2019 Analysis of Impediments to Fair Housing: Phase 1 Report

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As discussed, OHCD did take some steps to analyze some impediments to fair housing. While these demonstrate perfunctory systemic analysis, they do not indicate initiative taken by the agency to take meaningful actions to analyze, review, and then work 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 and access for protected class. For example, the agency submitted OHCD Fair Housing Coordinator Responsibilities. The document states that the coordinator's duties include serving as a "neutral party" to "resolve[] fair housing inquiries," attending meetings and trainings, setting fair housing goals for the agency, coordinating seminars and other trainings, and updating the website. These tasks are helpful steps in agency compliance with fair housing laws but do not focus on addressing and analyzing patterns of segregation or address areas of concentrated poverty. Overall, some community training and input is demonstrated, as well as identification of some impediments, but there is no evidence that the agency is engaging in more robust actions to survey barriers that might prevent fair housing. OHCD does show some evidence to indicate concerns for accessible housing for individuals with specific disabilities. However, solutions for providing units included in housing projects do not specifically demonstrate meaningful actions that intend to disrupt segregation patterns or analyze if such patterns exist. Overall, there is little evidence to suggest that OHCD has engaged with analysis on the level that federal regulations contemplate should be undertaken to take meaningful action to address disparities. The absence of evidence of any review of demographic or neighborhood living patterns or analysis of poverty or concentrations of projects or voucher holders suggests that OHCD has not been able to take meaningful actions to affirmatively further fair housing, but instead has only demonstrated minimum compliance. 4. Agency Recommendations After reviewing the adequacy of documents, the following are recommendations or next steps that could be taken by agencies to demonstrate that their documentation includes a commitment to fair housing. The recommendations are designed to 1) provide recommendations to ensure that documents meet minimum compliance; 2) provide recommendations on how agency documentation can better demonstrate the agency's commitment to affirmatively furthering fair housing. These recommendations are confined specifically to address the documentation and dissemination of written policies 4.1 Fair Housing Rules Policy Document Recommendations Create new agency administrative rules to comply with state law. As discussed previously, The Rules and Regulations of the Office of Housing and Community Development for the County of Hawai '1 (2016) ("PHA Administrative Plan") ("PHA Administrative Plan") was developed to include reference only to Federal policies. The PHA Administrative plan omits some of the protected classes, indicating that no state or local nondiscrimination laws or ordinances apply. Written policy documents should include applicable state law. Policies need to be immediately updated. Review and ensure all protected classes are included in all policy documents. 34