HomeMy WebLinkAbout2020-07-14; City Council; ; Fiscal Years 2020-25 Analysis of Impediments to Fair Housing Choice for the City’s Community Development Block Grant ProgramCA Review __RK_
Meeting Date: July 14, 2020
To: Mayor and City Council
From: Scott Chadwick, City Manager
Staff Contact: Nancy Melander, Program Manager
nancy.melander@carlsbadca.gov, 760‐434‐2812
Subject: Fiscal Years 2020‐25 Analysis of Impediments to Fair Housing Choice for
the City’s Community Development Block Grant Program
Recommended Action
That the Carlsbad City Council adopt a resolution approving the final fiscal years 2020‐25
analysis of impediments to fair housing choice for the city’s Community Development Block
Grant program.
Executive Summary
The Housing and Community Development Act of 1974 is the governing statute for the city’s
Community Development Block Grant program. The statute requires that each federal
entitlement grantee certify to the satisfaction of the U.S. Department of Housing and Urban
Development that an awarded federal grant will be carried out and administered in accordance
with the federal Fair Housing Act, and the grantee will work diligently to affirmatively further
fair housing.
As part of the CDBG certification process, participating jurisdictions must prepare an analysis of
impediments to fair housing choice every five years. This analysis is an assessment of the
regional laws, ordinances, statutes and administrative policies, as well as local conditions that
affect the location, availability and accessibility of housing.1 The analysis also provides solutions
and measures that will be pursued to mitigate or remove identified impediments.
The fy 2015‐20 analysis of impediments to fair housing choice was approved by the City Council
on May 5, 2015, and is required to be updated by the end of July. The action before the City
Council is to consider and approve the draft fy 2020‐25 analysis so the city can remain in
compliance with federal regulations and continue to participate in the CDBG program
(Attachment A to Exhibit 1).
1 The Department of Housing and Urban Development is committed to eliminating racial and ethnic segregation,
illegal physical and other barriers to the disabled and other discriminatory housing practices. HUD’s fair housing
policy is intending to give everyone choice in housing.
July 14, 2020 Item #6 Page 1 of 211
Discussion
Background
The analysis of impediments to fair housing choice covers the San Diego region and provides a
demographic profile of San Diego County, assesses the extent of housing needs among specific
income groups and evaluates the availability of a range of housing choices for residents. The
analysis also examines the conditions in the private market and public sector that may limit the
range of housing choices or impede a person’s access to housing. The analysis also reviews
impediments to fair housing that may prevent equal housing access and develops solutions to
mitigate or remove such impediments.
Preparation of the analysis of impediments to fair housing choice
The City of Carlsbad is a participating member of the San Diego Regional Alliance for Fair
Housing, which comprises fair housing service providers, enforcement agencies and
government entities. The municipal members of the alliance oversee the preparation of the
analysis, which has historically been funded with CDBG and other local funds contributed by the
entitlement jurisdictions in San Diego County on a pro rata basis. The alliance has successfully
collaborated on the development of the past three reports and assisted in the development of
the draft FY 2020‐25 analysis.
Community outreach and findings
Outreach is an essential component of developing the analysis and necessary to assess the
nature and extent of impediments to fair housing. Community members affected by restrictions
to fair housing choice were given an opportunity to share their concerns and participate in the
decision‐making process to mitigate and/or eliminate barriers.
A total of 63 people attended five regional community workshops held throughout the region.
The locations and dates of the meetings are provided in the chart below. A fair housing survey
was also conducted to learn about the public’s experience with housing discrimination issues
and concerns. The survey was available in both electronic and paper formats, and in English and
Spanish. A total of 1,132 responses were received.
Region Location Date
East El Cajon Nov. 6, 2019
North Escondido Nov. 7, 2019
Central Valencia Park Nov. 13, 2019
South Chula Vista Nov. 20, 2019
South National City Nov. 21, 2019
July 14, 2020 Item #6 Page 2 of 211
In reviewing the comments received during the community outreach period, some key findings
were identified:
1. Frequent targets of discrimination include seniors, people with physical and/or
mental disabilities, families with children, Section 8 recipients, undocumented
immigrants and non‐native English speakers.
2. The inadequate supply of housing in San Diego County impacts low‐income
households, large families and households of color.
3. Underreporting of discrimination occurs due to fear of retaliation, harassment or
deportation.
4. Finding and accessing information about what housing is available, services,
programs and fair housing laws and regulations can be difficult and confusing.
The San Diego regional analysis of impediments to fair housing choice
In addition to the robust community engagement, the draft analysis (Attachment A to Exhibit 1)
includes an in‐depth look at the regions demographic profiles and household characteristics,
income and housing profiles, lending practices, public policies, fair housing statistics,
homeownership/rental housing markets, hate crime statistics, and interviews with municipal
staff, housing providers, fair housing providers and oversight agencies. Based on this analysis, a
fair housing action plan was developed that identifies regional and jurisdiction‐specific
impediments and required action items.
Regional impediments
The following is a summary of the recommended actions that the city will take to address the
regional impediments identified in the analysis and its community outreach. Impediments and
recommended actions are modified to reflect current conditions, feasibility and past efforts:
1. Impediment: Hispanic and Black residents continue to be underrepresented in the
homebuyer market and experienced large disparities in loan approval rates (Finding 2).
Action: Coordinate with other organizations to receive annual reporting on progress in
outreach and education.
2. Impediment: Due to the geographic disparity in terms of rents, concentrations of
housing choice voucher use have occurred (Findings 2 and 4).
Actions: Expand the affordable housing inventory, as funding allows. Promote the
housing choice voucher program to rental property owners, in collaboration with the
various housing authorities in the region. Increase outreach and education through the
city’s fair housing provider, regarding the state’s new source of income protection
(Senate bills 329 and 222). And define housing choice vouchers as legitimate source of
income for housing.
July 14, 2020 Item #6 Page 3 of 211
3. Impediment: Housing choices for special needs groups, especially persons with
disabilities, are limited (Findings 1 and 2).
Actions: Increase housing options for special needs populations, including persons with
disabilities, senior households, families with children, farmworkers and the homeless.
Encourage universal design principles in new housing developments. Educate city and
county building, planning and housing staff on accessibility requirements.
4. Impediment: Enforcement activities are limited.
Actions: Provide news releases to local media outlets on the outcomes of fair housing
complaints and litigation. Support stronger and more persistent enforcement activity by
fair housing service providers. Conduct random testing on a regular basis to identify
issues, trends and problem properties. Expand testing to investigate emerging trends of
suspected discriminatory practices (Findings 3 and 4).
5. Impediment: Today, people obtain information through many forms of media, not
limited to traditional newspaper noticing or other print forms (Findings 3 and 4).
Actions: Education and outreach activities to be conducted as a multimedia campaign,
including social media, as well as other meeting and discussion forums such as chat
rooms and webinars. Involve neighborhood groups and other community organizations
when conducting outreach and education activities. Include fair housing outreach as
part of community events.
Carlsbad specific impediments
The following is a list of specific land use policies of the City of Carlsbad that affect the range of
housing choices available and the recommended actions that the city will take to improve and
increase fair housing choice and comply with state law.
1. Impediment: Recent changes to density bonus law
Actions: The city will review its regulations to ensure compliance with the recent
changes to California density bonus law. Amend density bonus ordinance to comply with
recent changes to state law.
2. Impediment: Accessory dwelling units policies
Action: Amend accessory dwelling units provisions to comply with recent changes to
state law.
3. Impediments: Low barrier navigation centers and emergency shelter capacity and
parking standards
Action: The city will review the low barrier navigation centers and emergency shelters
provisions to comply with recent changes to state law. Specifically, Assembly Bill 139
requires the assessment of shelter needs be based on the most recent point‐in‐time
count and the parking standards for shelters be based on staffing levels.
July 14, 2020 Item #6 Page 4 of 211
4. Impediment: Transitional and supportive housing
Action: The city will review and revise the zoning ordinance to comply with recent
changes to AB 139 requiring supportive housing to be permitted by right where
multifamily and mixed uses are permitted.
Fair housing services
To help ameliorate impediments to fair housing choice, the City of Carlsbad annually contracts
with the Legal Aid Society of San Diego to provide fair housing services. Legal aid fair housing
services include the investigation and resolution of housing discrimination complaints and
discrimination auditing. Testing services also provide education and outreach, including the
dissemination of fair housing information, such as written material, workshops and seminars.
Landlord/tenant counseling is another fair housing service that involves informing landlords
and tenants of their rights and responsibilities under fair housing law and other consumer
protection regulations, as well as mediating disputes between tenants and landlords.
Fiscal Analysis
The Community Development Block Grant program is a fully funded federal program and there
is no fiscal impact on the city’s General Fund. The city’s contribution to the study was fully
funded by the city’s CDBG funds.
Next Steps
Staff will use the analysis of impediments to inform future policies in the city that will promote
fair housing choice and inclusive communities.
Environmental Evaluation (CEQA)
This action does not constitute a “project” within the meaning of the California Environmental
Quality Act under Public Resources Code section 21065 in that it has no potential to cause
either a direct physical change in the environment or a reasonably foreseeable indirect physical
change in the environment and therefore does not require environmental review.
Public Notification and Outreach
To allow interested residents the opportunity to review and comment on the draft fy 2020‐25
analysis of impediments, the city published a public notice in The San Diego Union‐Tribune on
May 22, 2020, informing residents that a public review and comment period would be open
from May 22 to June 20, 2020.
Public notice of this item was posted in accordance with the Ralph M. Brown Act and it was
available for public viewing and review at least 72 hours prior to the scheduled meeting date.
Exhibits
1. City Council resolution
July 14, 2020 Item #6 Page 5 of 211
Exhibit 1
RESOLUTION NO. 2020-137
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,
CALIFORNIA, APPROVING THE FISCAL YEARS 2020-25 ANALYSIS OF
IMPEDIMENTS TO FAIR HOUSING CHOICE FOR THE CITY'S COMMUNITY
DEVELOPMENT BLOCK GRANT PROGRAM.
WHEREAS, the Housing and Community Development Act of 1974 is the governing statute for
the city's Community Development Block Grant Program requiring that each federal entitlement
grantee certify to the satisfaction of HUD that an awarded federal grant will be carried out and
administered in accordance with the federal Fair Housing Act and the grantee will work diligently to
actively further fair housing choice; and
WHEREAS, the CDBG program is a fully funded federal program and does not impact the
General Fund; and
WHEREAS, to be eligible for CDBG funds, the jurisdiction must adopt an Analysis of
Impediments to affirmatively further the fair housing objectives of the Fair Housing Act of 1968, as
amended, which must be considered and accepted by the City Council of the City of Carlsbad; and
WHEREAS, to assist in the analysis the city solicited input from community members, service
providers, stakeholder interviews, and community workshops to assess the nature and extent of
impediments to fair housing; and
WHEREAS, the City Council of the City of Carlsbad, California has considered the Analysis of
Impediments for the period beginning July 1, 2020 and ending on June 30, 2025, as required for the
city's CDBG program; and
WHEREAS, the draft Analysis of Impediments was released for a 30-day public review period
which began on May 22, 2020, and concluded on June 20, 2020; and
WHEREAS, public comments from the public review period and the public hearing, if any, have
been addressed through written response and included in the final Fiscal Years 2020-25 Analysis of
Impediments; and
July 14, 2020 Item #6 Page 6 of 211
ENGLESI ity Cle k
Exhibit 1
WHEREAS, the City Council of the City of Carlsbad, California has taken all testimony into
account in considering the Analysis of Impediments for the Fiscal Years 2020-25 as required for the
city's CDBG program; and
WHEREAS, the City Council of the City of Carlsbad, California, approves the Fiscal Years 2020-
25 Analysis of Impediments for the city's CDBG program; and
WHEREAS, the City of Carlsbad is committed to continuing to provide a suitable living
environment and to expand economic opportunities for the city's low-income residents as is outlined
in the CDBG Program; and
WHEREAS, the City Council has taken all testimony into account.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as
follows:
1. That the above recitations are true and correct.
2. That the Fiscal Years 2020-25 Analysis of Impediments (Attachment A) is hereby
approved by the City Council.
3. That, on the city's behalf, the City Manager, or designee, is authorized to finalize the
city's Fiscal Years 2020-25 Analysis of Impediments as set forth in Attachment A and to
execute all appropriate related documents for the final Analysis of Impediments.
PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of
Carlsbad on the 14th day of July 2020, by the following vote, to wit:
AYES: Hall, Blackburn, Bhat-Patel.
NAYS: Schumacher.
ABSENT: None.
MATT HALL, Mayor
(SEAL)
July 14, 2020 Item #6 Page 7 of 211
SAN DIEGO REGIONAL
ANALYSIS OF IMPEDIMENTS
TO FAIR HOUSING CHOICE
MAY 2020
Lead Agency
City of San Diego
Economic Development Department
1200 Third Avenue, 14th Floor
San Diego, CA 92101
Attachment A
July 14, 2020 Item #6 Page 8 of 211
Table of Contents
Chapter 1: Introduction
A. Purpose of Report ................................................................................................................................ 1
B. Geographic Area Covered .................................................................................................................. 2
C. Fair Housing Legal Framework ......................................................................................................... 2
D. Fair Housing Defined .......................................................................................................................... 5
E. Organization of Report ....................................................................................................................... 6
F. Data Sources ......................................................................................................................................... 7
Chapter 2: Community Outreach
A. Community Workshops ...................................................................................................................... 8
B. Targeted Stakeholder Interviews ...................................................................................................... 11
C. Fair Housing Survey .......................................................................................................................... 14
D. Public Review of Draft AI ................................................................................................................ 18
Chapter 3: Community Profile
A. Demographic Profile ......................................................................................................................... 19
B. Household Characteristics ................................................................................................................ 28
C. Special Needs Groups ....................................................................................................................... 33
D. Hate Crimes ........................................................................................................................................ 53
E. Income Profile .................................................................................................................................... 56
F. Housing Profile ................................................................................................................................... 66
G. Housing Condition ............................................................................................................................. 71
H. Housing Cost and Affordability ....................................................................................................... 74
I. Housing Problems .............................................................................................................................. 80
J. Publicly Assisted Housing ................................................................................................................. 84
K. Licensed Community Care Facilities ............................................................................................... 92
L. Accessibility to Opportunities .......................................................................................................... 95
M. ADA-Compliant Public Facilities (Section 504 Assessment) .................................................... 101
N. Exposure to Adverse Community Factors ................................................................................... 102
Chapter 4: Lending Practices
A. Background ....................................................................................................................................... 120
B. Overall Lending Patterns ................................................................................................................ 122
C. Lending by Race/Ethnicity and Income....................................................................................... 125
D. Lending Patterns by Tract Characteristics .................................................................................... 128
E. Major Lenders ................................................................................................................................... 129
F. Sub-Prime Lending Market ............................................................................................................. 130
Chapter 5: Public Policies
A. Policies and Programs Affecting Housing Development .......................................................... 132
B. Zoning Ordinance ............................................................................................................................ 139
C. Variety of Housing Opportunity .................................................................................................... 143
D. Building Codes and Occupancy Standards ................................................................................... 152
E. Affordable Housing Development ................................................................................................ 154
July 14, 2020 Item #6 Page 9 of 211
F. Other Land Use Policies, Programs, and Controls ..................................................................... 158
G. Policies Causing Displacement or Affect Housing Choice of Minorities and Persons with
Disabilities ......................................................................................................................................... 163
H. Local Housing Authorities .............................................................................................................. 164
I. California Environmental Quality Act (CEQA) .......................................................................... 164
J. Community Representation and Participation ............................................................................. 165
Chapter 6: Fair Housing Profile
A. Fair Housing in the Homeownership Market .............................................................................. 167
B. Fair Housing in the Rental Housing Market ................................................................................ 171
C. Fair Housing Services ...................................................................................................................... 176
D. California Department of Fair Employment and Housing (DFEH) ....................................... 177
E. Fair Housing Statistics ..................................................................................................................... 178
F. Fair Housing Testing ....................................................................................................................... 182
G. U.S. Department of Housing and Urban Development ............................................................ 187
H. Hate Crimes ...................................................................................................................................... 190
Chapter 7: Fair Housing Action Plan
A. Regional Impediments ..................................................................................................................... 192
B. Jurisdiction-Specific Impediments ................................................................................................. 198
List of Tables
Table 1: Community Workshop Locations .................................................................................................... 8
Table 2: Stakeholder Interviews ..................................................................................................................... 11
Table 3: Perpetrators of Alleged Discrimination ........................................................................................ 15
Table 4: Location of Alleged Discrimination .............................................................................................. 15
Table 5: Basis of Alleged Discrimination ..................................................................................................... 16
Table 6: Reason for Not Reporting Alleged Discrimination ..................................................................... 17
Table 7: Basis of Alleged Hate Crime ........................................................................................................... 17
Table 8: Population Growth (2000-2035) .................................................................................................... 20
Table 9: Age Characteristics ........................................................................................................................... 21
Table 10: Racial and Ethnic Composition.................................................................................................... 23
Table 11: Minority Population by Sub-region ............................................................................................. 25
Table 12: Language and Linguistic Isolation................................................................................................ 27
Table 13: Household Growth by Jurisdiction.............................................................................................. 29
Table 14: Household Type ............................................................................................................................. 30
Table 15: Household Characteristics............................................................................................................. 31
Table 16: Average Household Size by Jurisdiction ..................................................................................... 32
Table 17: Residents with Special Needs ....................................................................................................... 33
Table 18: Senior Profile – San Diego County .............................................................................................. 34
Table 19: Large Households ........................................................................................................................... 37
Table 20: Disability by Age ............................................................................................................................. 42
Table 21: Disability Characteristics ............................................................................................................... 43
Table 22: People living with HIV and AIDS (PLWHA) ........................................................................... 46
Table 23: HOPWA Program Resources ....................................................................................................... 47
July 14, 2020 Item #6 Page 10 of 211
Table 24: Homelessness Population by Jurisdiction – 2018 and 2019 .................................................... 49
Table 25: Farm Worker Population of San Diego County ........................................................................ 51
Table 26: Hate Crime Statistics – 2018 ......................................................................................................... 55
Table 27: Median Household Income .......................................................................................................... 58
Table 28: Income Categories .......................................................................................................................... 59
Table 29: Income Distribution, 2012-2016 .................................................................................................. 59
Table 30: Housing Assistance Needs of Low and Moderate Income Households (2012-2016) ......... 61
Table 31: Income by Race/Ethnicity ............................................................................................................ 62
Table 32: Housing Unit Growth .................................................................................................................... 67
Table 33: Housing Stock Mix 2019 ............................................................................................................... 68
Table 34: Housing Tenure and Vacancy ...................................................................................................... 69
Table 35: Housing Problems by Tenure ....................................................................................................... 70
Table 36: Housing Age and Lead-Poisoning Cases .................................................................................... 72
Table 37: Median Home Sale Prices by Jurisdiction ................................................................................... 75
Table 38: Average Rental Rates by Jurisdiction - Fall 2018 ....................................................................... 76
Table 39: Housing Affordability Matrix - San Diego County (2019) ....................................................... 79
Table 40: Overcrowding by Tenure .............................................................................................................. 81
Table 41: Housing Cost Burden by Tenure ................................................................................................. 83
Table 42: Public Housing Units ..................................................................................................................... 85
Table 43: Characteristics of Householders in Public Housing Units ....................................................... 85
Table 44: Characteristics of Public Housing Waiting list (Households) .................................................. 86
Table 45: Housing Choice Voucher Recipients ........................................................................................... 87
Table 46: Distribution of Housing Choice Voucher Recipients ............................................................... 88
Table 47: Housing Choice Voucher Use Metrics ........................................................................................ 90
Table 48: Housing Choice Voucher Waitlist ............................................................................................... 90
Table 49: Licensed Community Care Facilities by Jurisdiction ................................................................. 93
Table 50: Major Employers - San Diego County ........................................................................................ 97
Table 51: ADA-Compliant Public Facilities ............................................................................................. 102
Table 52: Opportunity Indicators by Race/Ethnicity – Entitlement Jurisdictions ............................. 108
Table 53: Opportunity Indicator - Poverty Rate – Urban County Participating Jurisdictions .......... 116
Table 54: Opportunity Indicators – School Proficiency, Labor Market, Job Proximity – ................. 117
Table 55: Opportunity Indicators – Transit – Urban County Participating Jurisdictions .................. 117
Table 56: Opportunity Indicators – Environmental Health – ............................................................... 118
Table 57: Demographics of Loan Applicants vs. Total Population ...................................................... 126
Table 58: Lending Patterns by Race/Ethnicity and Income (2012-2017) ............................................ 127
Table 59: Outcomes Based on Census Tract Income (2012-2017) ....................................................... 128
Table 60: Outcomes by Minority Population of Census Tract (2012-2017) ........................................ 129
Table 61: Top San Diego County Lenders by City (2017) ...................................................................... 130
Table 62: Reported Spread on Loans by Race/Ethnicity (2012-2017) ................................................. 131
Table 63: Housing Element Status for 2013-2021 Cycle ........................................................................ 134
Table 64: Typical Land Use Categories and Permitted Density by Jurisdiction .................................. 136
Table 65: Off-Street Parking Requirements .............................................................................................. 141
Table 66: Variety of Housing Opportunity ............................................................................................... 145
Table 67: Farmworker Employee Housing by Jurisdiction .................................................................... 152
Table 68: Rent-Restricted Multi-Family Housing Units by Jurisdiction ............................................... 155
Table 69: Planning Fees by Jurisdiction ..................................................................................................... 156
Table 70: Development Impact Fees by Jurisdiction .............................................................................. 157
Table 71: Land Use Policies and Controls by Jurisdiction...................................................................... 159
Table 72: Potential Discrimination in Listings of For-Sale Homes ....................................................... 168
July 14, 2020 Item #6 Page 11 of 211
Table 73: Potential Discrimination in Listings of Homes for Rent....................................................... 172
Table 74: CSA Clients Served (FY 2014-2018)* ....................................................................................... 178
Table 75: CSA Clients Served by Income Level (FY 2014-2018)* ......................................................... 179
Table 76: CSA Clients Served by Race/Ethnicity (FY 2014-2018)* ...................................................... 179
Table 77: LASSD- Clients Served (FY 2014-2018) .................................................................................. 180
Table 78: LASSD- Clients Served by Income Level (FY 2014-2018)* .................................................. 181
Table 79: LASSD- Clients Served by Race/Ethnicity (FY 2014-2018) ................................................ 181
Table 80: Fair Housing Audit Testing FY 2016-2018 ............................................................................. 184
Table 81: Basis for Discrimination of Fair Housing Cases filed with HUD (FY 2014-2018)*.......... 188
Table 82: Closing Categories for Fair Housing Cases filed with HUD (FY 2014-2018)* .................. 189
Table 83: Hate Crimes (FY 2013-2018) ..................................................................................................... 191
List of Figures
Figure 1: San Diego County Age Structure (2017)...................................................................................... 22
Figure 2: Minority Concentration Areas ....................................................................................................... 26
Figure 3: Licensed Care Facilities .................................................................................................................. 35
Figure 4: Persons with Disabilities ................................................................................................................ 44
Figure 5: Change in Hate Crimes between 2013 and 2018 ........................................................................ 54
Figure 6: San Diego County Household Income ........................................................................................ 57
Figure 7: Low and Moderate Income Areas ................................................................................................ 63
Figure 8: Poverty Concentration Areas ........................................................................................................ 65
Figure 9: Race of Homeowner ....................................................................................................................... 70
Figure 10: Childhood Lead Poisoning Risk Areas ...................................................................................... 73
Figure 11: Housing Opportunity Index Trend (2010-2019) ...................................................................... 74
Figure 12: Housing Cost Burden by Income and Tenure.......................................................................... 82
Figure 13: Public Transit and Affordable Housing ..................................................................................... 91
Figure 14: Licensed Care Facilities ................................................................................................................ 94
Figure 15: Transit Service and Major Employers ........................................................................................ 98
Figure 16: Transit Service and Publicly Assisted Housing ...................................................................... 100
Figure 17: Distribution of Title I Schools and Low- and Moderate-Income Areas ........................... 104
Figure 18: Distribution of Title I Schools and Areas of Minority Concentration Area ..................... 105
Figure 19: Environmental Exposure .......................................................................................................... 119
Figure 20: Conventional Home Purchase Loans (2012 versus 2017) ................................................... 124
Figure 21: Government-Backed Home Purchase Loans (2012 versus 2017) ...................................... 124
July 14, 2020 Item #6 Page 12 of 211
an Diego County, one of the most populous counties in the nation, is home to over 3 million
residents and an increasingly diverse demographic. The County encompasses 18 incorporated
cities and more than 25 rural and urban unincorporated neighborhoods and communities.
Diversity among its residents, in terms of cultural backgrounds and socioeconomic characteristics,
makes San Diego County a desirable area to live. To continue nurturing this diversity, civic leaders
must ensure that an environment exists where equal access to housing opportunities is treated as a
fundamental right.
A. Purpose of Report
The communities within San Diego County have established a commitment to providing equal
housing opportunities for their existing and future residents. Through the federally funded
Community Development Block Grant (CDBG) and HOME Investment Partnerships (HOME)
programs, among other state and local programs, the jurisdictions of San Diego County work to
provide a decent living environment for all.
Pursuant to CDBG regulations [24 CFR Subtitle A §91.225(a)(1)], to receive CDBG funds, a
jurisdiction must certify that it “actively furthers fair housing choice” through the following:
Completion of an Analysis of Impediments to Fair Housing Choice (AI);
Actions to eliminate identified impediments; and
Maintenance of fair housing records.
In 2016, HUD passed the Affirmatively Furthering Fair Housing (AFFH) Rule that would have
required the preparation of an Assessment of Fair Housing under the new rule. However, due to
extensive comments from grantees, HUD suspended the AFFH Rule in 2018 and is currently
working on amending the rule with simplified requirements. In the meantime, fair housing
requirements revert to the 1996 Fair Housing Planning Guide prepared by HUD.
This report, the Analysis of Impediments to Fair Housing Choice (commonly known as the “AI”),
presents a demographic profile of the County of San Diego, assesses the extent of fair housing
issues among specific groups, and evaluates the availability of a range of housing choices for all
residents. This report also analyzes the conditions in the private market and public sector that may
limit the range of housing choices or impede a person’s access to housing.
S
July 14, 2020 Item #6 Page 13 of 211
B. Geographic Area Covered
The AI covers the entirety of San Diego County, including the 18 incorporated cities and all
unincorporated areas:
City of Carlsbad
City of Chula Vista
City of Coronado
City of Del Mar
City of El Cajon
City of Encinitas
City of Escondido
City of Imperial Beach
City of La Mesa
City of Lemon Grove
City of National City
City of Oceanside
City of Poway
City of San Diego
City of San Marcos
City of Santee
City of Solana Beach
City of Vista
Unincorporated County
C. Fair Housing Legal Framework
Fair housing is a right protected by both Federal and State of California laws. Among these laws,
virtually every housing unit in California is subject to fair housing practices.
1. Federal Laws
The Fair Housing Act of 1968 and Fair Housing Amendments Act of 1988 (42 U.S. Code §§ 3601-
3619, 3631) are federal fair housing laws that prohibit discrimination in all aspects of housing,
including the sale, rental, lease, or negotiation for real property. The Fair Housing Act prohibits
discrimination based on the following protected classes:
Race or color
Religion
Sex
Familial status
National origin
Disability (mental or physical)
Specifically, it is unlawful to:
Refuse to sell or rent after the making of a bona fide offer, or to refuse to negotiate for the
sale or rental of, or otherwise make unavailable or deny, a dwelling to any person because of
race, color, religion, sex, disability, familial status, or national origin.
Discriminate against any person in the terms, conditions, or privileges of sale or rental of a
dwelling, or in the provision of services or facilities in connection therewith, because of race,
color, religion, sex, disability, familial status, or national origin.
Make, print, or publish, or cause to be made, printed, or published any notice, statement, or
advertisement, with respect to the sale or rental of a dwelling that indicates any preference,
July 14, 2020 Item #6 Page 14 of 211
limitation, or discrimination based on race, color, religion, sex, disability, familial status, or
national origin, or an intention to make any such preference, limitation, or discrimination.
Represent to any person because of race, color, religion, sex, disability, familial status, or
national origin that any dwelling is not available for inspection, sale, or rental when such
dwelling is in fact so available.
For profit, induce or attempt to induce any person to sell or rent any dwelling by
representations regarding the entry or prospective entry into the neighborhood of a person
or persons of a particular race, color, religion, sex, disability, familial status, or national
origin.
Reasonable Accommodations and Accessibility
The Fair Housing Amendments Act requires owners of housing facilities to make “reasonable
accommodations” (exceptions) in their rules, policies, and operations to give people with disabilities
equal housing opportunities. For example, a landlord with a "no pets" policy may be required to
grant an exception to this rule and allow an individual who is blind to keep a guide dog in the
residence. The Fair Housing Act also requires landlords to allow tenants with disabilities to make
reasonable access-related modifications to their private living space, as well as to common use
spaces, at the tenant’s own expense. Finally, the Act requires that new multi-family housing with
four or more units be designed and built to allow access for persons with disabilities. This includes
accessible common use areas, doors that are wide enough for wheelchairs, kitchens and bathrooms
that allow a person using a wheelchair to maneuver, and other adaptable features within the units.
HUD Final Rule on Equal Access to Housing in HUD Programs
On March 5, 2012, the U.S. Department of Housing and Urban Development (HUD) published the
Final Rule on “Equal Access to Housing in HUD Programs Regardless of Sexual Orientation or
Gender Identity.” It applies to all McKinney-Vento-funded homeless programs, as well as to
permanent housing assisted or insured by HUD. The rule creates a new regulatory provision that
generally prohibits considering a person’s marital status, sexual orientation, or gender identity (a
person’s internal sense of being male or female) in making homeless housing assistance available.
2. California Laws
The State Department of Fair Employment and Housing (DFEH) enforces California laws that
provide protection and monetary relief to victims of unlawful housing practices. The Fair
Employment and Housing Act (FEHA) (Government Code Section 12955 et seq.) prohibits
discrimination and harassment in housing practices, including:
Advertising
Application and selection process
Unlawful evictions
Terms and conditions of tenancy
Privileges of occupancy
Mortgage loans and insurance
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Public and private land use practices (zoning)
Unlawful restrictive covenants
The following categories are protected by FEHA:
Race or color
Ancestry or national origin
Sex
Marital status
Source of income
Sexual orientation
Familial status (households with children under 18 years of age)
Religion
Mental/physical disability
Medical condition
Age
Gender Identity
Gender Expression
Genetic Information
In October 2019, the California Legislature passed SB 329 and SB 222, expanding the Source of
Income protection to include “federal, state, or local public assistance and federal, state, or local
housing subsidies.” Prior to these bills, Source of Income protection excluded public housing
subsidies, such as the Housing Choice Vouchers, in the definition of income. Both bills went into
effect on January 1, 2020.
In addition, the FEHA contains similar reasonable accommodations and accessibility provisions as
the federal Fair Housing Amendments Act.
The Unruh Civil Rights Act provides protection from discrimination by all business
establishments in California, including housing and accommodations, because of age, ancestry,
color, disability, national origin, race, religion, sex, and sexual orientation. While the Unruh Civil
Rights Act specifically lists “sex, race, color, religion, ancestry, national origin, disability, and medical
condition” as protected classes, the California Supreme Court has held that protections under the
Unruh Act are not necessarily restricted to these characteristics.
Furthermore, the Ralph Civil Rights Act (California Civil Code Section 51.7) forbids acts of
violence or threats of violence because of a person’s race, color, religion, ancestry, national origin,
age, disability, sex, sexual orientation, political affiliation, or position in a labor dispute. Hate
violence can be: verbal or written threats; physical assault or attempted assault; and graffiti,
vandalism, or property damage.
The Bane Civil Rights Act (California Civil Code Section 52.1) provides another layer of
protection for fair housing choice by protecting all people in California from interference by force
or threat of force with an individual’s constitutional or statutory rights, including a right to equal
access to housing. The Bane Act also includes criminal penalties for hate crimes; however,
July 14, 2020 Item #6 Page 16 of 211
convictions under the Act are not allowed for speech alone unless that speech itself threatened
violence.
And, finally, California Civil Code Section 1940.3 prohibits landlords from questioning potential
residents about their immigration or citizenship status. Landlords in most states are free to inquire
about a potential tenant’s immigration status and to reject applicants who are in the United States
illegally.1 In addition, this law forbids local jurisdictions from passing laws that direct landlords to
make inquiries about a person’s citizenship or immigration status.
In addition to these laws, Government Code Sections 111135, 65008, and 65580-65589.8 prohibit
discrimination in State-funded programs and in land use decisions. Specifically, recent changes to
Sections 65580-65589.8 require local jurisdictions to address the provision of housing options for
special needs groups, including permanent supportive housing for the disabled and housing for the
homeless.
D. Fair Housing Defined
In light of the various pieces of fair housing legislation passed at the Federal and State levels, fair
housing throughout this report is defined as follows:
A condition in which individuals of similar income levels in the same housing market have a like
range of choice available to them regardless of their characteristics as protected under State and
Federal laws.
1. Housing Issues, Affordability, and Fair Housing
HUD’s Office of Fair Housing and Equal Opportunity (FHEO) draws a distinction between
housing affordability and fair housing. Economic factors that affect a household’s housing choices
are not fair housing issues per se. Only when the relationship between household income, household
type, race/ethnicity, and other factors create misconceptions, biases, and differential treatments
would fair housing concerns arise.
Tenant/landlord disputes are also typically not related to fair housing. Most disputes between
tenants and landlords result from a lack of understanding by either or both parties on their rights
and responsibilities. Tenant/landlord disputes and housing discrimination cross paths when the
disputes are based on factors protected by fair housing laws and result in differential treatment.
1 http://www.nolo.com/legal-update/california-landlords-ask-immigration-citizenship-29214.html
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2. Fair Housing Impediments
Within the legal framework of Federal and State laws, and based on the guidance provided by
HUD’s Fair Housing Planning Guide, impediments to fair housing choice can be defined as:
Any actions, omissions, or decisions taken because of the characteristics protected under
State and Federal laws, which restrict housing choices or the availability of housing choices;
or
Any actions, omissions or decisions which have the effect of restricting housing choices or
the availability of housing choices on the basis of characteristics protected under State and
Federal laws.
To affirmatively promote equal housing opportunity, a community must work to remove
impediments to fair housing choice.
E. Organization of Report
This report is divided into seven chapters:
Chapter 1: Introduction defines “fair housing” and explains the purpose of this report.
Chapter 2: Community Participation describes the community outreach program and
summarizes comments from residents and various agencies on fair housing issues such as
discrimination, housing impediments, and housing trends.
Chapter 3: Community Profile presents the demographic, housing, and income
characteristics in San Diego County. Major employers and transportation access to job centers
are identified. The relationships among these variables are discussed. In addition, this section
evaluates whether community care facilities, public and assisted housing projects, as well as
Section 8 recipients in the County are unduly concentrated in Low and Moderate Income areas.
Also, the degree of housing segregation based on race is discussed.
Chapter 4: Lending Practices assesses the access to financing for different groups.
Predatory and subprime lending issues are discussed.
Chapter 5: Public Policies analyzes various public policies and actions that may impede fair
housing within the County and the participating cities.
Chapter 6: Fair Housing Profile evaluates existing public and private programs, services,
practices, and activities that assist in providing fair housing in the County. This chapter also
assesses the nature and extent of fair housing complaints and violations in different areas of the
County. Trends and patterns of impediments to fair housing, as identified by public and private
agencies, are included.
Chapter 7: Impediments and Recommendations summarizes the findings regarding fair
housing issues in San Diego County and provides recommendations for furthering fair housing
practices.
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At the beginning of this report are Signature Pages that include the signatures of the Chief Elected
Officials (or his/her designee) along with a statement certifying that the Analysis of Impediments
represents the jurisdictions’ official conclusions regarding impediments to fair housing choice and
the actions necessary to address identified impediments.
