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Analysis of Impediments to Fair Housing & Fair Housing Action Plan Adopted 2003 Prepared by: The City of Moscow Fair Housing Commission DRAFT 02/10/03 ---PAGE BREAK--- i Table of Contents I. INTRODUCTION 1 II. EXECUTIVE SUMMARY 2 III. PLAN 3 IV. JURISDICTIONAL BACKGROUND 3 A. Housing Stock 4 B. Demographic 6 1. 6 2. Sampling 6 3. Household Selection 7 4. Survey Results 7 5. 17 V. ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING AND FAIR HOUSING ACTION PLAN 19 A. Public Sector 19 1. Comprehensive Plan 19 2. Zoning Ordinance 20 3. Subdivision 22 4. Building 22 5. Municipal 22 6. Employment, Housing and 23 7. Administrative 23 8. Property Tax 23 9. Planning and Zoning Commission and Zoning/Board of 24 10. Temporary Reduction of University of Idaho Housing 24 B. Private Sector 24 1. Architects, Builders, Contractors, Developers and 25 2. 26 3. Property Managers and 26 4. Realtors and Real Estate 26 5. Social Service 27 6. 27 ---PAGE BREAK--- ii Table of Contents (Continued) VI. FAIR HOUSING 28 VII. AFFORDABLE HOUSING 29 VIII. 31 IX. 32 X. 32 ---PAGE BREAK--- iii Index to Tables and Figures Table 1. Source of information used to find current housing 7 Table 2. Source of information by block used to find current housing unit. 8 Table 3. Frequency of households located by “other” sources of 8 Table 4. Number of households by block located by “other” sources of information.......... 9 Table 5. Factors influencing choice of 9 Table 6. Conditions affecting or limiting choice of housing. 10 Table 7. Could move to any other 11 Table 8. Could move to any other location by 11 Table 9. Reasons for ten households answering “No” to Question 4 11 Table 10. Number of knowing any examples of housing 12 Table 11. Number of knowing any examples by race of 12 Table 11a. Number of adults in unit 13 Table 11b. Number of adults in unit by block 13 Table 12a. Number of children in 13 Table 12b. Number of children in unit by 14 Table 13. The number of households by 14 Table 14. The number of households by race in each 14 Table 15. Number of households by racial 15 Table 16. Number of people with a 15 Table 17. Number of people with a disability by 15 Table 18. 16 Table 19. Ownership by 16 Figure 1. Map of Survey Blocks 18 ---PAGE BREAK--- iv Index to Fair Housing Action Items Action Item No. 1 (City Comprehensive Plan) 20 Action Item No. 2 (City Comprehensive Plan) 20 Action Item No. 3 (City Zoning Code) 21 Action Item No. 4 (City Zoning Code) 21 Action Item No 5 (Tax Policy) 24 Action Item No. 6 (Lack of Training, Design and Construction) 25 Action Item No. 7 (Lack of Understanding, Property Managers) 26 Action Item No. 8 (Lack of Training, Realtors) 27 Action Item No. 9 (Lack of Training, Social Service Agencies) 27 Action Item No. 10 (Rental Housing Advertisers) 28 Action Item No. 11 (Fair Housing Enforcement Agencies) 29 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 1 of 32 I. INTRODUCTION The Federal Fair Housing Act, 42 U.S.C. §3601 et seq., prohibits discrimination in the sale or rental of housing on the basis of race, color, religion, sex, national origin, handicap, and familial status (the presence of children under the age of eighteen years old). Furthermore, the Idaho Human Rights Act, I.C. 67-5901 et seq., also prohibits discrimination on the basis of race, color, religion, sex, national origin, and disability in all real-estate transactions in the state of Idaho. The State of Idaho has adopted the Idaho Fair Housing Plan, which was revised in January 1999. The Idaho Fair Housing Plan was prepared by the Idaho Department of Commerce in cooperation with the Idaho Housing and Finance Association on behalf of the State of Idaho. The impetus for the preparation of the Idaho Fair Housing Plan came from the United States Department of Housing and Urban Development (hereinafter “HUD”). Since 1983, the Community Development Block Grant (hereinafter “CDBG”) program has required that recipients of CDBG funding certify that they will affirmatively promote fair housing. Since 1995, HUD has required grantees to certify that they will affirmatively promote fair housing by preparing an analysis of impediments to fair housing choice within their jurisdiction, implement actions to overcome the effects of any impediments identified by the analysis of impediments, and maintain records of all relevant activities and actions taken. The State of Idaho prepared the Idaho Fair Housing Plan in order to comply with these HUD requirements. The Idaho Fair Housing Plan provides that rather than attempt to “research and analyze every possible aspect of the impediments identified, the resources needed, and the actions to be taken, and to catalogue them into a single document, . . . the State of Idaho established a planning process through which existing data and information is utilized to prepare the first Fair Housing Plan. As part of the process of preparing and updating the Consolidated Plan, the Fair Housing Plan is to be periodically revised to reflect new information, changing conditions, and evolving strategies to affirmatively further fair housing in Idaho.” Idaho Fair Housing Plan, p. 2. The Idaho Fair Housing Plan further states that its purpose is “to provide documentation of the fair housing problems identified through the analysis of impediments and the action strategies designed to mitigate and/or eliminate the impediments to fair housing choice.” Idaho Fair Housing Plan, p. 3. Similarly, this Analysis of Impediments to Fair Housing and Fair Housing Action Plan (hereinafter “Plan” or “the Plan”) is the City of Moscow’s endeavor to fulfill the CDBG requirements instituted by HUD and to promote compliance with the federal Fair Housing Act. The duties of the Moscow Fair Housing Commission (hereinafter “the Commission”), as established by the Moscow City Council are to further fair and affordable housing practices and education of the public, housing providers, and other individuals involved in the housing industry with respect to fair housing and the requirements of the relevant laws and regulations. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 2 of 32 II. EXECUTIVE SUMMARY Section III of this Plan provides details concerning the legislative basis and the actions taken for preparation and completion of the Plan. Section IV of the Plan sets forth jurisdictional information and analysis concerning the housing stock currently in existence in the city of Moscow, Idaho and a demographic profile of the housing stock and its residents. The housing stock profile provides an overview of contemporary housing inventory in light of historic trends that have affected and shaped the housing stock. The demographic profile was formulated based on quantitative research and examines demographic patterns existing in the city. Section V of the Plan sets out the results of the Commission’s analysis of both the public sector and the private sector in order to determine whether impediments to fair housing exist. Section VI provides details concerning the state of fair housing enforcement in Idaho, and examines the several enforcement entities that provide these services. Information regarding fair housing complaints that have been filed with the various enforcement entities is included. Finally, Section VII presents information regarding the state of affordable housing in Moscow and its relationship to fair housing. Rather than provide for a separate fair housing action plan, Fair Housing Action Items are included throughout the Plan where impediments to fair housing have been identified. An index to these items is provided in the Table of Contents, and each item is set out individually in a text box detailing the particular impediment identified and the proposed action to be taken in order to resolve the impediment. Few systemic impediments to fair housing have been identified in the public sector. Several possible impediments were identified in the City of Moscow’s Zoning Code and Comprehensive Plan. Appropriate Fair Housing Action Items have been devised in order to resolve these impediments. In the private sector, more substantial impediments were identified, particularly in the area of education and understanding with regards to the particular requirements of the Fair Housing Act. A significant number of individuals expressed a lack of knowledge regarding the scope of the protections afforded by the Fair Housing Act, including stakeholders involved in the provision of housing and housing services, and indicated a need for further education regarding these requirements. Fair Housing Action Items have been devised in order to remedy these impediments as well. