.05
Low
n/a
n/a
0%
0%
n/a
n/a
n/a
n/a
17% 0%
Santa Ana
0748.06
Low
0%
n/a
0%
20%
n/a
n/a
n/a
0%
0% 11%
Santa Ana
0749.01
Mod
33%
n/a
19%
33%
n/a
n/a
n/a
50%
26% 23%
Santa Ana
0749.02
Mod
0%
n/a
40%
25%
n/a
n/a 1
0%
0%
29% 33%
Santa Ana
0750.02
Mod
13%
100%
50%
33%
n/a
n/a
n/a
25%
30% 45%
Santa Ana
0750.03
Low
40%
n/a
75%
50%
n/a
n/a
n/a
0%
43% 67%
Santa Ana
0750.04
Low
25%
n/a
33%
n/a
n/a
n/a
n/a
0%
25% 33%
Santa Ana
0751.00
Low
0%
n/a
40%
0%
n/a
n/a
n/a
20%
18% 32%
Santa Ana
0752.01
Mod
0%
n/a
50%
41%
n/a
n/a
n/a
25%
40% 45%
Santa Ana
0752.02
IMod
0%
n/a
29%
20%
n/a
n/a
n/a
0%
23% 27%
Santa Ana
0753.01
Middle
18%
n/a
40%
0%
n/a
n/a
n/a
0%
17% 18%
Santa Ana
0753.02
Mod
13%
n/a 1
22%
0%
n/a
n/a
n/a
0%
16% 19%
Santa Ana
0753.03
Upper
3%
n/a
17%
67%
n/a
n/a
0%
13%
11% 25%
Page 12 of 14
14-257
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract
Income
White
Black I
Hispanic I
Applicant Race
Asian I Haw. Nat. Am.
Multi I
Unk/NA
I
Total
Min.
%
Santa Ana
0754.01
Middle
5%
0%
8%
33%
n/a
n/a
n/a
0%
9%
15%
Santa Ana
0754.03
Mod
17%
n/a
16%
38%
0%
n/a
n/a
50%
20%
21%
Santa Ana
0754.04
Mod
25%
n/a
0%
0%
n/a
n/a
n/a
25%
15%
0%
Santa Ana
0754.05
Middle
9%
n/a
14%
40%
n/a
n/a
n/a
0%
16%
21%
Santa Ana
0755.04
Middle
9%
n/a 1
17%
0%
n/a
n/a
n/a 1
17%
10%
8%
Santa Ana
0755.05
Mod
38%
0%
33%
0%
n/a
n/a
n/a
30%
33%
22%
Santa Ana
0755.15
Middle
20%
n/a
20%
16%
100%
n/a
n/a
18%
18%
18%
Santa Ana
0757.01
Middle
11%
0%
0%
0%
n/a
n/a
n/a
14%
9%
0%
Santa Ana
0758.06
Middle
4%
n/a
13%
38%
n/a
n/a
n/a
33%
13%
25%
Santa Ana
0759.02
Mod
9%
n/a
33%
50%
n/a
n/a I
n/a
0%
14%
38%
Santa Ana
0760.00
Mod
25%
100%
0%
26%
0%
100%
n/a
25%
25%
24%
Santa Ana
0889.03
Mod
n/a
n/a
0%
37%
n/a
n/a
0%
n/a
32%
32%
Santa Ana
0890.01
Mod
n/a
n/a
0%
4%
n/a
n/a
n/a
0%
3%
4%
Santa Ana
0890.04
Mod
33%
n/a
14%
23%
n/a
n/a
n/a
0%
21%
21%
Santa Ana
0891.02
Mod
14%
n/a
16%
19%
n/a
n/a
n/a
0%
16%
18%
Santa Ana
0891.04
Low
0%
n/a
30%
11%
n/a
n/a
n/a
0%
18%
21%
Santa Ana
0891.05
Mod
n/a
n/a
33%
44%
n/a
n/a
n/a
0%
35%
39%
Santa Ana
0891.07
Middle
0%
n/a
18%
23%
n/a
n/a
n/a
50%
23%
22%
Santa Ana
0992.02
Mod
0%
n/a
0%
15%
0%
n/a
n/a
25%
13%
13%
Santa Ana
0992.03
Middle
29%
n/a
0%
37%
n/a
n/a
n/a
n/a
33%
34%
Santa Ana
0992.47
Low
100%
n/a
0%
36%
n/a
n/a