F. Data Sources
According to the Fair Housing Planning Guide, HUD does not require the jurisdictions to commence a
data collection effort to complete the AI. Existing data can be used to review the nature and extent
of potential issues. Various data and existing documents were reviewed to complete this AI,
including:
2000 and 2010 U.S. Census
American Community Surveys2
State Department of Finance Population and Housing Estimates
Zoning ordinances, various plans, and resolutions of participating jurisdictions
California Department of Social Services Community Care Licensing Division
2018 Employment Development Department employment and wage data
2012 and 2017 Home Mortgage Disclosure Act (HMDA) data on lending activities from
LendingPatternsTM
Current market data for rental rates, home prices, and foreclosure activities
Fair housing records from the Legal Aid Society of San Diego and CSA San Diego County
Housing Choice Voucher (Section 8) data from local Housing Authorities
California Department of Education
Sources of specific information are identified in the text, tables, and figures.
2 The 2010 Census no longer provides detailed demographic or housing data through the “long form”. Instead, the
Census Bureau conducts a series of American Community Surveys (ACS) to collect detailed data. The ACS surveys
different variables at different schedules (e.g. every year, every three years, or every five years) depending on the size
of the community. Multiple sets of ACS data are required to compile the data for San Diego County in this report.
July 14, 2020 Item #6 Page 19 of 211
his Analysis of Impediments (AI) report has been developed to provide an overview of laws,
regulations, conditions, or other possible obstacles that may affect an individual’s or a
household’s access to housing. As part of this effort, the report incorporates the issues and
concerns of residents, housing professionals, and service providers. To assure the report responds
to community needs, a community outreach program consisting of community workshops, targeted
stakeholder interviews, and a fair housing survey was conducted in the development of this report.
This chapter describes the community outreach program conducted to involve the community.
To reach the various segments of the
community, several methods were used to obtain
community input:
Six community workshops
Nine targeted stakeholder interviews to
service providers and local organizations
Fair housing survey
Appendix A contains further background on the
outreach strategy, public outreach tools, surveys,
and summary of meeting notes.
A. Community Workshops
Six community workshops were held in communities throughout the County in October and
November 2019 to gather input regarding fair housing issues in the region. The locations and dates
of the workshops were as follows:
Table 1: Community Workshop Locations
Area of County Location Date
Central Region LISC San Diego, San Diego, CA October 30, 2019
Eastern Region El Cajon Police Department, El Cajon, CA November 6, 2019
Northern Region Escondido City Hall, Escondido, CA November 7, 2019
Central Region Valencia Park/Malcolm X Library November 13, 2019
Southern Region Chula Vista City Hall, Chula Vista, CA November 20, 2019
Southern Region MLK Jr. Community Center, National City, CA November 21, 2019
T
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To encourage attendance and participation, the workshops were publicized through the following
methods:
Multilingual flyers (print and digital) publicizing the six community workshops were mailed
to 621 agencies, organizations, and interested individuals throughout the County, including a
wide range of housing service providers and community organizations such as community
planning groups, housing development corporations, service providers, housing industry
professionals, civic organizations, housing authorities, housing groups, business
organizations, religious organizations, schools, and local elected officials’ offices.
Multilingual flyers were posted on the websites of the participating cities and the County.
Multilingual flyers were placed at public counters such as city halls, libraries, and community
centers.
Multilingual email-based (“e-blast”) notifications through the participating agencies’ email
networks.
Content for participating agencies’ and stakeholders’ communication channels such as
newsletters, public service announcements, websites, and cable television channels.
Social media posts to Facebook, Twitter, and Next Door.
1. Workshop Participants
A total of 63 individuals attended the community workshops. Aside from interested individuals and
staff from the various cities and the County, several service providers and housing professionals
participated in the fair housing workshops. These included:
CSA San Diego County - Fair Housing
Housing Navigators Homeless
Housing Opportunities Collaborative
Legal Aid Society San Diego
MAAC Project, Kimball
San Diego Housing Commission
Solutions for Change
Tirey & St. John LLP
San Dieguito Alliance
Community Resource Center – North Coast
Community
2. Key Issues Identified
In reviewing the comments received at these workshops, several key issues are noted:
1. Experiences with Housing Discrimination
Individuals and families in the following protected classes shared experiences of
housing discrimination:
o Homeless
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o Sexual orientation
o Individual with an emotional support animal
o Family with deported father
o Women with adopted children
o Families with children with autism
o Source of income or type of work
2. Reporting of Housing Discrimination Incidents
Burden of proof is on individual who has been discriminated against
Costs and length of time for litigation are a deterrent for reporting incidents
Fear of retaliation, harassment, or deportation from reporting incidents
3. Barriers to Housing in Community
Many people have difficulty finding and accessing information about Fair Housing
due to lack of access to computer/internet, knowing where to get the right
information, cultural barriers, and lack of education in schools.
The information on what subsidies or options are available are confusing and the
application process is confusing.
Many different languages and dialects.
The shortage of affordable units and long Section 8 waiting list.
Barriers are often layered
4. Protected Classes that Need Improved Services
Seniors
Individuals with mental and physical disabilities
Victims of domestic violence
Arbitrary factors
Country of origin
5. Misconceptions or Misunderstandings about Fair Housing
If prospective tenants have to pay for a background report for every application
What qualified as a reasonable accommodation request
6. Ways to Build Community Awareness about Fair Housing
Need to improve how information is provided to community members by relating
messaging to people’s lives, letting people know they will learn something,
simplifying language and documents.
Need to make sure that there are representatives at different agencies and providers
that can communicate in different languages of local community.
Go directly to communities to provide information at community gathering places,
community centers, churches, schools, colleges, community and cultural events,
senior housing complexes, and community meetings.
Partner with organizations, cultural and faith-based groups, and organizations
holding events to share information.
Provide incentives and expand how information can be seen and heard.
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7. Other Comments
There should be a universal rental application.
Should tap into 211 Community Information Exchange to help share information.
The comments received during these community workshops have been incorporated into this AI as
appropriate and documented in Appendix A.
B. Targeted Stakeholder Interviews
In addition to the input given by representatives from local organizations in attendance at the
community workshops, key stakeholders were contacted for one-on-one interviews about the AI.
Participants represented organizations that provide fair housing services and/or complementary and
related support services. A representative from each of the following organizations participated in a
telephone interview:
Table 2: Stakeholder Interviews
Stakeholder Contact
Alliance for Regional Solutions Mary Lynn McCorkle, Collaborations Manager
October 30, 2019
CSA San Diego Estela De Los Rios, Executive Director
November 6, 2019
Elder Help San Diego Robin Strickland, Housing Services Coordinator
November 7, 2019
La Maestra Community Health Centers John Kuek, Director of Integrated Community Services
November 13, 2019
Legal Aid Society of San Diego County Rosalina Spencer, Lead Lawyer
November 20, 2019
National Alliance on Mental Illness Aaron Basila, Community Outreach Worker
November 21, 2019
Regional Task Force on the Homeless Jennifer Yost, Director of Grants Management
San Diego Housing Federation Laura Nunn, Director of Policy and Programs
Southern California Rental Housing Association Molly Kirkland, Director of Public Affairs
1. Key Issues Identified
In reviewing the comments received at these interviews, several key issues are noted:
1. Greatest Challenges to Building Community Awareness
Keeping up with updates to laws and regulations
Identifying community partners to share information with and provide training
Resistance to change by homeowners
Language barriers
2. Barriers to Housing in Community
Large and diverse geographic area
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Language barriers and different dialects
Housing affordability impacts and low vacancy rate
Difficulty finding a place to live with Section 8 voucher
Access to technology
Limited hours and transportation route options
Lack of awareness about services and resources
Miscommunications between landlords and tenants, and tenants and service
providers
Individuals with mental and physical disabilities have difficulty finding housing
Large families have difficulty finding housing
Poor quality of housing and landlords that won’t improve units
3. Misconceptions or Misunderstandings about Fair Housing
Difficult or complex laws and requirements, different requirements for different
programs, and difficulty navigating process
Not understanding role of different agencies or service providers
Terminology and different definitions or understanding of terms like discrimination,
affordable housing, intent, or eviction
Lack of understanding about different individuals or people who are homeless,
suffering from mental illness, live in permanent supportive housing
4. Greatest Challenges in Meeting Fair Housing Needs
Under reporting of discrimination until after the fact, or due to fear of retaliation, or
the length of time to pursue legal action
It is difficult to find the right information and staff at public agencies are overloaded
with requests
Many homeless individuals don’t have the right documentation to apply to programs
Section 8 waitlist is over 10 years long
Lack of housing affordability is causing people to leave California
NIMBYs and opposition to growth and siting of new housing
5. Protected Classes that Need Improved Services
Disabled individuals
Lesbian, Gay, Bisexual, Transgender, and Queer (LGBTQ)
Large families
Tenants utilizing Section 8 vouchers
Seniors and aging population
Religious discrimination
Homeless individuals and families
6. Community Assets That Can be Leveraged to Further Fair Housing
Banks can promote first time home buying program
Community forums in North County
Community groups and centers
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Pop-up events at transit stations, or libraries where there is high foot traffic
Postings on Next Door
Utilizing 211 to help direct people to resources
Providing additional education and resources including a resource binder at housing
service providers and trainings targeted to landlords or property managers.
7. Possible Improvements to Inter-Agency Coordination
Ensuing that landlords are involved in the discussion
Reducing bureaucratic layers
SDRAFFH Fair Housing Conference can provide a venue to develop a shared
understanding of challenges and implementation
Shift focus to thinking about why rules and regulations exist rather than checking
boxes
Create a shared database of agencies and programs
Provide additional training opportunities and avenues for sharing information such
as email blasts
Collaborate with non-profits to provide wrap around services and trainings
Have City Council and Board of Supervisors on boards of different organizations
8. Ways to Promote Outreach for AI Workshops and Surveys
Provide notices and survey links to landlords and property owners
Place advertisements on billboards, at transit stops, or at churches, stores, swap
meets
Share information at community centers, religious facilities, and with community
leaders
Partner with elected officials or city staff to disseminate information
Link promotion of AI to other related topics such as homelessness
Send notification of workshops to individuals on Section 8 waitlist
9. Additional Comments
Recommend that landlords post evaluation criteria in advertisements
Need more housing and Fair Housing should be at the center of the discussion
about the housing crisis.
Getting information out to tenants about Fair Housing rights and regulations is
important
Supportive housing with other support services is important
Siting of permanent supportive housing should occur throughout the County within
proximity to other services and amenities.
The comments received during these interviews have been incorporated into this AI, as appropriate,
and documented in Appendix A.
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C. Fair Housing Survey
The Fair Housing Survey sought to gain knowledge about the nature and extent of fair housing
issues experienced and to gauge the perception of fair housing needs and concerns of County
residents. The survey was available in multiple languages, including English, Spanish, Tagalog,
Chinese, Arabic, and Vietnamese on the websites of the County and all participating jurisdictions.
Hard copies of the survey were provided to a number of local agencies for distribution to their
clients. The community workshop flyer, including links to the online survey, was mailed to over
1,000 housing and service providers, encouraging them to provide their unique perspective by
participating in the Community Needs Survey.
Because responses to the survey were not controlled3, results of the survey are used only to provide
some insight regarding fair housing issues, but cannot be treated as a statistically valid survey.
Furthermore, the survey asked for respondents’ perception in housing discrimination. A person
responding having been discriminated does not necessarily mean discrimination has actually taken
place.
1. Summary of Survey Results
Who Responded to the Survey?
A total of 1,132 persons responded to the Housing Discrimination Survey. The majority of survey
respondents felt that housing discrimination was not an issue in their neighborhoods. There were
305 persons who answered “YES” to whether they have personally experienced discrimination in
housing.
Who Do You Believe Discriminated Against You? 4
Among the persons indicating that they had experienced housing discrimination, 59 percent (248
persons) indicated that a landlord or property manager had discriminated against them, while eight
percent (35 persons) of respondents identified a Government staff person as the source of
discrimination. Responses for the fair housing survey are not mutually exclusive; respondents had
the option of listing multiple perpetrators of discrimination.
3 A survey with a “controlled” sample would, through various techniques, “control” the socioeconomic
characteristics of the respondents to ensure that the respondents are representative of the general population. This
type of survey would provide results that are statistically valid but is much more costly to administer.
4 Because respondents could indicate multiple answers on a single questions, the percentages on these multiple choice
questions do not add up to 100 percent nor do the total number answers add up to the total number of
respondents.
July 14, 2020 Item #6 Page 26 of 211
Table 3: Perpetrators of Alleged Discrimination
Number Percent
Landlord/Property Manager 248 59%
Other 55 13%
Real Estate Agent 36 9%
Government Staff Person 35 8%
Mortgage Lender 35 8%
Insurance Broker/Company 10 2%
Total Responses 419 --
Notes:
1. Categories are not mutually exclusive.
2. Survey respondents were not required to provide answers for every
question; therefore, total responses will vary by question.
Where Did the Act of Discrimination Occur?
Among the persons indicating that they had experienced housing discrimination, 38 percent (174
persons) indicated that the discrimination occurred in an apartment complex. About 21 percent (96
persons) indicated that the discrimination occurred in a single-family neighborhood, 10 percent (45
persons) indicated that it took place in a public/subsidized housing project, 11 percent (53 persons)
indicated that it took place at a condo/townhome development, and another 10 percent (46
persons) indicated that it took place when applying for City/County programs. Also, three percent
(15 persons) indicated that the act of discrimination occurred in a mobilehome park.
Table 4: Location of Alleged Discrimination
Location Number Percent
Apartment Complex 174 38%
Single-Family Neighborhood 96 21%
Condo/Townhome Development 53 11%
Applying for City/County Programs 46 10%
Public or Subsidized Housing Project 45 10%
Other 33 7%
Mobilehome Park 15 3%
Total Responses 462 --
Notes:
1. Categories are not mutually exclusive.
2. Survey respondents were not required to provide answers for every
question; therefore, total responses will vary by question.
July 14, 2020 Item #6 Page 27 of 211
On What Basis Do You Believe You Were Discriminated Against?
Of the 305 people who felt they were discriminated against, the most common causes for alleged
discrimination were race, other, source of income, and family status.
Table 5: Basis of Alleged Discrimination
Basis Number Percent
Race 105 16%
Source of Income 93 15%
Family Status 82 13%
Other 78 12%
Age 60 9%
Disability/Medical Conditions 54 8%
Color 45 7%
Marital Status 40 6%
Gender 40 6%
National Origin 13 2%
Religion 12 2%
Ancestry 10 2%
Sexual Orientation 9 1%
Total Response 641 --
Notes:
1. Categories are not mutually exclusive.
2. Survey respondents were not required to provide answers for every
question; therefore, total responses will vary by question.
Requests for Reasonable Accommodation or Modification
Among those who responded to the fair housing questions, 25 percent (77 persons) indicated that
they had been denied “reasonable accommodation” in rules, policies or practices for their disability
or a “reasonable modification” in the access to their homes.
Why Did You Not Report the Incident?
Of the survey respondents who felt they were discriminated against, 18 percent (54 persons)
reported the discrimination incident. Many of the respondents (27 percent) who did not report the
incident indicated that they don’t believe it makes a difference. In addition, 25 percent did not know
where to report the incident, 14 percent were afraid of retaliation, and 12 percent felt it was too
much trouble.
July 14, 2020 Item #6 Page 28 of 211
Table 6: Reason for Not Reporting Alleged Discrimination
Reason Number Percent
Other 150 27%
Don't believe it makes a difference 138 25%
Don't know where to report 120 22%
Afraid of Retaliation 77 14%
Too much trouble 66 12%
Total Responses 551 --
Notes:
1. Categories are not mutually exclusive.
2. Survey respondents were not required to provide answers for every question;
therefore, total responses will vary by question.
Has Any Hate Crime Been Committed in Your Neighborhood?
Of those who responded to the survey, seven percent (158 persons) indicated that a hate crime had
been committed in their neighborhood. Most of these respondents (24 percent) indicated that the
hate crime committed was based on race. Other notable causes of the alleged hate crimes include
religion, national origin, and color.
Table 7: Basis of Alleged Hate Crime
Basis Number Percent
Race 86 24%
National Origin 37 10%
Religion 37 10%
Color 36 10%
Sexual Orientation 31 9%
Source of Income 21 6%
Disability/Medical Conditions 21 6%
Age 13 4%
Ancestry 12 3%
Gender 11 3%
Family Status 9 3%
Marital Status 8 2%
Total Responses 353 --
Notes:
1. Categories are not mutually exclusive.
2. Survey respondents were not required to provide answers for
every question; therefore, total responses will vary by
question.
July 14, 2020 Item #6 Page 29 of 211
D. Public Review of Draft AI
The draft AI was made available for public review beginning in May 2020. During the 30-day public
review period, the document was made available at City Halls, County Administration Office, and
other public locations. The Draft AI was considered at the following public meetings:
City of Carlsbad – City Council Meeting, ____, 2020
City of Chula Vista – City Council Meeting, _____, 2020
City of El Cajon – City Council Meeting, June 9, 2020
City of Encinitas – City Council Meeting, June 24, 2020
City of Escondido – City Council Meeting, June 3, 2020
City of La Mesa – City Council Meeting, _____, 2020
City of National City – City Council Meeting, _____, 2020
City of Oceanside – City Council Meeting, _____, 2020
City of San Diego – City Council Meeting, _____, 2020
City of San Marcos – City Council Meeting, _____, 2020
City of Santee – City Council Meeting, June 10, 2020
City of Vista – City Council Meeting, _____, 2020
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an Diego County, boasts an estimated population of over three million residents, making it the
second most populous county in California and fifth in the nation (In California, only Los Angeles
County has a larger population). Encompassing 4,261 square miles, San Diego County’s borders
include 18 incorporated cities and numerous unincorporated neighborhoods and communities. The
county stretches south from Orange County to the U.S.-Mexico border. The Pacific Ocean forms the
western boundary, and the county’s eastern edge reaches to the Laguna Mountains and the Anza-
Borrego Desert.
Like many major metropolitan areas in the United States, the minority population in San Diego County
has increased significantly in recent years, especially among Asian and Hispanic groups. As this Chapter
and subsequent chapters will discuss, fair housing issues tend to affect racial and ethnic minority groups,
as well as persons with disabilities. The cost of living in San Diego County is high and getting higher
than many other regions in the nation. Median household incomes have not kept pace with the rising
cost of housing and living in the San Diego region, a trend seen nationwide. While housing affordability
is not a fair housing issue per se, the increased demand for housing and the dwindling supply may create
conditions where fair housing violations become a common part of the competition in the housing
market.
In an economic market where the need for affordable housing for the county's poorest residents
remains overwhelming, various factors may affect the ability of individuals with similar incomes and
needs in the same housing market to obtain a like range of housing choices. This section provides an
overview of San Diego County’s residents and housing stock, including population, economic, and
housing trends that help identify housing needs specific to the region. This overview will provide the
context for discussing and evaluating fair housing in the following chapters.
A. Demographic Profile
Examination of demographic characteristics provides some insight regarding the need and extent of
equal access to housing in a community. Supply and demand factors can create market conditions that
are conducive to housing discrimination. Factors such as population growth, age characteristics, and
race/ethnicity all help determine a community’s housing need and play a role in exploring potential
impediments to fair housing choice.
1. Population Growth
Population growth in San Diego County from 2010 to 2019 was slightly lower than the previous decade.
Overall, San Diego County experienced a 10 percent increase in population from 2000 to 2010 and a 8.3
percent increase in population from 2010 to 2019 (Table 8). From both 2000 to 2010 and 2010 to 2019,
the cities of San Marcos, Chula Vista, and Carlsbad had the largest growth. All cities experienced a
population growth in the last decade except for the city of Coronado, whose population dropped by two
percent. The San Diego Association of Governments (SANDAG) population projections indicate that
S
July 14, 2020 Item #6 Page 31 of 211
by 2035 the county’s population could reach 3,853,698, an approximately 15 percent increase from the
2019 population estimates. Several cities are projected to have larger increases between 2019 and 2035
than the San Diego region as a whole, including Chula Vista, La Mesa, National City, San Diego, and the
unincorporated areas of the county.
Table 8: Population Growth (2000-2035)
Jurisdiction
Total Population Percent Change
2000 2010 2019 2035
(Projected) 2000-2010 2010-2019 2019-2035
Urban County
Coronado 24,100 24,697 24,199 24,165 2.5% -2.0% -0.1%
Del Mar 4,389 4,161 4,451 4,672 -5.2% 7.0% 5.0%
Imperial Beach 26,980 26,324 27,448 30,369 -2.4% 4.3% 10.6%
Lemon Grove 24,954 25,320 27,208 28,673 1.5% 7.5% 5.4%
Poway 48,295 47,811 50,320 53,062 -1.0% 5.2% 5.4%
Solana Beach 12,887 12,867 13,933 14,207 -0.2% 8.3% 2.0%
Unincorporated 441,919 486,604 515,403 617,570 10.1% 5.9% 19.8%
Total Urban
County 583,524 627,784 662,962 772,718 7.6% 5.6% 16.6%
Entitlement Jurisdictions
Carlsbad 77,998 105,328 115,241 124,351 35.0% 9.4% 7.9%
Chula Vista 173,860 243,916 271,411 326,625 40.3% 11.3% 20.3%
El Cajon 94,819 99,478 105,559 109,383 4.9% 6.1% 3.6%
Encinitas 58,195 59,518 63,390 65,264 2.3% 6.5% 3.0%
Escondido 133,528 143,911 152,739 172,892 7.8% 6.1% 13.2%
La Mesa 54,751 57,065 60,820 70,252 4.2% 6.6% 15.5%
National City 54,405 58,582 62,307 73,329 7.7% 6.4% 17.7%
Oceanside 160,905 167,086 178,021 188,597 3.8% 6.5% 5.9%
San Diego 1,223,341 1,301,617 1,420,572 1,665,609 6.4% 9.1% 17.2%
San Marcos 55,160 83,781 98,369 109,095 51.9% 17.4% 10.9%
Santee 53,090 53,413 58,408 63,812 0.6% 9.4% 9.3%
Vista 90,131 93,834 101,987 111,771 4.1% 8.7% 9.6%
Total County 2,813,707 3,095,313 3,351,786 3,853,698 10.0% 8.3% 15.0%
Sources: U.S. Census Bureau, 2000, 2010 Census; California Department of Finance 2019 Population Estimates (E-5); SANDAG
Regional Growth Forecast Series 13 (2012).
2. Age
Housing demand is affected by the age characteristics of residents in a community. Different age
groups are often distinguished by important differences in lifestyle, family type, housing preferences and
income levels. Typically, young adult households may occupy apartments, condominiums, and smaller
single-family homes because of size and/or affordability. Middle-age adults may prefer larger homes as
they begin to raise their families, while seniors may prefer apartments, condominiums, mobile homes, or
smaller single-family homes that have lower costs and less extensive maintenance needs. Because a
July 14, 2020 Item #6 Page 32 of 211
community’s housing needs change over time, this section analyzes changes in the age distribution of
San Diego County residents and how these changes affect housing need.
As Table 9 shows, the median age has risen in all but three jurisdictions in San Diego County from 2010
to 2017. Median age decreased in Coronado, Solana Beach, and La Mesa. The county median age was
34.6 years in 2010 and rose to 35.4 by 2017. In 2017, the median age in the various cities ranged from a
low of 31.9 years in Imperial Beach to a high of 50.7 years in Del Mar. Based on the 2017 American
Community Survey, 12.9 percent of the population in San Diego County was age 65 or over (seniors),
with another 11.6 percent in the 55 to 64 age group (future seniors). Close to 12.1 percent of San Diego
County residents were school-age children between the ages of five and 14, and over 30 percent of
residents were between the age of 15 and 34 (Figure 1). This age structure suggests the county has a high
proportion of families with children and has a rapidly increasing older population.
Table 9: Age Characteristics
Jurisdiction Age Category Median Age
<5 5-14 15-24 25-34 35-44 45-54 55-64 65+ 2010 2017
Urban County
Coronado 4.9% 9.5% 19.3% 13.5% 9.1% 11.1% 13.8% 18.7% 40.7 38.1
Del Mar 1.7% 7.9% 3.7% 15.8% 9.2% 19.7% 16.5% 25.6% 48.6 50.7
Imperial Beach 6.5% 15.1% 16.1% 17.3% 12.6% 11.7% 10.4% 10.3% 31 31.9
Lemon Grove 6.3% 15.4% 11.5% 15.8% 14.7% 11.6% 12.3% 12.4% 35 35.6
Poway 6.3% 13.7% 13.0% 11.1% 12.1% 15.2% 13.8% 14.8% 41.3 40
Solana Beach 3.9% 9.6% 9.1% 13.7% 12.5% 14.8% 13.7% 22.8% 43.7 46.1
Unincorporated 6.7% 11.8% 15.7% 12.9% 11.6% 13.2% 13.1% 15.0% N/A N/A
Total Urban
County 6.5% 12.1% 15.3% 13.1% 11.7% 13.2% 13.1% 15.1% N/A N/A
Entitlement Jurisdictions
Carlsbad 6.0% 13.9% 10.5% 11.6% 15.0% 16.3% 12.5% 14.0% 38.9 40.4
Chula Vista 7.2% 15.6% 15.3% 13.7% 15.2% 13.8% 9.2% 10.0% 33.0 33.7
El Cajon 7.6% 13.5% 15.8% 14.7% 12.9% 14.3% 10.1% 11.0% 31.9 33.7
Encinitas 5.4% 11.6% 10.0% 13.4% 14.5% 16.9% 15.4% 12.8% 37.9 41.5
Escondido 8.1% 14.9% 15.4% 15.0% 13.5% 13.1% 9.6% 10.5% 31.2 32.5
La Mesa 6.3% 10.0% 14.4% 16.3% 13.1% 14.5% 11.2% 14.2% 37.3 37.1
National City 6.9% 13.8% 20.9% 14.7% 12.4% 12.0% 8.6% 10.6% 28.7 30.2
Oceanside 7.0% 12.7% 15.5% 14.5% 12.9% 14.0% 10.5% 12.9% 33.3 35.2
San Diego 6.2% 11.5% 16.7% 17.6% 14.1% 13.2% 10.1% 10.7% 32.5 33.6
San Marcos 8.4% 15.2% 15.3% 14.4% 15.8% 12.2% 8.7% 10.2% 32.1 32.9
Santee 6.6% 12.8% 13.9% 13.7% 14.0% 16.3% 12.0% 10.7% 34.8 37.2
Vista 8.0% 14.2% 17.1% 16.2% 13.2% 13.3% 8.7% 9.2% 30.3 31.1
Total County 6.6% 12.7% 16.0% 15.2% 13.6% 13.9% 10.6% 11.4% 33.2 34.6
Sources: U.S. Census Bureau, 2010 Census; American Community Survey, 2013-2017.
July 14, 2020 Item #6 Page 33 of 211
6.5%
12.1%
14.5%
16.3%
13.2%12.9%
11.6%
12.9%
0.0%
2.0%
4.0%
6.0%
8.0%
10.0%
12.0%
14.0%
16.0%
18.0%
<5 5 to 14 15-24 25-34 35-44 45-54 55-64 65+Proportion of County PopulationAge Category
Figure 1: San Diego County Age Structure (2017)
Source: American Community Survey, 2013-2017.
3. Racial and Ethnicity
The San Diego region’s racial and ethnic composition trends mirror those seen at the national level. The
nation’s demographic profiles are becoming increasingly diverse in their racial and ethnic compositions.
According to 2018 American Community Survey estimates, 40 percent of U.S. residents were non-
White. Growing Hispanic and Asian populations have contributed to a major transformation, reducing
the number of White majority places and increasing the number of minority-majority and no-majority
places. As of 2010, the most diverse communities in the U.S. were disproportionately western, southern,
and coastal metropolitan areas and their principal cities and suburbs. Studies have found that areas with
a strong government and/or the military employment base, as is the case in the San Diego region, tend
to be more diverse in general.5
Race and ethnicity have implications on housing choice in that certain demographic and economic
variables correlate with race. For example, median household income in the county between 2013 and
2017 was $70,588. However, the median income for Black, Hispanic American Indian, and Alaska
Native households was less than 75 percent of the county median while Asian and White household
median incomes were 125 and 114 percent of the county median income.
The State of California’s and San Diego County’s demographic profiles have become increasingly
diverse in their race and ethnic compositions since 1970, a period that coincides with the sharp increase
in immigration. As recently as 1970, the vast proportion of the population in the State was
predominantly White whereas now, non-White races (classified as minorities) are the majority in
California. When a population’s racial and ethnic composition is more than 50 percent non-White, the
population is said to have a minority-majority. The County of San Diego became a minority-majority
5 Lee, Barrett and Iceland, A. John and Sharp, Gregory. “Racial and Ethnic Diversity Goes Local: Charting Change in
American Communities Over Three Decades”. Project US2010, (2012).
July 14, 2020 Item #6 Page 34 of 211
area between 2000 and 2010, when the percent minority population increased from 45.1 to 51.5 percent.
The proportion of minority population continued to increase between 2010 and 2017 to 53.8 percent.
Table 10: Racial and Ethnic Composition
Jurisdiction White Black Hispanic Asian/
P. Isl. Other
Percent
Minority*
2010
Percent
Minority*
2017
Urban County
Coronado 75.1% 3.5% 14.5% 3.5% 3.4% 20.6% 24.9%
Del Mar 91.3% 0.5% 4.7% 2.6% 1.0% 9.3% 8.7%
Imperial Beach 31.4% 4.0% 51.3% 8.6% 4.8% 64.0% 68.6%
Lemon Grove 31.9% 12.7% 44.4% 6.1% 4.8% 65.3% 68.1%
Poway 63.7% 0.9% 18.5% 12.9% 4.0% 30.9% 36.3%
Solana Beach 78.4% 0.4% 11.5% 5.1% 4.6% 22.7% 21.6%
Unincorporated 58.6% 4.2% 26.9% 5.9% 4.3% 38.6% 41.4%
Total Urban
County 58.0% 4.2% 27.1% 6.4% 4.3% 39.1% 42.0%
Entitlement Jurisdictions
Carlsbad 74% 0.9% 14% 7.8% 3.4% 25% 26%
Chula Vista 18% 4.2% 60% 15% 1.0% 80% 82%
El Cajon 56% 5.4% 29% 4.1% 4.8% 43% 44%
Encinitas 79% 0.6% 13% 4.2% 4.8% 21% 21%
Escondido 37% 2.1% 51% 7.0% 4.0% 60% 63%
La Mesa 56% 6.6% 26% 6.2% 4.6% 38% 44%
National City 10% 4.5% 64% 20% 4.3% 88% 90%
Oceanside 48% 4.9% 35% 7.9% 4.3% 52% 52%
San Diego 43% 6.1% 30% 17% 3.4% 55% 57%
San Marcos 45% 2.5% 39% 10% 1.0% 51% 55%
Santee 70% 1.9% 18% 4.8% 4.8% 26% 30%
Vista 40% 2.8% 50% 4.8% 4.8% 59% 60%
Total County 46% 4.7% 33% 12% 4.0% 52% 54%
Total State 38% 5.5% 39% 14% 4.6% 60% 62%
Sources U.S. Census Bureau, 2010. American Community Survey. 2013-2017.
* Minority is defined as Blacks, Hispanics, Asian/Pacific Islanders, and all others not White.
July 14, 2020 Item #6 Page 35 of 211
After White residents, the largest racial/ethnic group in the county is Hispanic. As seen in Table 10,
White residents make up the single largest percentage of San Diego County residents (46.2 percent),
while Hispanic residents made up 33.4 percent. Asians/Pacific Islander, Blacks, and other groups
followed with 11.9 percent, 4.7 percent, and 3.9 percent, respectively (Table 10). The cities of National
City, Chula Vista, Imperial Beach, Escondido, and Vista have significant Hispanic concentrations
(greater than 50 percent), while the city of Del Mar has the smallest proportion of Hispanic residents
(4.7 percent). The largest concentrations of Asian/Pacific Islander populations reside in National City,
San Diego, and Chula Vista. The City of Lemon Grove has the highest concentration of Black residents
(13 percent) while the second highest concentration of Blacks was in La Mesa (7 percent). Del Mar,
Poway, Solana Beach, Carlsbad and Encinitas have the smallest proportions of Black residents, where
Blacks make up less than one percent of their population.
Race and Ethnic Concentration
Ethnic and racial composition of a region is useful in analyzing housing demand and any related fair
housing concerns, as it tends to demonstrate a relationship with other characteristics such as household
size, locational preferences and mobility. Nationally, HUD data show that race-based discrimination
ranks second in discrimination of protected classes, behind discrimination related to disability6. Figure 2
illustrates concentrations of minority households by Census block group in San Diego County. A
concentration is defined as a block group with a proportion of minority households that is greater than
the overall San Diego County minority average of 50.8 percent7 . An important note on the mapping of
racial/ethnic concentrations is that concentration is defined by the proportion of a racial/ethnic group
in the total population of a census block group. If a census block group has low population, such as in
and near the State and National Parks (eastern portions of the map), the proportion of a racial/ethnic
group may appear high even though the number of residents in that group may be limited.
Furthermore, block group boundaries may cross jurisdictional boundaries
The minority population in the county is described by sub-region in Table 11. In San Diego County, the
minority population is concentrated in the southern areas of the City of San Diego and continuing south
(Figure 2). This pattern can be attributed to the traditional cluster of minorities living in the urban core
and near the U.S./Mexican border. Another concentration is visible in the northwestern part of the
North County East sub-region just west of the Cleveland National Forest. This area is home to several
Native American reservations. An additional swath of minority concentration can be found in the
University and Mira Mesa communities of the City of San Diego. Clusters of minority populations are
also found in the North County cities of Oceanside, Vista, San Marcos, and Escondido.
6 U.S. Department of Housing and Urban Development. “Annual Report on Fair Housing FY 2017”, (2017).
7 This minority percentage differs from the 54 percent in Table 3 due to calculation differences in the unit of
measurement. This value was calculated using the census block groups and block group boundaries may cross
jurisdictional boundaries.
July 14, 2020 Item #6 Page 36 of 211
Table 11: Minority Population by Sub-region
MSA Region Minority Population Total Population % Minority in Region
2010 2018 2010 2018 2010 2018
0 Central 414,065 437,635 630,376 679,213 65.7% 64.4%
1 North City 296,118 371,440 733,866 812,706 40.4% 45.7%
2 South Suburban 312,045 335,810 385,468 407,514 81.0% 82.4%
3 East Suburban 187,436 229,518 481,993 509,452 38.9% 45.1%
4 North County West 149,733 174,472 405,715 440,048 36.9% 39.6%
5 North County East 226,139 250,322 431,208 458,801 52.4% 54.6%
6 East County 9,730 9,858 26,687 26,722 36.5% 36.9%
Total 1,595,266 1,809,055 3,095,313 3,334,456 51.5% 54.3%
Sources: U.S. Census Bureau, 2010 Census; SANDAG, Series 14 (2018).
A significant portion of San Diego County’s population is also foreign born. According to the 2013-
2017 ACS, one-fourth of the county’s population is foreign born and almost 90 percent of them are
from non-European countries. About half of foreign-born residents in the county are from Latin
America and a large portion of immigrants are from Asian countries (38 percent). More than a third of
the foreign-born Asian population came from the Philippines, a Southeast Asian country.
July 14, 2020 Item #6 Page 37 of 211
Figure 2: Minority Concentration Areas
July 14, 2020 Item #6 Page 38 of 211
Linguistic Isolation
A language barrier can be an impediment to accessing housing of choice. A population that is both
minority and does not speak English well may face discrimination based on national origin as well as
challenges related to obtaining housing, such as communicating effectively with a property owner,
landlord, rental agent, real estate agent, mortgage lender or insurance agent.
According to the 2013-2017 ACS, approximately 37.7 percent of county residents over the age of five
spoke a language other than “English only” at home. In some cities with a large minority population,
such as the cities of Imperial Beach, Lemon Grove, Chula Vista, El Cajon, Escondido, National City,
San Diego, San Marcos, and Vista this figure was higher. In National City, 70.3 percent of the
population over the age of five years spoke a language other than English at home.
