HomeMy WebLinkAboutMINUTES - 05252010 - SD.5RECOMMENDATION(S):
Continued public hearing to consider adoption of the Analysis of Impediments to Fair
Housing, including:
1. ACCEPTING a report from the Director of Conservation and Development responding to
concern expressed by Bay Area Legal Aid and Public Advocates, Inc.;
2. APPROVING the Analysis of Impediments of Fair Housing Choice; and
3. DETERMINING that this action is not a project under the California Environmental
Quality Act (CEQA) pursuant to Section 15061(b)(3) of the CEQA guidelines.
FISCAL IMPACT:
No General Fund impact. All funds are provided to the County on a formula basis through
the U.S. Department of Housing and Urban Development.
APPROVE OTHER
RECOMMENDATION OF CNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
Action of Board On: 05/25/2010 APPROVED AS RECOMMENDED OTHER
Clerks Notes:
VOTE OF SUPERVISORS
AYE:John Gioia, District I Supervisor
Gayle B. Uilkema, District II
Supervisor
Mary N. Piepho, District III
Supervisor
Susan A. Bonilla, District IV
Supervisor
Federal D. Glover, District V
Supervisor
Contact: Bob Calkins, (925)
335-7220
I hereby certify that this is a true and correct copy of an action taken and entered on the minutes of the Board
of Supervisors on the date shown.
ATTESTED: May 25, 2010
David J. Twa, County Administrator and Clerk of the Board of Supervisors
By: KATHERINE SINCLAIR, Deputy
cc:
SD. 5
To:Board of Supervisors
From:Catherine Kutsuris, Conservation & Development Director
Date:May 25, 2010
Contra
Costa
County
Subject:Approval of the Analysis of Impediments to Fair Housing Choice
BACKGROUND:
On April 27, 2010, the Board of Supervisors adopted the FY 2010 – 2015 Consolidated
Plan and the FY 2010/11 Annual Action Plan for the use of Community Development
Block Grant (CDBG), HOME Investment Partnerships Act (HOME), Emergency Shelter
Grants (ESG), and Housing Opportunities for Persons with AIDS (HOPWA) funds. The
Board continued the discussion on the Analysis of Impediments to Fair Housing Choice
(Attachment A) to May 25, 2010 to allow staff time to respond to a letter received on
April 26, 2010 (Attachment C) from Bay Area Legal Aid and Public Advocates, Inc.
(BALA/PA).
The Consolidated Plan regulations require Entitlement Jurisdictions that receive any of
the above sources of funds to affirmatively further fair housing (AFFH), and the CDBG
program specifically requires that each Entitlement Jurisdiction certify that it will
"affirmatively further fair housing."
The extent of the AFFH obligation has never been defined statutorily. However, the
Department of Housing & Urban Development (HUD) defines it as requiring an
Entitlement Jurisdiction to conduct an analysis to identify impediments to fair housing
choice within the jurisdiction; take appropriate actions to overcome the effects of any
impediments identified through the analysis; and maintain records reflecting the analysis
and actions taken in this regard (24 CFR 91).
HUD interprets those broad objectives to mean:
• Analyze and eliminate housing discrimination in the jurisdiction
• Promote fair housing choice for all persons
• Provide opportunities for inclusive patterns of housing occupancy regardless of race,
color, religion, sex, familial status, disability and national origin
• Promote housing that is structurally accessible to, and usable by, all persons,
particularly persons with disabilities
• Foster compliance with the nondiscrimination provisions of the Fair Housing Act
(HUD Fair Housing Planning Guide [March, 2006] at p 1-2)
Although the Entitlement Jurisdiction's AFFH obligation arises in connection with the
receipt of federal funding, its AFFH obligation is not restricted to the design and
operation of HUD-funded programs at the State or local level. The AFFH obligation
extends to all housing and housing-related activities in the Entitlement Jurisdiction's area,
whether publicly or privately funded. The guidance encourages a metro wide or regional
fair housing plan (FHP).
The Entitlement Jurisdictions of Antioch, Concord, Pittsburg, Richmond, Walnut Creek,
and Contra Costa County (Contra Costa Consortium) drafted a County-wide
Consolidated Plan and Analysis of Impediments to Fair Housing Choice (AI).
Before drafting the AI, the Contra Costa Consortium held two public meetings, one each
in Antioch and Richmond, to obtain input from fair housing service providers, public
agencies, community groups, and the general public. A notice of the meetings was
published in the Contra Costa Times and sent to a mailing list of over 500 agencies,
including Bay Area Legal Aid. The major agenda topics during the two public meetings
were:
• Purpose of the AI (what it does and the role of stakeholders)
• Housing Discrimination (forms of discrimination and the federal and state protected
classes)
• Community and Stakeholders input/experience with fair housing and housing
discrimination within their communities
Public participation was encouraged throughout the process. In addition to the two public
meetings, the Contra Costa Consortium solicited input via an on-line/internet survey that
was accessible during the months of August, September, and October 2009. According to
our records, neither BALA or PA attended any of the meetings or participated via the
survey.
Comments by BALA/PA: The letter was generally critical of the AI with particular
emphasis on the impediments to fair housing choice by Section 8 families (Section A of
the letter), and impediments imposed by the failure to identify and remove governmental
constraints to the development of affordable housing (Section B of the letter). Staff has
provided a response to each comment contained in the BALA/PA letter (see Attachment
B), and believes that the responses provided adequately address the comments contained
in the letter. Consequently, staff recommends approval of the Analysis of Impediments to
Fair Housing Choice.
CONSEQUENCE OF NEGATIVE ACTION:
CHILDREN'S IMPACT STATEMENT:
CLERK'S ADDENDUM
CLOSED the hearing; ACCEPTED report from the Director of Conservation and
Development; APPROVED the Analysis of Impediments of Fair Housing Choice; and
DETERMINED this action is not a project under the California Environmental
Quality Act (CEQA) pursuant to Section 15061(b)(3) of the CEQA guidelines.
ATTACHMENTS
Attachment A - Analysis of Impediments to Fair Housing Choice
Attachment B - Staff Reponse to BALA/PA Letter
Attachment C - BALA/PA Letter dated April 26, 2010
Attachment D - City of Antioch Letter dated April 29, 2010
Attachment E - Housing Element Status Chart