n/a
n/a
31%
27%
Santa Ana
0992.48
Mod
0%
n/a
20%
20%
100%
n/a
n/a
n/a
25%
27%
Santa Ana
0992.49
Low
n/a
n/a
50%
11%
n/a
n/a
n/a
n/a
18%
18%
Santa Ana
Total
16%
29%
23%
22%
33%
100%
25%
19%
20%
23%
Tustin
0219.14
Upper
22%
n/a
0%
10%
n/a
0%
n/a
0%
12%
6%
Tustin
0524.19
Upper
14%
n/a 1
0%
17%
n/a
n/a
n/a 1
29%
16%
13%
Tustin
0525.02
Middle
16%
n/a
0%
20%
n/a
n/a
n/a
14%
16%
15%
Tustin
0525.24
Upper
0%
n/a
0%
8%
n/a
n/a
0%
14%
6%
7%
Tustin
0744.06
Mod
0%
n/a
33%
0%
n/a
n/a
n/a
100%
30%
29%
Tustin
0744.07
Low
45%
n/a
75%
0%
n/a
n/a
n/a
0%
44%
50%
Tustin
0744.08
Mod
18%
0%
0%
20%
n/a
n/a
n/a
33%
17%
11%
Tustin
0754.03
Mod
17%
n/a
16%
38%
0%
n/a
n/a
50%
20%
21%
Tustin
0755.04
Middle
9%
n/a
17%
0%
n/a
n/a
n/a
17%
10%
8%
Tustin
0755.05
Mod
38%
0%
33%
0%
n/a
n/a
n/a
30%
33%
22%
Tustin
0755.06
Middle
9%
0%1
14%
22%
0%
n/a
n/a
50%
15%
17%
Tustin
0755.07
Mod
20%
n/a
50%
0%
0%
n/a
n/a
n/a
20%
20%
Tustin
0755.12
Mod
0%
n/a
0%
0%
n/a
n/a
n/a
100%
13%
0%
Tustin
0755.13
Mod
11%
n/a
40%
11%
n/a
n/a
n/a
40%
24%
26%
Tustin
0755.14
Mod
0%
n/a
0%
0%
n/a
n/a
0%
50%
10%
0%
Tustin
0755.15
Middle
20%
n/a 1
20%
16%
100%
n/a
n/a
18%
18%
18%
Tustin
0756.03
Upper 1
0%
n/a I
n/a 1
9%
0%
n/a
n/a
0%
2%
8%
Page 13 of 14
14-258
Appendix C-2
Percent of Denied Purchase Loans - By Census Tracts - Applicant Race
2013
City
Number
Tract I
Income
White I
Black I
Hispanic I
Applicant Race
Asian I Haw. I Nat. Am. I
Multi I
Unk/NA I
I
Total
Min.
Tustin
0756.04
Upper
17%
n/a
0%
12%
n/a
0%
100%
31%
18%
14%
Tustin
0756.05
Upper
11%
n/a
56%
14%
0%
n/a
n/a
43%
18%
29%
Tustin
0756.06
Upper
16%
0%
0%
20%
n/a
n/a
n/a
25%
17%
16%
Tustin
0756.07
Upper
10%
n/a
0%
8%
n/a
n/a
0%
22%
10%
8%
Tustin
0757.01
Middle
11%
0%
0%
0%
n/a
n/a
n/a 1
14%
9%
0%
Tustin
0757.02
Middle
12%
n/a
0%
29%
n/a
n/a
n/a
0%
14%
25%
Tustin
Total
15%
0%
20%
13%
14%
0%
25%
24%
16%
15%
OC County
12%
18%
19%
16%
18%
17%
18%
16%
15%
17%
Source: www.lendingpatterns.com, October 2015
Tabulations: GRC Associates, Inc., October 2015
1 - Includes conventional and govt -assisted (FHA, FSA/RHS and VA) home purchase applications.
2 - Table includes all applications that went through the complete underwriting process,
and excludes applications withdrawn or files closed for incompleteness.
