HomeMy WebLinkAbout1979-05-15; City Council; 5700-1; Affirmative Fair Housing Marketing PlanCITY OF CARLSBAD
Initial
AGENDA BILL NO: 3-1700- Dept. Hd.
a Cty. Atty
DATE: Mav �5, 1479 - Cty. Mgr.
DEPARTMENT: Redevelopment
SUBJECT: AFFIRMATIVE FAIR HOUSING MARKETING PLAN
Statement of the Matter
At its meeting of December 19 , 1978, Council instructed staff to prepare
documents which would bring the City into compliance with existing federal
guidelines on Affirmative Marketing.
The Redevelopment Coordinator has completed his research into the above
noted subject. Based on the attached report, there is a set of require-
ments that the City must follow prior to implementation and administration
of its own local AFHMP. The City must adopt an AFHMP and request the Fair
Employment Practice Commission to enter into a Memorandum of Understanding
which would allow the City to administer its own AFHMP.
EXHIBITS
Ass stant Redevelopment Coordinator's Memorandum, dated April 20, 1979.
RECOMMENDATION ,
That Council should adopt Resolution No. r 77,3 establishing an Affir-
mative Fair Housing Marketing Plan, and instruct staff to initiate a
Memorandum of Understanding with California State Fair Employment Practice
Commission.
JH:jd
4/20/79
Council Action:
5-15-79 Council adopted Resolution 5773, establishing an Affirmative
Fair Housing Marketing Plan, and instructed staff to initiate
a Memorandum of Understanding with California State Fair
Employment Practice Commission.
MEMORANDUM
DATE: April 18, 1979
TO: Paul Bussey, City Manager
VIA: .Tack E. Henthorn, Redevelopment Coordinator
FROM: Drew Aitken, Assistant Redevelopment Coordinator
SUBJECT: AFFIRMATIVE FAIR HOUSING MARKETING PLAN
BACKGROUND
At its meeting of December 19, 1978, Cout:il voted to pursue
local administration of Affirmative Fair housing Marketing Plan.
In telephone conversations during the week of April 9, 1979, I
spoke with representatives of the State Fair Employment Practice
Commission, HUD, and the Equal Opportunity Management Office of
the County of San Diego about the procedures that the City of
Carlsbad must follow in order to administer its own AFHMP.
According to the information received from all parties, the
following steps must be completed, prior to implementation of a
locally administered AFHMP. The first step in the process is for
the Council to adopt an AFHMP by resolution (Attachment A). Next,
the resolution and the plan shall accompany a request to be sub-
mitted to the California Fair Employment Practice Commission for
a Memorandum of Understanding (Attachment B) to be entered into
between the Fair Employment Practice Commission and the City of
Carlsbad in order to comply with HUD regulations pertaining to the
HCD Block Grant program. (See attached Memorandum from Redevelop-
ment Coordinator 12-12-78 (Attachment CH. After the MOU is
executed the City will have the authority to implement and administer
to its own AFHMP.
AFHMP PROCEDURES:
Under the terms of the plan proposed (Attachment D), when an
applicant applies to the City for any building or special use
permits or a final building inspection, they shall file with the
City an Affirmative Fair mousing Marketing Plan. The City shall
review the applicant's plans using the guidelines established by
the Division of Fair Employment Practices of the Department of
Industrial Relations of the State of California. If the applicant's
plans are approved, they are submitted to the California Fair
Employment Practice Commission for ratification.
The City shall have the responsibility to monitor and review
the applicant's compliance with the Affirmative Fair Housing
Marketing Plan of the applicants that was previously approved.
This is to ensure that the applicant is carrying out his AFHMP.
The applicant will submit a monthly progress report to the City.
The City will then submit a report, which shall be comprised
of the reports received from the applicants to the California
Fair Employment Practice Commission.
ANALYSIS:
The City of Carlsbad's Affirmative lousing Marketing Plan is
designed to attract buyers and tenants of all ethnic groups and
genders to housing for initial sale or rental.
The City's AFHMP is structured after the County's plan which has
already been approved by both HUD and the Fair Employment Practice
Commission. The City's plan has built into its implementation,
the flexibility to provide applicants with simplicity in processing
their AFHMP. For example, it is anticipated that the City will
become participants in the HUD/BCA agreements, which provides BCA
with the authority to implement Affirmative Fair housing Marketing
Plans for local builders and developers. This service is provided
to both members and non-members of BCA. As a participant in the
HUD/BCA agreement the City may encourage applicants to become
signatories with BCA.