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 3 of 32 III. PLAN PREPARATION In 1998, the Mayor and the City Council of the City of Moscow, Idaho enacted an ordinance that amended Title 3, Chapter 6 of the Moscow City Code to create the Moscow Fair Housing Commission. The Commission was empowered to “review, on at least an annual basis, the City Code Analysis and [sic] Impediments to Fair Housing and Action Plan and make recommendations to the Mayor, the City Council and the City’s Fair Housing Resource Representatives for amendments or changes to such Plan as it deems necessary.” Moscow City Code, Title 3, Chapter 6, §6-2. In 1999, another ordinance was enacted to amend Moscow City Code Title 10, Chapter 14, which was designated the Moscow Fair and Affordable Housing Ordinance, and created the position of Fair Housing Program Resource Representative to assist the Moscow Fair Housing Commission in the execution of its duties. The Commission began preparation of this Plan at its first meeting on October 19, 2000. A public meeting was held on April 12, 2001 to solicit public input regarding the state of fair housing in the Moscow area. The Commission also reviewed the City of Moscow’s codes, comprehensive plan, and other city regulations and policies, and it collected data and performed surveys to document and study any impediments to fair housing that may exist in both the public and the private sector, as mandated by HUD. The results of the Commission’s analysis have been compiled in this Plan, and action items have been distilled from the analysis and incorporated throughout. On February 27, 2003, the Commission made this Plan available for public comment. After receipt of public comments, the Commission amended the Plan, and the Moscow City Council duly adopted the Plan on 2003. IV. JURISDICTIONAL BACKGROUND DATA The Commission obtained detailed information from the Latah County Assessor’s Office concerning Moscow’s housing stock for the purpose of gaining an understanding of the makeup of the housing stock currently existing in the city. This information was analyzed in light of the historic trends that have affected the makeup of the housing stock, and an analysis is set forth in Section A below. Furthermore, the Commission contracted with the Department of Geography (hereinafter “the Department”) of the University of Idaho (hereinafter “the University”) in order to analyze the available year 2000 Census data. The Department prepared a demographic profile of Moscow’s population and conducted a door-to-door survey of selected portions of the city to further explore impediments to fair housing that may exist in the private sector. The data that was collected was analyzed to identify impediments to fair housing choice, if any, that have been encountered by the residents of private housing in Moscow. This analysis is set forth in Section B below. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 4 of 32 A. Housing Stock Profile This profile of housing stock examines the make up of housing currently available in Moscow and some of the factors that influence housing availability. This profile is not meant to provide an exhaustive analysis, but rather to give a broad overview of the housing inventory currently existing in Moscow in light of the historic trends that have affected the makeup of the housing stock. Over the years, available private housing has been developed directly in response to immediate demands and has resulted in a mix of housing types and locations that successfully meets the current housing needs of the city’s residents. However, various factors have led to periodic short-term shortages of available housing and a tight rental market. Historically, Moscow has experienced a cyclical housing start trend consisting of seven to ten (10) year boom-bust housing construction. In other words, a very high number of dwelling units. As a result of the transient nature of a small university town, rental housing makes up a large percentage of the housing units. The rental and sale of housing in Moscow is very competitive as a result of a diversity of ownership. With regard to rentals, no large dominant housing providers are able to influence rental rates. Pricing of rental housing is based on supply and demand, as well as on costs associated with the provision of housing interest rates, taxes, insurance, construction material costs, etc.). In the past, rental housing has been provided by local builders and developers who have constructed new housing based on current needs. This has resulted in a variety of small housing projects and a very few larger complexes with on-site managers. This process of building smaller projects has served to avoid large out-of-town developers over-building during times of rising demand. Demand is almost exclusively dependent on the University and its staffing and student numbers, a phenomenon that has existed for over 100 years in Moscow. Over this 100- year period, the University has had steady growth with only occasional dips or spikes. This is contrary to the boom-bust cycle of housing construction in Moscow. The reason for the difference in the relatively steady University of Idaho population increase versus the erratic and spiked housing construction has yet to be determined. Despite this, the two factors of supply and demand have been well balanced, on average, with only relatively short periods of shortage or surplus. Vacancy rates typically are very low or less) during peak occupancy in the fall, but can be 10-20% in student-occupied properties during the summer. The experience of the last 20 years typifies the historic trends in Moscow. In the early 1980’s, the state of Idaho was experiencing an economic recession. Although the country as a whole was also experiencing an economic downturn, the western region was particularly hard hit by the recession. As is often the case during a recession, demand for higher education continued to grow. However, interest rates were very high in the early 1980’s and this factor discouraged new construction. In 1986, a tax reform package was enacted by the federal government which, among other things, extended the allowable depreciation period for rental housing. This served to make investing in rental property ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 5 of 32 less attractive. By the end of the 1980’s, Moscow was experiencing a housing shortage. This situation began to correct itself in the early 1990’s, however, when rising demand drove rental prices up and lower interest rates again made building investment property attractive, returning balance to the housing market. The Moscow rental market remained reasonably balanced until 1995 when a doubling of out-of-state fee rates that had been mandated by the Idaho State Board of Education went into effect. The resulting two percent drop in enrollment at the University of Idaho was almost exclusively the result of a loss of out-of-state students, which led to a housing surplus. The effect of this change began to moderate as enrollment grew again at a slow rate. By 2001, a balanced market was again achieved. However, continued growth in 2002 and various changes in University housing is currently resulting in a shortage in the housing supply. A critical difference exists between the current situation and that which existed in 1982. The maintenance of historically low interest rates have resulted in record building activity. This activity is apparently resulting in a rapid re-balancing of the supply and demand of the market. While the cost of rental housing in Moscow is higher than many small towns in Idaho where employment and population is limited by a weak resource-based economy, it is very comparable to the housing costs currently existing in major cities in Idaho such as Boise, Coeur d’Alene, and Pocatello. Housing in Moscow is divided into four main categories: 1) private and rental single- family homes; 2) residential multi-family buildings containing up to four dwellings per building; 3) commercial multi-family buildings containing more than four dwelling units per building; 4) University-owned housing. Private single-family homes currently make up the majority of the housing stock existing in the city of Moscow based on assessed valuation. This represents 54.5 % of the total tax-assessed property valuation, not including University-owned housing. Interviews with property managers have revealed that the great majority (95+ of these homes are owner-occupied. Included in this category are condominium associations, constituting approximately 102 units. Of these 102 units, about 60% are owner-occupied. Also included in this category are 563 mobile homes located in mobile home parks within the city. Residential multi-family housing containing up to four units per building represents 9.7 % of the total valuation and constitutes a total of 1124 dwellings. This category is almost completely tenant-occupied. Commercial multi-family housing containing more than four units per building constitutes 10.3% of the total valuation and contains 2227 dwellings. The majority of these properties are located in close proximity to the University and therefore house mostly university students. This category also contains five rent-subsidized complexes with a total of 366 living units. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 6 of 32 The remaining 25.5% of the total tax-assessed property existing in the city of Moscow is composed of commercial, non-housing properties. University-owned housing is available in three categories: 1) social fraternities and sororities, which have a maximum occupancy of 1,478; 2) residence halls, which have a maximum occupancy of 1,952 persons; and 3) apartment units, which are made available to university students in special categories, such as family housing, scholars’ residences, and graduate students’ residences. These units total 351 apartments, ranging in size from studios to three-bedrooms. None of the University’s housing units are subject to property taxation. Therefore, these housing units are not contained in the total valuation of tax- assessed properties. B. Survey 1. Demographic Profile This section presents findings from a survey of households in Moscow, Idaho conducted by the University of Idaho Geography Department for the purpose of examining demographic patterns that exist within the city of Moscow. The primary research questions were designed to determine: the distribution of racial and ethnic minority populations, and households with minor children present in the city, and if households in blocks with high minority and high minor age children present had experienced any of the forms of discrimination prohibited by the Fair Housing Act. Using United States Census 2000 data, it was observed that the minority populations in Moscow are somewhat concentrated near the University of Idaho. Sixty households were surveyed in the blocks with highest minority and minor age children present. 2. Data Population data used for the project was derived from the U.S. 2000 Census Redistricting File and census block polygons are from U.S. Census TIGER files. ESRI Arc view 3.2 and Statistical Package for the Social Sciences (hereinafter “SPSS”) software were used to process the census data. A door-to-door survey of households provided the data on housing availability conditions. 3. Sampling Method From the census data was obtained total population information and total number of households information for each block, along with population counts for the following categories: • White • Black or African American • Asian and Pacific Islander • Native American • Hispanic • Children under age 18 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 7 of 32 The non-white population counts were added together to obtain a total minority population per block. Then, the total number of people that were non-white was divided by the total population to obtain a percentage of total minority population for each block. The total number of people under age 18 was divided by the total population to obtain a percentage of total minor aged population for each block. Using SPSS, the means and standard deviations for the blocks by percent minority and percent minors was determined. The blocks that were more than two standard deviations beyond the mean in either percent minority or percent minors were then identified. Blocks without enough population to be statistically significant were eliminated and 10 Moscow census blocks remained (see map in Figure 1) that met the criteria of high minority or minor age population concentration. One of these (block 50) was later discovered to have been vacated, leaving nine blocks that were surveyed in May 2002. 4. Household Selection For each selected block, the number of households corresponding to 25% percent of the total households in each block was established as the survey target. Interviewers selected households within the block until the target for each block was met, resulting in a total of 60 households surveyed in all blocks. All survey interviews were conducted during evenings and weekends. Results of the survey are presented below. 5. Survey Results Question 1: How did you find your current housing unit? Seventeen housing units were found through the University of Idaho housing office and 15 were located through realtors (Table The majority of households located by “other” sources were in the blocks containing Sixth, Asbury, Almon, and Third streets (Table The highest concentration of houses located through the University housing office was in the Third, Line and Sixth street blocks (Table Table 1. Source of information used to find current housing unit. Source Frequency Percent Realtor 15 25.0 Newspaper Ad 4 6.7 University housing office 17 28.3 Other 24 40.0 Total 60 100.0 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 8 of 32 Table 2. Source of information by block used to find current housing unit. Block Realtor Newspaper ad University housing office Other Total Sixth, Asbury, Third, and Almon Sts. 1 4 1 12 18 Fourth, Main, Fifth, Washington Sts 1 1 7 9 Line, Sixth, Third Sts. (10) 15 1 16 Mountain View St, Sixth St. (51) 1 1 Mountain View Rd, Joseph St, and Lemhi Dr (52) 4 4 Mountain View Rd, Rolling Hill Dr, Summit Rd (53) 3 2 5 A St, Howard St, B St, and Monroe St. (54) 3 3 Main St, Quail Run Dr, Franklin Rd (55) 2 1 3 Highway 8, Main St, and Harrison St (56) 1 1 Total 15 4 17 24 60 Of the 24 households who located their housing units through “other” sources, most (14 total) were located through friends (Table The other methods of obtaining housing were distributed evenly among “signs”, “the Internet”, “built own home”, and “work”. Thirteen of the 14 households located through friends were in blocks 2 and 3 near downtown Moscow (Table Table 3. Frequency of households located by “other” sources of information. Frequency Percent Built own home 3 12.5 Friends 14 58.3 Internet 2 8.3 Sign 4 16.7 Work 1 4.2 Total 24 100.0 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 9 of 32 Table 4. Number of households by block located by “other” sources of information. Block Built own home Friends Internet Sign Work Total Sixth, Asbury, Third, and Almon Sts. 6 2 3 1 12 Fourth, Main, Fifth, Washington Sts 7 7 Line, Sixth, Third Sts (10) 1 1 Mountain View St, Sixth St. (51) 1 1 Mountain View Rd, Joseph St, and Lemhi Dr (52) 0 Mountain View Rd, Rolling Hill Dr, Summit Rd (53) 1 1 2 A St, Howard St, B St, and Monroe St (54) 0 Main St, Quail Run Dr, Franklin Rd (55) 1 1 Highway 8, Main St, and Harrison St (56) 0 Total 3 14 2 4 1 24 Question 2: What factors influenced your choice of housing? Location was the primary factor in a total of 22 households that influenced choice of housing unit (Table Price was the second highest factor selected, followed by quality. Location was also the primary factor influencing choice of housing by blocks 2 (10 total) and 10 (7 total), while price was the primary factor in block 3. Table 5. Factors influencing choice of housing. Factor Frequency Percent Available 4 6.7 Location 22 36.7 Location, price 6 10.0 Location, quality 1 1.7 Price 7 11.7 Price, location 5 8.3 Price, location, quality 2 3.3 Price, quality 4 6.7 Quality 6 10.0 Quality, price, location 1 1.7 Work 2 3.3 Total 60 100.0 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 10 of 32 Question 3: Federal law protects everyone from housing discrimination on the basis of: a. Race b. Color c. Religion d. Sex e. National origin f. Presence of minor children g. Disability Do you feel that any of these conditions affected or limited your housing choice in Moscow in any way? Ninety-five percent of the households do not feel that these conditions affected or limited their housing choice (Table No other conditions were selected as having influenced housing choice in Moscow. Only three households felt that either race or sex affected their housing choice. Two Asian households in Block 3 felt that they were discriminated against because of their race. One white household in block 10 felt that they were discriminated against because of their sex. Table 6. Conditions affecting or limiting choice of housing. Condition Frequency Percent Race 2 3.3 Sex 1 1.7 No 57 95.0 Total 60 100.0 Question 4: Do you feel that you could move to any other part of the city if housing were available and affordable? Yes No___ if not, why? More than 80% (50 total) of the households indicated that they could move to any other part of the city if housing were available and affordable (Table These 50 households were comprised of 19 minorities and 31 whites. Of the 10 households that indicated they would not move to any other part of the city, seven were minorities and three were white. More than 50% (27 total) of the households that indicated that they could move to any other part of the city if housing were available and affordable were in Blocks 2 and 10 (Table The location of the respondent’s housing was the main reason that the ten households felt they could not move to any other part of the city. Four of the 10 households were in Block 2 and three in Block 10 (Table ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 11 of 32 Table 7. Could move to any other location Response Frequency Percent No 10 16.7 Yes 50 83.3 Total 60 100.0 Table 8. Could move to any other location by block Block No Yes Total Sixth, Asbury, Third, and Almon Sts. 4 14 18 Fourth, Main, Fifth, Washington Sts. 2 7 9 Line, Sixth, Third Sts. (10) 3 13 16 Mountain View St, Sixth St. (51) 1 1 Mountain View Rd, Joseph St, and Lemhi Dr (52) 4 4 Mountain View Rd, Rolling Hill Dr, Summit Rd (53) 5 5 A St, Howard St, B St, and Monroe St (54) 3 3 Main St, Quail Run Dr, Franklin Rd (55) 3 3 Highway 8, Main St, and Harrison St (56) 1 1 Total 10 50 60 Table 9. Reasons for ten households answering “No” to Question 4 Block Location Location, quality Price Total Sixth, Asbury, Third, and Almon Sts. 4 18 Fourth, Main, Fifth, Washington Sts. 1 1 9 Line, Sixth, Third Sts. (10) 3 16 Mountain View St, Sixth St. (51) 1 1 Mountain View Rd, Joseph St, and Lemhi Dr. (52) 4 