Page 14 of 14
14-259
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Appendix D: HUD Worksheet
APPENDIX
14-260
16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Survey of Zoning and Planning Codes, Policies and Practices
That May Pose an Impediment to Fair Housing Choice
HUD Worksheet
Name of Jurisdiction: City of Newport Beach
Completing Department: Community Development Department, Planning Division
Completed By: Melinda Whelan
Date Completed: September 16, 2015
INTRODUCTION
As part of the preparation of an Analysis of Impediments to Fair Housing Choice, which is required
for the receipt of certain federal funds, this survey seeks answers to questions regarding local
governmental codes or policies and practices that may result in the creation or perpetuation of one
or more impediments to fair housing choice. It has a particular focus on land use and zoning
regulations, practices and procedures that can act as barriers to the situating, development, or use
of housing for individuals with disabilities. However, it also touches on areas that may affect fair
housing choice for families with children or otherwise serve as impediments to full fair housing
choice.
The survey will help with the analysis of the codes and other documents related to land use and
zoning decision-making provided by the jurisdiction. Additional information may be sought through
interviews with appropriate staff. In identifying impediments to fair housing choice, the survey
looks to distinguish between regulatory impediments based on specific code provisions and practice
impediments, which arise from practices or implementing policies used by the jurisdiction.
APPENDIX D: HUD WORKSHEET
D-1
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
QUESTIONS
1. Does the Code definition of "family" have the effect of discriminating against unrelated
individuals with disabilities who reside together in a congregate or group living arrangement?
Yes No X
a. Background
Local zoning and land use laws that treat groups of unrelated persons with disabilities less favorably
than similar groups of unrelated persons without disabilities violate the Fair Housing Act. For
example, suppose a city's zoning ordinance defines "family" to include up to six unrelated persons
living together as a household unit, and gives such a group of unrelated persons the right to live in
any zoning district without special permission. If that ordinance also disallows a group home for six
or fewer people with disabilities in a certain district or requires this home to seek a use permit, such
requirements would conflict with the Fair Housing Act. The ordinance treats persons with
disabilities worse than persons without disabilities.
In 1980, the California Supreme Court in City of Santa Barbara v. Adamson struck down the City's
ordinance that permitted any number of related people to live in a house in a R1 zone, but limited
the number of unrelated people allowed to do so to five. Under the Santa Barbara ordinance, a
group home for individuals with disabilities that functions like a family could be excluded from the
R1 zone solely because the residents are unrelated by blood, marriage or adoption.
Both State and Federal fair housing laws prohibit definitions of family that either intentionally
discriminate against people with disabilities or have the effect of excluding such individuals from
housing. Fair housing laws, for instance, prohibit definitions of family that limit the development
and siting of group homes for individuals with disabilities (but not families similarly sized and
situated). Such definitions are prohibited because they could have the effective of denying housing
opportunities to those who, because of their disability, live in a group setting. The failure to modify
the definition of family or make an exception for group homes for people with disabilities may also
constitute a refusal to make a reasonable accommodation under the Fair Housing Act.
For example, the following definition of family would be inconsistent with fair housing laws:
"Family" means a householder and one or more other people living in the same household
who are related to the householder by birth, marriage or adoption.
A definition of family should look to whether the household functions as a cohesive unit instead of
distinguishing between related and unrelated persons.
APPENDIX D: HUD WORKSHEET
D-2
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REGIONAL ANALYSIS OF IMPEDIMENTS
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Newport Beach Zoning Code definition of "family' is: "One or more persons living together as a
single housekeeping unit in a dwelling unit."
A "single housekeeping unit" is defined by the Newport Beach Zoning Code as: "The functional
equivalent of a traditional family, whose members are an interactive group of persons jointly
occupying a single dwelling unit, including the joint use of and responsibility for common areas, and
sharing household activities and responsibilities such as meals, chores, household maintenance, and
expenses, and where, if the unit is rented, all adult residents have chosen to jointly occupy the
entire premises of the dwelling unit, under a single written lease with joint use and responsibility for
the premises, and the makeup of the household occupying the unit is determined by the residents
of the unit rather than the landlord or property manager."
The definitions of "family" or "single housekeeping unit" do not make any distinction between the
relationships of the individuals, and therefore, does not have the effect of discriminating against
unrelated individuals, or individuals with disabilities who reside together in a congregate or group
living arrangement.
2. Does the Code or any policy document define "disability', if at all, at least as broadly as the
Fair Housing Act? Yes X No
a. Background
The Fair Housing Act prohibits discrimination on the basis of handicap or disability, and defines
persons with disabilities as: "individuals with physical or mental impairments that substantially limit
one or more major life activities; has a record of such impairment; or is regarded as having such
impairment."