I14PACT
There is a two -fold benefit in utilizing the resources at BCA,
a) It appears to be less bureaucratic and more convenient overall
for the private developer and
bl It streamlines the administration of the process for the City
in that BCA will provide the applicant's monthly progress reports
to the City. No additional costs are anticipated and no additional
personnel required to administer this program.
RECOMMENDATION:
It is recommended that the AFHMP be forwarded to Council for their
adoption, and that we request Council to enter into a Memorandum
of Understanding with FEPC to administer AF11MP. Furthermore, it
is recommended that Council, via resolution, become participants
in with the Building Contractor Association and HUD agreement.
AA:jd
4/20/79
A Ai
1 RESOLUTION NO. 6773
CITY OF CARLSBAD RESOLUTION ESTABLISHING AN
AFFIRMATIVE FAIR HOUSING MARKETING PLAN
4 RL;SCLVED by the City Council of the City of Carlsbad, State
5 of California; that
6 WHEREAS, the California Fair Employment Pxactice Commission,
7 pursuant to authority contained in State of California Memorandum,
8 subject: Affirmative Fair Housing Marketing Guidelines, adopted
9 June 2, 1977, may, at its discretion, enter into a Memorandum
10 of Understanding with the County of San Diego to jointly admin-
11 ister an Affirmative Fair Housing Marketing Plan within *.he City
12 of Carlsbad; and
13 WHEREAS, it is the determination of this Council that it
14 is in the best interests of the City of Carlsbad to be a party
15 to such Memorandum of Understanding with the California Fair
16 Employment Practice Commission; and
17' WHEREAS, it is necessary for this Council to adopt rules,
18 regulations and administrative processes in order to implement
19 I an Affirmative Fair Housing Marketing Plan and thus enter into
20 such a Memorandum of Understanding; and
21 WHEREAS, it is the desire of this Council to set forth the
22 conditions under which certain sponsors/developers are exempted
23 from compliance with the Affirmative Fair Housing Marketing Plan;
24 and
25 WHEREAS, it is the%desir.F of this Council to set forth the
26 conditions under which certain sponsors/developers are exempted
27 from compliance with the Affirmative Fair Housing Marketing Plan;
28 and '
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Attachment "A"
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WHEREAS, it is the concern of this Council that quality
housing be available to its citizens; and.
WHEREAS, there is need to reestablish the concept of an
open community wherein persons are free to live where they choose
irrespective of race, color, religion, national origin, ancestry,
sex or marital status; and
WHEREAS, the Council acknowledges the need to take affirma-
tive action to expand the opportunities of all peoples to live
where they choose; and
WHEREAS, the Council desires to reaffirm the City's commit-
ment to take affiramtive action to provide a balanced community
environment for its citizens;
NOW, THEREFORE, IT IS RESOLVED, ORDERED AND DECLARED that
the attached Exhibit A which sets forth rules, regulations and
administrative processes of the Affirmative Fair Housing'Marketing
Plan (AFHMP) is hereby approved and adopted by this Council.
PASSED, ADOPTED AND APPROVED by the City Council of the City
of Carlsbad, State of California, this 15th day of _PLY.
1979, by the following vote:
AYES: Councilmen Packard, Skotnicki, Anear, Lewis and
IIII Councilwoman Casler
11.
NOES: None
ABSENT: None
RONALD C. PACKARD, Mayor
AIT"11A L. RAUTENKRANZ, �yC
(SEAL)
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Exty" it A to
Res,tion 5773
MEMORANDUM OF UNDERSTANDING
This Memorandum of Understanding, made and entered into
, by and between the
this
California Fair Employment Practice Commission (hereinafter calle(
the Commission), the Division of Fair Employment Practices of
the Department of Industrial Relations of the State of California
(hereinafter called the Division), as parties of the First Part,
AND
the City of Carlsbad, California thereinafter called the City)►
Party of the Second Part.
WHEREAS, the California Fair Housing Law, Part 5 (commending
with Section 35700) of Division 24 of the Health and Safety Code
(hereinafter called the Fair Housing Law) prohibits discriminatie
on the basis of race, color, religion, sex, marital status,
national origin, or ancestry in housing accommodations.