Mountain View Rd, Rolling Hill Dr, Summit Rd. (53) 5 A St, Howard St, B St, and Monroe St. (54) 3 Main St, Quail Run Dr, Franklin Rd. (55) 3 Highway 8, Main St, and Harrison St. (56) 1 Total 8 1 1 60 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 12 of 32 Question 5: Do you know of any examples of housing discrimination in Moscow? Yes__ No__. If yes, please describe. More than 80% (53 total) of the respondents said they did not know of any examples of housing discrimination (Table 10). These households were divided equally between minority (25 total) and white (28 total) (Table 11). Of the seven households who indicated that they were aware of examples of housing discrimination, six were white and one of the seven was Asian. The Asian respondent indicated that the example of housing discrimination that the respondent was aware of consisted of rude neighbors and was race-based. Table 10. Number of knowing any examples of housing discrimination Response Frequency Percent No 53 88.3 Yes 7 11.7 Total 60 100.0 The list below provides the stated examples of housing discrimination, including; attitudes toward homosexuality; bankruptcy; limitations of young family; unwillingness to rent to students, pet owners and single families; rude neighbors; and domestic violence, presence of children; and low income. Table 11. Number of knowing any examples by race of respondent Race of Respondent Response Total No Yes Other 25 1 26 White 28 6 34 Total 53 7 60 Question 6: What is your household status on the following items: a. Number of adults in unit b. Number of children under age 18__ c. Number of household members who are: White__ Black Asian or Pacific Islander__ Native American Hispanic__ Most (56.7%) of the surveyed housing units have 2 adults, followed by one-adult units, which comprised about 27% of the sample (Table 11a). Fourteen of the two-adult units were in Block 10. One case of five university students living together exists in Block 2 (Table 11b). ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 13 of 32 Table 11a. Number of adults in unit Frequency Percent 1 adult in unit 16 26.7 2 adults in unit 34 56.7 3 adults in unit 6 10.0 4 adults in unit 3 5.0 5 adults in unit 1 1.7 Total 60 100.0 Table 11b. Number of adults in unit by block Block Number of adults in unit Total 1 2 3 4 5 Sixth, Asbury, Third, and Almon Sts. 8 5 3 1 1 18 Fourth, Main, Fifth, Washington Sts. 5 4 9 Line, Sixth, Third Sts. (10) 2 14 16 Mountain View Rd, Sixth Sts. (51) 1 1 Mountain View Rd, Joseph St, Lemhi Dr (52) 1 2 1 4 Mountain View, Rolling Hills , Summit (53) 2 1 2 5 St, Howard, St, Monroe (54) 3 3 Main St, Quail Run, Franklin (55) 3 3 Hwy 8, Main St, Harrison (56) 1 1 Total 16 34 6 3 1 60 There exists 48 housing units with no children under age 18, followed by nine households with one child under the age of 18 (Table 12a). Forty of the 48 housing units with no children under the age of 18 are in Blocks 2, 3, and 10 (Table 12b). The nine households with one child under the age of 18 were distributed evenly among blocks. Table 12a. Number of children in unit Category Frequency Percent No child under age 18 in unit 48 80.0 1 child under age 18 in unit 9 15.0 2 children under age 18 in unit 1 1.7 3 children under age 18 in unit 1 1.7 4 children under age 18 in unit 1 1.7 Total 60 100.0 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 14 of 32 Table 12b. Number of children in unit by block Block Number of children in unit Total 0 1 2 3 4 Sixth, Asbury, Third, and Almon Sts. 18 18 Fourth, Main, Fifth, Washington Sts. 6 3 9 Line, Sixth, Third Sts (10) 16 16 Mountain View, Sixth St (51) 1 1 Mountain View, Joseph, and Lemhi Dr (52) 2 1 1 4 Mountain View, Rolling Hills, Summit (53) 4 1 5 St, Howard, St, Monroe (54) 1 1 1 3 Main St, Quail Run, Franklin (55) 2 1 3 Highway 8, Main St, and Harrison St. (56) 1 1 Total 48 9 1 1 1 60 Among the 60 households, 34 households contain whites and 26 households are “other” (Table 13). All of the “other” households are concentrated in Blocks 2, 3, and 10 (Table 14). The majority of white households are located in Blocks 2 and 10. All of households in Block 3 were Asian. Households with two white individuals were most common (13 total), followed by three-white, two-Asian, one-Asian, one-white households (Table 15). Most households with two white individuals were in Blocks 2 and 10. Table 13. The number of households by race Race Frequency Percent Other 26 43.3 White 34 56.7 Total 60 100.0 Table 14. The number of households by race in each block Block Other White Total Sixth, Asbury, Third, and Almon Sts 7 11 18 Fourth, Main, Fifth, Washington Sts 9 9 Line, Sixth, Third Sts (10) 8 8 16 Mountain View, Sixth St (51) 1 1 Mountain View, Joseph, Lemhi Dr. (52) 4 4 Mountain View, Rolling Hills, Summit (53) 5 5 St, Howard, St, Monroe (54) 1 2 3 Main St, Quail Run, Franklin (55) 3 3 Highway 8, Main St, Harrison (56) 1 1 Total 26 34 60 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 15 of 32 Table 15. Number of households by racial group Racial Group Frequency Percent 1 white, 1 Asian 1 1.7 1 Asian 7 11.7 2 Asians 9 15.0 3 Asians 3 5.0 1 Black 2 3.3 1 White, 2 Hispanics 1 1.7 1 White, 2 Blacks 1 1.7 1 White, 2 Native Americans 1 1.7 4 Whites, I Asian 1 1.7 1 White 6 10.0 2 Whites 13 21.7 3 Whites 9 15.0 4 Whites 4 6.7 5 Whites 1 1.7 6 Whites 1 1.7 Total 60 100.0 Question 7: What is the number of people with a disability in the household? There exists no persons with a disability in 56 households, and there exists 1 person with a disability in 4 households. Among these four households containing a disabled person, two households are located in Block 2, one household in Block 53, and one household in Block 54 (Table 17). Table 16. Number of people with a disability Category Frequency Percent No person with a disability 56 93.3 1 person with a disability 4 6.7 Total 60 100.0 Table 17. Number of people with a disability by block Block Number of Disabilities Total None ≥1 Sixth, Asbury, Third, and Almon Sts 16 2 18 Fourth, Main, Fifth, Washington Sts 9 9 Line, Sixth, Third Sts (10) 16 16 Mountain View, Sixth St (51) 1 1 Mountain View, Joseph, Lemhi Dr (52) 4 4 Mountain View, Rolling Hills, Summit Rd (53) 4 1 5 St, Howard, St, Monroe (54) 2 1 3 Main St, Quail Run, Franklin (55) 3 3 Highway 8, Main St, Harrison (56) 1 1 Total 56 4 60 ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 16 of 32 Question 8: Do you rent or own this house or apartment? Forty-three households rent their houses or apartments, and 17 own their homes (Table 18). All of the households that rent their houses or apartments are located in Blocks 2, 3, and 10 (Table 19). There exists no households who own their own homes in these blocks. Households that own homes are distributed fairly evenly among the remaining blocks. Table 18. Ownership Category Frequency Percent Own 17 28.3 Rent 43 71.7 Total 60 100.0 Table 19. Ownership by block Block Category Total Own Rent Sixth, Asbury, Third, and Almon Sts 18 18 Fourth, Main, Fifth, Washington Sts 9 9 Line, Sixth, Third Sts (10) 16 16 Mountain View, Sixth St (51) 1 1 Mountain View, Joseph, and Lemhi Dr (52) 4 4 Mountain View, Rolling Hills, Summit (53) 5 5 St, Howard, St, Monroe St (54) 3 3 Main St, Quail Run, Franklin (55) 3 3 Highway 8, Main St, Harrison St (56) 1 1 Total 17 43 60 Question 9: Do you recommend any improvements in Moscow’s housing market to make it more fair? Thirty-eight households answered “no” and 22 households answered “yes” to this question. The recommended improvements included: 1. Keep government out of the market 2. Provide benefits for everyone and equal access 3. Provide better resources 4. Provide low-income housing 5. Develop more high-quality apartments and houses 6. Create more leases 7. Create more housing related websites 8. Conserve power Two households answered, “somehow yes”, but did not give any specific examples or suggestions. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 17 of 32 6. Summary The population of Moscow, Idaho contains a few concentrations of minority populations and households with children under age 18. These concentrations are found in nine blocks within the city and most are within close proximity to the University of Idaho campus. Of the sampled households, 26 of the 60 (43%) contain minority population, and of these, most are Asian. Children under age 18 were found in 12 households and households containing a person with a disability in four of the sampled households. Evidence of discriminatory practices in their housing search were mentioned by only three of the respondents, and knowledge of other examples of discrimination in Moscow housing were mentioned by seven (12%) of the respondents. Most respondents indicated that they chose their housing unit with location in mind, and the two most important sources of information for locating their housing were realtors and the University’s housing office. Of the sampled households, 17 (28%) own, and 43 (72%) rent their housing unit. Most of the owned housing units are located in the blocks included for high number of children under age 18. Rental units are most common in the blocks near the University campus. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 18 of 32 Figure 1. Map of Survey Blocks ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 19 of 32 V. ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING AND FAIR HOUSING ACTION PLAN A. Public Sector Review In preparing this review of the public sector, the Commission examined the City of Moscow Municipal Code, the Comprehensive Plan, International Building Code, City Employment Manuals, and Hearing policies for possible impediments to fair housing. 1. Comprehensive Plan The stated goal of the Housing Element of the Comprehensive Plan is “To ensure decent and safe housing in sufficient quantity to accommodate the various housing needs of present and future residents of Moscow.” The Comprehensive Plan contains Objectives and Implementation Policies that acknowledge the need to provide a variety of housing in type, size, cost and location, as well as the need to promote the increased availability of affordable housing and the need to improve and protect the quality of the housing stock. Although many of the underlying concepts are indirectly addressed, the terms “fair housing” and “affordable housing” are absent from the Comprehensive Plan. The Housing Element within the Comprehensive Plan provides significant consideration to the availability of housing for both the resident and University of Idaho student populations. The Housing Element discusses the shortage of available housing and the required additional housing units that will be necessary to maintain acceptable housing availability to meet the anticipated demands and emphasizes the necessity for cooperation between the City, University and developers to adequately address the housing concerns and future housing needs. Additionally, the Housing Element discusses the use of zoning and subdivision regulations as a valuable tool in promoting the development of economically attractive housing through reduced lot size requirements, reducing minimum street widths and reducing setbacks to the minimum necessary to provide for open space, light, air, sight distance and fire safety. These steps help to reduce development costs, reduce property owner tax liability and promote the availability of economically attractive housing. Furthermore, the Housing Element addresses the use of manufactured housing as an economical alternative to traditional construction within the city. The Housing Element acknowledges the housing need that mobile home parks fulfill and provides that land should be made available for their use and acknowledges the local land use planning act requirement to allow the placement of manufactured homes on permanent foundations within any zoning district that allows single- family residential use, provided that the homes meet certain minimum standards. The Comprehensive Plan Land Use Designation Map may not adequately reflect diversity in location of housing and in particular, multi-family housing. Areas designated as Medium and High Density Residential are primarily concentrated in the west and southwest portions of the city. The High-Density Residential ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 20 of 32 designated areas are primarily clustered closely around the University of Idaho, SR 8 and U.S. Highway 95 with Low-Density Residential areas more spread out and predominately located around the periphery and east side of the city. The differences in distribution of low-, medium-, and high-density residential areas are quite important because only multi-family units that house four separate families or more are covered under HUD building guidelines. Single family residential homes are also more likely to be exempt from the other Fair Housing Act protections. FAIR HOUSING ACTION ITEM NO. 1: (City Comprehensive Plan) The City of Moscow’s Comprehensive Plan (Housing Element, Chapter 11 and Land Use Element, Chapter 13) affects the type, density and location of housing within the city. However, fair housing and affordable housing issues may not be adequately addressed in the City of Moscow’s Comprehensive Plan, and these terms are wholly absent from the Comprehensive Plan. Action to be taken in response to this impediment includes the incorporation of these concepts and terms into the Comprehensive Plan and the addition of fair housing related objectives and/or implementation policies. FAIR HOUSING ACTION ITEM NO. 2: (City Comprehensive Plan) The City of Moscow’s Comprehensive Plan provides for the location of medium- and high-density residential housing primarily in the west and southwest portions of the city. This has led to an inequitable distribution of housing that must comply with the disability access requirements of the Fair Housing Act throughout the city, with very little multifamily housing available in the eastern portion of Moscow, which is the primary residential section of the city. Action to be taken in response to this impediment includes amending the Comprehensive Plan to provide for more medium and high-density residential areas in the eastern portion of the city. 2. Zoning Code The City of Moscow Zoning Code promotes the creation of affordable housing while preserving the property rights and quality of life of the city’s residents. Many of the Comprehensive Plan’s recommendations such as lesser lot size requirements, the reduction of street widths, and set back requirements and flexibility through the Planned Unit Development process have been incorporated within the Zoning Code. The recently revised Planned Unit Development section of the Zoning Code allows the creation of higher-density, innovative and economical developments upon single lots or in subdivisions that would not be allowed by the underlying zoning district. Other related and recent Zoning Code amendments include reduced lot width requirements and the recognition of the ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 21 of 32 use of flagpole lots to encourage infill development. These changes have reduced the typical housing development cost and have provided flexibility in development methods to lower the cost of housing and increase the variety of housing that is available. The Zoning Code definition of “Day Care Facility” could be considered an impediment to fair housing. The definition of “Day Care Facility” includes foster homes, which subjects foster homes to zoning and location limitations that may violate the spirit of the Fair Housing Act’s prohibition against discrimination based on familial status. The Zoning District Boundary Map provides more diversity in distribution of medium-(R-3) and high-(R-4) density zoning districts throughout the city than the Comprehensive Plan Land Use Designation Map. However, the existing R-3 and R-4 Zoned property on the east side of town is already developed and no vacant R-3 and R-4 Zoned lands exist there. FAIR HOUSING ACTION ITEM NO. 3: (City Zoning Code) In accordance with the previously described Action Item Number 2, relating to the Comprehensive Plan Land Use Designations, there is very little property that is zoned for medium and high density residential use on the east side of the City. As a result, the vast majority of the new housing construction that has occurred in the eastern portions of the City has been almost exclusively for single-family residential structures. This results in an inequitable geographic distribution of the variety of housing types available to residents, which can be considered an impediment to Fair Housing. Action to be taken in response to this impediment includes amending the Zoning District Map to provide for more medium and high density residential areas in the eastern portion of the City. FAIR HOUSING ACTION ITEM NO. 4: (City Zoning Code) The City of Moscow’s Zoning Code provides for a definition of “Day Care Facility” which includes fosters, thereby subjecting foster homes to zoning and location limitations. Such limitation may violate the Fair Housing Act should they be enforced to prevent the location of a foster home outside of specific portions of the city. Action to be taken in response to this impediment includes amending the Zoning Code so that the definition of “day Care Facility” no longer includes foster homes. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 22 of 32 3. Subdivision Code The Subdivision Code regulates the division and development of land within the city and the related required public improvements such as streets, sidewalks and public utilities. All developments, regardless of development type or density, are required to provide the future residents with adequate public improvements including streets, sidewalks, utilities, stormwater detention systems and parkland dedications. These public improvement standards are applied uniformly throughout the community to ensure the delivery of equitable public services. No impediments to fair housing were identified within the Subdivision Code. 4. Building Codes The City of Moscow was required by the State of Idaho to adopt the International Building Code (hereinafter “IBC”). The IBC states that it “better reflect[s] the requirements of both the ADA [Americans with Disabilities Act] and the FHA [Fair Housing Act].” While the IBC does provide a closer alignment with many elements of the Americans with Disabilities Act and the Fair Housing Act, the IBC also includes a more stringent fire sprinkler requirement for residential care/assisted living facilities. Fire sprinklers are required in such facilities when there are more than eight occupants, as per IBC § 903.2, the adoption of which is mandated by the State of Idaho. In the building code applicable prior to the IBC, the same facility did not require sprinklers until it houses at least 16 occupants. Such sprinklers add a cost of between $2.00 and $2.50 per square foot to the cost of construction of a home. Therefore, this requirement results in an increase in cost of about $3,000 to $3,750 for a 1,500 square foot home. While this requirement may present an additional cost to the development of residential assisted living facilities, the additional safety of such improvements would appear prudent in such facilities. Additionally, the city is required to adopt the IBC by the State of Idaho Building Code Act and does not have the ability to lessen the life safety related requirements of the IBC. Therefore, no impediments to fair housing were identified within the building codes. 