Table 12: Language and Linguistic Isolation
Jurisdiction Total
Population
Speak Language Other
Than English at Home
Speak English
Less than "Very Well"
Total % Total
Population Total
% of Speaking
Non-English
Language
% Total
Population
Urban County
Coronado 22,878 3,311 14.5% 848 25.6% 3.7%
Del Mar 4,264 333 7.8% 60 18.0% 1.4%
Imperial Beach 25,500 12,550 49.2% 4,187 33.4% 16.4%
Lemon Grove 24,968 10,194 40.8% 3,357 32.9% 13.4%
Poway 46,715 12,149 26.0% 5,180 42.6% 11.1%
Solana Beach 12,847 1,847 14.4% 707 38.3% 5.5%
Unincorporated 473,988 119,992 25.3% 43,890 36.6% 9.3%
Total Urban
County 611,160 160,376 26.2% 58,229 36.3% 9.5%
Entitlement Jurisdictions
Carlsbad 106,371 18,183 17.1% 7,025 38.6% 6.6%
Chula Vista 246,395 146,846 59.6% 55,768 38.0% 22.6%
El Cajon 95,405 41,750 43.8% 20,103 48.2% 21.1%
Encinitas 59,177 9,405 15.9% 3,678 39.1% 6.2%
Escondido 138,640 67,537 48.7% 31,749 47.0% 22.9%
La Mesa 55,440 13,332 24.0% 4,324 32.4% 7.8%
National City 56,914 40,019 70.3% 15,991 40.0% 28.1%
Oceanside 163,706 51,440 31.4% 23,118 44.9% 14.1%
San Diego 1,303,777 529,264 40.6% 214,379 40.5% 16.4%
San Marcos 87,085 32,716 37.6% 17,263 52.8% 19.8%
Santee 53,894 8,447 15.7% 2,661 31.5% 4.9%
Vista 92,799 37,659 40.6% 17,757 47.2% 19.1%
Total County 3,070,763 1,156,974 37.7% 472,045 40.8% 15.4%
Source: American Community Survey, 2013-2017.
July 14, 2020 Item #6 Page 39 of 211
Linguistically isolated household can be described as a household whose members have at least some
difficulty speaking English. The ACS provides information on households with persons five years and
over who speak English “less than very well.” In San Diego County, 15.4 percent of residents indicated
that they spoke English “less than very well” and can be considered linguistically isolated. Of those that
speak a language other than English at home, 40.8 percent speak English less than very well. The cities
of National City, Escondido, and Chula Vista have the highest percentage of total residents who spoke
English less than “very well” (28.1, 22.9 and 22.6 percent of the total population, respectively).
Language barriers may prevent residents from accessing services, information, and housing, and may
affect educational attainment and employment. Executive Order 13166 ("Improving Access to Services
by Persons with Limited English Proficiency”) was issued in August 2000, which requires federal
agencies to assess and address the needs of otherwise eligible persons seeking access to federally
conducted programs and activities who, due to Limited English Proficiency (LEP), cannot fully and
equally participate in or benefit from those programs and activities. This requirement passes down to
grantees of federal funds as well.
B. Household Characteristics
Household type and size, income level, the presence of persons with special needs, and other household
characteristics may affect access to housing. This section details the various household characteristics
that may affect equal access to housing.
1. Household Composition and Size
According to the 2019 California Department of Finance Housing estimates, there are 1,219,460
households in San Diego County, a 12.2-percent increase since 2010. The cities of San Marcos,
Carlsbad, and Chula Vista saw the largest increases in the number of households between 2000 and
2010. However, in the last decade, the cities of Coronado and Del Mar had the greatest increases in the
number of households (31.5 percent and 27.2 percent) while San Marcos, Carlsbad, and Chula Vista had
moderate household growth (18.1, 13.9, and 13.3 percent). None of the cities saw a decrease in
household numbers.
Different household types generally have different housing needs. Seniors or young adults typically
constitute a majority of single-person households and tend to reside in apartment units, condominiums
or smaller detached homes. Families, meanwhile, often prefer single-family homes. Household size can
be an indicator of changes in population or use of housing. An increase in household size can indicate a
greater number of large families or a trend toward overcrowded housing units. A decrease in household
size, on the other hand, may reflect a greater number of senior or single-person households, or a
decrease in family size.
What is a Household?
A household is defined by the Census as all persons occupying a housing unit. Families are a subset of households and
include all persons living together who are related by blood, marriage or adoption. Single households include persons
living alone but do not include persons in group quarters such as convalescent homes or dormitories. “Other”
households are unrelated people living together, such as roommates.
July 14, 2020 Item #6 Page 40 of 211
Table 13: Household Growth by Jurisdiction
Jurisdiction Households Household Growth
2010 2019 2010-2019
Urban County
Coronado 7,409 9,740 31.5%
Del Mar 2,064 2,625 27.2%
Imperial Beach 9,112 10,074 10.6%
Lemon Grove 8,434 9,114 8.1%
Poway 16,128 16,917 4.9%
Solana Beach 5,650 6,569 16.3%
Unincorporated 159,339 178,844 12.2%
Total Urban County 208,136 233,883 12.4%
Entitlement Cities
Carlsbad 41,345 47,080 13.9%
Chula Vista 75,515 85,535 13.3%
El Cajon 34,134 36,148 5.9%
Encinitas 24,082 26,495 10.0%
Escondido 45,484 48,833 7.4%
La Mesa 24,512 26,869 9.6%
National City 15,502 17,264 11.4%
Oceanside 59,238 65,902 11.2%
San Diego 483,092 545,645 12.9%
San Marcos 27,202 32,126 18.1%
Santee 19,306 21,100 9.3%
Vista 29,317 32,580 11.1%
Total County 1,086,865 1,219,460 12.2%
Sources U.S. Census Bureau, 2010; California Department of Finance Population and Housing Estimates (E-5), 2019.
The majority of San Diego County households are family households, with a roughly even mix between
married-couple households with and without children (Table 14). Families with children account for
33.5 percent of all households in the county. “Other” families, primarily consisting of single-parent
households, represent 17.2 percent of all households. Households of single senior persons make up 8.7
percent of all households. Between 2010 and 2013-2017, the distribution of household types remained
relatively stable.
More than 67 percent of all households within the County of San Diego are family households.
Nationally, HUD data show that familial status discrimination ranks third in discrimination of protected
classes, behind discrimination due to disability and race.8 While the language in federal law about familial
status discrimination is clear, the guidelines landlords can use to establish occupancy can be very vague.
8 U.S. Department of Housing and Urban Development. “Annual Report on Fair Housing FY 2017”. (2017).
July 14, 2020 Item #6 Page 41 of 211
Although landlords can create occupancy guidelines based on the physical limitations of the housing
unit, landlords often impose strict occupancy limitations precluding large families with children.
Table 14: Household Type
Household Type
2010 2017
Number of
Households
Percent of
Households
Number of
Households
Percent of
Households
Family Households 720,480 66.3% 747,245 67.2%
Married with Children1 263,046 24.2% 259,963 23.4%
Married – no Children 268,879 24.7% 296,702.45 26.7%
Other Family with Children 113,072 10.4% 112,172 10.1%
Other Family – no Children 75,483 6.9% 78,408 7.1%
Non-Family Households 366,385 33.7% 364,494 32.8%
Single, non-senior 174,593 16.1% 169,854 15.3%
Single, senior 86,624 8.0% 96,591 8.7%
Total County 1,086,865 100.0% 1,111,739 100.0%
Source: U.S. Census Bureau, 2010 Census; American Community Survey, 2013-2017.
1 With children categories calculated using the HH with one or more persons under 18
Certain jurisdictions in the county had a higher than average proportion of family households with
children and, therefore, may be more vulnerable to this type of discrimination. The proportion of
families with dependent children was highest in the City of Chula Vista (39.9 percent) and Poway (37.7
percent). The proportion of families with children in the unincorporated areas (31.5 percent) is similar
to the countywide proportion (30.2 percent). Close to nine percent of households in the county included
senior members and six percent of households were female-headed households with children. Single-
parent households with children and households headed by seniors have unique fair housing issues as
discussed later in this chapter.
July 14, 2020 Item #6 Page 42 of 211
Table 15: Household Characteristics
Jurisdiction %
Families
%
Families
with
Children
% Elderly
Households
% Female-
Headed
Households
w/ Children
Urban County
Coronado 66.1% 27.0% 12.8% 4.0%
Del Mar 58.2% 13.4% 8.6% 0.9%
Imperial Beach 68.7% 32.0% 6.6% 10.6%
Lemon Grove 70.4% 33.9% 9.9% 7.0%
Poway 80.5% 37.7% 7.5% 4.6%
Solana Beach 55.4% 20.3% 16.1% 2.1%
Unincorporated 76.2% 31.5% 9.1% 2.7%
Total Urban County 75.9% 31.9% 9.4% 3.4%
Entitlement Cities
Carlsbad 70.8% 31.7% 9.6% 5.6%
Chula Vista 79.0% 39.9% 7.0% 8.6%
El Cajon 72.0% 35.8% 8.3% 20.7%
Encinitas 64.2% 27.7% 11.8% 3.6%
Escondido 72.7% 36.0% 8.9% 7.6%
La Mesa 58.4% 24.5% 13.0% 6.5%
National City 74.3% 34.9% 9.5% 11.8%
Oceanside 67.5% 26.6% 11.0% 5.2%
San Diego 60.4% 27.0% 8.0% 5.7%
San Marcos 73.9% 37.2% 9.4% 5.7%
Santee 73.4% 32.8% 9.7% 6.4%
Vista 70.9% 34.3% 7.3% 7.2%
Total County 67.2% 30.2% 8.7% 6.0%
Source: American Community Survey, 2013-2017.
Household Size
The average size and composition of households are highly sensitive to the age structure of the
population but they also reflect social and economic changes. For example, economic downturns may
prolong the time adult children live at home or result in multiple families and non-family members living
together to lower housing costs. The average household size countywide in 2017 was 2.87 persons per
household, a very slight increase from 2010 (2.75). Average household size ranged from a low of 2.01
persons in Del Mar to a high of 3.47 in National City. Geographically, average household size increased
in the Southern and Eastern areas of the county. Nine cities had an average household size over three
persons in 2017, compared to only five in 2019. Notably, no cities in the Urban County had with an
average household size over three persons in the 2010 but by 2017, average household size was greater
than 3.0 in Imperial Beach, Lemon Grove, and Poway.
July 14, 2020 Item #6 Page 43 of 211
Table 16: Average Household Size by Jurisdiction
Jurisdiction Average Household Size
2010 2017
Urban County
Coronado 2.31 2.40
Del Mar 2.02 2.01
Imperial Beach 2.82 3.02
Lemon Grove 2.96 3.12
Poway 2.93 3.12
Solana Beach 2.28 2.33
Unincorporated -- --
Entitlement Cities
Carlsbad 2.53 2.60
Chula Vista 3.21 3.34
El Cajon 2.84 3.09
Encinitas 2.45 2.56
Escondido 3.12 3.29
La Mesa 2.3 2.49
National City 3.41 3.47
Oceanside 2.8 2.81
San Diego 2.6 2.72
San Marcos 3.05 3.17
Santee 2.72 2.86
Vista 3.13 3.19
Total County 2.75 2.87
Sources: U.S. Census Bureau, 2010 Census; American Community Survey,
2013-2017.
July 14, 2020 Item #6 Page 44 of 211
C. Special Needs Groups
Certain households and residents, because of their special characteristics and needs, have greater
difficulty finding decent and affordable housing. These circumstances may be related to age, family
characteristics, or disability. Table 17 shows a summary of this section and the special needs groups
present in San Diego County. The following discussion highlights particular characteristics that may
affect access to housing in a community.
Table 17: Residents with Special Needs
Special Needs Group Number Percent of County
Households with a Senior (65+) 242,017 21.8%
Senior Persons (65+) 425,217 12.9%
Large Households 129,627 11.7%
Female Headed Households w/Children 80,886 7.3%
Disabled Persons 312,565 9.8%
HIV/AIDS 13,643 0.4%
Homeless Persons (Urban and Rural) 8,102 0.2%
Farm Workers 8,308 0.3%
Active Duty Military Personnel 143,000 4%
Veterans 225,694 7%
Sources: American Community Survey 2013-2017; San Diego Regional Task Force on the Homeless, Annual Report on the Homeless
2019; San Diego Military Advisory Council, San Diego Military Economic Impact Study, 2019; County of San Diego Health and Human
Services Agency, HIV Epidemiology Report, 2016.
1. Seniors
Seniors (persons age 65 and above) are gradually becoming a more substantial segment of a
community’s population. Americans are living longer than ever before in our history and are expected to
continue to do so. Senior households are vulnerable to housing problems and housing discrimination
due to limited income, prevalence of physical or mental disabilities, limited mobility, and high health
care costs. Seniors, particularly those with disabilities, may face increased difficulty in finding housing
accommodations and may become victims of housing discrimination or fraud. Seniors sometimes face
discrimination in the rental housing market, often based on the perception of increased risks and
liabilities associated with the frail conditions or disabilities of senior tenants. A senior on a fixed income
can face great difficulty finding safe and affordable housing. Subsidized housing and federal housing
assistance programs are increasingly challenging to secure and often involve a long waiting list.
According to the 2013-2017 ACS, 12.9 percent of all residents in San Diego County were ages 65 and
over. The proportion of residents over the age of 65 years ranged from a low of 9.7 percent in Vista to a
high of 25.6 percent in Del Mar (Table 9). ACS data (2013-2017) estimates that 21.8 percent of
households in San Diego County had at least one individual who was 65 years of age or older (Table 18).
According to HUD’s 2012-2016 Comprehensive Housing Affordability Strategy (CHAS) data, a higher
proportion (53.0 percent) of seniors had low and moderate incomes compared to all county residents
(45.6 percent).
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Table 18: Senior Profile – San Diego County
Residents
Percent of
Population
Percent with a
Disability
Percent Households
with Low/Moderate
Incomes
Percent Households
with Housing Problems
Seniors 12.9% 33.7% 53.0% 40.5%
All Residents 100.0% 9.5% 45.6% 45.4%
Sources: 2013-2017 American Community Survey (ACS); HUD Comprehensive Housing Affordability Strategy (CHAS), 2012-2016.
The San Diego County Health and Human Services Agency’s Aging & Independence Services (AIS)
provides services to older adults, people with disabilities and their family members. AIS provides a wide
range of services, including information and access, advocacy, coordination, assessment, and
authorization of direct services. Direct services are provided through contracts with vendors and
agencies, and include in-home support, respite care, meals (senior dining centers and home-delivered),
health promotions, legal assistance, adult day care, transportation, educational opportunities,
employment, money management, and counseling programs.
The City and the County of San Diego both administer a wide array of housing programs to assist in the
provision of affordable housing for senior households, including funding for acquisition and
construction, rehabilitation, rental assistance, and home repair. In addition to affordable housing located
near transportation, the housing needs of seniors include supportive housing, such as intermediate care
facilities, group homes, and other housing with a planned service component. Approximately 593 State-
licensed residential care facilities for the elderly, 401 adult residential facilities (for individuals ages 18
through 59) and 60 adult day care facilities (for individuals 18 and over) serve the senior population
throughout the county. These licensed care facilities have a combined capacity of 28,131 beds. These
numbers show a decrease from the number of licensed care facilities and bed capacity between 2014 and
2019. Between 2014 and 2015, the total bed capacity of licensed care facilities decreased by 3,716 from
31,847 to 28,131. The total number of facilities also dropped 700 from 1,855 to 1,155. Figure 3 shows
the location of the various licensed care facilities in San Diego County as of 2019.
Most of the community care facilities within the county are located within the larger incorporated cities.
There is a noticeable presence of facilities in the unincorporated areas, specifically those surrounding the
incorporated cities. However, since most of the county’s population is located within the incorporated
cities, residents living in these areas may have to travel a greater distance to access the region’s inventory
of care facilities. Concentrations of care facilities can be seen in the North County areas in and around
the cities of Vista and Escondido and in the South County in and around the cities of Chula Vista and
El Cajon. In the City of San Diego clusters of care facilities can be seen in the southern portion of the
City and in the Mira Mesa area.
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Figure 3: Licensed Care Facilities
July 14, 2020 Item #6 Page 47 of 211
2. Large Households
Large households are defined as those with five or more members. These households are usually
families with two or more children or families with extended family members such as in-laws or
grandparents. It can also include multiple families living in one housing unit in order to save on housing
costs. Large households are a special needs group because the availability of adequately sized (i.e. three
or more bedrooms), affordable housing units is often limited. Large households may face
discrimination in the housing market, particularly for rental housing. Although landlords can create
occupancy guidelines based on the physical limitations of the housing unit, landlords may impose strict
occupancy limitations precluding large families with children.
As indicated in Table 19, in 2017, close to 12 percent of all households in the county had five or more
members; specifically 10.9 percent of owner-households and 12.5 percent of renter-households in the
county were large households. This represents a decrease of two percentage points in the proportion of
large households in the county between 2010 and 2017 from 13.7 to 11.7 percent. The proportion of
large households was highest in the cities of National City (19.0 percent), Escondido (18.6 percent), and
Chula Vista (18.0 percent), although their respective proportions in 2010 were much higher at, 25.4m
20.7, and 20.5 percent. These three cities also had high proportions of non-White population (90.3, 63.5,
and 82.3 percent, respectively) and family households (74.3. 72.7, and 79.0 percent, respectively) in 2017.
Many ethnic minority groups have a younger age profile and tend to have larger families than the White
population. The 2012-2016 CHAS data shows that over half (51.3 percent) of large households were
estimated to earn low and moderate incomes compared with 45.6 percent of all county households.
July 14, 2020 Item #6 Page 48 of 211
Table 19: Large Households
City/Area
Total Large
Households
Large Owner
Households
Large Renter
Households
# % of Total
Households # % of Owner
Households # % of Renter
Households
Urban County
Coronado 484 5.7% 137 3.3% 347 8.1%
Del Mar 40 1.9% 40 3.5% 0 0.0%
Imperial Beach 1,291 14.6% 352 12.5% 939 15.6%
Lemon Grove 1,285 15.3% 832 18.3% 453 11.7%
Poway 2,121 13.5% 1,435 12.2% 686 17.0%
Solana Beach 197 3.4% 177 5.3% 20 0.8%
Unincorporated 20,110 12.5% 12,726 11.7% 7,384 14.2%
Total Urban County 25,528 12.2% 15,699 11.5% 9,829 13.4%
Entitlement Cities
Carlsbad 2,924 6.8% 1,921 6.8% 1,003 6.6%
Chula Vista 14,116 18.0% 8,421 18.5% 5,695 17.3%
El Cajon 5,243 16.1% 1,355 10.9% 3,888 19.3%
Encinitas 1,347 5.5% 876 5.7% 471 5.4%
Escondido 8,414 18.6% 3,305 14.7% 5,109 22.5%
La Mesa 1,588 6.7% 680 6.9% 908 6.6%
National City 3,073 19.0% 1,183 22.7% 1,890 17.2%
Oceanside 6,883 11.1% 3,252 9.4% 3,631 13.3%
San Diego 49,569 10.0% 22,901 9.8% 26,668 10.1%
San Marcos 4,192 14.4% 1,998 11.2% 2,194 19.4%
Santee 1,916 9.8% 1,164 8.7% 752 12.5%
Vista 4,834 15.8% 1,654 11.0% 3,180 20.5%
Total County 129,627 11.7% 64,409 10.9% 65,218 12.5%
Source: American Community Survey, 2013-2017.
3. Families with Children and Single-Parent Families
Families with children may face housing discrimination by landlords who fear that children will cause
property damage. Some landlords may have cultural biases against children of the opposite sex sharing a
bedroom. Differential treatments such as limiting the number of children in a complex or confining
children to a specific location are also fair housing concerns. For example, some landlords may charge
large households a higher rent or security deposit, limit the number of children in a complex, confine
them to a specific location, limit the time children can play outdoors, or choose not to rent to families
with children altogether, which would violate fair housing laws. Housing discrimination against families
with children can also be masked as overcrowding issues. Even when housing providers rent openly to
families with children, there can still be an issue of illegal discriminatory policies for families once they
become tenants. Neutral rules are expected to apply to all tenants equally, but once a housing provider
isolates a particular group upon which to singularly implement those rules, a discriminatory practice is
set in motion.
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The proportion of families with dependent children was highest in the cities of Chula Vista and National
City (Table 15). These communities may be more vulnerable to familial discrimination in the housing
market because of their higher than average proportion of families with children.
The proportion of female-headed households decreased between 2010 and 2017 from 7.5 to 6.0 percent
(Table 15). The proportion of female-headed households with children was highest in El Cajon (20.7
percent) and National City (11.8 percent). Female single-parent family households are disproportionately
affected by poverty. According to the 2013-2017 ACS, about 32.6 percent of female single-parent family
households in San Diego County lived below the poverty level (compared to 9.5 percent of all family
households in the county). Limited household income constrains the ability of these households to
afford adequate housing and childcare, health care, and other necessities. Finding adequate and
affordable childcare is also a pressing issue for many families with children and single-parent households
in particular.
4. Persons with Disabilities
Affordability, design, location, and discrimination limit the supply of housing for persons with
disabilities. Fair housing choice for persons with disabilities may be compromised based on the nature
of their disability. Adaptable housing is the most critical housing need for persons with mobility
limitations. Many single-family homes may not be adaptable to widened doorways and hallways, access
ramps, or other features necessary for accessibility. Furthermore, multi-family units built prior to 1990
are often not wheel-chair accessible and the cost of retrofitting a home is often prohibitive. Many
disabled individuals live in households where a member of the household is a homeowner. These
disabled individuals are less likely to have accessible units, since the Fair Housing Act (FHA) does not
apply to all owner-occupied dwelling units. Amendments to the Fair Housing Act, as well as state law,
require ground-floor units of new multi-family construction with more than four units to be accessible
to persons with disabilities. However, units built prior to 1989 are not required to be accessible to
persons with disabilities. Older units, particularly in older multi-family structures, are very expensive to
retrofit for disabled occupants because space is rarely available for elevator shafts, ramps, widened
doorways, etc. The site, parking areas, and walkways may also need modifications to install ramps and
widen walkways and gates. The location of housing and availability of transportation is also important
because disabled people may require access to a variety of social and specialized services.
Persons with physical disabilities may face discrimination in the housing market because of the use of
wheelchairs, need for home modifications to improve accessibility, or other forms of assistance. Persons
with disabilities may request reasonable accommodations or reasonable modifications from their
landlords. A reasonable accommodation is a change, exception or adjustment to a rule, policy, practice
or service while a reasonable modification is a structural change made to the premises while. For
example, a reasonable accommodation would include making an exception to an existing ‘no pet’ rule to
permit a service dog. A reasonable modification could include installing a ramp for an individual who
uses a wheelchair or grab bars in the bathroom.
Landlords are required to make “reasonable accommodations” to rules and policies to accommodate a
tenant’s disability. According to a HUD-DOJ Statement, requests for reasonable accommodations can
be denied when:
July 14, 2020 Item #6 Page 50 of 211
“…the request was not made by or on behalf of a person with a disability or if there is
no disability related need for the accommodation. [And]… if it would impose an undue
financial and administrative burden on the housing provider or it would fundamentally
alter the nature of the provider's operations.”9
In regard to reasonable modifications, landlords must allow a tenant with physical disabilities to make
"reasonable modifications" to the unit in order to address accessibility issues. According to the
HUD_JOJ Statement,
“A person with a disability must have the housing provider’s approval before making the
modification. However, if the person with a disability meets the requirements under the
Act for a reasonable modification and provides the relevant documents and assurances,
the housing provider cannot deny the request.”10
In privately owned properties, the tenant is responsible for the costs of modifications. In government
subsidized housing (Section 504, housing set up for those with disabilities, etc.), the housing provider
typically pays for the modification unless it is an undue administrative or financial burden.
While housing discrimination is not covered by the ADA, the Fair Housing Act prohibits housing
discrimination against persons with disabilities. In their 2019 Fair Housing Trends Report, the National
Fair Housing Alliance indicated that disability complaints were the most prevalent type of housing
discrimination complaint (56.3 percent). The report stated that since complaints are usually based on
denial of a request to make reasonable accommodations or modifications for people with disabilities, or
because it involves a multi-family property that is not accessible in obvious ways that violate the Fair
Housing Act., discrimination based on disability easier to detect. Discrimination against persons with
disabilities also continues to be the largest category of complaints HUD receives each year (59.4 percent
in 2017).11
Federal laws define a person with a disability as "any person who has a physical or mental impairment
that substantially limits one or more major life activities; has a record of such impairment; or is regarded
as having such an impairment." In general, a physical or mental impairment includes hearing, mobility
and visual impairments, chronic alcoholism, chronic mental illness, AIDS, AIDS Related Complex, and
mental retardation that substantially limits one or more major life activities. Major life activities include
walking, talking, hearing, seeing, breathing, learning, performing manual tasks, and caring for oneself.12
9 Joint Statement of the U.S. Department of Housing and Urban Development and the U.S. Department of Justice on Reasonable
Accommodations Under the Fair Housing Act (2004) -Question 7.
https://www.justice.gov/sites/default/files/crt/legacy/2010/12/14/joint_statement_ra.pdf
10 Joint Statement of the U.S. Department of Housing and Urban Development and the U.S. Department of Justice on Reasonable
Modifications Under the Fair Housing Act (2008)-Question 16
https://www.hud.gov/sites/documents/reasonable_modifications_mar08.pdf
11 U.S. Department of Housing and Urban Development. “Annual Report on Fair Housing FY 2017-2018”. (2018).
12 U.S. Department of Housing and Urban Development. “Disability Rights in Housing.” (2014).
http://portal.hud.gov/hudportal/HUD?src=/program_offices/fair_housing_equal_opp/disabilities/inhousing. Accessed December
23, 2014.
July 14, 2020 Item #6 Page 51 of 211
The U.S. Census Bureau classifies disabilities into the following categories:
Hearing difficulty: Deaf or having serious difficulty hearing
Vision difficulty: Blind or having serious difficulty seeing, even when wearing glasses
Cognitive difficulty: Because of a physical, mental, or emotional problem, having difficulty
remembering, concentrating, or making decisions
Ambulatory difficulty: Having serious difficulty walking or climbing stairs
Self-care difficulty: Having difficulty bathing or dressing
Independent living difficulty: Because of a physical, mental, or emotional problem, having
difficulty doing errands alone such as visiting a doctor’s office or shopping
According to 2013-2017 ACS data, 312,565 persons living in San Diego County had a range of
disabilities, comprising 9.8 percent of the population. The largest age group of persons with disabilities
were seniors, comprising 45.9 percent of the population with disabilities, followed by adults (ages 18 to
64) which comprised 47.1 percent of the population. Children under the age of 18 made up about seven
percent of the population with disabilities. (Table 20). The cities of El Cajon, La Mesa, and Lemon
Grove had the highest proportion of residents with disabilities (13.3, 12.6, and 11.9 percent).
Figure 4 shows population density for persons with disabilities in San Diego County. Figure 4 shows
that although disabled persons are geographically dispersed throughout the more urbanized areas of the
county, there are significant areas with a high density of disabled residents that coincide with minority
concentration areas and RECAPs (Racially Concentrated Areas of Poverty). Specifically, concentrations
of disabled residents can be seen in the North County cities of Oceanside, Vista, San Marcos, and
Escondido, as well as the southern areas of the City of San Diego and southern cities near the
U.S/Mexico border. Due to the presence of residential care facilities, the City of San Diego and the
cities of El Cajon, La Mesa, and Lemon Grove also have concentrations of residents with disabilities.
The coastal and inland areas show less dense concentrations of residents with disabilities, which could
be due to the high price of housing (in the coastal areas) or the scarcity of facilities and services for
persons with disabilities (inland areas).
Of those disabilities tallied between 2013 and 2017 (as shown in Table 21), cognitive, ambulatory, and
independent living disabilities were the most prevalent. The senior population had a significantly larger
percentage of all disability types. San Diego County’s senior population will grow substantially in the
next 20 years. Since seniors have a much higher probability of having a disability, the housing and
service needs for persons with disabilities should grow considerably, commensurate with the projected
growth of this population.
As previously stated, there are approximately 593 State-licensed residential care facilities for the elderly,
401 adult residential facilities, and 60 adult day care facilities throughout the county. These licensed care
facilities have a combined capacity of just over 28,000 beds.
Persons with Developmental Disabilities: As defined by federal law, “developmental disability”
means a severe, chronic disability of an individual that:
July 14, 2020 Item #6 Page 52 of 211
Is attributable to a mental or physical impairment or combination of mental and physical
impairments;
Is manifested before the individual attains age 2213;
Is likely to continue indefinitely;
Results in substantial functional limitations in three or more of the following areas of major life
activity: a) self-care; b) receptive and expressive language; c) learning; d) mobility; e) self-
direction; f) capacity for independent living; or g) economic self- sufficiency; and
Reflects the individual’s need for a combination and sequence of special, interdisciplinary, or
generic services, individualized supports, or other forms of assistance that are of lifelong or
extended duration and are individually planned and coordinated.
According to the U.S. Administration on Developmental Disabilities (ADD), the percentage of the
population that can be defined as developmentally disabled is approximately 1.5 percent. The Census
does not specifically record developmental disabilities. However, using the ADD percentage to create an
estimate, based on the 2019 Department of Finance population estimates, this equates to just over
50,000 persons in the County of San Diego.
The San Diego Regional Center provides a range of services to persons with or affected by
developmental disabilities. Services include diagnostic and eligibility assessments, program planning,
case management, and other services and supports. The San Diego Regional Center has four offices in
the county and is one of 21 non-profit regional centers in California providing lifelong services and
support for people with developmental disabilities residing in San Diego and Imperial Counties. As of
June 2018, the Regional Center had just over 27,000 clients living in San Diego County. The ARC of San
Diego and Community Interface Services offer comprehensive services for persons or individuals with
developmental disabilities and their families, including diagnosis, counseling, coordination of services,
advocacy and community education/training.
13 The State of California defines developmental disabilities slightly differently than federal law. The main difference is at
the manifestation age, where California established that threshold at age 18.
July 14, 2020 Item #6 Page 53 of 211
Table 20: Disability by Age
Jurisdiction
0-5 Years 5-17 Years 18-64 Years 65+ Years Total
# % # % # % # % #
% of
Disabled
Population
% of
Total
Population
Urban County
Coronado - 0.0% 133 0.0% 527 0.2% 1,075 0.3% 1,735 0.6% 9.1%
Del Mar - 0.0% 33 0.0% 137 0.0% 175 0.1% 345 0.1% 8.0%
Imperial Beach 28 0.0% 128 0.0% 1,635 0.5% 1,162 0.4% 2,953 0.9% 11.2%
Lemon Grove 11 0.0% 245 0.1% 1,524 0.5% 1,540 0.5% 3,320 1.1% 12.6%
Poway 43 0.0% 403 0.1% 1,989 0.6% 2,488 0.8% 4,923 1.6% 10.0%
Solana Beach - 0.0% 51 0.0% 233 0.1% 577 0.2% 861 0.3% 6.5%
Unincorporated 136 0.0% 3,618 1.2% 25,375 8.1% 24,934 8.0% 54,063 17.3% 11.4%
Total Urban County 218 0.1% 4,611 1.5% 31,420 10.1% 31,951 10.2% 68,200 21.8% 11.1%
Entitlement Cities
Carlsbad 44 0.0% 493 0.2% 3,528 1.1% 4,998 1.6% 9,063 2.9% 8.1%
Chula Vista 40 0.0% 1,706 0.5% 10,733 3.4% 11,958 3.8% 24,437 7.8% 9.4%
El Cajon 25 0.0% 1,009 0.3% 7,341 2.3% 5,076 1.6% 13,451 4.3% 13.3%
Encinitas - 0.0% 390 0.1% 1,648 0.5% 3,324 1.1% 5,362 1.7% 8.6%
Escondido 23 0.0% 1,206 0.4% 8,508 2.7% 6,031 1.9% 15,768 5.0% 10.5%
La Mesa - 0.0% 541 0.2% 3,192 1.0% 3,171 1.0% 6,904 2.2% 11.9%
National City 11 0.0% 339 0.1% 2,793 0.9% 3,178 1.0% 6,321 2.0% 11.3%
Oceanside 72 0.0% 1,007 0.3% 9,212 2.9% 9,146 2.9% 19,437 6.2% 11.3%
San Diego 586 0.2% 8,186 2.6% 58,738 18.8% 55,120 17.6% 122,630 39.2% 9.0%
San Marcos - 0.0% 668 0.2% 3,039 1.0% 3,689 1.2% 7,396 2.4% 8.0%
Santee 10 0.0% 321 0.1% 3,198 1.0% 2,676 0.9% 6,205 2.0% 11.2%
Vista 9 0.0% 435 0.1% 3,819 1.2% 3,128 1.0% 7,391 2.4% 7.6%
Total County 1,038 0.3% 20,912 6.7% 147,169 47.1% 143,446 45.9% 312,565 100.0% 9.8%
Source: American Community Survey, 2013-2017.
July 14, 2020 Item #6 Page 54 of 211
Table 21: Disability Characteristics
Disability by Age and Type Under 18 to 64
Years
65 Years and
Over
% of Population with
Disability2
Hearing Difficulty 0.5% 1.3% 14.8% 27.9%
Vision Difficulty 0.6% 1.2% 6.7% 17.5%
Cognitive Difficulty 2.5% 3.1% 10.7% 39.6%
Ambulatory Difficulty 0.5% 3.2% 22.8% 51.1%
Self-Care Difficulty 0.9% 1.2% 9.4% 21.8%
Independent Living Difficulty1 -- 2.6% 18.1% 39.9%
Total County 3.5% 7.0% 35.9% --
Notes:
1: Tallied only for persons 18 years and over
2. Totals add up to more than 100 percent because person may have more than one type of disability.
Source: American Community Survey (ACS), 2013-2017.
July 14, 2020 Item #6 Page 55 of 211
Figure 4: Persons with Disabilities
July 14, 2020 Item #6 Page 56 of 211
5. Persons with HIV/AIDS14
The Fair Housing Amendments Act of 1988, which is primarily enforced by HUD, prohibits housing
discrimination against persons with disabilities, including persons with HIV/AIDS. California has the
largest number of HIV and third largest number of AIDS cases in the United States; San Diego County
has the third largest number of people living with HIV and AIDS in California. Since the HIV epidemic
began in 1981, nearly 30,785 HIV or AIDS cases have been reported in San Diego County. New drugs,
better treatment, and preventative education have reduced the number of fatalities. Persons with
HIV/AIDS are living longer.
Of 13,643 PLWHA in San Diego County as of December 2016, 7,395 were diagnosed within the county
(Table 23). The City of San Diego had the greatest proportion of diagnoses (67.8 percent), followed by
Chula Vista (6.5 percent) and Oceanside (3.2 percent). Trailing behind were the communities in
unincorporated areas, where only 2.7 percent of the county’s PLWHA were diagnosed.
Individuals diagnosed with HIV or AIDS in San Diego County are most commonly white, male, more
than 49 years of age, and have had male-to-male sexual contact. Over the course of the epidemic, there
has been a slow increase in the proportion of cases affecting people of color. The percentage of people
of color who have been diagnosed with HIV disease has continued to increase over time, from 28
percent in the 1980s to 53 percent in 2016. The average age of HIV diagnosis has also increased from 34
years in 2007-2011 to 36 by 2012-2016. In 2016, 499 new HIV diagnoses were reported in the county,
which is near the lower end of the overall range of cases reported annually since 2007 (481-619 cases).
The primary source of funding for HIV/AIDS housing is HUD’s Housing Opportunities for Persons
with AIDS (HOPWA) program. The City of San Diego is the HOPWA program grantee, but all
HOPWA programs are administered by the County of San Diego Department of Housing and
Community Development (HCD). Established in 1992, the HOPWA program is designed to provide
States and localities with resources and incentives to develop long-term comprehensive strategies that
meet the housing and housing-related support service needs of low-income persons living with
HIV/AIDS or related diseases and their families. In FY 2020 (HUD PY 2019) , the City of San Diego’s
Annual Action Plan included a $5.1 million budget for HOPWA programs ($4.2 million from the 2019
Program Year entitlement allocation and $1.4 million from prior year funds). Programs funded through
the HOPWA must be housing related and designed to15:
Provide affordable housing for low-income persons living with HIV/AIDS and their families;
Enable low-income persons living with HIV/AIDS and their families to become housed;
Provide services needed to enable low-income HIV/AIDS clients to remain housed, locate
housing, and prevent homelessness.