The term physical or mental impairments may include conditions such as blindness, hearing
impairment, mobility impairment, HIV infections, AIDS, AIDS Related Complex, mental retardation,
chronic alcoholism, drug addiction, chronic fatigue, learning disability, head injury, and mental
illness. The term major life activities may include walking, talking, hearing, seeing, breathing,
learning, performing manual tasks, and caring for oneself.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Newport Beach Zoning Code definition of "individual with a disability' is: "As more specifically
defined under the fair housing laws, a person who has a physical or mental impairment that limits
one or more major life activities, a person who is regarded as having that type of impairment, or a
APPENDIX D: HUD WORKSHEET
D-3
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
person who has a record of that type of impairment, not including current, illegal use of a controlled
substance."
This definition of disability is very similar to the FEHA definition and as a result, it is not considered
discriminatory.
3. Are the personal characteristics of the (disabled) residents considered? Yes No X
a. Background
Under the Fair Housing Act, cities may have reasonable restrictions on the maximum number of
occupants permitted to occupy a dwelling; however, the restrictions cannot be based on the
characteristics of the occupants; the restrictions must apply to all citizens, and are based upon
health and safety standards. Similarly, a conditional use permit or variance requirement triggered
by the number of people with certain characteristics (such as a disability) who will be living in a
particular dwelling, is prohibited. Because licensed residential care facilities serve people with
disabilities, imposing a variance requirement on family -like facilities of a certain size and not
similarly sized housing for people without disabilities violates fair housing laws.
According to the DOJ and HUD, "group home" does not have a specific legal meaning. In the
DOJ/HUD Joint Statement* -
"...the term group home refers to housing occupied by groups of unrelated individuals with
disabilities. Sometimes, but not always, housing is provided by organizations that also offer
services for individuals with disabilities living in the group home. Sometimes it is this group
home operator, rather than the individuals who live in the home, that interacts with local
government in seeking permits and making requests for reasonable accommodations on
behalf of those individuals."
"The term group home is also sometimes applied to any group of unrelated persons who live
together in a dwelling — such as a group of students who voluntarily agree to share the rent on
a house. The Act does not generally affect the ability of local governments to regulate housing
of this kind, as long as they do not discriminate against residents on the basis of race, color,
national origin, religion, sex, handicap (disability) or familial status (families with minor
children)."
"Local zoning and land use laws that treat groups of unrelated persons with disabilities less
favorably than similar groups of unrelated persons without disabilities violate the Fair Housing
Act."
[*Joint Statement of DOJ and HUD, Group Homes, Local Land Use, and the Fair Housing Act,
August 18, 1999, page 3]
APPENDIX D: HUD WORKSHEET
D-4
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
Except when granting access to disabled individuals or groups that exceeds housing access granted
to other similarly situated groups, the Municipal Code and Zoning Code do not consider the
characteristics of the residents of a dwelling. Instead, the code considers whether or not a group of
individuals are residing in the dwelling as a single housekeeping unit. A group of individuals living as
a single housekeeping unit, whether disabled or nondisabled, can live together in any district zoned
for residential use in the City.
4. Does the zoning ordinance restrict housing opportunities for individuals with disabilities and
mischaracterize such housing as "boarding or rooming house" or "hotel'?
Yes No X
a. Background
Housing for disabled persons in some communities is limited to certain residential zones. Often,
housing for disabled persons is included in how cities define a boarding house or hotel.
Under California State law, licensed facilities serving six persons or fewer receive special land use
protection. California requires that many types of licensed facilities serving six persons or fewer be
treated for zoning purposes like single-family homes. Except in extraordinary cases in which even
single-family home requires a conditional use permit, these laws bar conditional use permits for
facilities that serve six or fewer persons. The land use protection applies to —
o Intermediate care facilities for individuals who have developmental disabilities
o Residential facilities for persons with disabilities and for abused children
o Residential care facility for the elderly
o Alcoholism and drug treatment facilities
o Residential facilities for persons with chronic life threatening illness
For example, Health and Safety Code Section 11834.23 (Zoning Laws) states:
"Whether or not unrelated persons are living together, an alcoholism or drug abuse recovery
or treatment facility, which serves six or fewer persons shall be considered a residential use of
property for the purposes of this article. In addition, the residents and operators of such a
facility shall be considered a family for the purposes of any law or zoning ordinance which
relates to the residential use of property..."
Furthermore:
"No conditional use permit, zoning variance, or other zoning clearance shall be required of an
alcoholism or drug abuse recovery or treatment facility which serves six or fewer persons that
is not required of a single —family residence in the some zone."