WHEREAS, the Commission and the Division are empowered by
Labor Code Section 1419.5 to prevent discrimination in housing
as provided in Part 5 commencing with Section 35700 of Division
24 of the Health and Safety Code.
WHEREAS, Health and Safety Code Section 35730.6(d) authoriz
the Division to obtain upon request and utilize the services of
all governmental departments and agencies and conciliation
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Attachment "S"
1. councils, the Division wishes to exercise that authority. -Labor
2 Code Section 1419.7 empowers the Division to provide assistance
3 to communities and persons in resolving disputes, disagreements
4 or difficulties relating to discriminatory practices which
5 impair the rights of persons in such communities under the
6 constitution or laws of the United States or of the Sta' of
7 California. Such assistance shall consist of endeavors at
8 conference, conciliation, and 'persuasion.
9 WHEREAS, the Commission wishes to designate the City as an
10 advisory agency and conciliation council with the limited charge
11 of implementing a program to further the purposes of the Fair
12 Housing Law in the area of Affirmative Fair Housing Marketing.
13 WHEREAS, the Commission has promulgated guidelines in the
14 area of Affirmative Fair Housing Marketing.
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16 NOW, THEREFORE, THIS MEMORANDUM OF UNDERSTANDING
17' WITNESSETH THAT:
18 1. The Commission, the Division, and the City agree to
19 establish a program which will provide for a combination of
20 efforts between the Commission, the Division, and the City in
21 order to eliminate discrimination in housing within the City.
22 The Office of Contract Compliance or other entity authorized by
23 the City shall act as the laison between the Commission, the
24 Division, and the City.
25 2. The Contract Compliance Coordinator or other duly authorized
26 person charged by the City with the administration of the
27 Affirmative Housing Marketing Plan -(hereinafter referred to as
28I Authorized Agent) shall be charged with the responsibility of
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1 carrying out the duties of the City in the implementation of this
2 program.
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3. The authorized agent shall, under this agreement, be
41 charged with the following duties and responsibilities:
51 A. The authorized agent shall accept for purposes of
•61 review, evaluation, and approval all Affirmative Fair
7 Housing Marketing Plans nereinafter referred to as Plans)
8 which are submitted to the City for approval.
9 B. • The authorized agent shall develop a program of
10 evaluation which entails the standards and requirements set
11 out by the Commission in its Guidelines.
12 C. The authorized agent shall review all plans and approve
13 or disapprove such plans.
14 D. The authorized agent shall maintain a record of all
15 plans submitted to it and the outcome of its determination
16 as to the adequacy of the plan.
17 E. The authorized agent shall submit to the Commission
1s plans which such entity has approved for the purpose of
19 Commission ratification of the authorized agent's determina-
20 tion.
21 F. The Commission shall ratify or disapprove the authorize
22 agent's determination as provided for in the Commission's
23 guidelines on Affirmative Fair Housing Marketing.
24 G. When a plan is disapproved by the authorized agent
25 such plan shall be submitted to the Commission with a
20 recommendation and report. The Commission may, at its
27 discretion, refer the matter to the Chief of the Division,
28 and request that the Chief of a duly authorized represen-
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1 tative engage in persuasion and conciliation with the rele-
2 want parties, pursuant to section 1419.7 of the Labor
3 Code. The Chief of the Division may also undertake any
4 other action he or she deems appropriate.
5 H. After a plan is deemed approved by the Commission, the
6 authorized agent shall'have primary responsibility for
7 monitoring and conducting reviews of compliance with the
8 approved plan. The authorized agent shall provide the
9 Commission with a report of such reviews as set forth in the
10 Guidelines on Affirmative Fair Housing Marketing.
11 I. If the authorized agent finds that there has not been
12 compliance with the approved plan, the authorized agent
13 shall refer the matter to the Commission for further action
14 as provided for in the Guidelines. The Commission may, at
15 its discretion, refer the matter to the Chief of the Divisi'o ,
16 and request that the Chief or a duly authorized represen
17 tative engage in the process of conference, persuasion, and
18 conciliation with the relevant parties, pursuant to Section
19 1419.7 of the Labor Code.