Several HOPWA-funded housing resources (Table 23) are in place; however, there are many more
people looking for housing than there are units available, particularly affordable housing units.
14 All statistics in Persons with HIV/AIDS section are taken from the “HIV/AIDS Epidemiology Report 2016” (County
of San Diego Health and Human Services Agency, 2016) unless otherwise noted.
15 City of San Diego, Fiscal Year 2020-2024 Consolidated Plan. (2019)
July 14, 2020 Item #6 Page 57 of 211
Table 22: People living with HIV and AIDS (PLWHA)
City/Community CPLWHA2 Percent
Urban County
Coronado 21 0.3%
Del Mar <20 -
Imperial Beach 48 0.6%
Lemon Grove 53 0.7%
Poway 26 0.4%
Solana Beach <20 -
Unincorporated 202 2.7%
Entitlement Cities
Carlsbad 88 1.2%
Chula Vista 478 6.5%
El Cajon 183 2.5%
Encinitas 37 0.5%
Escondido 125 1.7%
La Mesa 105 1.4%
National City 136 1.8%
Oceanside 239 3.2%
San Diego 5,014 67.8%
San Marcos 53 0.7%
Santee 57 0.8%
Vista 122 1.6%
Other3 195 2.6%
Other4 213 2.9%
Total County 7,395 100.0%
Notes:
1. Place of residence at time of diagnosis does not represent
the place of HIV diagnosis/exposure.
2. Of those known to be diagnosed with HIV in San Diego
County and currently living in San Diego County through
12/31/2016.
3. Other communities: San Ysidro, La Jolla, and Camp
Pendleton
4. Communities with <5 recent cases or <20 PLWHA:
Alpine, Bonsall, Borrego Springs, Boulevard, Campo,
Camp Pendleton, Cardiff-by-the-Sea, Del Mar, Jamul,
Julian, Pala, Pauma Valley, Rancho Bernardo, Rancho
Santa Fe, Santa Ysabel, Solana Beach, Valley Center,
Warner Springs.
Source: HIV/AIDS Epidemiology Report 2016. County of San
Diego Health and Human Services Agency.
July 14, 2020 Item #6 Page 58 of 211
Table 23: HOPWA Program Resources
Agency/Program Units/Program
Capacity
Emergency Housing
Townspeople - Provides emergency beds in the form of hotel/motel vouchers for up to 21
nights. 4,120
Licensed Care Facility
Fraternity House, Inc. - Provides 18 beds through Fraternity House (8) and Michaelle
House (10) for consumers who need 24-hour comprehensive care. 20
Recovery Housing
Stepping Stone of San Diego - Provides 15 beds through its Residential Treatment Program
located in the City Heights area in San Diego. 6
Transitional Group Home
St. Vincent de Paul Village, Inc. - Provides 38 beds through its five Josue Homes for
consumers who are ambulatory, self-sufficient and recovering substance abusers. 88
Stepping Stone of San Diego - Provides 17 beds through Enya House for consumers who
have a minimum of 60 days sobriety and a commitment to long term recovery. 17
Permanent Housing
Community Housing Works/Marisol Apartments - 10 units in Oceanside for consumers
and their families. Support services are provided. 10
Community Housing Works/Old Grove - 4 units in Oceanside for consumers and their
families. Support services are provided. 4
Mariposa Apartments - 2 units in San Marcos for consumers and their families. 2
Mercy Gardens - 23 units in the Hillcrest area in San Diego for consumers and their
families. 23
Paseo del Oro Apartments - 5 units in San Marcos for consumers and their families. 5
Shadow Hills - 5 units in Santee for consumers and their families. 5
Sierra Vista Apartments - 5 units in San Marcos for consumers and their families. 5
South Bay Community Services/La Posada - 12 units in San Ysidro for consumers and their
families. Case management and support services are provided. 12
Sonoma Court Apartments - 2 units in Escondido for consumer and their families. 2
Spring Valley Apartments - 9 units in Spring Valley for consumers and their families. 9
The Center- Sunburst Apartments - 3 units for consumers who are between 18 -24 years of
age. 3
Townspeople – 34th Street Apartments - 24 units in San Diego for consumers and their
families. Case Management services are provided. 524
Townspeople – Vista del Puente Apartments - 12 units in San Diego for consumers and
their families. Case Management services are provided. 12
Townspeople – 51st Street Apartments - 3 units in San Diego for consumers and their
families. Case Management services are provided. 3
Townspeople – Wilson Avenue Apartments - 4 units in San Diego for consumers and their
families. Case Management services are provided. 4
Tenant Based Rental Assistance
County of San Diego, Housing and Community Development (HCD) – Program provides rent
subsidies/vouchers for up to 80 consumers. Applicants are placed on a waiting list and preference is
given to extremely low-income households with at least one family member having an AIDS diagnosis.
80
August 2019. County of San Diego Health & Human Services Agency, August 2019.
July 14, 2020 Item #6 Page 59 of 211
6. Homeless
While homelessness is not a protected class, homeless persons are likely to belong to a protected class
(e.g. Medical condition, disability). HUD defines homelessness in the following categories:
Category 1 (Literally Homeless): Individual or family who lacks a fixed, regular, and adequate
nighttime residence.
Category 2 (Imminent Risk of Homelessness): Individual or family who will imminently lose
their primary nighttime residence.
Category 3 (Homeless under Other Federal Assistance): Unaccompanied youth under 25
years of age, or families with Category 3 children and youth, who do not otherwise qualify as
homeless under this definition.
Category 4 (Fleeing/Attempting to Flee Domestic Violence): Any individual or family who
is fleeing, or is attempting to flee, domestic violence; has no other residence; and lacks the
resources or support networks to obtain other permanent housing.
This definition demonstrates the diversity of people
experiencing homelessness. The numerous places where
people experiencing homelessness can be located complicate
efforts to accurately estimate their total population. For
example, an individual living with friends on a temporary
basis could be experiencing homelessness, but would be
unlikely to be identified in a homeless count. Since 2006, the
San Diego Regional Task Force on the Homeless (RTFH)
has conducted a point-in-time survey (PIT) to measure the
county’s homeless population, as well as to identify the needs
of persons experiencing homelessness. The 2019 San Diego
Regional Homeless Point-In-Time Count took place on the
night of January 25, 2019. The 2019 PIT count identified
8,102 homeless persons living in San Diego County (Table 24). Of the homeless persons counted, more
than half (54.6 percent) were unsheltered – living in a place not meant for human habitation, while 24.8
percent were in an emergency shelter and 19.2 percent in a transitional housing program. When
examining the different sub-regions within San Diego County, the City of San Diego had the largest
proportion of the homeless persons (63.4 percent), followed by El Cajon with 9.8 percent of the
region’s homeless persons.
Since 2014, the total number of sheltered and unsheltered homeless persons enumerated during the
annual PIT decreased by approximately five percent. Despite the overall decrease in homeless persons,
the proportion of unsheltered persons has increased by 8.4 percentage points. The number of homeless
persons sheltered on the selected night decreased by 20 percent over the five-year period (4,521 in 2014
to 3,635 in 2019), while the number of unsheltered homeless persons counted increased by 12.3 percent
(3,984 in 2014 to 4,476 in 2019). Many homeless service providers attributed the overall decrease to the
new “Housing First” model and the Continuum of Care system (described later). This approach
recognizes many people cannot to address their other issues (e.g., employment, health, and emotional)
until they have a more stable housing arrangement.
Fair Housing Also Applies to Homeless
Shelters
In 2013, the U.S. Department of Housing and
Urban Development (HUD) charged a
homeless shelter in Pennsylvania and one of
its employees with refusing to accept a blind
man and his guide dog at a homeless
shelter. HUD’s investigation found that the
homeless man was denied a reasonable
accommodation request to allow the man to
keep his dog in the shelter, in violation of the
Fair Housing Act.
July 14, 2020 Item #6 Page 60 of 211
The point-in-time count is just a snapshot of how many homeless people are on streets and in
emergency and transitional shelters on any given day in the San Diego region. RTFH estimated that over
the course of the year more than 20,000 people experience homelessness in San Diego County.
In addition, the 2019 PIT count used new methodology under HUD guidance “to survey a higher
percentage of those experiencing homelessness where you meet them and to count people rather than
structures or vehicles.” 16 The change in methodology resulted in changes in the PIT counts from
previous years.
Table 24: Homelessness Population by Jurisdiction – 2018 and 2019
Jurisdiction
2018 2019
Sheltered Unsheltered Total % of
County Sheltered Unsheltered Total % of County
Urban County
Coronado 0 6 6 0.1% 0 1 1 0.0%
Del Mar* 0 3 3 0.0% -- 6-- 6-- --
Imperial Beach 0 20 20 0.2% 0 12 12 0.1%
Lemon Grove 0 52 52 0.6% 0 35 35 0.4%
Poway 0 15 15 0.2% 0 9 9 0.1%
Solana Beach* 0 0 0 0.0% -- -- 4-- --
Unincorporated 6 445 451 5.3% 0 224 224 2.8%
Entitlement Cities
Carlsbad 58 152 210 58 59 102 161 2.0%
Chula Vista 108 229 337 108 79 242 321 4.0%
El Cajon 391 288 679 391 489 298 787 9.8%
Encinitas 39 86 125 39 41 79 120 1.5%
Escondido 148 263 411 148 109 241 350 4.4%
La Mesa 29 12 41 29 0 46 46 0.6%
National City 32 201 233 32 0 94 94 1.2%
Oceanside 157 326 483 157 202 193 395 4.9%
San Diego 2,282 2,630 4,912 2,282 2,482 2,600 5,082 63.4%
San Marcos 0 62 62 - 0 46 46 0.6%
Santee 0 46 46 - 0 35 35 0.4%
Vista 336 154 490 336 174 122 296 3.7%
Total County 3,586 4,990 8,576 3,586 3,635 4,379 8,014 100.0%
Notes: The 2019 San Diego Regional Homeless Profile indicate 8,102 persons enumerated in the Point-in-Time Count. The data
presented in the report indicates only 8,014.
* Del Mar and Solana Beach counts reported under the Encinitas community totals.
Source: San Diego Regional Taskforce on the Homeless 2019 Annual Report on Homelessness in the San Diego Region.
16 San Diego Regional Taskforce on the Homeless 2019 Annual Report on Homelessness in the San Diego Region.
July 14, 2020 Item #6 Page 61 of 211
Formerly homeless persons often have a very difficult time finding housing once they have moved from
transitional housing or other assistance programs. Housing affordability for those who were formerly
homeless is challenging from an economics standpoint, but this demographic group may also encounter
fair housing issues when property owners/managers refuse to rent to formerly homeless persons. The
perception may be that they are more economically (and sometimes mentally) unstable. Homeless
persons may also experience discrimination in homeless shelters. This can occur in the form of
discrimination based on protected classes, rules or policies with a disparate impact on a protected class,
or lack of reasonable accommodation.
A variety of public and nonprofit agencies in San Diego County also offer services to assist individuals
and families in obtaining and maintaining adequate housing, including those who are currently homeless
as defined by HUD and formerly homeless persons. These agencies administer programs that include
rental assistance, housing rehabilitation, shared housing, public housing, and home purchasing
assistance.
7. Farm Workers
As traditionally defined, farm workers are persons whose primary incomes are earned through
permanent or seasonal agricultural labor. Permanent farm workers tend to work in fields or processing
plants. During harvest periods when workloads increase, the need to supplement the permanent labor
force is satisfied with seasonal workers. Often these seasonal workers are migrant workers, defined by
the inability to return to their primary residence at the end of the workday. Determining the actual
number of farm workers in a region is difficult due to the variability of the definitions used by
government agencies and other peculiarities endemic to the farming industry. Agricultural work can
include weeding, thinning, planting, pruning, irrigation, tractor work, pesticide applications, harvesting,
transportation to the cooler or market, and a variety of jobs at packing and processing facilities.
According to 2013-2017 ACS data, just over 8,300 residents of San Diego County were employed in
farming, fishing, or forestry occupations. Estimates provided by other governmental agencies include
8,700 (Total Farm Employment, California Employment Development Department, 2019). The number
of farm workers, however, varies depending upon the different growing seasons. The numbers can
change quickly as more work becomes available. This population remains highly migratory, following
the work as it becomes available and even returning home for short periods during the off-season.
Just under one-third of the estimated farm worker population is located in the unincorporated county
areas. The Cities of Escondido, Vista, and San Diego had the greatest proportions of farm worker
population (17.8 percent for Escondido and San Diego, 13.5 percent in Vista).. The geographic
distribution of farm workers in San Diego County generally corresponds with agricultural production
areas. According to the California Department of Conservation’s farmland maps, agricultural production
in the county is concentrated in the unincorporated north inland areas of the county around Interstate
15, north of the cities of Vista, San Marcos, and Escondido, and west of the Cleveland National Forest
areas. County land use data also indicated that most agricultural activity consists of orchards and
vineyards or field crops. Only a small portion of agricultural land is used for intensive agricultural uses.
July 14, 2020 Item #6 Page 62 of 211
Table 25: Farm Worker Population of San Diego County
Jurisdiction # of
Persons
Percent of All Persons
Employed in Farming,
Fishing, and Forestry
Occupations
Urban County
Coronado 0 0.0%
Del Mar 0 0.0%
Imperial Beach 0 0.0%
Lemon Grove 22 0.3%
Poway 0 0.0%
Solana Beach 33 0.4%
Unincorporated 2,540 30.6%
Total Urban County 2,595 31.2%
Entitlement Cities
Carlsbad 125 1.5%
Chula Vista 190 2.3%
El Cajon 64 0.8%
Encinitas 39 0.5%
Escondido 1,477 17.8%
La Mesa 73 0.9%
National City 92 1.1%
Oceanside 640 7.7%
San Diego 1,478 17.8%
San Marcos 405 4.9%
Santee 10 0.1%
Vista 1,120 13.5%
Total County 8,308 100.0%
Source: American Community Survey (ACS), 2013-2017.
Although there exists little consensus as to the number of farm workers in San Diego County, analysis
reveals that this group has special housing needs. According to San Diego County’s 2017 Housing
Element Background Report, farmworker housing constitutes a critical housing need in the
unincorporated area due to the year-round agricultural production that generates a permanent presence
of farm labor force. The median size of a farm San Diego County is less than 10 acres. These small,
non-traditional farms often employ temporary workers but are not large enough to accommodate on-
site farmworker housing. These rural homeless persons typically reside in camps located throughout the
county. These encampments are generally small in size and are frequently at the edge of their employer’s
property in fields, hillsides, canyons, ravines, or riverbeds. According to the Regional Task Force on the
Homeless (RTFH), most of these homeless workers are undocumented immigrants whose families
reside elsewhere.17 Due to the migratory nature of these farmworkers, the camps typically are temporary
establishments and are not legally permitted. Consequently, this population is often under-counted. The
17 Regional Homeless Profile October 2006, Regional Task Force on the Homeless, http://www.rtfhsd.org/docs_profile/unincorporated.doc. As cited in the 2017 Housing Element Background Report.
July 14, 2020 Item #6 Page 63 of 211
RTFH reports that much of the recent information they have acquired is anecdotal and that camps have
been dwindling.
California Employment Development Department (EDD) estimates that the average salary for farm
workers and laborers working in the Farming, Fishing, and Forestry Occupations in the San Diego-
Carlsbad-San Marcos MSA in 2019 was approximately $32,872, less than half of the average $68,049 for
full-time, year-round workers with earnings. Given the relatively low incomes of farmworker
households, an increasingly important need for the permanently employed farmworkers is affordable
rental housing.. Low wages, high housing costs, and seasonal nature of this occupational category
means many farm workers are homeless at their place of employment while their families may reside
elsewhere.
Farm workers can benefit from programs and services that provide assistance to lower and moderate-
income households in general, such as the Housing Choice Voucher program, which offers rental
assistance to residents. According to the County of San Diego Housing Resources Directory 2020, one
development in the City of San Marcos (Firebird Manor) and one in Fallbrook (Fallbrook View
Apartments) provide 98 units of affordable housing for farm workers and their families. In addition, 40
affordable units at Old Grove Apartments in the City of Oceanside are reserved for farm workers and
and/or Day Laborers.
8. Military Personnel and Veterans
San Diego is one of the largest military regions in the United States. The county is the third largest in the
U.S. in terms of veteran residents, and the number one destination for veterans returning from Iraq and
Afghanistan as of 2013.18 San Diego County has a strong military personnel presence due to the various
large military bases, including Naval Air Station North Island, Naval Station San Diego, Naval Base
Point Loma, Marine Corps Air Station Miramar, and Marine Corps Base Camp Pendleton. The military
population increases the demand for low-cost rental housing. Military personnel generally earn lower
incomes and their length of residency is often uncertain. Although the need is partially met by the supply
of military housing, the demand outweighs the supply. Eligibility for military housing is based on pay
grade (which is based on rank) and family size. In addition to housing concerns, veterans may
experience specific difficulties when reintegrating into the civilian labor force. These include: trouble
translating military experience to civilian work, lack of resume, job search, and interview experience;
time needed to “decompress;” and health issues (physical and mental) from military service.19
Although one percent of the U.S. population lives in San Diego County, the region is home to more
than five percent of the active duty U.S. military population. Approximately 143,000 active duty
personnel are stationed in San Diego County. The 2013-2017 ACS data estimates that veterans made up
seven percent (225,694 persons) of the population in the county. The City of San Diego was home to a
plurality of the regional veteran population (40 percent).
18 County of San Diego and San Diego Regional Chamber of Commerce, “Military Employment in San Diego” (January
2013).
19 Id.
July 14, 2020 Item #6 Page 64 of 211
Due to the region’s high cost of living, many families at the lower range of pay and housing allowance
barely meet the California Family Needs Standard20 (formerly the Self-Sufficiency Standard) for San
Diego. The Family Needs Calculator measures the minimum income necessary to cover all of a non-
elderly (under 65 years old) and non-disabled individual or family’s basic expenses – housing, food, child
care, health care, transportation, and taxes – without public or private assistance. According to the
Calculator, 35 percent of households in San Diego County live below the “standard.” The 2019 Regional
Homeless Profile estimates that six percent (446 persons) of all homeless adult persons in San Diego
(8,102 persons), at a single point in time, were veterans of the U.S. Armed Forces and nearly half of the
homeless veterans were chronically homeless.21
Housing and supportive service needs for military personnel are addressed by the Department of
Defense, while the needs of veterans are addressed at the community level. The Veteran Services
division of the County’s Health and Human Services Agency provides benefit information and
assistance, plus other support to San Diego County veterans and their families. Services offered through
Veterans Services includes comprehensive benefits counseling, claims preparation and submission,
claims follow-up to ensure final decisions, initiation and development of appeals, and networking and
advocacy with federal, state and local agencies.
The Veteran’s Village of San Diego (VVSD) provides a continuum of care with a full range of
comprehensive and innovative services for military veterans. VVSD has five locations throughout San
Diego County where they provide services to more than 3,000 military veterans annually.
D. Hate Crimes
Hate crimes – violent acts against people, property, or organizations motivated by a bias related to
victim’s race, ethnicity, religion, gender, sexual orientation, national origin, or physical or mental
disability – become a fair housing concern when residents are intimidated or harassed at their residence
or neighborhood. Fair housing violations due to hate crimes also occur when people will not consider
moving into certain neighborhoods or have been run off from their homes for fear of harassment or
physical harm. The federal Fair Housing Act makes it illegal to threaten, harass, intimidate or act
violently toward a person who has exercised their right to free housing choice. Persons who break the
law have committed a serious crime and can face time in prison, large fines or both, especially for
violent acts, serious threats of harm, or injuries to victims. In addition, this same behavior may violate
similar state and local laws, leading to more punishment for those who are responsible. Some examples
of illegal behavior include threats made in person, writing or by telephone; vandalism of the home or
property; rock throwing; suspicious fires, cross-burning or bombing; or unsuccessful attempts at any of
these. The Matthew Shepard and James Byrd, Jr. Hate Crimes Prevention Act of 2009 greatly expanded
the federal government’s ability to prosecute hate crimes without having to show that the defendant was
engaged in a federally protected activity. The Shepard-Byrd Act also empowers the department to
prosecute crimes committed because of a person’s sexual orientation, gender identity, gender or
disability as hate crimes.
20 The Self-Sufficiency Standard for California, 2018. Center for Women’s Welfare, University of Washington. Based on
U.S. Census Bureau, 2016 American Community Survey 1-Year Public Use Microdata Sample.
21 San Diego Regional Taskforce on the Homeless, “2019 San Diego Regional Homeless Profile”.
July 14, 2020 Item #6 Page 65 of 211
The FBI’s Uniform Crime Reporting (UCR) Program releases Hate Crime Statistics annually. Table 26
shows that 71 hate crimes were reported in San Diego County in 2018. The jurisdiction with the largest
number of hate crimes was the City of San Diego (40 cases). More than half of reported hate crimes
appear to have been motivated by the victim’s race, ethnicity, or ancestry. Close to a quarter of reported
hate crimes appear to be motivated by the victim’s sexual orientation and another 23 percent of hate
crimes by religion. However, observations by staff and service providers indicated a spike in hate crimes
by religion in 2019.
Hate crimes of all motivations have declined in San Diego region by 28 percent between 2013 and 2018
(Figure 5). However, reporting hate crimes is voluntary on the part of the local jurisdictions. Some
states started submitting data only recently, and not all jurisdictions are represented in the reports. Many
jurisdictions across the country, including those with well-documented histories of racial prejudice,
reported zero hate crimes. Another obstacle to gaining an accurate count of hate crimes is the
reluctance of many victims to report such attacks.
However, the incidence of hate crimes appear to be increasing since 2018. While 2019 crime reports
have not been published as of April 2020, some jurisdictions reported an increase in hate crimes based
on religion in 2019. A study by the California State University of San Bernardino reported 15 hate
crimes on between January 1 and May 31 in the City of San Diego with religion being the top bias for
these hate crimes22. In addition, on April 2020, the San Diego County District Attorney launched a hate
crime online reporting form and hotline in response to reported incidents of hate crimes against Asian
Americans as a result of COVID-19. Whether these are situational upticks or the beginning of trends
remains to be seen.23
Figure 5: Change in Hate Crimes between 2013 and 2018
Source: U.S. Federal Bureau of Investigation, Hate Crime Statistics, 2018.
22 Center for the Study of Hate and Extremism. “Factbook on hate & extremism in the U.S. & internationally” (2019). California State
University of San Bernardino.
23 City News Service. “DA launches hate crime hotline due to incidents against Asians during pandemic” (April 30, 2020). Fox 5 News
San Diego.
-33.3%
-15.8%
-26.1%
0.0%
0.0%
0.0%
-28%
-35.0%-30.0%-25.0%-20.0%-15.0%-10.0%-5.0%0.0%
Race/Ethnicity/Ancestry
Religion
Sexual Orientation
Disability
Gender
Gender identity
Total
July 14, 2020 Item #6 Page 66 of 211
Table 26: Hate Crime Statistics – 2018
Jurisdiction
Race/
Ethnicity/
Ancestry
Religion Sexual
Orientation Disability Gender Gender
Identity Total
Urban County Cities
Coronado 0 0 0 0 0 0 0
Del Mar 0 0 0 0 0 0 0
Imperial Beach 1 0 0 0 0 0 1
Lemon Grove 0 0 0 0 0 0 0
Poway 0 1 0 0 0 0 1
Solana Beach 0 0 0 0 0 0 0
Entitlement Jurisdictions
Carlsbad 4 2 0 0 0 0 6
Chula Vista 1 1 0 0 0 0 2
El Cajon 3 0 1 0 0 0 4
Encinitas 0 3 0 0 0 0 3
Escondido 2 0 0 0 0 0 2
La Mesa 1 0 0 0 0 0 1
National City 0 0 0 0 0 0 0
Oceanside 2 0 0 0 0 0 2
San Diego 20 8 12 0 0 0 40
San Marcos 1 0 0 0 0 0 1
Santee 1 0 0 0 0 0 1
Vista 0 0 1 0 0 0 1
San Diego County 2 1 3 0 0 0 6
Total County 38 16 17 0 0 0 71
Percentage 53.5% 22.5% 23.9% 0.0% 0.0% 0.0% 100.0%
Note: Hate Crime Statistics, 2018 includes data about bias-motivated incidents reported by law enforcement agencies throughout the
nation. However, no estimates are included for agencies that do not submit reports.
Source: U.S. Federal Bureau of Investigation, Hate Crime Statistics, 2018.
July 14, 2020 Item #6 Page 67 of 211
E. Income Profile
Household income is the most important factor determining a household’s ability to balance housing
costs with other basic life necessities. Regular income is the means by which most individuals and
families finance current consumption and make provision for the future through saving and investment.
The level of cash income can be used as an indicator of the standard of living for most of the
population. While economic factors that affect a household’s housing choice are not a fair housing issue
per se, the relationships among household income, household type, race/ethnicity, and other factors
often create misconceptions and biases that raise fair housing concerns.
1. Median Household Income
The 2013-2017 ACS data shows that the median household income for San Diego County was $70,588.
Approximately 36 percent of the county’s households earned less than $50,000, nearly 30 percent earned
between $50,000 and $99,999 and 35 percent earned more than $100,000 between 2013 and 2017
(Figure 6).
Median income between 2013 and 2017 ranged from a high of $122,563 in Del Mar to a low of $43,168
in National City (Table 27). Areas with high median household incomes are found along the coastal
cities of Del Mar and Solana Beach and in Poway. The income gap between cities can be attributed to
many factors, including the high cost of housing on the coast, the cities with lower incomes having
significantly younger residents, having fewer professional and management employees, or having more
students.
Many of the cities with lower median incomes are also cities with a higher proportion of non-white
population. For instance, the percent minority population in the jurisdictions with the lowest median
incomes Imperial Beach, El Cajon, and National City is 69, 44, and 90 percent, respectively. As stated
earlier in this chapter, the median income for Black, Hispanic American Indian, and Alaska Native
households was less than 75 percent of the county median while Asian and White household median
incomes were 125 and 114 percent of the county median income. In another example, per capita income
for Black, Asian, and Hispanic households was five, 12 and 33 percent respectively of the county per
capita income, compared with White, non-Hispanic households who earned 46 percent of the county
per capita income from 2013 to 2017.
According to 2013 and 2017 ACS data, the median income in the county appears to have risen both in
absolute terms and when adjusted for inflation (Table 27). Median county income jumped from $62,962
to $70,588 between 2013 and 2017, a 12-percent gain in absolute terms. However, adjusting the 2013
income to 2017, the number becomes $66,602, with a resulting change to a 6-percent increase. Even
when adjusted for inflation, most cities saw an increase in median income, except for Imperial Beach
which experienced a modest decline of approximately four percent during this period.24 However, based
on Figure 6, it appears that median income increases are due to the increase in the proportion of
households earning more than $100,000.
24 Inflation calculated with U.S. Department of Labor, Bureau of Labor Statistics inflation calculator
https://data.bls.gov/cgi-bin/cpicalc.pl
July 14, 2020 Item #6 Page 68 of 211
Figure 6: San Diego County Household Income
Source: American Community Survey (ACS), 2006-2010, 2013-2017.
Less than 25,000 25,000 to $49,999 $50,000 to
$74,999
$75,000 to
$99,999 >$100,000
2013 18.9%21.4%17.2%13.1%29.4%
2017 16.4%19.4%16.8%12.9%34.5%
0.0%
5.0%
10.0%
15.0%
20.0%
25.0%
30.0%
35.0%
40.0%
July 14, 2020 Item #6 Page 69 of 211
Table 27: Median Household Income
Jurisdiction
Median
Household
Income
2013
(Not Adjusted for
Inflation)
Median
Household
Income
2013
(In 2017 Inflation-
Adjusted Dollars)
Median
Household
Income
(2017)
% Change
2013-2017
(Inflation-
Adjusted
Dollars)
Urban County
Coronado $91,103 $96,371 $99,641 3.4%
Del Mar $107,457 $113,670 $122,563 7.8%
Imperial Beach $49,268 $52,117 $49,950 -4.2%
Lemon Grove $51,496 $54,474 $60,309 10.7%
Poway $93,856 $99,283 $102,338 3.1%
Solana Beach $86,451 $91,450 $103,864 13.6%
Entitlement Jurisdictions
Carlsbad $83,908 $88,760 $102,722 15.7%
Chula Vista $64,801 $68,548 $70,197 2.4%
El Cajon $44,112 $46,663 $49,445 6.0%
Encinitas $91,795 $97,103 $103,842 6.9%
Escondido $49,362 $52,216 $58,834 12.7%
La Mesa $53,605 $56,704 $59,629 5.2%
National City $37,933 $40,126 $43,168 7.6%
Oceanside $58,153 $61,515 $61,778 0.4%
San Diego $64,058 $67,762 $71,535 5.6%
San Marcos $53,657 $56,759 $70,417 24.1%
Santee $70,899 $74,998 $81,430 8.6%
Vista $47,346 $50,084 $59,833 19.5%
Total County $62,962 $66,602 $70,588 6.0%
State of California $61,094 $64,626 $67,169 3.9%
Source: Community Survey (ACS), 2009-2013 and 2013-2017; U.S. Department of Labor, Bureau of Labor Statistics.
2. Income Distribution
HUD periodically receives "custom tabulations" of Census data from the U.S. Census Bureau that are
largely not available through standard Census products. The most recent estimates are derived from the
2012-2016 ACS. These data, known as the "CHAS" data (Comprehensive Housing Affordability
Strategy), demonstrate the extent of housing problems and housing needs, particularly for low-income
households. The CHAS cross-tabulates the Census data to reveal household income in a community in
relation to the Area Median Income (AMI).
For purposes of most housing and community development activities, HUD has established four
income categories based on the Area Median Income (AMI) for the Metropolitan Statistical Area (MSA).
HUD income definitions differ from the State of California income definitions. Table 28 compares the
HUD and State income categories. This AI report is a HUD-mandated study and therefore HUD
income definitions are used.
July 14, 2020 Item #6 Page 70 of 211
Table 28: Income Categories
HUD Definition State of California (HCD)
Extremely Low Income Less than 30% of AMI Extremely Low Income Less than 30% of AMI
Low Income 31-50% of AMI Very Low Income 31-50% of AMI
Moderate Income 51-80% of AMI Low Income 51-80% of AMI
Middle/Upper Income Greater than 80% of AMI Moderate Income 81-120% of AMI
Above Moderate Income Greater than 120% of AMI
Source: Department of Housing and Urban Development and California Department of Housing and Community Development, 2013.
Table 29: Income Distribution, 2012-2016
Jurisdiction Total
Households
Extremely Low
Income
(0-30%)
Low Income
(31-50%)
Moderate
Income
(51-80%)
Middle/Upper
Income
(80%+)
Urban County
Coronado 8,980 8.6% 9.4% 14.0% 67.9%
Del Mar 2,260 16.4% 4.0% 2.2% 77.4%
Imperial Beach 9,045 20.6% 18.4% 23.0% 38.0%
Lemon Grove 8,465 14.7% 16.5% 21.8% 47.0%
Poway 15,800 8.7% 8.9% 12.9% 69.5%
Solana Beach 5,750 7.6% 7.7% 12.2% 72.5%
Entitlement Jurisdictions
Carlsbad 42,925 10.5% 7.5% 11.2% 70.8%
Chula Vista 77,810 15.7% 13.7% 18.4% 52.3%
El Cajon 32,940 24.8% 17.8% 19.1% 38.3%
Encinitas 23,690 9.9% 9.3% 9.6% 71.1%
Escondido 45,220 18.6% 18.4% 19.1% 43.8%
La Mesa 23,770 15.2% 14.6% 19.9% 50.4%
National City 15,860 29.1% 18.1% 23.3% 29.5%
Oceanside 61,475 16.1% 13.7% 21.0% 49.2%
San Diego 490,220 15.1% 12.2% 16.6% 56.1%
San Marcos 29,125 16.6% 14.4% 18.3% 50.7%
Santee 19,520 9.1% 10.0% 18.8% 62.1%
Vista 30,635 16.5% 18.8% 21.2% 43.5%
Total County 1,103,125 15.1% 13.0% 17.4% 54.4%
Note: Data presented in this table is based on special tabulations from sample Census data. The number of households in
each category usually deviates slightly from the 100% count due to the need to extrapolate sample data out to total
households. Interpretations of this data should focus on the proportion of households in need of assistance rather than
on precise numbers.
Source: HUD Comprehensive Housing Affordability Strategy (CHAS) Data, 2012-2016.
July 14, 2020 Item #6 Page 71 of 211
3. Income by Household Type and Race/Ethnicity
Household income often varies by household type and tenure. As shown, in Table 30, the majority of
the City’s extremely low, low, and moderate-income households experienced at least one housing
problem and cost burden. As defined by CHAS, housing problems include:
Units with physical defects (lacking complete kitchen or bathroom);
Overcrowded conditions (housing units with more than one person per room);
Housing cost burden, including utilities, exceeding 30 percent of gross income; and
Severe housing cost burden, including utilities, exceeding 50 percent of gross income.
Renter households were also disproportionately affected with housing problems. The percentage of
owner households with housing problems was 35.1 percent between 2012 and 2016, compared to the
56.8 percent of renter households. When comparing by household types, a greater proportion of renter
elderly, renter small family, and renter large family households faced housing problems than owner
households of the same type.
Race/ethnicity can indicate housing need to the extent that different race/ethnic groups earn different
incomes. Overall, lower-income households represented just over 28 percent of all households in San
Diego County in 2012-2016. However, certain groups had higher proportions of lower-income
households. Specifically, Hispanic (40.9 percent) and Black (36.8 percent) households had a
considerably higher proportion of lower-income households than the rest of the county (Table 31).
Proportionally fewer Asian (22.8 percent) and Non-Hispanic White households (22.9 percent) fell in the
lower-income category compared to the county average.
July 14, 2020 Item #6 Page 72 of 211
Table 30: Housing Assistance Needs of Low and Moderate Income Households (2012-2016)
Household by Type, Income &
Housing Problem
Renters Owners
Total
Households Elderly
(65 years
or older)
Small
Families
(1-4
members)
Large
Families
(5+
members)
Total
Renters
Elderly
(65 years
or older)
Small
Families
(1-4
members)
Large
Families
(5+
members)
Total
Owners
Extremely Low Income
(0-30% AMI) 26,585 43,555 13,770 119,030 23,750 13,230 2,210 47,700 166,730
% of Household Type 37.2% 19.2% 24.6% 22.8% 12.4% 5.1% 3.9% 8.2% 15.1%
#% with Any Housing Problems 74.1% 85.5% 96.8% 79.7% 69.7% 59.1% 89.6% 66.9% 76.0%
#% with Cost Burden > 30% 73.0% 84.5% 91.8% 78.1% 69.5% 58.2% 84.2% 66.1% 74.6%
Low Income
(31-50% AMI) 15,100 41,795 13,615 93,670 26,435 13,110 4,985 49,995 143,665
% of Household Type 21.1% 18.4% 24.3% 18.0% 13.8% 5.0% 8.7% 8.6% 13.0%
#% with Any Housing Problems 81.0% 88.8% 95.5% 89.3% 51.3% 75.6% 84.1% 63.1% 80.2%
#% with Cost Burden > 30% 79.9% 86.1% 81.9% 85.8% 51.0% 74.3% 68.1% 61.0% 77.2%
Moderate Income
(51-80% AMI) 11,930 50,650 13,550 107,295 35,855 29,855 10,295 85,145 192,440
% of Household Type 16.7% 22.3% 24.2% 20.6% 18.7% 11.4% 18.0% 14.6% 17.4%
#% with Any Housing Problems 64.4% 66.6% 82.9% 68.4% 40.5% 66.6% 74.4% 56.7% 63.2%
#% with Cost Burden > 30% 60.6% 59.3% 44.9% 59.3% 40.1% 65.3% 56.0% 53.8% 56.9%
Middle/Upper Income
(81% + AMI) 17,800 91,365 15,015 201,495 105,865 205,680 39,815 398,805 600,300
% of Household Type 24.9% 40.2% 26.8% 38.6% 55.2% 78.5% 69.5% 68.6% 54.4%
#% with Any Housing Problems 26.6% 20.9% 46.5% 22.1% 19.5% 21.4% 34.4% 23.1% 22.8%
% with cost burden > 30% 23.4% 16.3% 12.5% 16.6% 19.1% 20.5% 21.4% 21.2% 19.7%
Total Households 71,415 227,365 55,950 521,490 191,905 261,875 57,305 581,645 1,103,135
% with Any Housing Problems 62.1% 55.9% 79.6% 56.8% 34.0% 31.2% 48.0% 35.1% 45.4%
% with Cost Burden > 30% 60.0% 51.7% 56.7% 51.9% 33.7% 30.2% 34.1% 33.1% 42.0%
Note: Data presented in this table is based on special tabulations from sample Census data. The number of households in each category usually deviates slightly from the 100%
count due to the need to extrapolate sample data out to total households. Interpretations of this data should focus on the proportion of households in need of assistance rather
than on precise numbers.
Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2012-2016.
July 14, 2020 Item #6 Page 73 of 211
Table 31: Income by Race/Ethnicity
Income Level All Households
Non-
Hispanic
White
Hispanic
or Latino Black Asian
Extremely Low Income (0-30% AMI) 166,720 15.1% 12.3% 21.1% 21.8% 12.7%
Low Income (31-50% AMI) 143,680 13.0% 10.6% 19.8% 15.0% 10.1%
Moderate Income (51-80% AMI) 192,440 17.4% 15.6% 22.2% 19.6% 15.6%
Middle/Upper Income (81% + AMI ) 600,305 54.4% 61.5% 36.9% 43.5% 61.6%
Percent of Total Households 1,103,145 100.0% 57.6% 24.5% 4.8% 10.3%
Note: Data presented in this table is based on special tabulations from sample Census data. The number of households in each
category usually deviates slightly from the 100% count due to the need to extrapolate sample data out to total households.
Interpretations of this data should focus on the proportion of households in need of assistance rather than on precise numbers.
Source: HUD Comprehensive Housing Affordability Strategy (CHAS) Data, 2012-2016.
4. Concentrations of Lower- and Moderate-Income Populations
Figure 7 shows the Lower and Moderate Income (LMI) areas in the county by Census block group.
Determining LMI areas is important for programming Community Development Block Grant (CDBG)
activities. The CDBG program requires that each CDBG funded activity must “either principally
benefit low- and moderate-income (LMI) persons, aid in the prevention or elimination of slums or
blight, or meet a community development need having a particular urgency.” Activities may also qualify
for CDBG funds if the activity will benefit all the residents of a primarily residential area where at least
51 percent of the residents are low- and moderate-income persons.
Typically, HUD defines a LMI area as a Census tract or block group where over 51 percent of the
population is LMI. However, certain communities are higher income, with few block groups qualifying
as LMI using this definition. These communities are considered “exception” jurisdictions. The cities of
Carlsbad, Encinitas, and Santee are identified by HUD as "exception" jurisdictions (where their LMI
thresholds are not set at 51 percent). LMI areas in these communities are defined as the top 25 percent
(fourth quartile) of block groups with the highest concentration of low-and moderate-income
population.
For FY 2019-20, the LMI thresholds for these "exception" jurisdictions are:
City of Carlsbad: 39.2 percent
City of Encinitas: 39.8 percent
City of Santee: 45.2 percent
Low- and moderate-income (LMI) areas are concentrated in three very general areas. In the North
County area, LMI areas are seen at Camp Pendleton and in the cities of Oceanside, Vista, San Marcos,
and Escondido, in a pattern generally following State Route 78. In the southern portion of the county,
clusters of LMI areas are seen in the central and southern areas of the City of San Diego and continuing
down to the U.S./Mexico border. In the East County areas, there are vast LMI areas in sparsely
populated parts of the unincorporated county and in the City of El Cajon.
July 14, 2020 Item #6 Page 74 of 211
Figure 7: Low and Moderate Income Areas
July 14, 2020 Item #6 Page 75 of 211
5. Concentrations of Poverty
National poverty data suggests that people living in poverty tend to be clustered in certain communities
rather than being evenly distributed across geographic areas. Identifying concentrations of poverty is
important because living in areas with many other poor people has been shown to places burdens on
low-income families beyond what the families’ own individual circumstances would dictate. Other
research indicates that this concentration of poverty can result in higher crime rates, underperforming
public schools, poor housing and health conditions, as well as limited access to private services and job
opportunities.25 The consequences of poverty are particularly harmful to children. Children who grow
up in densely poor neighborhoods and attend low-income schools face many barriers to academic and
occupational achievement.
Countywide, over 13 percent of residents (or 427,031 persons) were living below the poverty level
(according to 2013-2017 ACS data).26 Poverty was more prevalent for specific groups such as Hispanics
18.7 percent), Blacks (19.9 percent), and adults with less than a high school education (23.4 percent). In
contrast, 12.6 percent of White residents, 10.3 percent of Asian residents, and five percent of residents
with at least a bachelor’s degree were living below the poverty level during the same time period.
Figure 8 shows the geographic concentration of poverty in San Diego County (areas where the
proportion of persons living in poverty is greater than countywide). According to the 2013-2017 ACS
estimates, 13.3 percent of the population is living below the poverty line countywide. Similar to low- and
moderate-income areas, areas of poverty concentration are clustered in three general areas of the
County. In North County, concentrations can be seen in the cities of Oceanside, San Marcos,
Escondido, Carlsbad and Encinitas. In the southern portion of the county, concentrations can be seen
in the central areas of the City of San Diego.
Increasing concentrations of low-income and poverty households are linked to racial and ethnic
concentrations. In East County, poverty concentrations can be seen in many parts of the unincorporated
county and in El Cajon. Many of the areas with a concentration of poverty in the western part of the
county (in and around the incorporated cities) are also areas with minority concentrations. In some areas
such as La Jolla and San Marcos, the large student populations may contribute to poverty
concentrations.
In an effort to identify racially/ethnically-concentrated areas of poverty (RECAPs), HUD has identified
census tracts with a majority non-White population (greater than 50 percent) and has a poverty rate that
exceeds 40 percent or is three times the average tract poverty rate for the metro/micro area, whichever
threshold is lower. An analysis of racially and ethnically concentrated areas of poverty is important
because families who live in such neighborhoods encounter challenges and stresses that hinder their
ability to reach their full potential, and such neighborhoods impose extra costs on neighboring
communities and the region. In San Diego County, there are RECAPs scattered in small sections of
Escondido, El Cajon, La Mesa, Lemon Grove, National City, and Chula Vista. Larger RECAP clusters
can be seen in the central/southern portion of the City of San Diego.
25 U.S. Census Bureau, “Areas with Concentrated Poverty: 2006–2010”. American Community Survey Briefs, December 2 011.
26 The U.S. Census Bureau determines poverty status by comparing annual income to a set of dollar values called poverty thresholds that
vary by family size, number of children, and age of householder. If a family’s before tax money income is less than the dollar value of
their threshold, then that family and every individual in it are considered to be in poverty. For people not living in families, poverty
status is determined by comparing the individual’s income to his or her poverty threshold.
July 14, 2020 Item #6 Page 76 of 211
Figure 8: Poverty Concentration Areas
July 14, 2020 Item #6 Page 77 of 211
F. Housing Profile
A discussion of fair housing choice must include an assessment of the housing market being analyzed.
This section provides an overview of the characteristics of the local and regional housing markets. The
Census Bureau defines a housing unit as a house, an apartment, a mobile home, a group of rooms, or a
single room that is occupied (or, if vacant, is intended for occupancy) as separate living quarters.
Separate living quarters are those in which the occupants live separately from any other individuals in
the building and which have direct access from outside the building or through a common hall.
1. Housing Growth
Housing data reveals that the San Diego County housing stock increased by almost five percent between
2010 and 2019 (Table 32), the most recent Census data available and the most current housing estimates
available.
This growth rate is lower than the preceding decade where housing growth increased by almost 12
percent from 2000 to 2010. Among jurisdictions in the county, the City of San Marcos continued to
experience the largest housing growth (12.2 percent) followed by Chula Vista (7.7 percent) and San
Diego (5.9 percent). These housing growth rates are small compared to those between 2000 and 2010,
where the highest rates ranged from 52 to 32 percent. In the last decade, most jurisdictions in the county
experienced housing growth of less than five percent.
SANDAG growth forecasts estimate that by 2035, the county’s housing stock will increase by 14.4
percent. The cities of National City, Chula Vista, and San Diego are expected to see housing stock
growth that in excess of 15 percent (20.9 percent, 18.3 percent, and 17.4 percent, respectively). The
estimated population growth for the county is expected to exceed production marginally (growth from
3.4 to 3.9 million, 15 percent) Inability to produce enough housing units to accommodate growth in the
number of households will reduce vacancy rates, could drive up market prices, increase the incidence of
overcrowding.
July 14, 2020 Item #6 Page 78 of 211
Table 32: Housing Unit Growth
Jurisdiction # of Units
2010
# of Units
2019
% Change
2010 to 2019
Projected
2035
% Change
2019-2035
Urban County
Coronado 9,634 9,740 1.1% 9,697 -0.4%
Del Mar 2,596 2,625 1.1% 2,653 1.1%
Imperial Beach 9,882 10,074 1.9% 10,926 8.5%
Lemon Grove 8,868 9,114 2.8% 9,654 5.9%
Poway 16,715 16,917 1.2% 17,685 4.5%
Solana Beach 6,540 6,569 0.4% 6,833 4.0%
Unincorporated 173,756 178,844 2.9% 209,506 17.1%
Total Urban County 227,991 233,883 2.6% 266,954 14.1%
Entitlement Cities
Carlsbad 44,673 47,080 5.4% 50,261 6.8%
Chula Vista 79,416 85,535 7.7% 101,188 18.3%
El Cajon 35,850 36,148 0.8% 38,163 5.6%
Encinitas 25,740 26,495 2.9% 26,765 1.0%
Escondido 48,044 48,833 1.6% 55,633 13.9%
La Mesa 26,167 26,869 2.7% 30,001 11.7%
National City 16,762 17,264 3.0% 20,877 20.9%
Oceanside 64,435 65,902 2.3% 70,395 6.8%
San Diego 515,275 545,645 5.9% 640,668 17.4%
San Marcos 28,641 32,126 12.2% 35,795 11.4%
Santee 20,048 21,100 5.2% 22,776 7.9%
Vista 30,986 32,580 5.1% 35,307 8.4%
Total County 1,164,028 1,219,460 4.8% 1,394,783 14.4%
Sources: Bureau of the Census, 2010 Census; SANDAG Series 13 Regional Growth Forecast; California Department of
Finance Housing Estimates (E5), 2019.
2. Housing Type
A region’s housing stock generally includes three categories: single-family dwelling units, multi-family
dwelling units, and other types of units such as mobile homes. Single-family units are attached or
detached dwelling units usually on individual lots of land. As shown in Table 33, approximately 60
percent of the housing units in the county are single-family dwellings. The cities of Del Mar, Lemon
Grove, Poway, Carlsbad and Encinitas, as well as the unincorporated county areas, have a much larger
proportion of this housing unit type (over 70 percent), while El Cajon and Imperial Beach have a much
lower proportion (less than 50 percent).
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Table 33: Housing Stock Mix 2019
Jurisdiction Single Family Units Multi-Family Units Mobile
Homes Detached Attached Total 2-4 Units 5+ Units Total
Urban County
Coronado 45.7% 10.7% 56.4% 6.8% 36.8% 43.5% 0.0%
Del Mar 51.6% 19.7% 71.3% 7.7% 21.1% 28.7% 0.0%
Imperial Beach 39.1% 7.6% 46.7% 12.3% 37.9% 50.1% 3.2%
Lemon Grove 65.9% 8.7% 74.6% 7.3% 17.2% 24.5% 0.9%
Poway 75.1% 4.1% 79.1% 2.4% 13.6% 16.0% 4.9%
Solana Beach 47.8% 19.4% 67.2% 6.2% 26.4% 32.6% 0.2%
Unincorporated 68.6% 5.9% 74.5% 4.6% 12.4% 17.1% 8.4%
Total Urban County 66.0% 6.7% 72.6% 5.1% 15.3% 20.4% 7.0%
Entitlement Jurisdictions
Carlsbad 53.1% 16.9% 70.0% 5.5% 21.8% 27.2% 2.7%
Chula Vista 53.5% 9.8% 63.4% 5.9% 26.0% 31.9% 4.8%
El Cajon 41.1% 4.9% 46.0% 7.8% 40.8% 48.7% 5.3%
Encinitas 58.1% 18.7% 76.8% 6.8% 13.8% 20.6% 2.6%
Escondido 50.8% 6.1% 56.9% 6.8% 28.5% 35.3% 7.7%
La Mesa 46.9% 6.0% 52.9% 9.0% 37.4% 46.5% 0.7%
National City 43.3% 9.4% 52.7% 9.2% 35.6% 44.8% 2.5%
Oceanside 52.5% 11.5% 64.0% 8.8% 22.2% 31.0% 5.0%
San Diego 44.3% 8.6% 52.9% 8.3% 37.6% 45.8% 1.2%
San Marcos 51.1% 6.9% 58.0% 3.9% 27.8% 31.6% 10.4%
Santee 55.6% 9.1% 64.8% 5.9% 18.2% 24.1% 11.1%
Vista 49.3% 7.4% 56.8% 7.2% 30.3% 37.4% 5.8%
Total County 50.9% 8.7% 59.6% 7.2% 29.4% 36.6% 3.8%
Source: California Department of Finance, Population and Housing Estimates (E5), 2019.
3. Tenure and Vacancy
Housing tenure describes the arrangement by which a household occupies a housing unit; that is,
whether a housing unit is owner-occupied or renter-occupied. Tenure preferences are primarily related
to household income, composition, and age of the resident. Communities need to have an adequate
supply of units available both for rent and for sale in order to accommodate a range of households with
varying incomes, family sizes, composition, lifestyles, etc. A person and households may face different
housing issues in the rental housing market versus the for-sale housing market. Residential stability is
also influenced by tenure with ownership housing resulting in a much lower turnover rate than rental
housing.
As seen in Table 34, San Diego County has a higher proportion of owner-occupied housing (53 percent)
than renter-occupied housing (47 percent). The ownership level fell by 1.4 percent between 2010 and
2017, but was still below the national level of 63.8 percent and slightly lower than the 54.5 percent State
figure for housing ownership. However, ownership rates decreased at all levels between 2010 and 2017.
July 14, 2020 Item #6 Page 80 of 211
Half of the jurisdictions in the county had more owner-occupied housing units than renter-occupied
units. Exceptions include Coronado, Imperial Beach, El Cajon, Escondido, La Mesa, National City, San
Diego, and Vista. The tenure distribution in Coronado, Imperial Beach, and National City may be
attributed to the large proportion of military families in those cities living off base due to the lack of, or
demand for, housing and the close proximity of the cities to military bases. The large proportion of
renters in El Cajon is partially explained by the large amount of multi-family housing in the City.
Table 34: Housing Tenure and Vacancy
Jurisdiction
Percent
Owner-
Occupied
Percent
Renter-
Occupied
Vacancy
Rate
Urban County
Coronado 49.2% 50.8% 26.8%
Del Mar 53.4% 46.6% 31.6%
Imperial Beach 31.8% 68.2% 14.3%
Lemon Grove 54.1% 45.9% 5.4%
Poway 74.4% 25.6% 4.1%
Solana Beach 58.6% 41.4% 16.0%
Unincorporated 67.6% 32.4% 9.1%
Total Urban County 64.9% 35.1% 9.9%
Entitlement Jurisdictions
Carlsbad 65.0% 35.0% 8.9%
Chula Vista 58.0% 42.0% 8.9%
El Cajon 38.2% 61.8% 3.1%
Encinitas 63.8% 36.2% 8.4%
Escondido 49.8% 50.2% 4.5%
La Mesa 41.6% 58.4% 6.4%
National City 32.1% 67.9% 7.1%
Oceanside 56.0% 44.0% 7.6%
San Diego 46.8% 53.2% 7.4%
San Marcos 61.3% 38.7% 4.5%
Santee 69.0% 31.0% 4.3%
Vista 49.2% 50.8% 3.6%
Total County 65.0% 35.0% 8.9%
Sources: American Community Survey, 2013-2017.
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4. Tenure by Income and Race/Ethnicity
A substantial income and housing disparity exists between owner- and renter-households. Table 35
indicates that San Diego County renters are more likely to be lower and moderate income and are more
likely to experience housing problems such as cost burden and substandard housing conditions.
The county’s tenure distribution also has a racial and ethnic component as many ethnic minority
populations in San Diego County have not achieved housing homeownership as readily as the White
population. In fact as of 2017, the majority of owner-occupied households were White (Figure 9). Of
those who owned the housing units they occupied, 64 percent were White; 18 percent were Hispanic;
three percent were Black; and 11 percent were Asian/Pacific Islanders. Comparing these figures to race
data from the 2013-2017 ACS demonstrates that minorities in the county are underrepresented in terms
of homeownership. For comparison purposes, according to 2013-2017 ACS data, Whites are 46 percent
of the county population, Hispanics are 33 percent, while 12 percent are Asian/Pacific Islander and only
five percent of the population was Black.
Table 35: Housing Problems by Tenure
Tenure Percent of All
Households
Percent Low
and Moderate
Income
Percent with
Housing
Problems
Percent with
Cost Burden
(>30%)
Renters 47.3% 61.4% 56.8% 51.9%
Owners 52.7% 31.4% 35.1% 33.1%
Total Households 100.0% 45.6% 45.4% 42.0%
Source: HUD Comprehensive Housing Affordability Strategy (CHAS) Data, 2012-2016.
Figure 9: Race of Homeowner
Sources: American Community Survey (1-year estimates), 2010, 2017.
July 14, 2020 Item #6 Page 82 of 211
G. Housing Condition
Assessing housing conditions in San Diego County can provide the basis for developing policies and
programs to maintain and preserve the quality of the housing stock. Housing age can indicate general
housing conditions within a community. Housing is subject to gradual deterioration over time.
Deteriorating housing can depress neighboring property values, discourage reinvestment, and impact the
quality of life in a neighborhood. State and federal housing programs typically consider the age of a
community’s housing stock when estimating rehabilitation needs. In general, most homes begin to
require major repairs or have significant rehabilitation needs at 30 or 40 years of age. Furthermore,
housing units constructed prior to 1979 are more likely to contain lead-based paint.
The housing stock in the San Diego region is older, with a majority of the housing units (54 percent)
built before 1979 and is at least 40 years old (Table 36). The highest percentages of pre-1980 housing
units are generally found in the older, urbanized neighborhoods of the cities of La Mesa, Lemon Grove,
El Cajon, San Diego, Coronado and National City and will most likely have the largest proportions of
housing units potentially in need of rehabilitation. Home rehabilitation can be an obstacle for senior
homeowners with fixed incomes and mobility issues.
1. Lead-Based Paint Hazard
Housing age is a key variable used to estimate the number of housing units with lead-based paint (LBP).
Lead based-paint was banned in the United States in 1978. Residences constructed before 1978 may
have lead-based paint hazards. According to the federal Centers for Disease Control (CDC),
approximately 250,000 children aged one to five years in the United States have elevated levels of lead in
their blood. High blood lead levels are a concern because they may be harmful to a child’s developing
organ systems such as the kidneys, brain, liver, and blood-forming tissues, potentially affecting a child’s
ability to learn. Very high blood lead levels can cause devastating health consequences, including
seizures, coma, and even death. Children are much more vulnerable to lead poisoning than adults
because children tend to put items into their mouths and some of these items may contain lead paint. In
addition, their bodies absorb up to 40 percent of the lead with which they come into contact, as
opposed to only ten percent absorbed by adults. Lead can enter the body through breathing or
ingestion. Several factors contribute to higher incidence of lead poisoning:
All children under the age of six years old are at higher risk.
Children living at or below the poverty line are at a higher risk.
Children in older housing are at higher risk.
Children of some racial and ethnic groups and those living in older housing are at
disproportionately higher risk.
According to the County Health and Human Services Agency, between 2013 and 2017, 273 cases of
lead-poisoning (Blood Lead Level > 9.5 mcg/dL or greater) among children under 21 years of age were
recorded. This figure is an increase from the reported 104 cases between 2009 and 2013. However, the
increase may be due to changes in the reporting threshold from 14.4mcg/dL to 9.5mcg/dL.
July 14, 2020 Item #6 Page 83 of 211
Table 36: Housing Age and Lead-Poisoning Cases
Jurisdiction Built 1960-
1979
Built 1940-
1959
Built Before
1940
Median
Year Built
Lead
Poisoning
Cases
2009-2013
Urban County
Coronado 38.0% 19.3% 15.1% 1972 -
Del Mar 53.3% 18.7% 3.1% 1971 -
Imperial Beach 40.9% 30.0% 2.5% 1970 -
Lemon Grove 34.7% 40.8% 4.9% 1963 -
Poway 48.0% 7.0% 0.9% 1978 -
Solana Beach 54.6% 12.4% 2.5% 1976 -
Unincorporated 34.7% 10.4% 2.6% - 5
Total Urban County 36.9% 12.7% 3.2% - 5
Entitlement Jurisdictions
Carlsbad 26.3% 4.6% 1.1% 1987 2
Chula Vista 28.5% 16.4% 1.4% 1983 6
El Cajon 45.3% 23.4% 1.1% 1973 8
Encinitas 42.0% 10.4% 3.3% 1978 2
Escondido 38.3% 7.4% 2.3% 1981 6
La Mesa 41.1% 30.6% 5.0% 1969 1
National City 36.8% 25.3% 8.0% 1970 3
Oceanside 33.2% 7.5% 1.4% 1983 9
San Diego 34.2% 16.7% 6.9% 1976 4
San Marcos 26.8% 2.8% 0.7% 1990 6
Santee 52.0% 8.4% 0.8% 1977 -
Vista 33.5% 8.2% 1.6% 1982 7
Total County 34.9% 14.3% 4.4% 1978 1
Note: Lead poisoning cases refer to children under 21 years of age with a venous BLL 14.5 ug/dL or greater.
Sources: American Community Survey (ACS), 2009-2013; County of San Diego Childhood Lead Poisoning
Prevention Program (CLPPP) Epidemiology & Immunization Services, Public Health Services, 2014.
July 14, 2020 Item #6 Page 84 of 211
Figure 10: Childhood Lead Poisoning Risk Areas
July 14, 2020 Item #6 Page 85 of 211
Q1_12, 61.3
Q3_19, 20.1
0
10
20
30
40
50
60
70
H. Housing Cost and Affordability
This section evaluates the affordability of the housing stock in San Diego County to low and moderate
income households. If housing costs are relatively high in comparison to household income, a
correspondingly high rate of housing problems occurs. It is important to emphasize that housing
affordability alone is not a fair housing issue. However, fair housing concerns may arise when housing
affordability interacts with other factors covered under the fair housing laws, such as household type,
composition, and race/ethnicity.
1. Housing Cost
Every year, the National Association of Home Builders (NAHB) tracks the ability of households to
afford a home in metropolitan areas across the country. NAHB develops a Housing Opportunity Index
(HOI) for a given area that is defined as the share of homes sold in that area that would have been
affordable to a family earning that area’s median income. The nation’s 10 least affordable metro areas in
2019 were located in California. The San Diego-Carlsbad-San Marcos Metropolitan Statistical Area
(MSA) is one of the least affordable areas in the nation ranking as the sixth least affordable region in the
United States. In 2019 (Third Quarter), only 20 percent of the homes sold in the San Diego MSA were
affordable to a family earning the area’s median income. Figure 11 shows that affordability for the
region peaked in 2012 during the recession and has dropped considerably since then.
Figure 11: Housing Opportunity Index Trend (2010-2019)
Note: Housing Opportunity Index represents the percentage of homes sold that were affordable to families earning the median income
during the respective quarter.
Source: National Association of Home Builders, The NAHB/Wells Fargo Housing Opportunity Index: Complete History by Metropolitan
Area (2012-Current).
July 14, 2020 Item #6 Page 86 of 211
According to HUD’s 2012-2016 Comprehensive Housing Affordability Strategy (CHAS) data, close to
20 percent of households in San Diego County paid more than half their income on housing. As cost of
living is consistently on the rise, housing affordability drops, and lower-income families are most acutely
affected. The California Housing Partnership (CHPC) estimates that the county’s lowest-income renters
spend 69 percent of their income on rent.27 The CHPC estimated that in 2018, renters needed to earn
$38.31/hr (three times the minimum wage) to afford the median monthly asking rate of $1,992. Rents
increase in response to demand and more renter households have entered the San Diego market since
2006, many because of displacement during the foreclosure crisis.
Table 37 displays median home sale prices for each jurisdiction in San Diego County. For 2019, the
median sales price for homes in San Diego County was $594,909, an increase of 38 percent from 2014.
Home prices vary by area/jurisdiction, with very high median prices in coastal areas such as the cities of
Coronado, Del Mar, and Solana Beach. Imperial Beach and Lemon Grove had the lowest median sales
price in the region.
Table 37: Median Home Sale Prices by Jurisdiction
County/City/Area # Sold
Nov. 2014
# Sold
Nov. 2019
Median Price
Nov. 2014
Median Price
Nov. 2019
% Change
2014-2019
Urban County
Coronado 13 42 $1,059,500 $1,820,000 71.8%
Del Mar 23 13 $1,249,000 $1,675,000 34.1%
Imperial Beach 8 17 $427,000 $530,000 24.1%
Lemon Grove 24 19 $331,750 $490,000 47.7%
Poway 35 46 $558,409 $677,000 21.2%
Solana Beach 24 14 $1,022,500 $1,200,000 17.4%
Entitlement Jurisdictions
Carlsbad 121 13 $687,500 $859,000 24.9%
Chula Vista 214 282 $405,000 $535,000 32.1%
El Cajon 116 165 $365,000 $523,000 43.3%
Encinitas1 60 57 $768,000 $992,000 29.2%
Escondido 117 182 $394,000 $580,000 47.2%
La Mesa 69 76 $417,000 $549,000 31.7%
National City 16 14 $277,500 $446,000 60.7%
Oceanside 164 196 $392,500 $549,000 39.9%
San Diego 1023 1,180 $439,500 $625,000 42.2%
Santee 81 110 $350,000 $622,500 51.7%
Vista 53 78 $420,000 $531,000 34.5%
San Diego County 83 102 $430,000 $565,000 38.4%
Note: 1. Does not include Cardiff-by-the-Sea sales data.
Sources: DQNews.com, California Home Sale Activity by City, November 2014; CoreLogic, California Home Sale Activity by
City, November 2019. Accessed January 30,2020.
27 California Housing Partnership Corporation. “San Diego County Report: San Diego County’s Housing Emergency and
Proposed Solutions.” (May 2018).
July 14, 2020 Item #6 Page 87 of 211
The San Diego County Apartment Association (SDCAA) publishes average rental rates biannually.
Table 38 displays the average rent by jurisdiction on Fall 2014 and Fall 2018, providing a reasonable
five-year timeframe to capture the change in rental rates. The estimated average rental costs in San
Diego County increased by an average of 33 percent. The percent increase in rent between 2014 and
2018 was 34 percent for a studio, 47 percent for a one-bedroom, 28 percent for a two-bedroom, and 22
percent for a three-bedroom unit. Among communities with data for one-, two-, and three-bedroom
units, Imperial Beach had the lowest average rents in the region and highest rents were observed in Del
Mar and Solana Beach.
Table 38: Average Rental Rates by Jurisdiction - Fall 2018
Jurisdiction/Area Unit Type Average Monthly Rent % Change Fall 2014* Fall 2018
Urban County
Coronado
Studio N/A N/A N/A
1 Bedroom $1,325 $1,404 6.0%
2 Bedrooms $1,200 $1,700 41.7%
3+ Bedrooms $2,308 N/A N/A
Del Mar
Studio $1,526 N/A N/A
1 Bedroom $1,564 $2,338 49.5%
2 Bedrooms $1,894 $2,806 48.2%
3+ Bedrooms $2,300 $2,650 15.2%
Imperial Beach
Studio $925 N/A N/A
1 Bedroom $825 $1,517 83.9%
2 Bedrooms $1,635 $1,500 -8.3%
3+ Bedrooms $1,988 $1,683 -15.3%
Lemon Grove
Studio $762 $891 16.9%
1 Bedroom $864 $1,030 19.2%
2 Bedrooms $1,102 $1,282 16.3%
3+ Bedrooms $1,475 N/A N/A
Poway
Studio $1,012 N/A N/A
1 Bedroom $1,245 N/A N/A
2 Bedrooms $1,325 N/A N/A
3+ Bedrooms $1,842 $2,350 27.6%
Solana Beach
Studio $900 N/A N/A
1 Bedroom $1,656 $2,043 23.4%
2 Bedrooms $1,967 $2,391 21.6%
3+ Bedrooms $2,310 $2,770 19.9%
Entitlement Jurisdictions
Carlsbad
Studio $911 $1,099 20.6%
1 Bedroom $1,168 $1,457 24.7%
2 Bedrooms $1,557 $2,685 72.4%
3+ Bedrooms $4,525 N/A N/A
July 14, 2020 Item #6 Page 88 of 211
Table 38: Average Rental Rates by Jurisdiction - Fall 2018
Jurisdiction/Area Unit Type Average Monthly Rent % Change Fall 2014* Fall 2018
Chula Vista
Studio $720 $1,210 68.1%
1 Bedroom $970 $1,539 58.7%
2 Bedrooms $1,354 $1,850 36.6%
3+ Bedrooms $1,566 $2,299 46.8%
El Cajon
Studio $693 $752 8.5%
1 Bedroom $1,149 $1,742 51.6%
2 Bedrooms $1,069 $1,728 61.6%
3+ Bedrooms $1,557 $2,185 40.3%
Encinitas
Studio $1,362 N/A N/A
1 Bedroom $1,233 $1,295 5.0%
2 Bedrooms $1,654 $2,145 29.7%
3+ Bedrooms $1,575 $2,150 36.5%
Escondido
Studio N/A N/A N/A
1 Bedroom $739 $1,462 97.8%
2 Bedrooms $1,116 $1,728 54.8%
3+ Bedrooms $1,393 $1,784 28.1%
La Mesa
Studio $875 $1,168 33.5%
1 Bedroom $1,075 $1,568 45.9%
2 Bedrooms $1,467 $1,968 34.2%
3+ Bedrooms $1,875 $2,397 27.8%
National City
Studio $675 N/A N/A
1 Bedroom $809 N/A N/A
2 Bedrooms $969 $1,075 10.9%
3+ Bedrooms N/A $1,900 N/A
Oceanside
Studio $922 $1,620 75.7%
1 Bedroom $1,106 $1,503 35.9%
2 Bedrooms $2,217 $1,774 -20.0%
3+ Bedrooms $2,018 $2,195 8.8%
San Diego
Studio $824 $1,433 73.9%
1 Bedroom $1,075 $1,825 69.8%
2 Bedrooms $1,496 $2,172 45.2%
3+ Bedrooms $1,892 $2,637 39.4%
San Marcos
Studio N/A N/A N/A
1 Bedroom $1,013 $1,021 0.8%
2 Bedrooms $1,267 N/A N/A
3+ Bedrooms N/A $1,650 N/A
July 14, 2020 Item #6 Page 89 of 211
Table 38: Average Rental Rates by Jurisdiction - Fall 2018
Jurisdiction/Area Unit Type Average Monthly Rent % Change Fall 2014* Fall 2018
Santee
Studio $900 N/A N/A
1 Bedroom $1,012 $1,599 58.0%
2 Bedrooms $1,568 $1,740 11.0%
3+ Bedrooms $2,763 $1,737 -37.1%
Vista
Studio $674 $1,313 94.8%
1 Bedroom $1,016 $1,636 61.0%
2 Bedrooms $1,257 $1,863 48.2%
3+ Bedrooms $1,326 $2,493 88.0%
San Diego County
Studio $812 $1,085 33.6%
1 Bedroom $1,066 $1,564 46.7%
2 Bedrooms $1,463 $1,873 28.0%
3+ Bedrooms $1,813 $2,218 22.3%
Note: Fall 2014 average rents were not available for studio units in Del Mar, Imperial Beach, Poway, and
Solana Beach and 3+ bedroom units in Coronado. Spring 2014 average rents are used for those values. Fall
2018 average rents not available for studios in Encinitas, Escondido, National City, San Marcos, and Santee.
Fall 2018 average rent was also not available for one-bedroom units in National City.
Source: San Diego County Apartment Association. Vacancy and Rental Rate Survey, Fall 2018 and Spring
2019.
2. Housing Affordability
Housing affordability can be inferred by comparing the cost of renting or owning a home in a
community with the maximum affordable housing costs for households at different income levels.
Taken together, this information can generally show who can afford what size and type of housing and
indicate the type of households most likely to experience overcrowding and overpayment. While
housing affordability alone is not a fair housing issue, fair housing concerns may arise when housing
affordability interacts with factors covered under the fair housing laws, such as household type,
composition, and race/ethnicity.
HUD conducts annual household income surveys nationwide to determine a household’s eligibility for
federal housing assistance. Households in the lower end of each income category can afford less by
comparison than those at the upper end. Table 39 shows the annual household income by household
size and the maximum affordable housing payment based on the standard of 30 to 35 percent of
household income. Also shown are general cost assumptions for utilities, taxes, and property insurance.
The countywide median home sales price in 2019 ($594,909) places home ownership out of reach for all
low- and moderate-income households. When homeownership is out of reach, rental housing is the only
viable option for many low-income persons.
Based on the rental data presented in Table 38, none of jurisdictions had a rents within the range of
affordability for lower-income families. Table 39 shows that extremely low-income households cannot
afford rents in any part of the county. Larger, low-income households can afford some of the studio and
one-bedroom rental units but those would be inadequate to house a large family. Moderate-income
July 14, 2020 Item #6 Page 90 of 211
households have a few more options for rentals but again, large households may encounter difficulty
finding adequately sized units. The situation is most difficult for seniors with fixed incomes. When the
housing market is tight, with high demand, low vacancies, and rising costs, the potential for
discriminatory housing practices also increases.
Table 39: Housing Affordability Matrix - San Diego County (2019)
Income
Group
Annual
Income
Limits
Affordable Payment Housing Costs Maximum Affordable Price
Renter Owner Utilities
Taxes &
Insurance
(Owner)
Rental
(per month)
Home (purchase
price)
Extremely Low (0-30% AMI)
1-Person $22,500 $563 $563 $160 $197 $403 $47,856
2-Person $25,700 $643 $643 $201 $225 $442 $50,416
3-Person $28,900 $723 $723 $241 $253 $482 $53,209
4-Person $32,100 $803 $803 $283 $281 $520 $55,536
5-Person $34,700 $868 $868 $345 $304 $429 $50,940
Low (31-50% AMI)
1-Person $37,450 $936 $936 $160 $328 $776 $104,396
2-Person $42,800 $1,070 $1,070 $201 $375 $869 $115,087
3-Person $48,150 $1,204 $1,204 $241 $421 $963 $126,011
4-Person $53,500 $1,338 $1,338 $283 $468 $1,055 $136,470
5-Person $57,800 $1,445 $1,445 $345 $506 $1,006 $138,303
Moderate (51-80% AMI)
1-Person $59,950 $906 $1,057 $160 $370 $746 $122,689
2-Person $68,500 $1,036 $1,208 $201 $423 $835 $135,994
3-Person $77,050 $1,165 $1,359 $241 $476 $924 $149,531
4-Person $85,600 $1,295 $1,510 $283 $529 $1,012 $162,603
5-Person $92,450 $1,398 $1,631 $345 $571 $1,053 $166,451
Middle/Upper (80-120 %AMI)
1-Person $72,500 $1,661 $1,938 $160 $678 $1,501 $255,962
2-Person $82,850 $1,899 $2,215 $201 $775 $1,698 $288,305
3-Person $93,200 $2,136 $2,492 $241 $872 $1,895 $320,881
4-Person $103,550 $2,373 $2,769 $283 $969 $2,090 $352,992
5-Person $111,850 $2,563 $2,990 $345 $1,047 $2,218 $372,071
Assumptions: California Department of Housing and Community Development 2018 income limits; 30 - 35% gross household income as
affordable housing costs (depending on tenure and income level); 35% of monthly affordable cost for taxes and insurance; 5% down-
payment, 4% interest rate for a 30-year fixed rate mortgage loan; utilities based on the Housing Authority of the County of San Diego’s
Allowances for Tenant-Furnished Utilities and Other Services, July 2019. Assumed Natural Gas.