APPENDIX D: HUD WORKSHEET
D-5
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
Essentially, identical provisions are stated with regard to a residential facility, which serves six or
fewer persons. A residential facility
"...means any family home, group care facility, or similar facility for 24-hour nonmedical
care of persons in need of personal services, supervision, or assistance essential for
sustaining the activities of daily living or for the protection of the individual."
Health and Safety Code Section 1566.3 states:
"No conditional use permit, zoning variance, or other zoning clearance shall be required of a
residential facility which serves six or fewer persons which is not required of a family dwelling
of the same type in the same zone."
Further:
"'family dwelling' includes, but is not limited to, single-family dwellings, units in multi -family
dwellings, including units in duplexes and units in apartment dwellings, mobile homes,
including mobile homes located in mobile home parks, units in cooperatives, units in
condominiums, units in townhouses, and units in planned developments."
State law requires that residential care facilities not be defined within the meaning of boarding
house, rooming house, institution or home for the care of minors, the aged, or the mentally infirm,
foster care home, guest home, rest home, sanitarium, mental hygiene home, or other similar term
which implies that a residential facility is a business run for profit.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
For groups not living as a single housekeeping unit, the code provides more favorable treatment to
disabled groups than non -disabled groups. Licensed residential care facilities housing six or fewer
individuals can locate in any residential zone in the City while all other groups not living as single
housekeeping units are prohibited in all residential zones of the City. In this way, the City makes a
favorable exception for groups of individuals with disabilities. The Zoning Code also provides both a
use permit and reasonable accommodation procedure that allow groups of disabled individuals not
living as single housekeeping units to establish residences in residential zones within the City.
5. Does the zoning ordinance deny housing opportunities for disabled individuals with on site
housing supporting services ? Yes No X
APPENDIX D: HUD WORKSHEET
D-6
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
a. Background
Housing for disabled persons often must incorporate on-site supportive services. Zoning provisions
that limit on-site supportive services will, in effect curtail the development of adequate housing for
the disabled. As the joint statement by DOJ and HUD indicates:
"Sometimes, but not always, housing is provided by organizations that also offer services for
Individuals with disabilities living in the group home."
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Zoning Code places no restrictions on the provision of any on-site supportive services required
by disabled individuals, and therefore, they would be allowed.
6. Does the jurisdiction policy allow any number of unrelated persons to reside together, but
restrict such occupancy, if the residents are disabled? Yes No X
a. Background
The joint statement by DOJ and HUD describes this issue as follows:
"A local government may generally restrict the ability of groups of unrelated persons to live
together as long as the restrictions are imposed on all such groups. Thus, in the case where a
family is defined to include up to six unrelated people, an ordinance would not, on its face,
violate the Act if a group home of seven unrelated people with disabilities was not allowed to
locate in single-family zoned neighborhood, because a group of seven unrelated people
without disabilities would also not be allowed."
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Zoning Code makes no distinction between and does not consider whether groups living
together are related or unrelated to each other. In addition, for groups not living as a single
housekeeping unit, the code provides more favorable treatment to disabled groups than non -
disabled groups. Licensed residential care facilities housing six or fewer individuals can locate in any
residential zone in the City. Although all other groups not living as single housekeeping units are
prohibited in all residential zones of the City. In this way, the City makes a favorable exception for
groups of disabled individuals. The Zoning Code provides use permit and reasonable
accommodation procedures that allow groups of disabled individuals not living as single
housekeeping units to establish residences in residential zones within the City.
APPENDIX D: HUD WORKSHEET
D-7
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16 ORANGE COUNTY CITIES
REGIONAL ANALYSIS OF IMPEDIMENTS
7. Does the jurisdiction policy not allow disabled persons to make reasonable modifications or
provide reasonable accommodation for disabled people who live in municipal -supplied or
managed residential housing? Yes No X or N/A
a. Background
A joint statement by DOJ and HUD explains this issue as follows:
"As a general rule, the Fair Housing Act makes it unlawful to refuse to make 'reasonable
accommodations' (modifications or exceptions) to rules, policies, practices, or services, when
such accommodations may be necessary to afford persons with disabilities an equal
opportunity to use or enjoy a dwelling."
