2019 Analysis of Impediments to Fair Housing: Phase 1 Report

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1. Overview A review of submitted documents was undertaken to assess "the degree to which agency policies and procedures (legal, regulatory, and administrative) align with fair housing law and affirmatively promote equal access to housing for all Hawai`i's residents." In particular, this analysis focused on two questions: 1) do the documents comply with current interpretation of fair housing law; and 2) are the policies and procedures adequate to the task of affirmatively furthering equal housing access for disadvantaged communities in Hawai`i. The County of Hawai`i's Office of Housing and Community Development (OHCD) plans, administers, and operates housing programs for the County of Hawai`i, including Section 8 rental assistance. 2. Agency Policies Agencies were asked to submit all documentation that showed policies as well as their steps taken to affirmatively further fair housing. First reviewed were documents submitted by OHCD to demonstrate current policies regarding fair housing laws. 2.1 Compliance OHCD's policy documents do not fully comply with fair housing laws in the state of Hawai`i. The PHA Administrative Plan omits protected classes under state law and overall presents confusing language about the applicability of state fair housing law. Other submitted documents reflect a similar confusion about the applicable protected classes. OHCD does appear to have the required policies for laws regarding minimum compliance with reasonable accommodation for disabilities. Finally, there is some question as to the sufficiency of the agency's language access plan. As to be discussed in Section III, while OHCD does submit some evidence to demonstrate a review of impediments to fair housings, there is little evidence submitted that suggests OHCD has taken steps to analyze and review demographic data, or has worked to challenge patterns of segregation or review and address areas of concentrated poverty. Instead, policies appear to be confined to mere basic minimum compliance with fair housing laws. 2.2 Policy Documents OHCD focused on submitting policy documents and project proposals that demonstrated some commitment to communicating and ensuring that individuals accessed fair housing and were informed of their rights and responsibilities. OHCD also submitted some public -facing notices and forms. However, despite identifying language access as a key need for affirmatively further fair housing, none of the notices and forms submitted had translations available. 27