Methodology: Affordable housing costs in this table are calculated based on California Health and Safety Code definitions, which generally
result in lower affordable housing costs.
Sources: California Department of Housing and Community Development, 2019; Housing Authority of the County of San Diego, 2019.
July 14, 2020 Item #6 Page 91 of 211
How is Overcrowding Defined?
According to State and federal guidelines,
overcrowding is defined as a unit with more
than one person per room, including dining
and living rooms but excluding bathrooms,
kitchens, hallways, and porches. Severe
overcrowding is defined as households with
more than 1.5 persons per room.
Overcrowding Threshold ≠ Occupancy
Standard
Overcrowding thresholds only describe how
a unit is occupied but by no means
represent the maximum occupancy standard
of a unit. In general, there are no occupancy
standards except for those established in the
building codes. Occupancy standards are
discussed later in Chapter 5: Public Policies.
I. Housing Problems
1. Overcrowding
Some households may not be able to accommodate high cost
burdens for housing but may instead accept smaller housing or
reside with other individuals or families in the same home.
Potential fair housing issues emerge if non-traditional
households are discouraged or denied housing due to a
perception of overcrowding. Household overcrowding is
reflective of various living situations: (1) a family lives in a
home that is too small; (2) a family chooses to house extended
family members; or (3) unrelated individuals or families are
doubling up to afford housing. However, cultural differences
also contribute to the overcrowded conditions since some
cultures tend to have a larger household size than others due
to the preference of living with extended family members. Not
only is overcrowding a potential fair housing concern, it can
potentially strain physical facilities and the delivery of public
services, reduce the quality of the physical environment,
contribute to a shortage of parking, and accelerate the
deterioration of homes.
As a result, some landlords or apartment managers may be more hesitant to rent to larger families, thus
making access to adequate housing even more difficult. According to local fair housing service providers
and property managers, addressing the issue of large households is complex as there are no set of
guidelines for determining the maximum capacity for a unit. Fair housing issues may arise from policies
aimed to limit overcrowding that have a disparate impact on specific racial or ethnic groups with higher
proportion of overcrowding. For example, 2013-2017 ACS data shows that seven percent of housing
units in the county were overcrowded compared with 17 percent for units with a Hispanic head of
household.
As mentioned, approximately seven percent of all households in San Diego County were affected by
overcrowding while two percent experienced severe overcrowding. The prevalence of overcrowding
varies among jurisdictions, with the lowest percentage of overall overcrowding occurring in Del Mar (no
overcrowded or severely overcrowded units). National City and Escondido had approximately twice the
county’s proportion of overcrowded units. El Cajon, Vista, and Imperial Beach also had high levels of
overcrowding. These jurisdictions had high proportions of minority residents and lower median incomes
as a whole as well. Table 40 also shows that overcrowding is significantly more prevalent among renter-
households than among owner-households.
July 14, 2020 Item #6 Page 92 of 211
Table 40: Overcrowding by Tenure
Jurisdiction
Overcrowded
(1+ occupants per room)
Severely Overcrowded
(1.5+ occupants per room)
Renter Owner Total Renter Owner Total
Urban County
Coronado 2.3% 0.6% 1.5% 1.7% 0.0% 0.8%
Del Mar 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Imperial Beach 14.1% 2.4% 10.4% 4.4% 0.7% 3.2%
Lemon Grove 8.5% 4.7% 6.4% 3.6% 1.5% 2.5%
Poway 9.3% 1.6% 3.6% 3.6% 0.3% 1.1%
Solana Beach 1.8% 0.8% 1.2% 1.2% 0.0% 0.5%
Unincorporated 9.1% 2.5% 4.6% 3.0% 0.6% 1.4%
Total Urban County 8.7% 2.4% 4.6% 3.0% 0.6% 1.4%
Entitlement Cities
Carlsbad 3.7% 1.2% 2.1% 0.8% 0.3% 0.4%
Chula Vista 17.1% 4.4% 9.8% 5.5% 0.9% 2.9%
El Cajon 17.6% 3.2% 12.1% 4.1% 0.9% 2.9%
Encinitas 7.1% 1.2% 3.4% 2.7% 0.5% 1.3%
Escondido 21.7% 6.1% 14.0% 9.3% 1.4% 5.3%
La Mesa 6.0% 1.7% 4.2% 2.7% 0.6% 1.9%
National City 17.2% 9.2% 14.6% 5.7% 2.7% 4.7%
Oceanside 8.6% 1.9% 4.8% 2.4% 0.6% 1.4%
San Diego 9.5% 2.7% 6.3% 3.5% 0.7% 2.2%
San Marcos 11.6% 2.5% 6.0% 3.4% 0.8% 1.8%
Santee 5.5% 1.2% 2.5% 0.2% 0.2% 0.2%
Vista 17.9% 4.1% 11.1% 6.1% 1.2% 3.7%
Total County 10.8% 2.8% 6.5% 3.7% 0.7% 2.1%
Source: American Community Survey (ACS), 2013-2017.
2. Housing Cost Burden
State and Federal standards specify that a household experiences housing cost burden if it pays more
than 30 percent of its gross income on housing – typically a point at which housing costs become
burdensome and may affect the ability to comfortably make monthly rent or mortgage payments and/or
maintain a decent standard of living.
Housing cost burden is typically linked to income levels. The lower the income, the larger percentage of
a household’s income is allotted to housing costs. Cost burden by low income households tends to
occur when housing costs increase faster than income. Figure 12 shows how dramatically the housing
cost burden for owner- and renter-households is influenced by household income. As shown, as
income increases, the proportion of households experiencing cost burden decreases. Among the lower
income groups, larger proportions of renter-households experienced housing cost burden.
July 14, 2020 Item #6 Page 93 of 211
Figure 12: Housing Cost Burden by Income and Tenure
Source: American Community Survey (ACS), 2013-2017.
About 42 percent of county households experienced cost burden per the 2012-2016 CHAS (Table 41).
A higher proportion of renter-occupied households experienced cost burden (52 percent) compared
with owner-occupied households (33 percent). Carlsbad, Del Mar, Encinitas Poway, San Diego, Santee,
and Carlsbad were the only jurisdictions in the region where less than 50 percent of renters were cost
burdened. Approximately two-thirds (69 percent) of lower and moderate-income households
experienced cost burden, and 40 percent experienced a severe cost burden.
0.0%20.0%40.0%60.0%80.0%100.0%
<$20,000
$20,000-$34,999
$35,000- $49,999
$50,000- $74,999
$75,000+
<$20,000 $20,000-$34,999 $35,000- $49,999 $50,000- $74,999 $75,000+
Owner 81.0%61.4%56.4%50.8%18.8%
Renter 91.8%93.1%77.8%50.9%13.8%
July 14, 2020 Item #6 Page 94 of 211
Table 41: Housing Cost Burden by Tenure
Jurisdiction
Owner-
Occupied
Households
Renter-
Occupied
Households
All Households
Urban County
Coronado 37.5% 51.9% 44.9%
Del Mar 38.1% 42.3% 40.0%
Imperial Beach 31.4% 53.5% 46.7%
Lemon Grove 33.1% 57.0% 43.9%
Poway 29.5% 45.3% 33.7%
Solana Beach 26.6% 48.5% 35.8%
Unincorporated 35.9% 55.6% 42.3%
Total Urban County 35.0% 54.3% 41.8%
Entitlement Cities
Carlsbad 28.6% 46.4% 35.0%
Chula Vista 36.6% 55.9% 44.7%
El Cajon 31.6% 57.7% 47.7%
Encinitas 30.9% 47.7% 36.9%
Escondido 33.5% 57.9% 46.0%
La Mesa 30.6% 51.9% 43.1%
National City 32.8% 57.4% 49.5%
Oceanside 33.4% 55.1% 42.9%
San Diego 31.8% 49.5% 41.3%
San Marcos 35.3% 53.2% 42.4%
Santee 32.1% 47.4% 36.7%
Vista 34.6% 53.2% 44.3%
San Diego County 33.1% 51.8% 42.0%
Source: HUD Comprehensive Housing Affordability Strategy (CHAS) Data, 2012-2016 Estimates
July 14, 2020 Item #6 Page 95 of 211
J. Publicly Assisted Housing
The availability and location of public and affordable housing may be a fair housing concern. If such
housing is concentrated in one area of a community or a region, a household seeking affordable housing
is restricted to choices within a limited geographic area. Public/affordable housing and housing
assistance must be accessible to qualified households regardless of race/ethnicity, disability, or other
special characteristics.
1. Public Housing
Housing Authority of the County of San Diego (HACSD)
Two housing authorities in the San Diego region own and operate public housing units (Figure 13 on
page 91) – the Housing Authority of the County of San Diego (HACSD) and the San Diego Housing
Commission (SDHC). HACSD owns and administers public housing rental complexes (121 units), all of
which are located in the City of Chula Vista. Eligible residents must be a senior (62 years of age or
older), a disabled individual, or a low-income family and must live in one of the jurisdictions covered by
HACSD. The household's annual gross income must be at or below 50 percent of the San Diego AMI.
As of August 2019, 117 households were being assisted by HACSD. As shown in Table 43, Hispanic
and White-headed households make up the majority of households assisted.
San Diego Housing Commission (SDHC)
As federal subsidies to operate and maintain public housing began decreasing, and City-owned units
became operationally restrictive and inefficient, SDHC opted out of the Conventional Public Housing
Program in 2007 (which provided for the upkeep of 1,366 units). Through a landmark agreement, the
U.S. Department of Housing and Urban Development (HUD) transferred ownership and operating
authority for these units to SDHC, which then leveraged the equity in these properties to create or
preserve 810 additional affordable rental housing units. SDHC now owns the converted units and
operates them as rent-restricted affordable rental housing units that are available at varying ranges of
affordable rents to households earning no greater than 80 percent of AMI.28 At the time of conversion
from public housing to SDHC ownership, residents of the units were awarded Section 8 Housing
Choice Vouchers, which enabled them to choose to remain in their current home or to move to another
rental property that would accept Housing Choice Vouchers. Approximately half of the residents at that
time moved to another unit and half remained in their existing unit. SDHC provides federal Housing
Choice Voucher rental assistance to more than 15,000 low-income households. SDHC retained a small
number of Public Housing units (currently 189 units). As of September 2019, 178 households were
being assisted by SDHC in Public Housing units. As shown in Table 43 Hispanic-headed and White
households make up the majority of households assisted in Public Housing.
28 San Diego Housing Commission, “Re-positioning of the San Diego Housing Commission’s Public Housing Portfolio.”
Housing Authority Report (November 9, 2006).
July 14, 2020 Item #6 Page 96 of 211
Table 42: Public Housing Units
Housing Authority Name Address Units
HACSD Towncentre Manor 434 F Street, Chula Vista, CA 91910 59 Units
HACSD Melrose Manor 1678 Melrose Avenue, Chula Vista, CA 91911 24 Units
HACSD L Street Manor 584 L Street, Chula Vista, CA 91911 16 Units
HACSD Dorothy Street Manor 778 Dorothy Street, Chula Vista, CA 91911 22 Units
SDHC Otay Villas 649 Picador Blvd., San Diego, CA 92154 78 Units
SDHC University Canyon North 2090 Via Las Cumbres, San Diego, CA 92111 36 units
SDHC Vista Verde 351 South 33rd Street, San Diego, CA 92113 40 units
SDHC Camulos 32222 Camulos St., San Diego, CA 92110 12 units
SDHC Mason 3919 Mason St, San Diego, CA 92110 8 units
SDHC 44th St 2420 44th St, San Diego, CA 92105 8 units
SDHC Trojan 5385-5389 Trojan Ave., San Diego, CA 92115 3 units
SDHC Valeta 4095 Valeta St, San Diego, CA 92110 4 units
Sources: San Diego Housing and Community Development, August 2019, San Diego Housing Commission, September 2019.
Table 43: Characteristics of Householders in Public Housing Units
Characteristics HACSD SDHC
Number Number
Senior/Disabled 76 66
Small Family 88 163
Large Family 27 15
Non-Hispanic 39 76
Hispanic 77 102
White 88 118
Black 14 50
American Indian 0 4
Asian/Pacific Islander 5 8
Total Households 117 178
Note: Values represent head of household characteristics. The count of White households includes Hispanic households. Data for non-
Hispanic Whites is not available. Householders may belong to more than one category. For example, a householder may be both a large
family householder and Hispanic.
Sources: Housing Authority of the County of San Diego, August 2019; San Diego Housing Commission, September 2019.
The number of persons on the waiting list for public housing far exceeds current capacity. HACSD
indicates that as of August 2019, there were 20,136 households on the waiting list. Over 40 percent of
waitlisted households were Hispanic and about one quarter were Black. Households with a disabled
head of household make up almost 20 percent of the waiting list. There are 76,749 households on the
SDHC public housing waiting list (September 2019). Over 25 percent of SDHC waitlisted households
included a disabled head of household; 36.1 percent of households are Hispanic and 28.6 percent are
Black. With the extremely limited capacity and the length of tenancy, it is unlikely that the
characteristics of the public housing residents would change substantially in the near future.
July 14, 2020 Item #6 Page 97 of 211
Table 44: Characteristics of Public Housing Waiting list (Households)
Characteristics HACSD SDHC
Number Percent Number Percent
Senior 2,225 11.0% 7,612 9.9%
Disabled 3,987 19.8% 19,743 25.7%
Family 10,454 51.9% 38,302 49.9%
Non-Hispanic 11,699 58.1% 44,595 58.1%
Hispanic 8,365 41.5% 27,678 36.1%
White 12,865 63.9% 39,121 51.0%
Black 4,710 23.4% 21,948 28.6%
American Indian 465 2.3% 1,599 2.1%
Asian/Pacific Islander 1,581 7.9% 4,871 6.3%
Total 20,136 100.0% 76,749 100.0%
Note: Values represent head of household characteristics. The count of White households includes Hispanic households. Data for non-
Hispanic Whites is not available.
Sources: Housing Authority of the County of San Diego, August 2019; San Diego Housing Commission, September, 2019.
2. Housing Choice Vouchers Program
The Section 8 Housing Choice Voucher (HCV) program is a rent subsidy program that helps low-
income families and seniors pay rents of private units. HCV tenants pay approximately 30 percent of
their income for rent, and the local housing authority pays the difference up to the payment standard
established by the housing authority. The program offers low-income households the opportunity to
obtain affordable, privately owned rental housing and to increase their housing choices. The owner’s
asking price must be supported by comparable rents in the area. The program participant pays any
amount in the excess of the payment standard.
Six Housing Authorities administer the HCV program for San Diego County residents:
Housing Authority of the City of Carlsbad administered 475 HCVs as of February 2020.
There are 401 households on the waiting list. The waitlist is closed as of April 2020.
Housing Authority of the City of Encinitas administered 97 vouchers as of February
2020. There are 956 households on the waiting list. The waitlist is open as of April 2020.
Housing Authority of the City of National City administered 1,123 vouchers as of September
2019. There are 3,458 households on the waiting list. The waitlist is open as of April 2020.
Housing Authority of the City of Oceanside 1,539 vouchers as of February 2020. There are
5,532 households on the waiting list. The waitlist is open as of April 2020.
San Diego Housing Commission (SDHC, City of San Diego) administered 15,591
vouchers as of September 2019. There are 98,376 households on the waiting list. The waitlist is
open as of April 2020.
Housing Authority of the County of San Diego (HACSD) administered 9,945 vouchers as
of August 2019. There are 36,337 households on the waiting list. The waitlist is indefinitely
open as of April 2020.
July 14, 2020 Item #6 Page 98 of 211
As of February 2020, 29,057 San Diego County households were receiving HCV Assistance, with 89
percent of all vouchers administered by HACSD or SDHC. Table 45 summarizes the race and ethnicity
of households assisted by the HCV program. A third of the county’s HCV recipients (34 percent) were
Hispanic and 22 percent were Black. Senior and/or disabled households represent a significant portion
of those assisted by the HCV program, making up 65 percent of all households receiving HCVs.
Due to the geographic disparity in terms of rents, concentrations of voucher use have occurred (Table
46). For example, the City of El Cajon represents about three percent of the county’s population but
more than eight percent of the HCV use. Furthermore, 27 percent (2,656 participants) of the 9,945
vouchers administered by HACSD are concentrated in the City of El Cajon.
Table 45: Housing Choice Voucher Recipients
Housing Authority Total Black Hispanic White Other Senior Disabled
City of Carlsbad 475 9.1% 21.7% 65.1% 4.2% 50.9% 54.5%
City of Encinitas 97 3.1% 21.6% 73.2% 2.1% 46.4% 27.8%
City of National City 1,123 5.7% 68.0% 82.0% 0.7% 12.2% 35.9%
City of Oceanside 1,539 16.0% 34.0% 76.0% 7.0% 11.6% 48.0%
San Diego Housing
Commission (SDHC) 15,878 28.6% 32.0% 53.3% 16.1% 14.5% 47.3%
County of San Diego
(HACSD) 9,945 16.6% 34.9% 78.8% 4.6% 39.9% 53.8%
Total 29,057 22.5% 34.3% 48.2% 10.8% 15.7% 49.2%
*Note: The count of White households includes Hispanic households. Data for non-Hispanic Whites is not available.
Source: Area Housing Authorities 2019/2020.
July 14, 2020 Item #6 Page 99 of 211
Table 46: Distribution of Housing Choice Voucher Recipients
Jurisdiction Vouchers % of All HCV % County
Population
Urban County
Coronado 18 0.1% 0.7%
Del Mar 1 0.0% 0.1%
Imperial Beach 404 1.3% 0.8%
Lemon Grove 360 1.1% 0.8%
Poway 109 0.3% 1.5%
Solana Beach 17 0.1% 0.4%
Unincorporated 1,545 4.9% 15.4%
Total Urban County 2,454 7.8% 19.8%
Entitlement Jurisdictions
Carlsbad 475 1.5% 3.4%
Chula Vista 2,436 7.7% 8.1%
El Cajon 2,656 8.4% 3.1%
Encinitas 97 0.3% 1.9%
Escondido 933 3.0% 4.6%
La Mesa 559 1.8% 1.8%
National City 1,123 3.6% 1.9%
Oceanside 1,539 4.9% 5.3%
San Diego 15,878 50.4% 42.4%
San Marcos 230 0.7% 2.9%
Santee 266 0.8% 1.7%
Vista 411 1.3% 3.0%
Total County 31,511 100.0% 100.0%
Note: Assisted households exceed allocations to a jurisdiction due to voucher use outside of
originating jurisdiction. SDHC’s Moving to Work flexibility and funding enable SDHC to
issue a higher number of vouchers than its baseline allocation to assist more families. Total
number of voucher use deviates slightly from Table 45 due to different timing of data
processing. Also, total number of voucher use deviates slightly
Sources: Area Housing Authorities 2019/2020.
In 2019, only 14 percent of metropolitan families with children nationwide that received rent subsidies
through HUD lived in low-poverty neighborhoods and only five percent lived in high-opportunity
neighborhoods.29 To help with the de-concentration of HCV use and allow households to locate
adequate housing at a location of their choice, SDHC’s Moving Forward (also known as Moving to
Work, or MTW) program works to provide families with tools to assist them to move from high-
poverty neighborhoods to low-poverty neighborhoods. The Choice Communities Initiative (a subset of
the Moving Forward program) provides families receiving federal rental assistance administered by
SDHC the opportunity to live in neighborhoods in the City of San Diego that offer a broader selection
of schools and employment opportunities. SDHC created the Choice Communities Initiative in 2010
and expanded it in 2018. To increase housing opportunities through this initiative and to assist as many
low-income families as possible, SDHC updated the payment standards that are used to determine the
29 Mazzara, A. & Knudsen, B. (January 2019). Where families with children use housing vouchers: A comparative look at
the 50 largest metropolitan areas. Center on Budget and Policy Priorities, Poverty and Race Research Action Council.
July 14, 2020 Item #6 Page 100 of 211
amount of rental assistance each family receives. SDHC divided City of San Diego ZIP Codes into three
groups, each with its own payment standards: Choice Communities, Enterprise Communities, and
Signature Communities. Higher payment standards are set in Choice or Enterprise Communities, where
rental costs would typically be higher.Families moving to Choice or Enterprise Communities are eligible
for no-interest security deposit loans and assistance from SDHC’s Mobility Counseling Program.
Another important issue with the HCV program is the decreasing number of landlords willing to accept
vouchers. In a tight housing market, landlords are typically able to capture high rents for the units and
less likely to participate in government programs that place restrictions on rents, policies, and quality
standards. Primarily in economically depressed neighborhoods, where the housing and neighborhood
conditions are less than ideal, voucher recipients are most likely to find rental units that accept voucher
payments. With owners opting out in more integrated neighborhoods, tenants will be increasingly
confined to low-income areas, defeating the original purpose of the program. Another issue that related
to the HCV program is the amount of time it takes voucher recipients to find a unit. On average, it takes
about two months for voucher recipients to find a unit after the issuance of their voucher. According to
the San Diego Area Housing Commissions, approximately 70 to 80 percent of householders successfully
find a unit with their voucher. Table 47 summarizes the Housing Choice Voucher use metrics for the
San Diego Area Housing Authorities.
Since the demand for housing assistance often exceeds the limited resources available, long waiting
periods are common. The amount of time spent on the waiting list often varies, but the wait for rental
assistance after a family is placed on the waiting list may be 10 or more years. These wait times can
disproportionately impact seniors. As of February 2020, there were over 145,000 on the HCV waiting
list (Table 48).
In 2019, the State passed SB 329 that prohibits source of income discrimination. Landlords cannot deny
an applicant for rental housing based on the use of public assistance for rents. Presumably, the voucher
use would increase, the time to locate a property accepting HCV would decrease, and a HCV recipient’s
locational choices would be expanded.
July 14, 2020 Item #6 Page 101 of 211
Table 47: Housing Choice Voucher Use Metrics
Housing Authority
# of
Participating
Landlords
Time to Find Unit
after Voucher
Issuance
(Days)
% Households that
Successfully Find
Unit
# of Port-Out
Households
Housing Authority of the
City of Carlsbad See Note 5 See Note 5 See Note 5 See Note 5
Housing Authority of the
City of Encinitas 391 68 70% 1
Housing Authority of the
City of National City 480 44 See Note 2 8
Housing Authority of the
City of Oceanside 540 60 76% 12
San Diego Housing Commission
(SDHC, City of San Diego) 5,735 51 See Note 3 101
See Note 4
Housing Authority of the County of
San Diego (HACSD) 3,427 60 80% 176
Note 1: These landlords only own one rental unit and it is rented to the HCV participant
Note 2: The Housing Authority of the City of National City reported that 13 households had lost their HCV in the last 6 months
(November 2019-April 2020).
Note 3: The SDHC reported that approximately 4% of new admission vouchers issued result in the family not utilizing the rental assistance
and either surrendering the voucher, letting it expire, or no longer keeping contact with the Housing Commission.
Note 4: Year-to-date Fiscal Year 2020 data.
Note 5: Data could not be provided by the Housing Authority of Carlsbad prior to the public review period. The data will be added to the
final draft of the AI.
Sources: San Diego Area Housing Authorities, April/May 2020.
Table 48: Housing Choice Voucher Waitlist
Housing Authority Total Black Hispanic White Other Senior Disabled
City of Carlsbad 401 2.9% 4.3% 24.0% 10.8% 16.1% 15.3%
City of Encinitas 956 12.0% 14.1% 67.5% 6.4% 32.6% 41.7%
City of National City 3,458 10.1% 66.3% 73.0% 32.0% 27.1% 24.0%
City of Oceanside 5,532 14.3% 34.1% 71.8% 13.9% 13.2% 19.2%
San Diego Housing
Commission (SDHC) 98,376 27.9% 35.0% 50.4% 21.7% 10.0% 23.9%
Count of San Diego
(HACSD) 36,337 20.0% 34.4% 66.8% 13.2% 13.3% 18.6%
Total 145,060 24.3% 34.1% 53.3% 18.9% 11.1% 21.8%
Sources: San Diego Area Housing Authorities 2019/2020.
July 14, 2020 Item #6 Page 102 of 211
Figure 13: Public Transit and Affordable Housing
July 14, 2020 Item #6 Page 103 of 211
3. Other Affordable Housing Projects
A number of developments countywide have set aside some or all of the units as affordable for low to
moderate-income households. Together these projects provide approximately 39,398 units of affordable
housing. The location of these units is shown on Figure 13.
As in typical urban environments throughout the country, lower- and moderate-income households tend
to live in higher density neighborhoods. However, as housing becomes increasingly costly to develop
due to limited land available, redevelopment of existing neighborhoods such as Little Italy, East Village
and other higher density areas have raised the debate about gentrification.
In general, the location of public/assisted housing is partly the result of economic feasibility.
Concentrations of affordable housing are located in central San Diego, Chula Vista, National City, and
Escondido. Close to 68 percent of all affordable units are located in these cities, much of that is in the
City of San Diego (55 percent). Figure 13 also shows that in the western/coastal areas, the distribution
of these units follows a somewhat similar pattern exhibited by the distribution of both low- and
moderate-income population and minority population. However, this is not true for the desert
communities where there is a lack of affordable housing resources but very few affordable housing
units.
The lack of affordable housing resources, compared to the magnitude of need, may become acute as the
population in the region increases, especially given that the housing market is not keeping pace with the
increasing population. According to the California Housing Partnership Corporation, San Diego County
needs 143,800 more affordable rental homes to meet current demand.30 Furthermore, funding sources
(such as Tax Credits and Affordable Housing and Sustainable Communities) for affordable housing
developments may inadvertently contribute to the concentration of affordable housing in transit-
oriented neighborhoods with high-density developments.
K. Licensed Community Care Facilities
Persons with special needs, such as seniors and those with disabilities, must also have access to housing
in a community. Community care facilities provide a supportive housing environment to persons with
special needs in a group situation. Restrictions that prevent this type of housing represent a fair housing
concern. While affordability is not a fair housing issue per se, stakeholders indicated that these facilities
are often only available to wealthy persons.
According to the California Department of Social Services, Community Care Licensing Division, there
were approximately 593 State-licensed residential care facilities for the elderly, 401 adult residential
facilities, and 60 adult day care facilities throughout the county as of August 2019. These licensed care
facilities had a combined capacity of just over 28,000 beds. The location of the various licensed care
facilities in San Diego County in 2019 is shown on Figure 14. Most of the community care facilities
within the county were located within the larger incorporated cities. There was a noticeable presence of
facilities in the unincorporated areas, specifically those surrounding the incorporated cities. However,
since most of the county’s population is located within the incorporated cities, residents living in
30 California Housing Partnership Corporation. “San Diego County’s Housing Emergency and Proposed Solutions” (May 2018)
July 14, 2020 Item #6 Page 104 of 211
unincorporated areas would have to travel a great distance to access the region’s inventory of care
facilities.
Table 49 provides a tabulation of capacity of licensed care facilities for special needs persons by
jurisdiction in 2019. The ratio of beds per 1,000 persons is used to identify concentration of residential
care facilities. Licensed care facilities in San Diego County were most concentrated in La Mesa,
Carlsbad, Escondido, and Lemon Grove and were least concentrated in Imperial Beach and Del Mar.
The Cities of San Diego, Escondido, Chula Vista, and El Cajon had the greatest number of facilities. A
high concentration of community care facilities corresponds with the highest proportion of elderly
population only for La Mesa. On the other hand, the Urban County jurisdictions of Coronado, Del Mar,
and Solana Beach have the highest proportion of senior population but a low concentration of care
facilities. These communities also have the highest median age in the County.
Table 49: Licensed Community Care Facilities by Jurisdiction
Jurisdiction
Number
of
Facilities
Capacity % Senior
Population
Median Age
Zoning
Compliant With
Lanterman Act Beds Beds/1,000
Population
Urban County
Coronado 1 120 5.0 18.40% 34.2 Yes
Del Mar 1 6 1.3 20.80% 43.5 Yes
Imperial Beach 2 38 1.4 9.00% 28.6 Yes
Lemon Grove 17 501 18.4 11.20% 34.7 Yes
Poway 39 373 7.4 12.30% 36.9 Yes
Solana Beach 4 148 10.6 18.70% 41.6 Yes
Unincorporated 168 3,262 6.3 12.80% N/A Yes
Total Urban County 232 4,448 6.7 18.40% 34.2 --
Entitlement Jurisdictions
Carlsbad 29 2,240 19.4 14.00% 38.9 Yes
Chula Vista 73 2,304 8.5 10.00% 33 Yes
El Cajon 98 1,753 16.6 11.00% 31.9 Yes
Encinitas 12 551 8.7 12.80% 37.9 Yes
Escondido 133 2,918 19.1 10.50% 31.2 Yes
La Mesa 35 1,243 20.4 14.20% 37.3 Yes
National City 18 716 11.5 10.60% 28.7 Yes
Oceanside 56 1,608 9.0 12.90% 33.3 Yes
San Diego 349 7,798 5.5 10.70% 32.5 Yes
San Marcos 32 1,166 11.9 10.20% 32.1 Yes
Santee 16 179 3.1 10.70% 34.8 Yes
Vista 72 1,207 11.8 9.20% 30.3 Yes
Total County 1,155 28,131 8.4 11.40% 33.2
Source: State of California Department of Social Services, Community Care Licensing Division, January 2020.California Department of
Finance, Population Estimates (E5), 2019.
July 14, 2020 Item #6 Page 105 of 211
Figure 14: Licensed Care Facilities
July 14, 2020 Item #6 Page 106 of 211
L. Accessibility to Opportunities
Having access to quality jobs and effective public transportation helps facilitate a good quality of life and
improved life outcomes. Unfortunately, research has shown that racial and ethnic minorities, individuals
with disabilities, and other protected classes often have restricted access to these vital amenities. This
section addresses access to public transit and employment (Exposure to Adverse Community Factors,
inclusive of Public Schools, is addressed in the next Section).
1. Public Transit
Access to public transit is of paramount importance to households affected by low incomes and rising
housing prices. Public transit should strive to link lower income persons, who are often transit
dependent, to major employers where job opportunities exist. Access to employment via public
transportation can reduce welfare usage and increase housing mobility, which enables residents to locate
housing outside of traditionally low-income neighborhoods.31 The lack of a relationship between public
transit, employment opportunities, and affordable housing may impede fair housing choice. Persons
who depend on public transit may have limited choices regarding places to live. In addition, seniors and
disabled persons also often rely on public transit to visit doctors, go shopping, or attend activities at
community facilities. Public transit that provides a link between job opportunities, public services, and
affordable housing helps to ensure that transit-dependent residents have adequate opportunity to access
housing, services, and jobs.
The San Diego Association of Governments (SANDAG) is the Regional Transportation Planning
Authority responsible for planning and allocating local, state, and federal funds for the region's
transportation network. Two primary agencies are responsible for transit operations and services in the
county: Metropolitan Transit System (MTS) and the North County Transit District (NCTD). Transit
services provided by these agencies include commuter and light rail, fixed-route bus service, demand-
response service, and paratransit. Transit services are primarily provided to the larger, more urbanized
communities, although limited services are available in unincorporated areas. In addition, tribal
governments operating casinos and non-profit agencies also provide transit services for their clients and
customers. The NCTD and MTS also own and maintain the main rail line along the coast from
downtown San Diego to the Orange County line, which is shared between Amtrak intercity, COASTER,
and Metrolink commuter passenger rail services. NCTD also owns the rail corridor between Oceanside
and Escondido, operating SPRINTER light rail service. Figure 15 illustrates the transit routes in relation
to employment centers.
As shown in Figure 15, public transit providers serve large portions of the western side of the county.
In particular, transit use is higher in parts of the region where the greatest investment in transit service
has been made: the north coastal, central and south bay regions of the county. Almost all major
employment centers in San Diego are served by some form of public transit. However, having regional
access to jobs by means of public transit does not necessarily translate into stable employment. Low-
income workers, especially female heads of household with children, have unique travel patterns that
may prevent them from obtaining work far from home, regardless of access to public transit. Women in
general are disproportionately responsible for household-supporting activities such as trips to grocery
31 Ong, Paul and Evelyn Blumenberg, “Job Accessibility and Welfare Usage: Evidence from Los Angeles”. UCLA
Department of Policy Studies, (1998).
July 14, 2020 Item #6 Page 107 of 211
stores or accompanying young children to and from schools. Women using public transit are often
limited to looking for employment near home, allowing them time to complete these household-
sustaining trips.32 The Center for Housing Policy33 has done extensive research showing that the real
cost of housing includes the cost of a household’s daily commute to work, and typically low income
households spend a much higher proportion of after-tax income on transportation – about one-third –
than the average household.34
2. Major Employers
As one of the major metropolitan areas in the country, San Diego County has a diverse economy. The
San Diego County population and employment growth rates typically correlate to national economic
cycles and are sensitive to military spending. Military employment is still concentrated in the region as
San Diego County is home to major naval bases and the U.S. Marine base at Camp Pendleton. San
Diego is the headquarters of the U.S. Navy's Eleventh Naval District and is the Navy's principal location
for West Coast and Pacific Ocean operations. Naval Base San Diego is the principal home to the Pacific
Fleet. Naval Air Station (NAS) North Island is located on the north side of Coronado, and is the
headquarters for Naval Air Forces and Naval Air Force Pacific, the bulk of the Pacific Fleet's helicopter
squadrons, and part of the West Coast aircraft carrier fleet. Marine Corps Base Camp Pendleton is the
major west coast base of the United States Marine Corps and serves as its prime amphibious training
base.
Major employers, organizations with the largest number of employees, are mostly located throughout
the Central Coastal and South Bay sub-regions of San Diego County. Major employers in the region
include colleges, university campuses, military, federal and state government, and hospitals and medical
centers. Inland/desert areas are still relatively scarce with regard to employment opportunities. The
closest major employers to the inland/desert areas are the eight Indian casino/gaming/lodging centers.
Because of its location along the Mexican border and adjacent to the Pacific Ocean, international trade
is a major economic strength for the region. The border between San Diego and Mexico is the busiest
in the world and the San Diego Port contributes a significant number of jobs to the region.
Figure 15 shows that public transit routes provide adequate access to employment centers on the
western side of the county. In the eastern inland areas, public transit access and major employers are
scarce.
32 Blumenberg, Evelyn. “Reverse Commute Transit Programs and Single Mothers on Welfare: A Policy Mismatch?”,
Institute of Transportation Studies, Volume 1 Number 2, (December 2002).
33 Lipman, Barbara J. “A Heavy Load: The Combined Housing and Transportation Burdens of Working Families”. Center
for Housing Policy, (October 2006).
34 Giuliano, Genevieve. “The Role of Public Transit in the Mobility of Low Income Households”. School of Policy,
Planning, and Development, University of Southern California (May 2001).
July 14, 2020 Item #6 Page 108 of 211
Table 50: Major Employers - San Diego County
Name Address City Industry Employer Size
Class
Naval Base San Diego 32nd St Naval Station San Diego Federal Government-
National Security
10,000+
Barona Resort & Casino 1932 Wildcat Canyon
Rd. Lakeside Casinos 1,000-4,999
Ceasar Entertainment 33750 Valley Center
Rd.