5. Municipal Services The Fair Housing Act promotes the non-discriminatory distribution of public services such as parks, streets, public transportation, recreational opportunities, police protection, fire protection, street lighting and trash collection throughout the community. The City of Moscow provides water, sewer and garbage service equitably throughout the community at the same rate to all residents, and the City of Moscow is currently exploring the possibility of a fee waiver policy for certain City service and/or permit fees. Service response times of the fire department appear to be equally as rapid to multiple family housing developments as to single family homes and police services are equitably provided throughout the community. Therefore, no impediments to fair housing were identified related to public services. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 23 of 32 6. Employment, Housing and Transportation Public transit service in Moscow is handicapped-accessible and the majority of the multi-family housing is located in areas near the transit route and local employers. Additionally, the City of Moscow is currently in the process of exploring expanded public transit service in cooperation with the Idaho Transportation Department, the University of Idaho, and public transit service providers. The Commission found no significant impediments to fair housing related to the housing and employment transportation linkage. 7. Administrative Policies Resolution 2001-05, was passed by the City Council in February of 2001. This resolution provides that the City of Moscow will assist all persons who feel they have been discriminated against because of race, color, religion, sex, national origin, disability or familial status to promote compliance with the Fair Housing Act under federal and state laws by filing a complaint with the U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Compliance Division. This resolution represents a commitment by the City to encourage owners of real estate, developers, and builders to become aware of their respective responsibilities and rights under the federal fair housing laws and amendments. The City of Moscow also distributes grant money annually to various service organizations for valuable activities. A portion of the grant monies are regularly allocated to organizations that promote affordable and accessible housing. No impediments to fair housing were identified with regards to the City of Moscow’s administrative policies. 8. Property Tax Policies Property tax policies are controlled by the State of Idaho and locally administered and collected by Latah County. There are established property tax relief programs such as the State of Idaho Tax Commissions Property Tax Reduction Program that is administered within the community by the Latah County Assessor. As discussed in the Housing Stock Profile section of this document, tax policies may have a significant effect on the construction of housing, and may reduce the development of multifamily housing in the community. The City of Moscow does not have a regular program that promotes the use of tax incentives in order to increase the development of accessible and affordable housing. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 24 of 32 FAIR HOUSING ACTION ITEM NO. 5: (Tax Policy) Tax policies may lead to a decrease in the amount of available accessible and affordable housing in Moscow. Action to be taken in response to this impediment includes encouraging the City of Moscow to coordinate an effort to promote the use of tax incentive programs to develop and increase the availability of accessible and affordable housing. 9. Planning and Zoning Commission and Zoning/Board of Adjustment The Planning and Zoning Commission and Board of Adjustment members are selected in compliance with State of Idaho and City Code. Members are appointed by the Mayor with the advice and approval of the Council without respect to political affiliation. The Planning and Zoning Commission and Board or Adjustment consist of members that reflect the diversity of the community’s population. The Commission and Board meetings are open to the public with accommodations for persons with disabilities made available. Therefore, the Commission finds no impediments to fair housing within the Planning and Zoning Commission and Board of Adjustment. 10. Temporary Reduction of University of Idaho Housing Stock The University of Idaho is currently in the process of restructuring and modernizing the available on-campus student housing. This plan includes the destruction of some on-campus student housing that will temporarily decrease the amount of available housing on campus. In total, the plan includes the demolition of residential buildings containing approximately 500 beds with the construction of residential buildings containing approximately 600 new beds for a total net gain of 100 beds. During the demolition and construction process, the loss of student housing may place additional pressures on the available housing for students in Moscow at a time when enrollment has increased by 3% over the 2001 figures setting a new record enrollment of 10,998 students. B. Private Sector Review The Commission conducted a survey during the summer of 2001 of the following five local groups of fair housing stakeholders: 1) architects, builders, contractors, developers, and engineers; 2) lenders; 3) property managers and landlords; 4) realtors and real estate brokers, and; 5) service agencies. A total of thirty-three (33) individuals (all 5 stakeholder groups combined) were surveyed equating to x% of each local stakeholder group. The Commission surveyed between five and twenty-five percent of the individuals included in each of these stakeholder groups. The purpose of the survey was to identify what, if any, impediments to fair housing exist in the private sector in the Moscow area. Detailed questions concerning individuals’ understanding of and experience with fair housing issues were posed. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 25 of 32 Although a majority of the stakeholders surveyed (22 of 33) indicated that their knowledge of the Fair Housing Act requirements as they relate to their particular jobs is “moderate” or “substantial,” approximately one-half (16 of 33) indicated that their need for more information regarding the Fair Housing Act requirements is “moderate” or substantial.” The survey results reveal that while numerous stakeholders involved in the housing market in the Moscow area have indicated that they have received fair housing training and that they feel comfortable with their knowledge and understanding of the Fair Housing Act, a majority of those surveyed perceive a need for further education. This implies that an impediment to fair housing exists in the private sector due to a lack of education. The Commission also contacted local publishers that advertise housing in order to acquire information regarding any policies or procedures that each publisher may employ in screening the content of housing advertisements. 1. Architects, Builders, Contractors, Developers and Engineers A total of nine members of this stakeholder group were surveyed. Nearly one- half of those surveyed (4 of 9) indicated that they had received no fair housing training whatsoever. However, more than one-half (5 of 9) indicated that their need for more information regarding the Fair Housing Act requirements was “none” or “minimal.” Also, the majority (6 of 9) reported that fair housing issues “never” or “sometimes” arise in the course of their work. All of the members of this group indicated that they had never encountered any barriers to fair housing. FAIR HOUSING ACTION ITEM NO. 6: (Lack of Training, Design, and Construction A significant number of the stakeholders contained in this group have indicated a lack of knowledge and training regarding the Fair Housing Act. An impediment to fair housing exists if these stakeholders do not understand the design and construction requirements of the Act. Action to be taken includes an increased effort to make available for distribution Fair Housing Act Design Manuals and other pertinent fair housing materials that address the design and construction requirements of the Fair Housing Act by the City of Moscow’s Building Department. Also, the Commission will publicize and encourage participation in upcoming educational opportunities regarding these requirements, and continue to encourage the incorporation of such information into the curriculum of the School of Architecture at the University of Idaho. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 26 of 32 2. Lenders A total of three members of this stakeholder group were surveyed. Of the five groups surveyed, lenders described themselves as the best educated regarding the requirements of the Fair Housing Act. All of those surveyed indicated that they had received over ten hours of fair housing requirements as “moderate” or “substantial.” Two-thirds (2 of 3) reported that they felt that they had no need for more information regarding fair housing. This same number of individuals also indicated that fair housing issues never arise in the course of their work. All members of this group that were surveyed indicated that they have written policies in place addressing the Fair Housing Act requirements. 3. Property Managers and Landlords A total of ten members of this stakeholder group were surveyed. Nearly one-half (4 of 10) indicated that they had received over ten hours of fair housing training and the majority (7 of 10) indicated that their knowledge of the Fair Housing Act requirements as they relate to their jobs is “moderate” or “substantial.” However, more than one-half (6 of 10) indicated that their need for more information regarding the Fair Housing Act is “moderate.” One fifth (2 of 10) of those surveyed indicated that when they sought more information regarding the Fair Housing Act, they did not receive the information they sought. This is the only group surveyed that so indicated. FAIR HOUSING ACTION ITEM NO. 7: (Lack of Understanding, Property Managers, Training, Realtors) A significant number of the members of this stakeholder group have indicated that they feel a need for further education regarding the requirements of the Fair Housing Act. An impediment to fair housing exists in that this is the stakeholder group that accomplishes the day-to-day management of rental housing and they may not have a full understanding of the requirements of the Act. This is further supported by the results of the survey wherein a significant number of residents had either experienced or had knowledge of discriminatory incidents. Action to be taken includes the promotion of further educational opportunities for housing providers and the provision of pertinent fair housing resources and information. 4. Realtors and Real Estate Brokers A total of eight members of this stakeholder group were surveyed. The majority (6 of 8) indicated that they had received less than ten hours of fair housing training. All reported that they considered their knowledge of the Fair Housing Act to be either “moderate” or “substantial.” However, more than one-half (5 of 8) indicated that they had either a “moderate” or “substantial” need for more information. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 27 of 32 FAIR HOUSING ACTION ITEM NO. 8: (Lack of Training, Realtors) More than one-half of the members of this stakeholder group indicated that they have a need for further education regarding the requirements of the Fair Housing Act. This constitutes a significant impediment to fair housing. Action to be taken includes the promotion of educational opportunities for housing providers, including the continuation of yearly presentations to the local realtor organization and the provision of pertinent fair housing resources and information. 5. Social Service Agencies A total of three members of this stakeholder group were surveyed. A majority (2 of 3) indicated that they had received no fair housing training. This same number, however, indicated that they recognized a “substantial” need for more information. FAIR HOUSING ACTION ITEM NO. 9: (Lack of Training, Social Service Agencies) One-third of the members of this stakeholder group indicated that they have received no education regarding the requirements of the Fair Housing Act. This constitutes a significant impediment to fair housing. Action to be taken includes the promotion of educational opportunities specifically directed toward this stakeholder group, as well as making available pertinent fair housing resources and information such as informational pamphlets that can be displayed at the various service provider’s facilities. 6. Advertisers The Moscow-Pullman Daily News is the only private newspaper publishing in the city of Moscow. Advertising procedures at the Daily News include an ongoing review of classified advertisements prior to publication, as well as the publishing of a fair housing statement at the beginning of the Apartment Rental Section of the classifieds. Advertisements placed with the Daily News are reviewed to ensure that they are free from discriminatory statements. The University of Idaho also operates a student newspaper that serves the University of Idaho campus, as well as the Moscow area. This newspaper indicated that it does not have any policies or procedures in place for the review of housing-related advertisements for discriminatory content. Likewise, the Eagle, a newspaper that is published outside of the city of Moscow but serves the Moscow area, indicated that it has no policies or procedures in place for the review of housing-related advertisements for discriminatory content. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 28 of 32 Moscow is also served by the Money Saver, a classifieds advertisement publication. The Money Saver makes use of a word and phrase list to determine the acceptability of advertisements regarding housing. Finally, the University operates an off-campus housing list on its Internet website which is accessible to anyone who wishes to post a housing-related advertisement. No procedures for monitoring this website for discriminatory content was reported. FAIR HOUSING ACTION ITEM NO. 10: (Rental Housing Advertisers) A significant number of the advertisers in the Moscow area do not have in place any policies and procedures for the review of housing-related advertisements for discriminatory content. Although the Commission did not engage in a review of these publications in order to determine whether fair housing violations are occurring, the lack of review mechanisms at the various advertisers constitutes an impediment to fair housing in that it is likely that advertisements in violation of the Fair Housing Act have or will be published. Action to be taken includes further education of advertisers regarding their obligations and potential for liability under the Fair Housing Act and the promotion of policies and procedures in order to ensure compliance. The Commission will encourage the University to impose a requirement that all housing providers that wish to make use of the website obtain fair housing training. VI. FAIR HOUSING ENFORCEMENT The Fair Housing Act protects all individuals from housing discrimination throughout the entire country. 42 U.S.C. §3601 et seq. The Act protects individuals from housing discrimination on the basis of race, color, religion, sex national origin, familial status (presence of minor children), and disability. The Act designates the United States Department of Housing and Urban Development as the government agency that is empowered to enforce the requirements of the Act. This federal agency receives fair housing complaints, investigates the complaints, attempts to conciliate an out-of-court settlement. If the matter cannot be resolved through settlement, HUD may file a court complaint on behalf of the complainant and thereby seek a judicial remedy by referring the complaint to the United States Department of Justice for litigation. The requirements of the Act may also be enforced through private litigation. As of June 2001, HUD has received 34 fair housing complaints concerning properties located in Moscow, Idaho. All of these complaints but one has reached resolution, either through settlement, judicial action, or dismissal by HUD. To assist with education and outreach and with the intake of complaints, HUD provides grants to non-profit fair housing organizations throughout the country. In Idaho, HUD helps to fund the ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 29 of 32 Intermountain Fair Housing Council located in Boise. The Council, established in 1996, conducts education and outreach activities concerning the requirements of the Fair Housing Act throughout the state, receives and investigates complaints from individuals, and refers complaints on to HUD for further investigation and possible litigation if it appears the complaint is justified. Since 1996, the Council has filed over 200 fair housing complaints with HUD concerning properties throughout the state of Idaho. In Idaho, individuals are also protected from housing discrimination under the Idaho Human Rights Act. Idaho Code §67-5901 et seq. The Human Rights Act protects individuals from housing discrimination on the basis of race, color, religion, sex, national origin, and disability. The Idaho Human Rights Act empowers the Idaho