20 J. once the first sales, rentals or leases of all the
21 relevant units of a particular plan are completed, the
22 authorized agent shall submit to the Commission a report
28 on such sales, rentals, or leases and compliance with the
24 plan.
25 K. This Memorandum of Understanding shall be revocable by
26 the Commission and the Division at their discretion.
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1 IN WITNESS WHEREOF, the parties hereto have caused this
2 Memorandum of Understanding to be executed by their duly
3 authorized officers, the day and year first written
It above.
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8 FAIR EMPLOYMENT PRACTICE COMMISSION
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DIVISION OF FAIR EMPLOYMENT PRACTIC•S
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CITY OF CARLSBAD
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Memorandum
Date: December 12, 1978
To: Paul Bussey, City Manager
From: Jack flenthorn, Redevelopment Coordinator
Subject: Affirmative Fair Housing Marketing Plaa
At it's meeting of December 5, 1978, Council was advised of the
County': policy requiring that I1ousing and Community Development
Block Grant recipients comply with the County's Affirmative Fair
Housing Marketing Plan, or formulate a similar plan for local
administration.
On December 8, 1978, I met with a represeiitative of the Contract
Compliance office to discuss the AFIIMP and it's impact upon the
city's development review process. Of primary concern was whether
or not a less complex system could be utilized to merit the
combined requiremants of the Federal, State and County levels.
Historical Perspective
In 1972, as a condition of receiving funds from the Federal
Department of Housing and Urban Developmen, the County prepared
documents which would insure affirmative marketing of housing.
In 1974 a program was adopted to ensure receipt of HCD funds.
It was subsequently found that the State pre-empts local entry
into this area through the Rumford Act and specifically reserves
sanction activity for itself.
On January 12, 1977, the State Fair Employment Practices
Comission found the County in violation of State statute. This
put the County into the position of having a document which was
acceptable to the Federal Government, but deemed 'o violate
State statute. In turn, the County could not, by Federal
regulations, pass responsibility onto the State.
The County subsequently petitioned the State for permission to
administer an AFHMP for purposes of obtaining Federal funding
This gave rise to a City of San Diego/County/Building Contractor's
Association/IIUD/State of California dialogue. As a result of
this effort a cooperative venture between government and
builders was developed which enables funding to be received
'through an AFHM program based upon advertising and education.
Attachment "C"
PURPOSE
Builders utilizing any type of Federal'or State funding are
currently required to meet the requirements outlined in the
County's document. The effect of the AFHMP is basically to
ensure that conventional developers undertake efforts to promote
their projects to all segments of the population.
It is important to note that neither the City nor the County can
exercise any sanctions against developers who do not comply with
the AFHMP. in fact, this total area is reserved to the State.
IMPACT
Although the packet forwarded is rather voluminous, when the
process was explained by the County staff it appeared rather
simple. The filing process entails approximately 1 to 3 hours
of time dependent upon the size of the project, the existence
of demographic data, and the builder/developer's past involve-
ment with the process.
According to County Staff, most builders are encouraged to
process through the Local Building Contractor's Association
which will process the development for a fee of less than five
dollars per unit. in addition to lowering the.cost to the developer
by making their services available, the program reduces the cost
to the governmental entity due to BCA's familiarity with the
program.
CONCLUSION
From research to date and the meeting of December 8, 1978, it is
concluded that AFHMP is a legitimate requirement relative to IiCD
funding. As noted in the Historical Perspective section above,
the requirement stems from the original housing and Community
Development Act of 1974 and is complicated by State statute.
The County staff indicates that the provisions of the AFHMP need
apply only to development initiated after adoption of the plan by
the City. Therefore, only initial sales of new development would
be subject to the provisions of the AFHMP.
OPTIONS ANALYSIS
The County indicates that in order to meet the HUD/State/County
guidelines, the following options are available:
(1) Adopt the County AFHMP and contract with the County for
administration.
(2) Formulate and administer a local program.
(3) Withdraw from participation in the Block Grant Program.
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The County has indicated a willingness.to administer the AFHMP
for the City on a cost basis via a mutually approved agreement.
At this point in time, the County cannot provide an estimate of
costs. In addition, no determination has been made as to whether
their cost would include overhead or be made up of direct costs
only. Further, the contract approach raises questions of whether
or not future changes in the County program would reflect local
concerns. This is especially true in terms of the level of informa-
tion required to be filed and processing/procedural changes.