Valley
Center
Swimming Pool
Construction, Dealers,
& Designers
1,000-4,999
Employees' Association-
SDG&E 8330 Century Park Ct. San Diego Associations 1,000-4,999
General Dynamics NASSCO 2798 Harbor Dr. San Diego Ship Builders &
Repairers (mfrs)
1,000-4,999
Illumina Inc 5200 Illumina Way San Diego Biotechnology
Products & Services
1,000-4,999
Kaiser Permanente Vandever
Med 4405 Vandever Ave. San Diego Physicians & Surgeons 5,000-9,999
Kaiser Permanente Zion Med
Ctr 4647 Zion Ave. San Diego Hospitals 1,000-4,999
MCCS MCRD (Marine Corps
Community Services Marine
Corps Recruit Depot)
3800 Chosin Ave. San Diego Towing-Marine
10,000+
Merchants Building
Maintenance 9555 Distribution Ave. San Diego Janitor Service 1,000-4,999
Palomar Pomerado Health
Rehab
555 E Valley Pkwy 5th
Floor Escondido Rehabilitation Services 1,000-4,999
Rady Children's Hospital 3020 Children's Way. San Diego Hospitals 1,000-4,999
San Diego Community
College
3375 Camino Del Rio
S. San Diego Junior-Community
College-Tech Institutes
5,000-9,999
San Diego County Sheriff John F. Duffy
Administrative Center San Diego Police Departments 1,000-4,999
Scripps Mercy Hosp Sn Diego 4077 Fifth Ave. San Diego Hospitals 1,000-4,999
Scripps Research Institute 10550 N Torrey Pines
Rd. La Jolla Laboratories-Research
& Development
1,000-4,999
Seaworld San Diego 500 Sea World Dr. San Diego Water Parks 1,000-4,999
Sharp Mary Birch Hospital 3003 Health Center Dr. San Diego Hospitals 1,000-4,999
Sharp Memorial Hospital 7901 Frost St. San Diego Hospitals 1,000-4,999
Sony Electronics 16535 Via Esprillo San Diego Electronic Equipment
& Supplies-Retail
1,000-4,999
UC San Diego Health 200 W Arbor Dr. San Diego Health Care
Management
5,000-9,999
University of California San
Diego 9500 Gilman Dr. La Jolla University-College
Dept/Facility/Office
10,000+
US Navy Med Ctr-
Orthopedics
34800 Bob Wilson Dr
# 112 San Diego Clinics 1,000-4,999
Source: State of California Employment Development Department, 2020.
July 14, 2020 Item #6 Page 109 of 211
Figure 15: Transit Service and Major Employers
July 14, 2020 Item #6 Page 110 of 211
3. Affordable Housing and Public Transit
Limited access to public transit may counteract some of the benefits of affordable housing. Current
research indicates a strong connection between housing and transportation costs. Housing market
patterns in parts of California with job-rich city centers are pushing lower-income families to the
outskirts of urban areas, where no transit is available to connect them with jobs and services. In lower-
income communities with underserved city centers, many residents must commute out to suburban job-
rich areas. In an attempt to save money on housing, many lower-income households are spending
disproportionately higher amounts on transportation. A study conducted by the Center for Housing
Policy revealed that families who spend more than half of their income on housing spend only eight
percent on transportation, while families who spend 30 percent or less of their income on housing
spend almost 24 percent on transportation.35 This equates to more than three times the amount spent by
persons living in less affordable housing.
According to the Reconnecting America organization, “for low-income families, the ability to live in an
affordable home near good public transportation translates into improved access to healthcare,
education and employment opportunities, and reduced commuting costs.” 36 Given the benefits of living
close to transit, locating assisted housing near public transportation would increase the quality of life of
the assisted householders. Figure 16 illustrates the location of the county’s affordable housing stock in
relation to regional transit services. Many affordable housing projects are located in close proximity to
regional transit routes, with the exception of the eastern portions of the county, where few assisted units
are located.
35 Sard, Barbara and Rice, Douglas. “Creating Opportunity for Children How Housing Location Can Make a Difference”.
Center on Budget and Policy Priorities. (October 2014).
36 The National Housing Trust Reconnecting America. “Preserving Affordable Housing Near Transit.” Enterprise
Community Partners (2010).
July 14, 2020 Item #6 Page 111 of 211
Figure 16: Transit Service and Publicly Assisted Housing
July 14, 2020 Item #6 Page 112 of 211
M. ADA-Compliant Public Facilities (Section 504
Assessment)
Access to civic life by people with disabilities is a fundamental goal of the Americans with Disabilities
Act (ADA). To ensure that this goal is met, Title II of the ADA requires State and local governments to
make their programs and services accessible to persons with disabilities. This requirement not only
extends to physical access at government facilities, programs, and events, but also to policy changes that
governmental entities must make to ensure that all people with disabilities can take part in, and benefit
from, the programs and services of State and local governments.
The development of an ADA Transition Plan is a requirement of the federal regulations implementing
the Rehabilitation Act of 1973, which require that all organizations receiving federal funds make their
programs available without discrimination to persons with disabilities. The Transition Plan (also known
as a Program Access Plan) identifies physical obstacles that limit the accessibility of facilities to
individuals with disabilities, describes the prescribed methods to make the facilities accessible, provides a
schedule for making the access modifications, and identifies the public officials responsible for
implementation of the transition plan.
Carlsbad, Encinitas, Imperial Beach, National City, San Diego (City), San Diego (County), and Santee
provided updates for this report. The County of San Diego has indicated that their government
facilities are ADA-compliant. The City of San Diego conducted a Self-Evaluation as mandated under the
ADA. From that analysis, a required transition plan was created which included 212 high use city
facilities that needed physical modifications to make them accessible. In 2009 the City updated its
Transition Plan and identified 182 additional high-use public facilities requiring architectural barrier
removal. Since the 2009 update the City has completed 34 of these facilities; an additional 32 facilities
are funded and 116 remain unfunded. Both the County of San Diego and the City of San Diego
continue to evaluate their public facilities for compliance with current accessibility regulations and
update its list of projects needing barrier removal. National City indicated its facilities are not ADA
compliant, however the City has a transition plan in place that was adopted in June 2019. Santee also
indicated that its City facilities are not fully ADA Compliant, however, there are plans to make all of the
City facilities compliant, has an approved ADA Transition Plan, and has made numerous ADA
improvements to City Parks, Fire Stations, and other facilities, including City Hall. The City of Carlsbad
and City of Imperial Beach indicated that their government facilities are ADA-compliant, as all
improvements identified in their ADA Transitions Plans are complete. The City of Encinitas indicated
that they have an approved Self-Evaluation and ADA Transition Plan.
July 14, 2020 Item #6 Page 113 of 211
Table 51: ADA-Compliant Public Facilities
Jurisdiction ADA Transition Plan Facilities ADA Compliant
Urban County
Coronado
Del Mar
Imperial Beach Yes Yes
Lemon Grove
Poway
Solana Beach
Entitlement Cities
Carlsbad Yes Yes
Chula Vista
El Cajon
Encinitas Yes In progress
Escondido
La Mesa
National City Yes In progress
Oceanside
San Diego Yes In progress
San Marcos
Santee Yes In progress
Vista
San Diego County Yes
Note: Jurisdictions with empty cells did not provide information regarding ADA compliance.
N. Exposure to Adverse Community Factors
Communities must consider fair housing when addressing exposure to community factors adverse to
their quality of life and poverty mitigation because either the problems themselves, or solution to the
problems, may have a disproportionate negative effect on some residents. Community factors of
concern include disparities in access to opportunities affecting including public education,
transit/transportation, jobs/labor, and environmental health. Another concern are environmental risks
to vulnerable populations, including pregnant women, young children, and individuals with disabilities—
all of whom are protected under fair housing law.
1. Public Schools
Public schools within San Diego County are grouped by 23 elementary school districts, six high school
districts, 13 unified school districts, and five community college districts. The San Diego County Office
of Education provides a variety of services for these 42 school districts, 139 charter schools, and five
community college districts in the county.
July 14, 2020 Item #6 Page 114 of 211
As part of President Johnson’s “War on Poverty,” the Elementary and Secondary Education Act
(ESEA), passed in 1965. The ESEA is often regarded as the most far-reaching federal legislation
affecting education ever passed by Congress. The act is an extensive statute that funds primary and
secondary education, while emphasizing equal access to education and establishing high standards and
accountability. A major component of ESEA is a series of programs typically referred to as “Title I”.
Title I provides financial assistance to states and school districts to meet the needs of educationally at-
risk students. To qualify as a Title I school, a campus typically must have around 40 percent or more of
its students coming from families who are low-income. The goal of Title I is to provide extra
instructional services and activities which support students identified as failing or most at risk of failing
the state’s challenging performance standards in mathematics, reading, and writing.
Figure 17 and Figure 18 show the location of Title I schools in San Diego County. While Title I schools
are not located in all cities and communities, the geographic distribution of Title I schools generally
matches the geographic distribution of minorities and low- and moderate-income persons in the county.
Addressing access to higher achieving schools is important, as studies have shown that low-income
children who live in low-poverty neighborhoods and consistently attend high-quality schools perform
significantly better academically than those who do not.37
37 Sard, Barbara and Rice, Douglas. “Creating Opportunity for Children How Housing Location Can Make a Difference”.
Center on Budget and Policy Priorities. (October 2014).
July 14, 2020 Item #6 Page 115 of 211
Figure 17: Distribution of Title I Schools and Low- and Moderate-Income Areas
July 14, 2020 Item #6 Page 116 of 211
Figure 18: Distribution of Title I Schools and Areas of Minority Concentration Area
July 14, 2020 Item #6 Page 117 of 211
2. Disparities in Access to Opportunity
HUD has developed a series of indices for the purpose of fair housing assessment to help inform
communities about disparities in access to opportunity. HUD-provided index scores are based on
nationally available data sources and assess residents’ access to key opportunity assets in San Diego
County. These indices are only available to Entitlement Jurisdictions (with population over 50,000 and
receiving CDBG funds from HUD). For Urban County jurisdictions for which a HUD-provided index
is not provided, a similar analysis as that provided by the indices was conducted using comparable
information. For example, for the Low Poverty Index, the poverty status of the population provided by
the 2013-2017 American Community Survey estimates were used.
Table 52 provides index scores or values (the values range from zero to 100) for the following
opportunity indicator indices:
Low Poverty Index: The low poverty index captures poverty in a given neighborhood. The
poverty rate is determined at the census tract level. The higher the score, the less exposure
to poverty in a neighborhood.
School Proficiency Index: The school proficiency index uses school-level data on the
performance of 4th grade students on state exams to describe which neighborhoods have high-
performing elementary schools nearby and which are near lower performing elementary schools.
The higher the score, the higher the school system quality is in a neighborhood.
Labor Market Engagement Index: The labor market engagement index provides a summary
description of the relative intensity of labor market engagement and human capital in a
neighborhood. This is based upon the level of employment, labor force participation, and
educational attainment in a census tract. The higher the score, the higher the labor force
participation and human capital in a neighborhood.
Transit Trips Index: This index is based on estimates of transit trips taken by a family that
meets the following description: a three-person single-parent family with income at 50% of the
median income for renters for the region (i.e. the Core-Based Statistical Area (CBSA)). The
higher the transit trips index, the more likely residents in that neighborhood utilize
public transit.
Low Transportation Cost Index: This index is based on estimates of transportation costs for a
family that meets the following description: a three-person single-parent family with income at
50 percent of the median income for renters for the region/CBSA. The higher the index, the
lower the cost of transportation in that neighborhood.
Jobs Proximity Index: The jobs proximity index quantifies the accessibility of a given
residential neighborhood as a function of its distance to all job locations within a region/CBSA,
with larger employment centers weighted more heavily. The higher the index value, the
better the access to employment opportunities for residents in a neighborhood.
Environmental Health Index: The environmental health index summarizes potential exposure
to harmful toxins at a neighborhood level. The higher the index value, the less exposure to
toxins harmful to human health. Therefore, the higher the value, the better the
environmental quality of a neighborhood, where a neighborhood is a census block-
group.
July 14, 2020 Item #6 Page 118 of 211
As shown in Table 52, in San Diego County, Native American, Black, and Hispanic residents were more
likely (compared to other racial/ethnic groups) to be impacted by poverty, limited access to proficient
schools, lower labor participation rate. Black residents were most likely to reside in areas with the
lowest environmental quality levels, the lowest accessibility to employment centers, and the lowest cost
of transportation. Black and Asian residents scored highest as most likely to utilize public transportation.
Additional detailed breakdowns by Entitlement Jurisdiction are shown in Table 52. For the smaller
jurisdictions (with population less than 50,000) participating in the HUD programs as part of the Urban
County, the report utilizes other sources of data to provide similar analysis.
July 14, 2020 Item #6 Page 119 of 211
Table 52: Opportunity Indicators by Race/Ethnicity – Entitlement Jurisdictions
Low
Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
San Diego County
Total Population
White, Non-Hispanic 61.91 64.61 48.93 70.89 55.42 52.89 54.81
Black, Non-Hispanic 51.74 53.72 35.21 78.11 63.07 49.79 43.66
Hispanic 51.71 53.49 37.87 75.68 60.19 51.28 47.15
Asian or Pacific Islander, Non-Hispanic 65.75 64.96 55.06 78.19 59.63 51.68 47.98
Native American, Non-Hispanic 50.41 48.00 31.93 54.60 47.68 56.76 67.85
Population below federal poverty line
White, Non-Hispanic 51.94 58.45 41.93 72.79 58.18 52.36 51.65
Black, Non-Hispanic 42.16 42.08 33.28 86.15 69.30 48.05 36.75
Hispanic 39.99 46.71 32.57 79.68 65.00 48.70 42.87
Asian or Pacific Islander, Non-Hispanic 60.01 60.14 48.58 75.21 59.26 51.72 50.68
Native American, Non-Hispanic 45.10 37.12 34.42 64.82 54.52 51.65 57.91
Carlsbad
Total Population
White, Non-Hispanic 56.98 88.09 70.63 87.29 64.71 54.62 56.23
Black, Non-Hispanic 58.41 87.68 72.18 86.91 64.92 63.87 54.04
Hispanic 53.57 84.92 64.92 87.35 67.62 56.59 52.54
Asian or Pacific Islander, Non-Hispanic 58.22 89.63 73.27 87.17 64.04 57.91 56.49
Native American, Non-Hispanic 56.38 83.47 66.64 87.15 66.85 60.13 53.79
Population below federal poverty line
White, Non-Hispanic 54.04 86.83 67.87 87.02 66.3 54.77 54.96
Black, Non-Hispanic 46.85 93.95 70.88 86.44 57.14 47.44 58.41
Hispanic 48.35 82.09 61.14 87.85 69.88 60.68 50.51
Asian or Pacific Islander, Non-Hispanic 51.63 88.62 69.97 90.35 73.31 46.14 57.38
Native American, Non-Hispanic 31.00 86.82 68.00 92.00 75.00 50.36 71.00
July 14, 2020 Item #6 Page 120 of 211
Table 52: Opportunity Indicators by Race/Ethnicity – Entitlement Jurisdictions
Low
Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Chula Vista
Total Population
White, Non-Hispanic 65.41 69.32 48.41 83.96 64.09 52.89 39.92
Black, Non-Hispanic 62.25 69.74 47.89 86.1 66.52 55.89 38.15
Hispanic 54.71 64.74 38.93 87.71 69.38 53.35 35.32
Asian or Pacific Islander, Non-Hispanic 73.70 74.41 58.92 83.65 61.59 53.95 40.95
Native American, Non-Hispanic 56.87 66.29 40.33 86.75 68.86 55.53 37.19
Population below federal poverty line
White, Non-Hispanic 54.91 68.71 41.46 86.61 69.61 55.5 37.15
Black, Non-Hispanic 36.78 62.01 27.56 91.31 76.50 56.96 29.09
Hispanic 39.43 61.19 28.35 89.97 75.32 56.76 31.86
Asian or Pacific Islander, Non-Hispanic 46.94 62.93 35.44 88.98 71.40 46.31 30.76
Native American, Non-Hispanic 53.31 69.93 44.32 85.73 68.56 54.61 40.06
El Cajon
Total Population
White, Non-Hispanic 34.31 57.15 31.85 87.87 74.73 55.87 25.51
Black, Non-Hispanic 22.38 51.51 24.01 91.16 80.62 58.30 20.24
Hispanic 24.02 52.85 24.75 90.45 78.93 57.18 21.95
Asian or Pacific Islander, Non-Hispanic 30.57 54.15 29.31 88.97 76.95 57.27 23.22
Native American, Non-Hispanic 29.17 55.97 27.51 89.00 76.98 56.93 23.95
Population below federal poverty line
White, Non-Hispanic 19.39 52.91 20.82 91.51 80.07 55.85 22.47
Black, Non-Hispanic 11.70 49.66 15.47 92.94 83.40 63.33 17.01
Hispanic 17.74 52.63 21.92 91.58 81.06 58.48 20.62
Asian or Pacific Islander, Non-Hispanic 17.43 54.99 22.33 91.85 79.27 50.48 22.24
Native American, Non-Hispanic 12.14 56.01 11.98 94.35 85.6 56.03 15.43
July 14, 2020 Item #6 Page 121 of 211
Table 52: Opportunity Indicators by Race/Ethnicity – Entitlement Jurisdictions
Low
Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Encinitas
Total Population
White, Non-Hispanic 63.69 79.79 76.64 85.15 66.08 62.34 65.91
Black, Non-Hispanic 60.80 81.90 74.07 84.07 65.39 63.41 67.20
Hispanic 59.78 80.52 73.07 85.61 66.44 57.09 65.67
Asian or Pacific Islander, Non-Hispanic 63.94 79.74 75.98 84.26 64.83 63.57 66.08
Native American, Non-Hispanic 61.90 80.83 77.06 86.31 67.7 58.66 66.58
Population below federal poverty line
White, Non-Hispanic 62.73 81.38 77.22 85.19 67.46 65.58 66.43
Black, Non-Hispanic 40.00 94.94 54.00 73.00 53.00 59.69 70.00
Hispanic 49.48 83.75 73.41 87.92 70.29 57.08 67.57
Asian or Pacific Islander, Non-Hispanic 63.18 78.08 76.72 86.37 65.1 54.08 65.32
Native American, Non-Hispanic 31.00 86.82 68.00 92.00 75.00 50.36 71.00
Escondido
Total Population
White, Non-Hispanic 43.28 37.79 41.14 78.66 63.19 41.67 39.58
Black, Non-Hispanic 33.94 28.16 32.53 86.74 71.34 42.83 33.46
Hispanic 30.08 21.66 29.39 88.31 72.37 42.35 30.93
Asian or Pacific Islander, Non-Hispanic 42.64 34.36 39.52 80.57 64.68 40.38 38.63
Native American, Non-Hispanic 37.19 28.36 35.76 84.03 68.32 44.13 34.78
Population below federal poverty line
White, Non-Hispanic 35.98 32.2 37.19 84.22 68.56 42.83 35.4
Black, Non-Hispanic 26.28 22.15 31.14 88.59 76.63 42.18 30.13
Hispanic 25.71 20.75 26.71 90.17 75.36 46.89 27.52
Asian or Pacific Islander, Non-Hispanic 21.05 16.34 28.22 88.42 68.27 39.84 31.09
Native American, Non-Hispanic 28.73 22.45 26.37 89.23 75.52 28.60 32.84
July 14, 2020 Item #6 Page 122 of 211
Table 52: Opportunity Indicators by Race/Ethnicity – Entitlement Jurisdictions
Low
Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
La Mesa
Total Population
White, Non-Hispanic 61.16 68.68 60.78 89.24 78.00 57.47 30.71
Black, Non-Hispanic 55.07 61.30 55.90 90.02 78.98 59.59 29.24
Hispanic 58.63 64.56 58.06 89.57 78.42 58.95 29.82
Asian or Pacific Islander, Non-Hispanic 58.50 62.51 57.44 89.7 78.28 56.02 30.23
Native American, Non-Hispanic 58.04 63.49 56.41 89.72 78.17 58.13 29.70
Population below federal poverty line
White, Non-Hispanic 60.07 68.63 59.5 89.63 79.22 63.90 30.92
Black, Non-Hispanic 43.60 55.39 40.49 91.63 81.08 63.07 26.66
Hispanic 51.55 63.82 55.25 90.36 80.26 63.12 28.65
Asian or Pacific Islander, Non-Hispanic 55.39 65.15 53.25 90.82 79.48 58.08 30.81
Native American, Non-Hispanic 64.66 43.29 48.95 89.39 73.23 46.96 29.05
National City
Total Population
White, Non-Hispanic 26.34 43.72 23.61 72.63 73.64 69.90 37.58
Black, Non-Hispanic 23.89 43.73 21.65 75.24 75.84 65.29 36.49
Hispanic 21.74 39.84 22.83 87.27 78.85 52.60 36.83
Asian or Pacific Islander, Non-Hispanic 24.64 45.55 27.13 88.11 78.09 59.39 36.80
Native American, Non-Hispanic 23.95 41.65 21.48 74.45 75.35 65.53 37.15
Population below federal poverty line
White, Non-Hispanic 20.02 43.54 20.63 86.62 80.33 60.64 36.51
Black, Non-Hispanic 14.34 39.00 16.26 92.77 83.85 47.55 35.56
Hispanic 18.64 39.69 21.71 89.20 81.33 53.94 36.15
Asian or Pacific Islander, Non-Hispanic 18.99 46.55 33.29 92.66 83.71 66.3 36.44
Native American, Non-Hispanic 28.82 50.82 32.27 87.56 75.12 47.05 37.46
July 14, 2020 Item #6 Page 123 of 211
Table 52: Opportunity Indicators by Race/Ethnicity – Entitlement Jurisdictions
Low
Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Oceanside
Total Population
White, Non-Hispanic 53.73 50.45 45.6 86.58 65.37 46.16 42.91
Black, Non-Hispanic 50.82 49.21 40.33 87.26 65.64 43.06 41.48
Hispanic 45.20 42.52 36.15 87.80 67.19 38.18 40.28
Asian or Pacific Islander, Non-Hispanic 53.49 51.54 43.13 86.59 63.23 42.73 43.03
Native American, Non-Hispanic 48.60 43.64 39.83 87.25 67.76 46.11 41.52
Population below federal poverty line
White, Non-Hispanic 46.73 42.01 39.93 88.36 69.82 47.45 41.82
Black, Non-Hispanic 38.33 33.45 31.98 90.09 73.53 46.19 42.61
Hispanic 35.87 30.17 32.26 89.42 72.41 43.46 37.40
Asian or Pacific Islander, Non-Hispanic 51.67 50.85 39.48 87.25 61.54 41.53 43.14
Native American, Non-Hispanic 39.13 30.18 38.02 84.62 65.63 52.66 38.89
San Diego
Total Population
White, Non-Hispanic 67.86 67.39 75.24 89.49 74.41 53.52 43.16
Black, Non-Hispanic 42.82 43.19 40.74 88.67 76.29 44.98 34.94
Hispanic 38.13 40.65 39.45 89.92 76.98 44.50 31.79
Asian or Pacific Islander, Non-Hispanic 62.52 60.38 63.70 90.04 72.16 45.25 43.20
Native American, Non-Hispanic 56.84 55.62 58.86 87.99 77.15 52.11 36.63
Population below federal poverty line
White, Non-Hispanic 57.16 60.31 68.63 91.72 79.98 55.53 37.76
Black, Non-Hispanic 28.86 37.4 32.76 92.71 81.27 45.64 28.50
Hispanic 25.68 36.41 31.20 91.36 80.07 43.14 28.27
Asian or Pacific Islander, Non-Hispanic 56.10 57.91 62.52 92.72 80.36 50.92 37.26
Native American, Non-Hispanic 31.81 52.90 52.98 93.31 86.59 54.09 26.11
July 14, 2020 Item #6 Page 124 of 211
Table 52: Opportunity Indicators by Race/Ethnicity – Entitlement Jurisdictions
Low
Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
San Marcos
Total Population
White, Non-Hispanic 51.24 80.35 44.17 86.26 58.76 57.85 47.26
Black, Non-Hispanic 47.23 75.73 40.45 87.51 61.71 56.39 43.82
Hispanic 43.10 65.37 34.64 89.92 65.89 49.74 36.64
Asian or Pacific Islander, Non-Hispanic 45.83 78.76 44.33 86.13 58.59 55.01 47.72
Native American, Non-Hispanic 50.14 72.69 40.00 88.08 63.59 54.76 41.49
Population below federal poverty line
White, Non-Hispanic 46.98 76.51 41.72 86.81 61.55 54.93 44.75
Black, Non-Hispanic 48.95 72.59 41.78 89.36 63.89 52.96 41.71
Hispanic 36.20 58.52 33.06 91.14 69.37 45.58 33.97
Asian or Pacific Islander, Non-Hispanic 40.97 63.27 34.36 90.16 69.26 58.82 34.83
Native American, Non-Hispanic 58.46 86.70 44.35 86.76 64.26 69.49 47.15
Santee
Total Population
White, Non-Hispanic 69.83 78.14 49.29 84.84 64.16 44.37 47.24
Black, Non-Hispanic 68.69 79.70 40.44 83.79 66.05 56.11 45.21
Hispanic 69.41 78.36 47.70 84.77 64.75 48.32 46.15
Asian or Pacific Islander, Non-Hispanic 69.90 79.62 47.36 84.22 64.42 49.78 46.20
Native American, Non-Hispanic 70.35 77.07 48.44 84.06 63.91 43.52 47.93
Population below federal poverty line
White, Non-Hispanic 65.71 77.7 48.15 84.63 64.63 48.01 44.73
Black, Non-Hispanic 69.79 77.16 56.49 85.38 61.96 63.50 49.63
Hispanic 69.44 79.81 49.54 83.95 64.00 48.99 46.61
Asian or Pacific Islander, Non-Hispanic 75.16 74.24 55.79 86.75 66.23 50.10 46.26
Native American, Non-Hispanic 66.24 83.59 61.38 81.16 59.21 30.44 53.33
July 14, 2020 Item #6 Page 125 of 211
Table 52: Opportunity Indicators by Race/Ethnicity – Entitlement Jurisdictions
Low
Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Vista
Total Population
White, Non-Hispanic 42.50 45.98 33.25 87.97 66.11 53.16 46.57
Black, Non-Hispanic 41.84 42.91 29.49 89.43 68.67 52.55 44.7
Hispanic 37.97 32.22 26.59 90.00 68.53 48.01 41.73
Asian or Pacific Islander, Non-Hispanic 43.33 47.70 33.89 88.5 66.78 54.41 45.63
Native American, Non-Hispanic 39.87 39.52 28.71 89.24 67.84 53.47 43.49
Population below federal poverty line
White, Non-Hispanic 39.91 39.30 30.72 88.80 67.05 50.27 45.17
Black, Non-Hispanic 30.99 49.43 34.35 89.18 67.87 55.12 45.40
Hispanic 32.99 29.16 24.82 90.26 68.64 48.35 40.60
Asian or Pacific Islander, Non-Hispanic 40.76 51.93 30.98 89.65 69.40 56.11 46.67
Native American, Non-Hispanic 39.96 24.06 26.20 89.68 65.39 51.54 51.34
Source: Affirmatively Furthering Fair Housing (AFFH) Data and Mapping Tool (AFFH-T), 2017
July 14, 2020 Item #6 Page 126 of 211
The following tables indicate similar opportunity characteristics for the Urban County jurisdictions. As
shown in Table 53, the cities of Imperial Beach (19.0 percent) and Lemon Grove (13.8 percent) had the
highest population ratio below the poverty level. In the Urban County, generally American
Indian/Alaskan Native and Black or African American residents had the highest poverty rates compared
to other racial/ethnic groups.
According to Table 54, a large percentage of schools in Imperial Beach, Lemon Grove and Solano
Beach are considered Title I schools, and help low-achieving children meet state standards in core
academic subjects. These schools coordinate and integrate resources and services from federal, state, and
local sources. To be considered for Title 1 school funds, at least 40 percent of the students must be
considered low-income.
When considering labor market participation, the unemployment rates of the Urban County show that
the cities of Imperial Beach and Lemon Grove had slightly higher unemployment rates than overall San
Diego County (2.8 percent).
Table 54 shows that the majority of Urban County city residents had commutes under 30 minutes.
AllTransit explores metrics that reveal the social and economic impact of transit, specifically looking at
connectivity, access to jobs, and frequency of service. According to the data provided, the cities of
Lemon Grove (7.9), Imperial Beach (6.7), and Coronado (6.6) scored the highest, illustrating a moderate
combination of trips per week and number of jobs accessible that enable a moderate number of people
to take transit to work (Table 55).
July 14, 2020 Item #6 Page 127 of 211
Table 53: Opportunity Indicator - Poverty Rate – Urban County Participating Jurisdictions
Race/Ethnicity
Coronado Del Mar Imperial Beach
Total
Below
Poverty
Level
Percent
Below
Poverty
Level
Total
Below
Poverty
Level
Percent
Below
Poverty
Level
Total
Below
Poverty
Level
Percent
Below
Poverty
Level
Population for whom
poverty status is determined 20,330 1,082 5.3% 4,321 300 6.9% 27,001 5,117 19.0%
White alone 18,610 961 5.2% 4,146 274 6.6% 19,203 3,636 18.9%
Black or African
American alone 188 11 5.9% 21 0 0.0% 1,067 334 31.3%
American Indian and
Alaska Native alone 53 0 0.0% 0 0 - 317 72 22.7%
Asian alone 613 44 7.2% 112 26 23.2% 2,206 304 13.8%
Native Hawaiian and
Other Pacific Islander
alone
23 0 0.0% 0 0 - 195 0 0.0%
Some other race alone 150 12 8.0% 0 0 - 1,524 231 15.2%
Two or more races 693 54 7.8% 42 0 0.0% 2,489 540 21.7%
Race/Ethnicity
Lemon Grove Poway Solana Beach
Total
Below
Poverty
Level
Percent
Below
Poverty
Level
Total
Below
Poverty
Level
Percent
Below
Poverty
Level
Total
Below
Poverty
Level
Percent
Below
Poverty
Level
Population for whom
poverty status is determined 26,422 3,646 13.8% 49,353 3,331 6.7% 13,340 656 4.9%
White alone 17,161 1,879 10.9% 37,575 2,390 6.4% 11,148 454 4.1%
Black or African
American alone 3,547 827 23.3% 607 55 9.1% 81 14 17.3%
American Indian and
Alaska Native alone 146 82 56.2% 461 219 47.5% 120 24 20.0%
Asian alone 1,527 104 6.8% 6,480 263 4.1% 685 75 10.9%
Native Hawaiian and
Other Pacific Islander
alone
122 22 18.0% 18 0 0.0% 0 0 -
Some other race alone 2,205 247 11.2% 1,670 231 13.8% 614 32 5.2%
Two or more races 1,714 485 28.3% 2,542 173 6.8% 692 57 8.2%
Source: American Community Survey 2013-2017, S1701
July 14, 2020 Item #6 Page 128 of 211
Table 54: Opportunity Indicators – School Proficiency, Labor Market, Job Proximity –
Urban County Participating Jurisdictions
Opportunity
Indicator Coronado Del Mar Imperial
Beach
Lemon
Grove Poway Solana
Beach
School Proficiency
Total Title I Schools 1 1 5 5 4 3
Total Schools 5 2 6 5 12 4
% of Schools 20.0% 50.0% 83.3% 100.0% 33.3% 75.0%
Unemployment Rate
Annual Rate 2.2% 1.5% 3.5% 3.2% 2.2% 1.4%
Job Proximity
<29 mins. 79.3% 75.7% 51.5% 63.7% 59.6% 70.5%
30-59 mins. 16.2% 16.0% 41.8% 29.2% 35.3% 24.6%
60 mins. or more 4.5% 8.3% 6.7% 7.1% 5.1% 4.9%
Source: California Department of Education, Public Schools and Districts Data File 18-19, Feb 2020; American Community Survey 2013-
2017, S0801; CalEnviroScreen 3.0 Results (June 2018 Update).
Table 55: Opportunity Indicators – Transit – Urban County Participating Jurisdictions
All Transit
Performance
Score
Transit Trips Per
Week within 1/2
Mile
Jobs
Accessible in
30-min trip
Commuters
Who Use
Transit
Transit Routes
within 1/2 Mile
Coronado 6.6 916 86,924 2.30% 1
Del Mar 5.1 738 58,060 0.03% 2
Imperial Beach 6.7 1,188 31,400 4.25% 3
Lemon Grove 7.9 1,274 75,237 4.45% 5
Poway 3.1 432 15,312 1.29% 2
Solano Beach 5.9 950 68,617 2.02% 3
Source: https://alltransit.cnt.org/metrics/, accessed March 13, 2020.
Continuing the analysis of Urban County jurisdictions for which the HUD Environmental Health Index
was not provided, the Environmental Health Screening tool (CalEnviroScreen) was used. The California
Office of Environmental Health Hazard Assessment (OEHHA) developed a screening methodology to
help identify California communities disproportionately burdened by multiple sources of pollution called
the California Communities Environmental Health Screening Tool (CalEnviroScreen). In addition to
environmental factors (pollutant exposure, groundwater threats, toxic sites, and hazardous materials
exposure) and sensitive receptors (seniors, children, persons with asthma, and low birth weight infants),
CalEnviroScreen also takes into consideration socioeconomic factors. These factors include educational
attainment, linguistic isolation, poverty, and unemployment. Research has shown a heightened
vulnerability of people of color and lower socioeconomic status to environmental pollutants. Table 56
shows the Urban County’s CalEnviroScreen scores by census tract in Urban County jurisdictions. High
scoring communities tend to be more burdened by pollution from multiple sources and most vulnerable
to its effects, taking into account their socioeconomic characteristics and underlying health status. As
expected, the areas indicated as having higher EnviroScreen scores generally matched the geographic
distribution of minorities, low- and moderate-income persons, and poverty concentrations.
July 14, 2020 Item #6 Page 129 of 211
Table 56: Opportunity Indicators – Environmental Health –
Urban County Participating Jurisdictions
Urban County Census Tract Total Population CES 3.0 Score
Coronado
6073021600 3391 13.59
6073011000 2799 6.18
6073021800 2022 5.73
6073010800 2390 5.70
6073010900 1750 4.77
6073011100 3698 4.71
6073010601 2127 4.67
6073009902 2 NA
Del Mar
6073017029 8823 7.62
6073017306 2818 3.69
6073017200 4146 2.89
6073008324 6600 2.11
Imperial Beach
6073010402 5558 30.50
6073010502 5514 24.30
6073010200 6800 23.76
6073010300 4507 23.55
6073010401 2458 19.82
6073010501 1433 15.27
Lemon Grove
6073014400 3523 39.22
6073014300 3618 31.85
6073014001 4630 24.52
6073014200 6277 23.65
6073014101 3507 20.27
6073014002 4488 19.38
Poway
6073017049 2919 16.25
6073017048 6123 13.73
6073017009 4024 10.78
6073017040 4363 9.05
6073017020 3694 8.58
6073017010 3152 8.17
6073017054 5810 6.87
6073017041 6147 6.18
6073017053 3364 5.01
6073017006 2876 3.73
Solano Beach
6073017304 5508 12.39
6073017303 3018 6.78
6073017305 2969 3.05
Source: CalEnviroScreen 3.0 Results (June 2018 Update).
July 14, 2020 Item #6 Page 130 of 211
Figure 19: Environmental Exposure
July 14, 2020 Item #6 Page 131 of 211
key aspect of fair housing choice is equal access to credit for the purchase or improvement of a
home, particularly in light of the recent lending/credit crisis. This chapter reviews the lending
practices of financial institutions and the access to financing for all households, particularly minority
households. Lending patterns in low and moderate income neighborhoods and areas of minority
concentration are also examined. However, publicly available data on lending does not contain the
detailed information necessary to make conclusive statements of discrimination, but it can point out
potential areas of concern. Furthermore, except for outreach and education efforts, local
jurisdictions’ ability to influence lending practices is limited. Such practices are largely governed by
national policies and regulations.
A. Background
1. Legislative Protection
In the past, credit market distortions and other activities such as “redlining” were prevalent and
prevented some groups from having equal access to credit. The Community Reinvestment Act
(CRA) in 1977 and the subsequent Home Mortgage Disclosure Act (HMDA) were designed to
improve access to credit for all members of the community and hold the lender industry responsible
for community lending.