Human Rights Commission as the state enforcement agency. The Commission receives complaints from individuals and investigates in order to determine if the complaint is justified. If it determines that the complaint is justified, the Commission will attempt to conciliate an out-of-court settlement of the complaint. If the complaint cannot be settled, it may file a court complaint on behalf of the complainant and thereby seek a judicial remedy. FAIR HOUSING ACTION ITEM NO. 11: (Fair Housing Enforcement Agencies) All three of the public enforcement entities in the state of Idaho are located in Boise. These entities also provide education and outreach to the public and to housing providers regarding the requirements of the Fair Housing Act. An impediment to fair housing exists in that access to these entities, their resources, and expertise is somewhat limited, and their presence is not as prevalent in the Moscow area. Action to be taken entails the continued support for education and enforcement entities in the state of Idaho, and to encourage these entities to increase their presence in the Moscow area. VII. AFFORDABLE HOUSING The issue of affordability implicates fair housing rights because it directly affects housing choice. Financial limitations affect choice of the type and location of housing which may constitute a significant impact on community diversity due to the disparity of per capita income between the various racial and ethnic groups, as well as between the disabled and non-disabled populations. According to the 1999 BBC Research and Consulting Study, Barriers to Housing Affordability in Idaho, the six top barriers to affordable housing include: • Confusion about/lack of property tax exemptions • Confusion about fair housing accessibility requirements • Labor shortages in building trades • Local government capacity to address issues affecting planning, zoning, and affordable housing ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 30 of 32 • Neighborhood and community opposition to affordable housing • Regulatory process which increases housing costs The lack of available affordable housing in a community often constitutes a formidable barrier to fair housing and may promote a segregated community. “Affordable housing” is defined as that for which a family spends no more than 30 percent of their income. According to HUD, families that spend more than 30% of the total household income on housing are considered to be “cost- burdened”. Accurate information regarding affordable housing in the City of Moscow is currently unavailable and it is the intention of the Commission to compile this information as part of its ongoing effort to promote fair housing and to fulfill the goals of the fair housing action items contained in this Plan. Annual area median income information published by HUD each year is broken down only by county. Therefore, specific information regarding the city of Moscow cannot be accurately distilled from the data. However, recently released 2000 United States Census Bureau data indicates that the median annual household income for the City of Moscow is $26,884.00 and the median annual family income is $46,331.00 with an annual per capita income of $14,930.00. According to the 1999 BBC Study, the market rent for a 2-bedroom unit ranges from $400-$550 across the state. As previously mentioned, the housing rates in Moscow are typically higher than many of Idaho’s smaller communities and are typically on par with other Idaho cities such as Boise and Coeur d’Alene. Using the higher end of the statewide 2-bedroom market range of $550.00, a household in Moscow would be considered cost-burdened if the total household annual income was less than $22,000.00. According to the Census 2000 data, 47.3% of all households and 26.3% of all families in Moscow have a total annual household income of less than $25,000.00. Additionally, 29.5% of all households and 14.1% of all families earn less than $15,000.00 per year. These percentages may be artificially high due to the large student population within the city which may have other revenue sources such as scholarships, student loans or parental support that may not be reflected in the income levels reported. Nevertheless, it would appear that a portion of the city’s residents are cost-burdened and affordable housing may be a formidable barrier to fair housing within the community. As more data becomes available, the Commission intends to conduct a study of the information in order to assess the availability of affordable housing for Moscow residents. The Commission intends to develop a profile of Moscow residents and the housing stock with regard to rental and non-rental status, rental and sale prices, vacancy and absorption rates, and type, size and location of housing units. The Commission will analyze whether an oversupply or undersupply for each type of unit exists, and develop a plan with suggested goals and implementation strategies to promote the creation of a fair and affordable balance of available housing. ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 31 of 32 VIII. CONCLUSION This Analysis of Impediments to Fair Housing and Fair Housing Action Plan was prepared over a two-year period beginning in October 2000. It is the result of a comprehensive study of both the public and private sectors in Moscow, Idaho to determine whether impediments to fair housing exist and to develop a plan by which any impediments identified can be remedied. The work on the plan was accomplished by the members of the City of Moscow Fair Housing Commission, the staff of the City of Moscow Community Development Department, the Moscow City Attorney working with a law school intern from the University of Idaho College of Law, and a team of demographers from the University of Idaho Department of Geography. The analysis was completed through direct examination of city documents and demographic data, and through interviews with community members and stakeholders who are directly involved in the provision of housing. The results of this analysis found very few systemic impediments to fair housing existing in the public sector. Several impediments to fair housing were identified within the City of Moscow’s ordinances, codes, policies and procedures, and remedies to these impediments will be implemented. However, in the private sector more substantial impediments to fair housing were identified, particularly in the area of education and understanding of the particular requirements of the Fair Housing Act. It was observed, for example, that a general lack of understanding and knowledge about fair housing laws exists among the residents of Moscow. The Commission has concluded that an impediment to fair housing exists when individuals do not know when their rights have been violated, or what rights they in fact enjoy under the Fair Housing Act. Also, a number of individuals exhibited a lack of knowledge regarding fair housing requirements in their belief that the protections afforded by the Fair Housing Act are more extensive than the Act actually provides. Although many of the stakeholders involved in the provision of housing reported that they have obtained a significant level of fair housing education, some individuals reported a need for further education in order to obtain a better understanding of the requirements of the Fair Housing Act. In a few cases, these individuals reported that when they sought additional information regarding the Fair Housing Act, they were unable to find the resources necessary to give them the information that they needed. Impediments to fair housing were therefore identified in the need for further educational opportunities, and for better access to fair housing- related resources for housing providers. Where impediments were identified, an action item was developed aimed at resolving the impediment. The task of resolving these impediments will be the ongoing work of the Moscow Fair Housing Commission. A lack of understanding of the requirements of the Fair Housing Act was found to be the most systemic and pervasive impediment to fair housing in Moscow. Therefore, the challenge for the Commission will be to find an effective educational method to deepen the understanding of the ---PAGE BREAK--- City of Moscow Fair Housing Analysis of Impediments Page 32 of 32 Fair Housing Act and to attract individuals to those educational opportunities and to improve access to necessary fair housing resources. IX. ACKNOWLEDGEMENTS This Analysis of Impediments to Fair Housing and Fair Housing Action Plan was prepared by the City of Moscow Fair Housing Commission. The Commission is currently composed of the following individuals: Karl Johnson – Chair Kirk Lightfield – Vice Chair Ken Nagy – Secretary Raúl M. Sánchez – Commissioner Tayo Omotowa – Commissioner The Commission wishes to thank the following individuals for their valuable assistance in completing this project: Bill Belknap, Larry Betts, Randy Fife, Hal Godwin, Harley Johansen, Krista Kramer, Richard Mabbutt, JoAnn Mack, Linda Pall, Joel Plaskon, Max Ruckdeschel, Lyliane Sheetz, Jing Lan Yu. X. SIGNATURES , Marshall H. Comstock, Mayor , Karl Johnson, Fair Housing Commission Chair , Joel D. Plaskon, Fair Housing Resource Representative