Local administration of the program would undisputedly ensure
local control. of all aspects of the program, including its inclusion
as a part of the City's overall Housing Element revision program.
In light of recent changes in State Statute, the City is faced
with substantially revising its Housing Element to bring it into
compliance with recently formulated State HUD guidelines. One
portion of the guidelines deals with affirmative action to ensure
that housing is available to all segments of the community. The
program offered by the County or a model appears to address and
meet the state requirement. It appears as though local administration
of an AFHMP in conjunction with the Carlsbad Housing Authority's
involvement in Section 8 and Section 23 program would provide a
fairly comprehensive approach tc meet4ng the new Housing Element
requirements.
Since the City/Housing authority structure is currently operational
the costs associated with administration of a local program should
be minimal. In fact, the majority of the costs would in all proba-
bility be related to file space and clerical activity associated
with filing. The actual processing would be accomplished via form
letters and check lists.
The third option available is to forego further expenditure of
block grant funding. This option would prevent future expenditure
of grant funding. Dependent upon the determination of the County
this could jeopardize up to $360,000.00 in funding, i.e. yer.rs 3,
4, and s.
FINDING
The County's insistence that the City adopt ari AFIIMP as a condition
of receiving Block Grant funding is supported by existing Federal
Regulations.
In addition, the State housing element guidelines will require -the
City to have a similar program in operation by the end of calendar
year 1979.
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It appears at this time as though the question is not one of
whether or not the City is, or will be, required to have an AFHMP,
but one of when it will be required to have one operational.
RECOMMENDATION
If Council desires to continue to receive HCD funding, then it is
recommended that staff be directed to prepare documents for adoption
and local administration of an AFHMP.
i
THE
CITY OF CARLSBAD
AFFIRMATIVE FAIR HOUSING MARKETING PLAN (AFHMP)
Part I - General
POLICY
Citizens of the City of Carlsbad shall be free to live where they
choose irrespective of race, color, religion, national origin,
ancestry, sex or marital status.
OBJECTIVES
1. To promote a condition in which individuals of similar income
levels have the same opportunity to obtain housing.
2. To encourage the establishment of racially balanced communities.
APPLICABILITY
This Affirmative Fair Housing Marketing Plan (hereinai er referred
to as AFHMP) shall be applicable to sponsors/developers (hereinafter
referred to as Applicants) who apply to the City of Carlsbad for.:
1. Building permits for subdivisions and multi -family projects
which will be constructed for the purpose of sale, rental or
lease.
2, Special use permits for mobile home parks► planned residential
developments, and multi -family residences.
NOTE: if ar Applicant contracts marketing responsib Uity to another
party through contractual agreement or sale, this AFHMP
shall be applicable to such party. The requirements of
this AF11MP shall be applicable to the original successors -
in -interest of an Applicant: insofar as the first sales,
rentals, or leases to the public are concerned.
EXEMPTIONS
Applicants in the following categories are exempt from the pro-
visions of this AF11MP:
1. Those who apply for building permits for a subdivision pro-
ject involving less than 20 dwelling, units for sale.
2. Those who apply for building permits for a multi -family
Attachment "D"
project and/or special use permits for a mobile home park
involving .t(-'.ss than 10 dwelling units for rent or lease.
3. Those who apply for building permits for dwellings to be
listed as hotels or motels.
4. Those who are or become voluntary signatories to the Depart-
ment of Housing and Urban Development/Building Contractors
Association (IiUI)/BCA) Affirmative Marketing Agreement.
Part II - Procedures
APPLICANT SALES, RENTAL AND LEASE INTEGRATION GOALS
1.
Sales .integration goals shall be:
Minority Integration Goals
20%
15%
1'0%
A. Cost of 11ousin
Up •to $62, 000
$62,001 to 85,000
$85,001 and over
B. Cost of 11ousin
Up to $62,noQ
$62,001 to 85,000
$85,001 and over
White Iritegration Goals
- 80%
75%
70%
2. Rental and lease integration goals shall be: For all housing
costs 30% minority and 70% white.
3. Integration goals shall be reveiwed annually and adjusted
accordingly when there are significant changes in the cost
of housing.