"Even though a zoning ordinance imposes on group homes the same restrictions it imposes on
other groups of unrelated people, a local government may be required, in individual cases and
when requested to do so, to grant a reasonable accommodation to a group home for persons
with disabilities. For example, it may be a reasonable accommodation to waive a setback
required so that a paved path of travel can be provided to residents who have mobility
impairments. A similar waiver might not be required for a different type of group home
where residents do not have difficulty negotiating steps and do not need a setback in order to
have an equal opportunity to use and enjoy a dwelling."
"Where a local zoning scheme specifies procedures for seeking a departure from the general
rule, courts have decided, and the Department of Justice and HUD agree, that these
procedures must ordinarily be followed. If no procedure is specified, persons with disabilities
may, nevertheless, request a reasonable accommodation in some other way, and a local
government is obligated to grant it if it meets the criteria discussed above. A local
government's failure to respond to a request for reasonable accommodation or an inordinate
delay in responding could also violate the Act."
"Local governments are encouraged to provide mechanisms for requesting reasonable
accommodations that operate promptly and efficiently, without imposing significant costs or
delays. The local government should also make efforts to insure that the availability of such
mechanisms is well known within the community."*
[*Joint Statement of DOJ and HUD, Group Homes, Local Land Use, and the Fair Housing Act,
August 18, 1999, pages 3 and 4]
The Fair Housing Act requires housing providers to make reasonable accommodations for persons
with disabilities. A reasonable accommodation is a change in rules, policies, practices, or services so
that a person with a disability will have an equal opportunity to use and enjoy a dwelling unit or
common space. A housing provider should do everything s/he can to assist, but s/he is not required
to make changes that would fundamentally alter the program or create an undue financial and
administrative burden. Reasonable accommodations may be necessary at all stages of the housing
process, including application, tenancy, or to prevent eviction.
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Example: A housing provider would make a reasonable accommodation for a tenant with mobility
impairment by fulfilling the tenant's request for a reserved parking space in front of the entrance to
their unit, even though all parking is unreserved.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The City does not own or manage any housing units.
8. Does the jurisdiction require a public hearing to obtain public input for specific exceptions to
zoning and land use rules for disabled applicants and is the hearing only for disabled
applicants rather than for all applicants? Yes X No
a. Background
Persons with disabilities cannot be treated differently from non -disabled persons in the application,
interpretation and enforcement of a community's land use and zoning policies.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The City does not require disabled individuals to apply for a variance in order to obtain an exception
from zoning and land use rules. Instead, the Zoning Code provides reasonable accommodation
procedures for disabled individuals and groups. Like variances, reasonable accommodations involve
a public hearing, but the matter is heard before a hearing officer rather than the Planning
Commission. Unlike the variance application, the reasonable accommodation application does not
require a fee.
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9. Does the zoning ordinance address mixed uses? Yes X No
How are the residential land uses discussed? What standards apply?
a. Background
Housing for disabled persons in a mixed-use development that includes commercial and residential
land uses in a multi -story building could be a challenge. In such a development, it is especially
important to correctly interpret the Title 24 accessibility requirements.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
Yes, the Zoning Code allows for mixed uses consistent with the General Plan. The ordinance considers the
ability of mixed-use development to enhance housing affordability and the Building Code includes
standards for mixed -uses taking into consideration the challenges of providing housing accessible to
persons with disabilities in such mixed-use buildings. Building disability standards are consistently applied
to all like buildings and structures.
10. Does the zoning ordinance describe any areas in this jurisdiction as exclusive?
Yes No X
Are there exclusions or discussions of limiting housing to any of the following groups?
Yes No -X If yes, check any of the following that apply:
Race _Color _Sex
Marital or Familial Status
a. Background
Religion _Age _Disability
Creed or National Origin
Fair housing means the ability of persons of similar income levels to have available to them the
same housing choices. The City's land use and zoning policies cannot exclude persons from living in
the neighborhoods in which they want to reside.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Zoning Code and adopted Planned Communities do not exclude anyone from residing in any
neighborhood based upon race, color, creed or national origin, sex, gender affiliation, religious
beliefs, age, disability, or marital/familial status.
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11. Are there any restrictions for Senior Housing in the zoning ordinance? Do the restrictions
comply with Federal law on housing for older persons (i.e., solely occupied by persons 62
years of age or older or at least one person 55 years of age or older and has significant
facilities or services to meet the physical or social needs of older people?) Yes X No
a. Background
According to HUD, the Fair Housing Act protests all citizens from discrimination on the basis of
familial status — that is, families with children under the age of 18 living with parents or legal
guardians; pregnant women; and people trying to secure custody of children under 18. However,
housing that meets the Fair Housing Act's definition of 'housing for older persons' is exempt from
the law's familial status requirements, provided that:
o HUD has determined that the dwelling is specifically designed for and occupied by elderly
persons under a Federal, State or local government program, or
o It is occupied by persons who are 62 or older, or
o It houses at least one person who is 55 or older in at least 80% of the occupied units, and
adheres to a policy that demonstrates intent to house persons who are 55 or older.
