2019 Analysis of Impediments to Fair Housing: Phase 1 Report

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alternative ways to articulate in a reasonable manner a plan for providing meaningful access. Entities having significant contact with LEP persons, such as schools, grassroots and faith -based organizations, community groups, and groups working with new immigrants will be contacted for input into the process. If the PHA determines it is appropriate to develop a written LEP plan, the following five steps will be taken: (1) Identifying LEP individuals who need language assistance; (2) identifying language assistance measures; (3) training staff; (4) providing notice to LEP persons; and (5) monitoring and updating the LEP plan. PHA Administrative Plan at 2- 16 to 2-17. The agency did not submit a written LAP, an implementation plan, or an explanation regarding its analysis if the agency had determined that a LAP was not necessary. 2.3 Agency Reflection The agency submitted relevant parts of its latest Consolidated Annual Performance and Evaluation Report (CAPER), which covered the period from July 1, 2018, to June 30, 2019. The CAPER included analysis of efforts to affirmatively further fair housing. Multiple documents submitted by the agency, like the 2015-2019 Consolidated Plan and the 2018 Action Plan of the Consolidated Plan (2015-2019), also attached the 2011 Analysis of Impediments to Fair Housing. These self -reflective reports are helpful in achieving agency goals to affirmatively further fair housing. As the reports recognize, there are still impediments and continued work is required to achieve these goals. The CAPER reported The Analysis of Impediments (AI) completed in 2016, identified the general lack of awareness of fair housing rights on the part of people with disabilities, members of the general public, landlords and property managers. Many are unaware of the legal requirements for fair housing choice. They are unaware of the available resources and programs that support people with disabilities and assist in obtaining and retaining suitable housing. This lack of awareness is a major impediment for the County of Hawaii." The CAPER focused on agency trainings, on the agency's website, and other literature for public education. CAPER at 26. The CAPER reported on the agency's training efforts to affirmatively further fair housing: "In PY2018, the OHCD conducted a total of 7 Fair Housing training/seminar sessions for property managers, homeless programs and for the general public. Of these 7 training/seminars, 2 were conducted for property managers and the general public (1 in Hilo and 1 in Kona) and 4 additional Fair Housing training/seminars were held with local non -profits and for people re- entering the housing market. The OHCD also held 1 Fair Housing training for non-English speaking and limited English proficiency families. Total attendance included 7 staff members and approximately 135 public attendees, 45 of which were new landlords and 23 of which were non-English speaking or of limited English proficiency." CAPER at 8-9. These trainings can be effective ways to affirmatively further fair housing if they are advertised and implemented in accessible ways. The CAPER also focused on the website as a way to affirmatively further fair 31