APPLICANT AFFIRMATIVE FAIR 11OUSING MARKETING PLAN (AF11MP)
Each applicant shall submit an hffirmative Fair Housing Marketing
Plan (hereinafter referred to as Plan) to the City of Carlsbad
Contract Compliance Officer or Duly Authorized Agent before the
issuance of any building Permit orsspecial rein ef permit
ectun il ichais
subject to this policy.
Tile Plan units are sold, rented or leased and shall contain, but not be
limited to the following:
1. Designation of a qualified official to perform duties of
Equal Opportunity Officer. This official will be riven the
responsibility for assuring Applicant compliance with this
Plan.
2. Demographic information of the area in which the project is
located.
3. Anticipated market based on racial composition of the area.
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4. Sales, rental, or lease goal which has been determined based
upon'the demographic makeup of the area.
5. Outreach efforts which will be taken to attract the appro-
priate racial group(s) to the housing market.
6. Name(s) of minority/nonminority media which will be used,
and expected frequency of use.
7. Assurance that radio advertisements will use the equal housing
opportunity slogan.
8. Assurance that T.V. advertisements will use either the equal
housing opportunity logo or slogan.
9. Assurance that all billboard signs, brochures, handouts, and
newspaper and magazine advertisements will have an equal
housing opportunity logo and slogan of appropriate size.
10. Description of bilingual sales, rental or lease advertising
which will be used.
11. Assurance that one fair housing poster in English and one in
Spanish will be posted in the project sales or rental/lease
office and one fair housing poster in English will be posted
in each housing model. ,
12. Names of community organizations which will be given informa-
t3on concerning the project.
13. Description of affirmative action recruiting and hiring
policy for staff engaged in sale, rental or lease of housing.
14. Information concerning the racial composition of the staff.
15. Summary of training to be provided to the staff on local,
state and federal fair housing laws and on affirmative
housing principles.
16. A statement of intent to participate in the County of San
Diego llousing Referral Service, when i,aplemented.
17. Assurance that sales, rental or lease reports will be sub-
mitted to the City of Carlsbad Contract Compliince Officer
by the 5th day of each month for the preceding month until
all units are sold, rented, or leased. These reports shall
include:
A. Name, location and census tract of project.
B. Total number of units in the project.
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C. Cumulative number of units sold, rented, or leased
during the month reported.
D. Cumulative number of units sold,
rented,the or leased
by racial ethnic grouping during
E. A+statement in percent of the sales, rental,
or lease
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integration goal as determined by g
F. A statement in percent of the sales, rental, or lease
integration goal which has been achieved to date.
G. If the achieved integration goal to date is below the
integration goal established from housing cost data, a
summary of affirmative marketing action which shall be
taken to bring the achieved goal up
18. Assurance that the Plan, when approved by the City of Carlsbad
shall be posted at the sales, rental, or lease office with
the address and telephone number of the Contract Compliance
Officer in plain view for public inspection by an interested
group or individual.
19. Assurance that the Plan, when approved, shall not be modified
without the concurrence of the Contract Compliance of
CITY OF CARLSBAD RESPONSIBILITIES
The Contract Compliance Coordinator (hereinafter referred to as
-Authorized Agent) shall be charged with the responsibility of
carrying out the duties of the City of Carlsbad in the implemen-
tation of this plan. Duties of the Authorized Agent shall include
the following:
1. The review and approval or disapproval of Applicant Plans.
2. Assisting the Applicant in revising a disapproved plan
d
providing continuing technical assistance to the Applicant
through the period of initial sale, rental, or lease.
3. The monitoring of applicant's sale, rental, or lease activity
for compliance with this AFHMP and Applicant's Plan. Compli-
ance determinations will be based on results achieved and the
Applicant's documented good faith efforts.
q. Investigation pplicant Plansno all aandsof determinatic isasfto whether
this
AFFFMP and/or App
corrective action is required.
5. When corrective action is needed, determination as to
whether the corrective action can be initiated by the City
of Carlsbad or whether the matter should be referred for
resolution to the State of California Fair Employment
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Practice Commission who may, at its discretion, direct the
noncomplying party to submit to the process of conference,
conciliation or pursuasion.
6. The submission of Plans and reports to the State of California
Fair Employment Practice Commission.
AA/j
4/19/79