The Housing for Older Persons Act of 1995 eliminated the requirements for "significant services and
facilities" (mentioned in Q. 11) within designated senior housing units or areas.
In California, Section 51 of the Unruh Civil Rights Act, also defines seniors as meaning persons 62
years of age or older, or 55 years of age and older in a senior citizen housing development. A senior
citizen housing development is one for senior citizens that has at least 35 dwelling units.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
Senior housing is not treated differently than any other rental or for -sale housing and is allowed in
any zoning district that allows residential uses. The City makes two favorable accommodations for
senior housing. First, Section 20.48.200 of the Zoning Code allows for the creation of "granny units"
pursuant to California Government Code Section 65852.2 in zoning districts where there is only one
dwelling unit permitted. This specific accommodation is not provided to other populations. Second,
Section 20.40.040 of the Zoning Code allows a lower parking ratio for senior housing based upon the
premise that seniors drive less. These two favorable accommodations are in response to the City's
high senior population and current National demographic trends attempting to facilitate increased
senior housing.
12. Does the zoning ordinance contain any special provisions for making housing accessible to
persons with disabilities? Yes No X
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a. Background
Fair housing laws that require accessible units apply to "covered multifamily dwellings" constructed
for first occupancy after March 13, 1991. First occupancy is defined as a "building that has never
been used for any purpose".
There is no timetable for the production of accessible housing; as such housing is constructed when
residential projects are built. The Fair Housing Act does not require any renovations to existing
buildings. Its design requirements apply to new construction only.
Both privately owned and publicly assisted housing — including rental and for sale units — must
meet the accessibility requirements when they are located in 1) buildings of four or more dwellings
if such buildings have one or more elevators, and 2) all ground floor dwellings in other buildings
containing four or more units.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The provision for making housing accessible to persons with disabilities is found within the 2013
Edition of the California Building Code. Fair Housing is referenced within the Building Code Sections
but the Fair Housing Amendments Act of 1988 is not specifically cited.
13. Does the ordinance establish occupancy standards or maximum occupancy limits?
Yes X No,
Do the restrictions exceed those imposed by state law? Yes _ No
a. Background
Occupancy standards sometimes can impede the development of housing for disabled persons.
Some zoning regulations limit occupancy to five related persons occupying a single family home.
Such regulations can prevent the development of housing for disabled persons.
The Fair Housing Act provides that nothing in the Act "limits the applicability of any reasonable local,
State or Federal restrictions regarding the maximum number of occupants permitted to occupy a
dwelling".
HUD implements section 589 of the QHWRA by adopting as its policy on occupancy standards for
purposes of enforcement actions under the Fair Housing Act, the standards provided in the
Memorandum of General Counsel Frank Keating to Regional Counsel dated March 20, 1991.
Specifically, HUD believes that an occupancy policy of two persons in a bedroom, as a general rule, is
reasonable under the Fair Housing Act. However, HUD has pointed out, that there is nothing in the
legislative history which indicates any intent on the part of Congress to provide for the development
of a national occupancy code.
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Thus, HUD believes that in appropriate circumstances, owners and managers may develop and
implement reasonable occupancy requirements based on factors such as the number and size of
sleeping areas or bedrooms and the overall size of the dwelling unit.
In this regard, it must be noted, in connection with a complaint alleging discrimination on the basis
of familial status, HUD will carefully examine any such nongovernmental restriction to determine
whether it operates unreasonably to limit or exclude families with children.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Zoning Code does not generally limit the number individuals who may occupy a residential unit.
