2019 Analysis of Impediments to Fair Housing: Phase 1 Report

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for use of agency notices and literature is important. Does the agency provide them to potential applicants of housing programs? Does the agency place them in their offices? The use and context of these documents are necessary components in assessing their effectiveness in affirmatively furthering fair housing. Additionally, the agency did not submit any translated documents. The reviewers were thus unable to review the extent to which the agency's translated forms and brochures, if any, complied with its LEP policy or affirmatively furthered fair housing. Finally, the reviewers also looked at the OHCD website to examine relevant fair housing content and its accessibility. As previously mentioned, the CAPER focused on the website as a way to affirmatively further fair housing: "The OHCD's website has continued to be successful in increasing awareness of housing rights and resources. In PY2018, there were approximately 1,000 hits to the website for people seeking information. On June 19, 2019, the OHCD launched a dedicated Fair Housing website from the County of Hawaii's main website to further increase awareness and exposure." CAPER at 9. Although developing a website is a good and important step, there are inherent limitations to websites. There are barriers to access for many individuals in the target population, particularly among the elderly, individuals with disabilities, and LEP individuals. They may not be aware of the website, may not know how to access the website, or may not be able to access the website. The website (https://www.hawaiicounty.gov/departments/office-of-housing/fair-housing) is simple and streamlined, which is helpful in increasing accessibility and readability. The website appropriately lists all the federal and state protected classes for nondiscrimination. The website can be strengthened by including information about reasonable accommodations and language access. Importantly, there are no translated links or parts of the website. If they do exist are on the website, the lack of ease in finding these resources or brochures would likely be a high barrier for LEP individuals. 3. Affirmatively Furthering Fair Housing The duty of agencies as outlined in federal regulations to affirmatively further fair housing goes beyond communication of fair housing laws. According to regulations, affirmatively furthering fair housing means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a program participant's activities and programs relating to housing and urban development. 24 C.F.R. § 5.152. 33