However, Zoning Code Section 20.52.030.G.2.b states: "There shall be no more than two residents
per bedroom, plus one additional resident. Notwithstanding, upon request by the applicant for
additional occupancy, the Hearing Officer has discretion to set occupancy limits based upon the
evidence provided by the applicant that additional occupancy is appropriate at the site. In
determining whether to set a different occupancy limit, the Hearing Officer shall consider the
characteristics of the structure, whether there will be an impact on traffic and parking and whether
the public health, safety, peace, comfort, or welfare of persons residing in the facility or adjacent to
the facility will be impacted." The standard above does not apply generally to residential units and
it only applies when a hearing officer is reviewing a use permit for certain uses within residential
districts. Specifically, the hearing officer reviews requests for bed and breakfast inns, general day
care uses, and residential care facilities with the exception of State licensed facilities with 6 or fewer
residents. The standard does allow flexibility for an applicant to request and receive a different
number of occupants when appropriate and the specific facts of each living situation inform the final
determination through the discretionary use permit process.
14. Does the zoning ordinance include a discussion of fair housing? Yes No X
If yes, how does the jurisdiction propose to further fair housing?
a. Background
Affirmatively furthering fair housing is an important responsibility of local government. Although a
city may have numerous plans, policies, and standards, fair housing is rarely discussed in a zoning
ordinance. Other documents of a city may further fair housing.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Zoning Code does not provide general discussion of fair housing but it provides a definition of
applicable fair housing laws. In accordance with federal and state Fair Housing laws NBMC Section
20.52.070 provides reasonable accommodations in the City's zoning and land use regulations,
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policies and practices, when needed to provide an individual with a disability an equal opportunity
to use and enjoy a dwelling.
15. Describe the minimum standards and amenities required by the ordinance for a multiple
family project with respect to handicap parking?
a. Background
Federal and State laws require handicap parking. To further fair housing for disabled persons, a
city's requirements should equal or exceed the minimum standards of Federal and State laws.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Zoning Code requires that parking for the disabled be properly stripped and marked. The
number of disabled parking spaces is provided consistent with the 2013 Edition of the California
Building Code adopted by reference by the City.
16. Does the zoning code distinguish senior citizen housing from other single- and multifamily
residential uses by the application or a conditional use permit (CUP)? Yes No X
a. Background
Senior housing is an important component of the community's housing stock. As a population ages,
seniors need a variety of housing opportunities.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Zoning Code distinguishes between convalescent housing and residential uses but not between senior
citizen housing and residential uses.
17. How are "special group residential housing units" defined in the jurisdiction's zoning code?
a. Background
The term group home does not have a specific legal meaning. According to the DOJ/HUD Joint
Statement the term 'group home' is sometimes applied to any group of unrelated persons who live
together in a dwelling — such as a group of students who voluntarily agree to share the rent on a
house. The Fair Housing Act does not generally affect the ability of local governments to regulate
housing of this kind, as long as they do not discriminate against residents on the basis of race, color,
national origin, religion, sex, handicap (disability) or familial status (families with minor children).
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b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The Zoning Code includes a definition for "Group Residential" uses as "meaning shared living
quarters, occupied by two or more persons not living together as a single housekeeping unit ("Single
housekeeping unit"). Includes, without limitation, boarding or rooming houses (see "Boarding or
rooming house"), dormitories, fraternities, sororities, parolee -probationer homes (see "Parolee -
probationer home"), and private residential clubs. Excludes residential care facilities (see
"Residential care facilities")" (emphasis added). "Residential Care Facilities" allow for a place, site or
building, or groups of places, sites or buildings, licensed or unlicensed by the State, in which
individuals with a disability reside who are not living together as a single housekeeping unit (see
"Single housekeeping unit") and in which every person residing in the facility (excluding the licensee,
members of the licensee's family, or persons employed as facility staff) is an individual with a
disability. Housing Element Goal H5 and Housing Programs 5.1.1 through 5.1.8 found in the Housing
Element also address the housing needs of the special needs population within the City.
18. Do the jurisdiction's planning and building codes presently make a specific reference to the
accessibility requirements contained in the 1988 amendments to the Fair Housing Act?
Yes No X
Is there any provision for monitoring compliance? Yes No X
a. Background
The Fair Housing Act establishes accessibility requirements for new housing. Title 24 of the
California Code of Regulations, known as the California Building Standards Code or just 'Title 24',
contains the regulations that govern the construction of buildings in California. Chapter 11A
contains the regulations governing housing accessibility. The City enforces the Title 24 accessibility
regulations.
b. Explanation of Answer Given Above
In light of the background provided, please provide a brief explanation of the how you arrived at
your answer:
The provision for making new housing accessible to persons with disabilities is found within the
2013 Edition of the California Building Code that has been adopted by reference by the City. Fair
Housing is referenced within the Building Code but the 1988 Amendments of the Fair Housing Act
are not specifically cited.
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