Community Reinvestment Act
The Community Reinvestment Act (CRA) is intended to encourage regulated financial institutions
to help meet the credit needs of their entire communities, including low and moderate income
neighborhoods. Depending on the type of institution and total assets, a lender may be examined by
different supervising agencies for its CRA performance. CRA ratings are provided by the Federal
Reserve Board (FRB), Federal Financial Institutions Examination Council (FFIEC), Federal Deposit
Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC). However,
the CRA rating is an overall rating for an institution and does not provide insights regarding the
lending performance at specific locations by the institution.
Home Mortgage Disclosure Act
In tandem with the CRA, the Home Mortgage Disclosure Act requires lending institutions to make
annual public disclosures of their home mortgage lending activity. Under HMDA, lenders are
required to disclose information on the disposition of home loan applications and on the race or
national origin, gender, and annual income of loan applicants. This section examines detailed 2012
and 2017 HMDA data for San Diego County.38
38 2017 HMDA data is the most updated lending data available that can provide consistent comparative analysis of
data from 2012. In 2018, the FFIEC changed the reporting format, making comparison with prior years for trends
difficult.
A
July 14, 2020 Item #6 Page 132 of 211
HMDA data provide some insight into the lending patterns that exist in a community. However, HMDA data are
only an indicator of potential problems; the data cannot be used to conclude definite redlining or discrimination
practices due to the lack of detailed information on loan terms or specific reasons for denial.
Conventional versus Government-Backed Financing
Conventional financing involves market-rate loans provided by private lending institutions such as
banks, mortgage companies, savings and loans, and thrift institutions. To assist lower and moderate
income households that may have difficulty in obtaining home mortgage financing in the private
market due to income and equity issues, several government agencies offer loan products that have
below market interest rates and are insured (“backed”) by the agencies. Sources of government-
backed financing include loans insured by the Federal Housing Administration (FHA), the
Department of Veterans Affairs (VA), and the Rural Housing Services/Farm Service Agency
(RHA/FSA). Often government-backed loans are offered to the consumers through private lending
institutions. Local programs such as first-time homebuyer and rehabilitation programs are not
subject to HMDA reporting requirements and therefore are not included in this analysis.
Financial Stability Act
The Financial Stability Act of 2009 established the Making Home Affordable Program, which assists
eligible homeowners who can no longer afford their home with mortgage loan modifications and
other options, including short sale or deed-in-lieu of foreclosure. The program is targeted toward
homeowners facing foreclosure and homeowners who are unemployed or “underwater” (i.e.,
homeowners who owe more on their mortgage than their home is worth).
For homeowners who can no longer afford their homes but do not want to go into foreclosure, the
Home Affordable Foreclosure Alternatives Program (HAFA) offers homeowners, their mortgage
servicers, and investor incentives for completing a short sale or deed-in-lieu of foreclosure. HAFA
enables homeowners to transition to more affordable housing while being released from their
mortgage debt. The program also includes a “cash for keys” component whereby a homeowner
receives financial assistance to help with relocation costs in return for vacating their property in
good condition.
Helping Families Save Their Homes Act
The Helping Families Save Their Homes Act was passed by Congress in May 2009 and expands the
Making Home Affordable Program. This Act includes provisions to make mortgage assistance and
foreclosure prevention services more accessible to homeowners and increases protections for
renters living in foreclosed homes. It also establishes the right of a homeowner to know who owns
their mortgage and provides over two billion dollars in funds to address homelessness. Under this
bill, tenants also have the right to stay in their homes after foreclosure for 90 days or through the
term of their lease.
Fraud Enforcement and Recovery Act
The Fraud Enforcement and Recovery Act (FERA) enhances the criminal enforcement of federal
fraud laws by strengthening the capacity of federal prosecutors and regulators to hold accountable
those who have committed fraud. FERA amends the definition of a financial institution to include
July 14, 2020 Item #6 Page 133 of 211
private mortgage brokers and non-bank lenders that are not directly regulated or insured by the
federal government, making them liable under federal bank fraud criminal statutes. The new law also
makes it illegal to make a materially false statement or to willfully overvalue a property in order to
manipulate the mortgage lending business.
B. Overall Lending Patterns
1. Data and Methodology
The availability of financing affects a person’s ability to purchase or improve a home. Under the
HMDA, lending institutions are required to disclose information on the disposition of loan
applications by the income, gender, and race of the applicants. This applies to all loan applications
for home purchases, improvements, and refinancing, whether financed at market rate or with
government assistance.
HMDA data are submitted by lending institutions to the FFIEC. Certain data is available to the
public via the FFIEC site either in raw data format or as pre-set printed reports. The analyses of
HMDA data presented in this AI were conducted using Lending PatternsTM. Lending Patterns is a
web-based data exploration tool that analyzes lending records to produce reports on various aspects
of mortgage lending. It analyzes HMDA data to assess market share, approval rates, denial rates,
low/moderate income lending, and high-cost lending, among other aspects.
General Overview
A detailed summary of the disposition of loan applications submitted to financial institutions in 2012
and 2017 (the most recent HMDA data available) by residents (or prospective residents) of San
Diego County can be found in Appendix B. Included is information on loan types and outcomes. In
2017, the cities of San Diego, Chula Vista, and Oceanside recorded the most loan applications, while
the cities of Del Mar, Solana Beach, Coronado recorded the fewest due to the built out character of
these small communities.
The loan approval rates varied somewhat by jurisdiction. Applications from the cities of Carlsbad,
La Mesa, Poway and Santee generally exhibited higher approval rates (over 67 percent). By contrast,
applications from the cities of National City, Imperial Beach, and Chula Vista had slightly lower
approval rates (ranging from 57 percent to 61 percent). However, the differences are not significant.
Overall, approval rates were slightly lower in 2017 than in 2012. In 2012, the cities of La Mesa,
Carlsbad, and Poway recorded the highest home loan approval rates; these approval rates ranged
from 74 to 76 percent. The cities with the lowest loan approval rates were the same in 2012 as in
2017 (Imperial Beach, Chula Vista, and National City, under 65 percent). However, the
discrepancies in approval rates between the high-rate and the low-rate cities have substantially
narrowed since 2012.
Aside from income, another major impediment to securing a home loan is insufficient
understanding of the homebuying and lending processes. About 14 percent of all applications
countywide were withdrawn by the applicants or deemed incomplete by the financial institution in
2012. The rate of withdrawn or incomplete applications was higher in 2017 (21 percent). The
July 14, 2020 Item #6 Page 134 of 211
highest rates of withdrawn/closed applications were seen in Lemon Grove, National City, and
Solana Beach, which are also some of the cities with the lowest approval rates. .Withdrawn or closed
applications can be indicative of a lack of knowledge about the homebuying and lending process.
Home Purchase Loans
In 2017, a total of 37,949 households applied for conventional loans to purchase homes in San
Diego County, representing an increase of approximately 41 percent from 2012. This trend is
indicative of a housing market that is slowly recovering from its peak in 2006-2007.
The approval rate countywide in 2017 for conventional home purchase loans was 64 percent, while
the denial rate was 15 percent. As mentioned previously, approval rates were slightly higher in 2012.
Specifically, the countywide approval rate for conventional home purchase loans was 76 percent in
2012 and the denial rate was 11 percent. When the housing market began to show signs of collapse
and foreclosures were on the rise in 2007, many financial institutions instituted stricter approval
criteria for potential borrowers, which caused approval rates to drop. However, as time passed, the
applicant pool for mortgage lending also became smaller and increasingly selective.
As an alternative to conventional home loans, potential homeowners can choose to apply for
government-backed home purchase loans when buying their homes. In a conventional loan, the
lender takes on the risk of losing money in the event a borrower defaults on a mortgage. For
government-backed loans, the loan is insured, either completely or partially, by the government. The
government does not provide the loan itself, but instead promises to repay some or all of the money
in the event a borrower defaults. This reduces the risk for the lender when making a loan.
Government-backed loans generally have more lenient credit score requirements, lower
downpayment requirements, and are available to those with recent bankruptcies. However, these
loans may also carry higher interest rates and most require homebuyers to purchase mortgage
insurance. Furthermore, government-backed loans have strict limits on the amount a homebuyer can
borrow for the purchase of a home. In competitive and high-end housing markets, many of the
homes available for purchase exceed the maximum allowable loan amount.
In 2017, 13,515 San Diego County households applied for government-backed loans—comparable
in terms of the number of households who applied for this type of loan in 2012 (15,141
households), but represented a lower proportion of all loan applicants in 2017. Unlike approval rates
for conventional loans, the approval rate for government-backed loans increased slightly from 2012
to 2017 (from 75 percent to 77 percent).
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Figure 20: Conventional Home Purchase Loans (2012 versus 2017)
Figure 21: Government-Backed Home Purchase Loans (2012 versus 2017)
Note: HMDA reports data based on census tract. To arrive at numbers for the unincorporated County areas, numbers
for individual cities are subtracted from the County total. However, this methodology may underestimate the lending
activities in the unincorporated areas because census tracts cross jurisdictional boundaries.
Source: www.lendingpatterns.com, 2020
July 14, 2020 Item #6 Page 136 of 211
Home Improvement Loans
Reinvestment in the form of home improvement is critical to maintaining the supply of safe and
adequate housing. Historically, home improvement loan applications have a higher rate of denial
when compared to home purchase loans. Part of the reason is that an applicant’s debt-to-income
ratio may exceed underwriting guidelines when the first mortgage is considered with consumer
credit balances. Another reason is that many lenders use the home improvement category to report
both second mortgages and equity-based lines of credit, even if the applicant’s intent is to do
something other than improve the home (e.g., pay for a wedding or college). Loans that will not be
used to improve the home are viewed less favorably since the owner is divesting in the property by
withdrawing accumulated wealth. From a lender’s point of view, the reduction in owner’s equity
represents a higher risk.
In 2017, 9,621 applications for home improvement loans were submitted by San Diego County
households—higher than the number of applications for this loan type in 2012 (4,205 applications).
Generally, the approval rates for home improvement loans were lower than for home purchase
loans. The overall approval rate for home improvement loans in both 2012 and 2017 was 60
percent. In 2012, 30 percent of these loans were denied, while 23 percent of these applications were
denied in 2017.
Refinancing
Homebuyers will refinance existing home loans for a number of reasons. Refinancing can allow
homebuyers to take advantage of better interest rates, consolidate multiple debts into one loan,
reduce monthly payments, alter risk (i.e. by switching from variable rate to fixed rate loans), or free
up cash and capital.
The majority of loan applications submitted by San Diego County households in 2017 were for
home refinancing (74,811 applications). This figure is nearly half the number of refinancing
applications submitted in 2012 (155,940 applications). About 58 percent of refinance applications
were approved and 18 percent were denied in 2017. These approval rates represent a decrease from
2012, when 71 percent of refinance applications were approved.
C. Lending by Race/Ethnicity and Income
The federal Fair Housing Act prohibits discrimination in mortgage lending based on race, color,
national origin, religion, sex, familial status or handicap (disability). It is, therefore, important to
look not just at overall approval and denial rates for a jurisdiction, but also whether or not these
rates vary by other factors, such as race/ethnicity. (Race/ethnicity is the only personal characteristic
available from the HMDA data.)
1. Loan Applicant Representation
In a perfect environment, the applicant pool for mortgage lending should be reflective of the
demographics of a community. When one racial/ethnic group is overrepresented or
underrepresented in the total applicant pool, it could be an indicator of unequal access to housing
opportunities. Such a finding may be a sign that access to mortgage lending is not equal for all
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individuals. As shown in Table 57, throughout San Diego County, White applicants were noticeably
overrepresented in the loan applicant pool, while Hispanics were severely underrepresented. The
underrepresentation of Hispanics was most acute in the cities of Escondido (-33 percent), Vista (-32
percent), Imperial Beach (-30 percent). Detailed comparisons of the applicant pool with overall
demographics by jurisdiction can be found in Appendix B.
Table 57: Demographics of Loan Applicants vs. Total Population
San Diego County
Percent of
Applicant Pool
(2017 HMDA)
Percent of Total
Population
(2010 Census)
Variation
White 51.5% 48.5% 3.0%
Black 3.1% 4.7% -1.6%
Hispanic 16.4% 32.0% -15.6%
Asian 9.7% 10.6% -0.9%
Other 19.2% 4.2% 15.0%
Notes:
1. Percent of total population estimates are based on 2017 applicant data and compared to total
population estimates from the 2010 Census.
2. Other” includes Native American, Hawaiian, MultiRace, Unknown/NA.
3. Local jurisdiction data can be found in Appendix B.
Source: Bureau of the Census, 2010; www.lendingpatterns.com, 2020
Race by Income Level
Table 58 summarizes lending outcomes by race/ethnicity and income in San Diego County. White
applicants at all income levels generally had the highest approval rates. Similarly high approval rates
were recorded for Asian applicants, although there was some variation by jurisdiction. Approval
rates for Black and Hispanic applicants, however, were well below the approval rates for White and
Asian applicants in the same income groups in 2012. These gaps had narrowed somewhat by 2017,
but were still present. Specifically, Black applicants consistently had the lowest approval rates
compared to other racial/ethnic groups in the same income groups.
The largest discrepancies (between loan approval rates for White and Asian applicants versus Black
and Hispanic applicants) in 2017 were recorded in the cities of El Cajon, Encinitas, and San Marcos.
Detailed lending outcomes by race/ethnicity and income for each jurisdiction can be found in
Appendix B.
While this analysis provides a more in-depth look at lending patterns, it does not conclusively
explain any of the discrepancies observed. Aside from income, many other factors can contribute to
the availability of financing, including credit history, the availability and amount of a downpayment,
and knowledge of the homebuying process. HMDA data does not provide insight into these other
factors.
July 14, 2020 Item #6 Page 138 of 211
Table 58: Lending Patterns by Race/Ethnicity and Income (2012-2017)
San Diego County Approved Denied Withdrawn/
Incomplete
2012 2017 2012 2017 2012 2017
White
Low (0-49% AMI) 55.7% 41.6% 27.3% 30.4% 17.0% 27.9%
Moderate (50-79% AMI) 65.2% 54.0% 17.3% 19.9% 17.5% 26.0%
Middle (80-119% AMI) 69.8% 64.0% 13.3% 13.1% 16.8% 22.9%
Upper (≥120% AMI) 70.9% 66.9% 11.8% 11.2% 17.4% 21.9%
Unknown/NA 75.3% 55.7% 9.6% 13.1% 15.1% 31.2%
Black
Low (0-49% AMI) 45.5% 31.7% 38.8% 49.2% 15.8% 19.1%
Moderate (50-79% AMI) 54.9% 45.2% 24.7% 27.6% 20.5% 27.2%
Middle (80-119% AMI) 61.6% 57.5% 19.3% 17.9% 19.1% 24.6%
Upper (≥120% AMI) 60.6% 59.5% 19.9% 18.1% 19.5% 22.5%
Unknown/NA 74.3% 58.8% 9.0% 9.3% 16.7% 31.9%
Hispanic
Low (0-49% AMI) 49.2% 30.7% 31.5% 38.1% 19.3% 31.2%
Moderate (50-79% AMI) 57.5% 47.4% 21.7% 23.8% 20.8% 28.8%
Middle (80-119% AMI) 62.0% 58.8% 18.4% 15.4% 19.6% 25.8%
Upper (≥120% AMI) 63.1% 61.7% 16.2% 13.5% 20.7% 24.8%
Unknown/NA 68.9% 50.0% 12.7% 14.2% 18.4% 35.8%
Asian
Low (0-49% AMI) 47.4% 31.5% 34.6% 38.5% 17.9% 30.0%
Moderate (50-79% AMI) 58.7% 51.7% 22.3% 22.7% 19.0% 25.6%
Middle (80-119% AMI) 66.5% 58.8% 15.3% 16.5% 18.2% 24.7%
Upper (≥120% AMI) 70.0% 63.7% 12.4% 12.0% 17.6% 24.3%
Unknown/NA 72.2% 48.8% 10.0% 12.3% 17.8% 38.9%
Note: Local jurisdiction data can be found in Appendix B.
Source: www.lendingpatterns.com, 2020.
July 14, 2020 Item #6 Page 139 of 211
D. Lending Patterns by Tract Characteristics
1. Income Level
To identify potential geographic differences in mortgage lending activities, an analysis of the HMDA
data was conducted by census tract. Based on the Census, HMDA defines the following income
levels:39
Low-Income Tract – Tract Median Income less than or equal to 49 percent AMI
Moderate-Income Tract – Tract Median Income between 50 and 79 percent AMI
Middle-Income Tract – Tract Median Income between 80 and 119 percent AMI
Upper-Income Tract – Tract Median Income equal to or greater than 120 percent AMI
The vast majority of census tracts in San Diego County are considered middle or upper income.
Only four percent of the County’s census tracts are categorized as low income by HMDA. Most
loan applications were submitted by residents from one of the County’s upper-income tracts. Table
59 summarizes lending outcomes by the income level of the census tract where an applicant resides.
In general, home loan approval rates increased and denial rates decreased as the income level of the
census tract increased. Higher income households are more likely to qualify for and be approved for
loans, so this trend is to be expected.
Table 59: Outcomes Based on Census Tract Income (2012-2017)
Tract Income Level Total Applicants Approved Denied Other
# % # % # % # %
2012
Low 9,918 4.9% 5,467 3.8% 3000 10.1% 1451 5.2%
Moderate 24,729 12.2% 16,207 11.2% 4,860 16.4% 3662 13.1%
Middle 41,607 20.6% 29,820 20.6% 6,180 20.9% 5,607 20.0%
Upper 108,335 53.6% 79,670 55.1% 13,642 46.1% 15,023 53.5%
NA 17,649 8.7% 13,447 9.3% 1,884 6.4% 2,318 8.3%
Total 202,238 100.0% 144,611 100.0% 29,566 100.0% 28,061 100.0%
2017
Low 5,818 4.3% 2,342 2.7% 1974 9.8% 1502 5.2%
Moderate 14,814 10.9% 7,918 9.1% 3,336 16.5% 3,560 12.3%
Middle 29,765 21.9% 19,060 21.9% 4462 22.1% 6243 21.6%
Upper 77,357 56.9% 52,349 60.3% 9519 47.2% 15,489 53.7%
NA 8,142 6.0% 5,182 6.0% 889 4.4% 2,071 7.2%
Total 135,896 100.0% 86,851 100.0% 20,180 100.0% 28,865 100.0%
Source: www.lendingpatterns.com, 2020.
39 These income definitions are different from those used by HUD to determine low and moderate income areas.
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Minority Population
HMDA also records lending outcomes by the proportion of minorities residing in a census tract.
Much of San Diego County is comprised of census tracts where 20 to 40 percent of residents are
minorities. Table 60 summarizes lending outcomes by the proportion of minority residents in a
census tract. In general, approval rates steadily increased as the proportion of minority residents
decreased.
Table 60: Outcomes by Minority Population of Census Tract (2012-2017)
Tract Minority Level Total Applicants Approved Denied Other
# % # % # % # %
2012
0-19% Minority 28,198 13.9% 20,417 72.4% 3,875 13.7% 3,906 13.9%
20-39% Minority 77,893 38.5% 56,702 72.8% 10,602 13.6% 10,589 13.6%
40-59% Minority 50,590 25.0% 36,556 72.3% 7,141 14.1% 6,893 13.6%
60-79% Minority 25,291 12.5% 17,545 69.4% 4,119 16.3% 3,627 14.3%
80-100% Minority 20,189 10.0% 13,378 66.3% 3,797 18.8% 3,014 14.9%
Unknown/NA 77 0.0% 13 16.9% 32 41.6% 32 41.6%
Total 202,238 100.0% 144,611 71.5% 29,566 14.6% 28,061 13.9%
2017
0-19% Minority 12,930 9.5% 8,343 64.5% 1,982 15.3% 2,605 20.1%
20-39% Minority 44,578 32.8% 29,311 65.8% 6,170 13.8% 9,097 20.4%
40-59% Minority 35,988 26.5% 23,438 65.1% 5,044 14.0% 7,506 20.9%
60-79% Minority 21,213 15.6% 13,206 62.3% 3,334 15.7% 4,673 22.0%
80-100% Minority 20,591 15.2% 12,236 59.4% 3,598 17.5% 4,757 23.1%
Unknown/NA 596 0.4% 317 53.2% 52 8.7% 227 38.1%
Total 135,896 100.0% 86,851 63.9% 20,180 14.8% 28,865 21.2%
Note: NA=Minority tract percentage data was not available.
Source: www.lendingpatterns.com, 2020.
E. Major Lenders
1. General Overview
Table 61 identifies the top ten lenders in San Diego County in 2017. As shown, these top lenders
were similarly active throughout most jurisdictions. In 2017, about 38 percent (39,017 applications)
of all loan applications in San Diego County were submitted to one of the County's top ten lenders.
The region’s top two lenders have remained fairly consistent since 2012 (Table 61). The region’s
remaining top lenders are all smaller financial institutions that each accounted for less than four
percent of the County’s market share.
July 14, 2020 Item #6 Page 141 of 211
Table 61: Top San Diego County Lenders by City (2017)
Jurisdiction
Top 10 Lenders
Wells
Fargo
Bank, NA
JP
Morgan
Chase
Bank,
NA
Navy
Federal
Credit
Union
Quicken
Loans,
Inc.
Caliber
Home
Loans,
Inc.
Loan
depot.com
Bank of
America,
NA
Shore
Mortgage
Nationstar
Mortgage
U.S. Bank
National
Assoc.
Carlsbad ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Chula Vista ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Coronado ✓ ✓ ✓ ✓ ✓ ✓ ✓
Del Mar ✓ ✓ ✓ ✓ ✓ ✓ ✓
El Cajon ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Encinitas ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Escondido ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Imperial Bch. ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
La Mesa ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Lemon
Grove ✓ ✓ ✓ ✓ ✓ ✓ ✓
National City ✓ ✓ ✓ ✓ ✓ ✓ ✓
Oceanside ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Poway ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
San Diego ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
San Marcos ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Santee ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Solana Beach ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Vista ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Notes:
1. Comparison only indicates if a top County lender was also a top lender in a city, and does not compare the specific order of top lenders in the County
as a whole.
2. Data for just the unincorporated areas is not available
Source: www.lendingpatterns.com, 2020.
F. Sub-Prime Lending Market
According to the Federal Reserve, “prime” mortgages are offered to persons with excellent credit
and employment history and income adequate to support the loan amount. “Subprime” loans are
loans to borrowers who have less-than-perfect credit history, poor employment history, or other
factors such as limited income. By providing loans to those who do not meet the critical standards
for borrowers in the prime market, subprime lending can and does serve a critical role in increasing
levels of homeownership. Households that are interested in buying a home but have blemishes in
their credit record, insufficient credit history, or non-traditional income sources may be otherwise
unable to purchase a home. The subprime loan market offers these borrowers opportunities to
obtain loans that they would be unable to realize in the prime loan market.
Subprime lenders generally offer interest rates that are higher than those in the prime market and
often lack the regulatory oversight required for prime lenders because they are not owned by
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regulated financial institutions. In the recent past, however, many large and well-known banks
became involved in the subprime market either through acquisitions of other firms or by initiating
subprime loans directly. Though the subprime market usually follows the same guiding principles as
the prime market, a number of specific risk factors are associated with this market.
Subprime lending can both impede and extend fair housing choice. On the one hand, subprime
loans extend credit to borrowers who potentially could not otherwise finance housing. The increased
access to credit by previously underserved consumers and communities contributed to record high
levels of homeownership among minorities and lower income groups. On the other hand, these
loans left many lower income and minority borrowers exposed to default and foreclosure risk. Since
foreclosures destabilize neighborhoods and subprime borrowers are often from lower income and
minority areas, mounting evidence suggests that classes protected by fair housing faced the brunt of
the recent subprime and mortgage lending market collapse.40
While HMDA data does not classify loans as subprime, it does track the interest rate spread on
loans. Since 2005, the Federal Reserve Board has required lenders to report rate spreads for loans
whose APR was above the Treasury benchmark. Loans with a reported spread are typically referred
to as higher-priced or subprime loans.
Table 62: Reported Spread on Loans by Race/Ethnicity (2012-2017)
San Diego County Frequency of Spread Average Spread
2012 2017 2012 2017
White 1.0% 0.0% 3.10 0.00
Black 1.3% 3.6% 2.67 2.66
Hispanic 1.6% 4.9% 3.41 2.87
Asian 0.5% 1.7% 2.82 2.85
Total 1.0% 3.6% 3.10 2.86
Source: www.lendingpatterns.com, 2020.
As shown in Table 62, the frequency of subprime loans issued has increased over time. In 2012,
approximately one percent of all loans issued had a reported spread but, by 2017, almost four
percent of loans issued were subprime loans. What appears to be most troubling, however, is that
Black and Hispanic applicants seem to be significantly more likely to receive these higher-priced
loans. In 2012 and 2017, Blacks and Hispanics were twice as likely as Asians to receive a subprime
loan. White applicants utilizing subprime loans were limited.
Since 2012, there has been a decrease in the magnitude of spread reported on these loans. Generally,
the higher the reported spread on a loan, the worse that loan is compared to a standard prime loan.
In 2012, the average reported spread for a subprime loan was just above three points; by 2017, the
average reported spread had dropped to below three points. The most significant change in the
reported magnitude of spread for subprime loans by race/ethnicity of the applicant was noted for
White applicants.
40 Association of Community Organizations for Reform Now. September 2007. “Foreclosure Exposure: A Study of
Racial and Income Disparities in Home Mortgage Lending in 172 American Cities.”
July 14, 2020 Item #6 Page 143 of 211
ublic policies established at the regional and local levels can affect housing development, and
therefore, may impact the range and location of housing choices available to residents. Fair
housing laws are designed to encourage an inclusive living environment, active community
participation, and an assessment of public policies. An assessment of public policies and practices
can help determine potential impediments to fair housing opportunity. This section presents an
overview of government regulations, policies, and practices enacted by each of the 19 jurisdictions in
San Diego County that may impact fair housing choice.
A. Policies and Programs Affecting Housing
Development
The General Plan of a jurisdiction establishes a vision for the community and provides long-range
goals and policies to guide the development in achieving that vision. Two of the eight State-
mandated General Plan elements – Housing and Land Use Elements – have direct impact on the
local housing market in terms of the amount and range of housing choice. The Environmental
Justice Element The zoning ordinance, which implements the General Plan, is another important
document that influences the amount and type of housing available in a community – the availability
of housing choice. In addition, 11 jurisdictions (Carlsbad, Chula Vista, Coronado, Del Mar,
Encinitas, Imperial Beach, National City, Oceanside, Solana Beach, City of San Diego, and
unincorporated areas of San Diego County) have Local Coastal Plans that also play a significant role
in affordable housing in the Coastal Zone of each jurisdiction.
1. Housing Element Law and Compliance
As one of the eight State-mandated elements of the local General Plan, the Housing Element is the
only element with specific statutory requirements and is subject to review by the California
Department of Housing and Community Development (HCD) for compliance with State law.
Enacted in 1969, Housing Element law requires that local governments adequately plan to meet the
existing and projected housing needs of all economic segments of the community. The law
acknowledges that for the private market to adequately address housing needs and demand, local
governments must adopt land use plans and regulatory systems that provide opportunities for and
do not unduly constrain housing development. Specifically, the Housing Element must:
Identify adequate sites which will be made available through appropriate zoning and
development standards, with services and facilities needed to facilitate and encourage the
development of a variety of types of housing for all income levels in order to meet the
community’s housing goals;
P
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Assist in the development of adequate housing to meet the needs of extremely low, very low,
low, and moderate income households;41
Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and development of
housing, including housing for all income levels and housing for persons with disabilities;
Conserve and improve the condition of the existing affordable housing stock; and,
Promote and affirmatively further fair housing opportunities and promote housing
throughout the community or communities for all persons regardless of race, religion, sex,
marital status, ancestry, national origin, color, familial status, or disability, and other
characteristics protected by the California Fair Employment and Housing Act, or any other
state and federal fair housing laws.
Specifically in 2017, the State passed AB 686, requiring the next Housing Element update to include
an analysis of barriers that restrict access to opportunity and a commitment to specific meaningful
actions to affirmatively furthering fair housing.
Compliance Status
Table 63 summarizes the Housing Element compliance status of jurisdictions in San Diego County.
A Housing Element found by HCD to be in compliance with State law is presumed to have
adequately addressed its policy constraints. According to HCD, all 19 Housing Elements for
participating jurisdictions (including the County) for the fifth cycle (2013-2020 are in compliance.
A number of jurisdictions have begun updating the Housing Element for the sixth cycle (2021-
2029). As part of the 2021-2029 update, each jurisdiction must demonstrate that it has capacity to
meet its housing needs, as determined by SANDAG and HCD. Each jurisdiction is allocated its
share of housing during the Regional Housing Needs Assessment (RHNA) process, which identifies
the number of housing units each jurisdiction must accommodate by providing adequate sites. As of
February 2020, the cities of Coronado, Imperial Beach, Lemon Grove, and Solana Beach had
requested reductions in the number of housing units they must accommodate under the RHNA
allocation for the 2021-2029 Housing Element cycle.
41 Under the State Housing Element law, the income categories are: extremely low income (30 percent AMI); very low
income (50 percent AMI); low income (80 percent AMI); moderate income (120 percent AMI); and above moderate
income (greater than 120 percent AMI).
July 14, 2020 Item #6 Page 145 of 211
Table 63: Housing Element Status for 2013-2021 Cycle
Jurisdiction Document Status Compliance Status
Carlsbad Adopted In
Chula Vista Adopted In
Coronado Adopted In
Del Mar Adopted In
El Cajon Adopted In
Encinitas Adopted In
Escondido Adopted In
Imperial Beach Adopted In
La Mesa Adopted In
Lemon Grove Adopted In
National City Adopted In
Oceanside Adopted In
Poway Adopted In
San Diego (City) Adopted In
San Diego (County) Adopted In
San Marcos Adopted In
Santee Adopted In
Solana Beach Adopted In
Vista Adopted In
Source: Department of Housing and Community Development, State of California,
April 2020.
2. San Diego Forward: Regional Plan
SANDAG adopted San Diego Forward: Regional Plan in 2015. Updated periodically, the Regional
Plan serves as the long-term planning framework for the San Diego region. It provides a broad
context in which local and regional decisions can be made that move the region toward a sustainable
future – a future with more choices and opportunities for all residents of the region. The Regional
Plan better integrates San Diego’s local land use and transportation decisions and focuses attention
on where and how the region wants to grow. The Regional Plan contains an incentive-based
approach to encourage and channel growth into existing and future urban areas and smart growth
communities. SANDAG is in the process of updating the Regional Plan with adoption anticipated in
2021.
3. Land Use Element
The Land Use Element of a General Plan designates the general distribution, location, and extent of
uses for land planned for housing, business, industry, open space, and public or community facilities.
As it applies to housing, the Land Use Element establishes a range of residential land use categories,
specifies densities (typically expressed as dwelling units per acre [du/ac]), and suggests the types of
July 14, 2020 Item #6 Page 146 of 211
housing appropriate in a community. Residential development is implemented through the zoning
districts and development standards specified in the jurisdiction’s zoning ordinance.
4. Residential Densities
Many factors, governmental and non-governmental, affect the supply and cost of housing in a local
housing market. The governmental factor that most directly influences these market conditions is
the allowable density range of residentially designated land. In general, higher densities allow
developers to take advantage of economies of scale, reduce the per-unit cost of land and
improvements, and reduce developments costs associated with new housing construction.
Reasonable density standards ensure the opportunity for higher-density residential uses to be
developed within a community, increasing the feasibility of producing affordable housing, and offer
a variety of housing options that meet the needs of the community. Minimum required densities in
multi-family zones ensure that land zoned for multi-family use, the supply of which is often limited,
will be developed as efficiently as possible for multi-family uses.
Table 64 presents a summary of allowable densities by land use type for jurisdictions in the San
Diego region. While most jurisdictions have Land Use Elements that allow a range of single-family
(0-14 du/ac) and multi-family (6-30+ du/ac) residential uses, Del Mar and Poway due to the
characteristics of existing residential neighborhoods, do not accommodate multi-family uses at a
density greater than 20 du/ac without a density bonus or other incentive for affordable housing.
As a part of its 2013-2021 Housing Element, the City of Del Mar committed to redesignating two
vacant properties in the North Commercial (NC) zone to allow residential development at a density
of 20 units per acre or greater. In addition to the land use re-designation noted above, the City of
Del Mar also plans to pursue amendments to the North Commercial (NC) and Professional
Commercial (PC) zones expanding the list of uses allowed by right to include residential uses at a
density of 20 units per acre for projects that include an affordable housing component. The City has
prepared an Environmental Impact Report (EIR) to address the proposed re-designation, and the
City Council will consider the amendments after the public review period closes in February 2020.
To provide adequate sites for affordable housing development, an Affordable Housing Overlay
Zone (AHOZ) was established in the Poway Zoning Code for Low Income (AH-L) and Moderate
Income (AH-M) households. In 2012, placement of an AHOZ designation was completed on six
publicly-owned sites. An AHOZ may be applied to property within any land use category, including
non-residential categories, not including the Open Space or Rural Residential categories. The Poway
Municipal Code (PMC) was also amended in 2012 to provide development incentives on AHOZ
sites to encourage affordable housing that is consistent with State law. Development incentives
include allowing densities up to 30 dwelling units per acre on properties that have the AHOZ
applied on them.
All jurisdictions have very low or no minimum density requirements in their General Plan Land Use
Elements for at least some of their residentially-zoned land. State law requires a local government to
make a finding that a density reduction, rezoning, or downzoning is consistent with its Housing
Element prior to requiring or permitting a reduction of density of a parcel below the density used in
determining Housing Element compliance. The legislation also allowed courts to award attorneys’
fees and costs if the court determines that the density reduction or downzoning was made illegally.
July 14, 2020 Item #6 Page 147 of 211
Table 64: Typical Land Use Categories and Permitted Density by Jurisdiction
Generalized
Land Use
(By Density)
Density
Range
(du/ac)
Typical Residential
Type Carlsbad Chula
Vista Coronado Del Mar El Cajon Encinitas
Single-family
Estate/Rural <1 unit
per acre
Very low-density
housing where
agricultural is
predominant
Very Low 0-1
Single-family
homes on large
lots in rural areas
Low 1-3
Single-family
homes on large
lots
Medium 3-6
Single-family
homes on
medium-sized lots
High 6-14 Smaller single-
family homes
Multi-Family
Low 6-15
Town homes,
duplexes,
condominiums,
and small single-
story apartments
Medium 15-20
One and two-
story apartment
complexes
High 20-30
Two and three-
story apartment
complexes
Very High 30-50
Large multi-story
apartment and
condo complexes
Special High 50+
High-rise
apartment and
condo complexes
Source: General Plan Land Use Elements for jurisdictions in San Diego County (February 2020).
Note: This table represents a summary of typical land use categories, as defined by density. These categories are not necessarily representative of
a specific jurisdiction’s General Plan Land Use categories. Instead, they are meant to provide an overview of the type of land uses and densities
permitted in that jurisdiction. The squares identify a jurisdiction as supporting land use densities within the identified range (according to the
General Plan’s Land Use Element). However, a jurisdiction’s land use category might not include all the densities listed in that range. For example,
a jurisdiction’s Multi-Family Very High density category might support densities from 21 to 35 du/ac, but the High and Very High categories have
been marked with a square since the range covers both categories.
July 14, 2020 Item #6 Page 148 of 211
Table 64: Typical Land Use Categories and Permitted Density by Jurisdiction
Generalized
Land Use
(By Density)
Density
Range
(du/ac)
Typical Residential
Type
Escon-
dido
Imperial
Beach La Mesa Lemon
Grove
National
City
Ocean-
side
Single-family
Estate/Rural <1 unit
per acre
Very low-density
housing where
agricultural is
predominant
Very Low 0-1
Single-family
homes on large
lots in rural areas
Low 1-3
Single-family
homes on large
lots
Medium 3-6
Single-family
homes on
medium-sized lots
High 6-14 Smaller single-
family homes
Multi-Family
Low 6-15
Town homes,
duplexes,
condominiums,
and small single-
story apartments
Medium 15-20
One and two-
story apartment
complexes
High 20-30
Two and three-
story apartment
complexes
Very High 30-50
Large multi-story
apartment and
condo complexes
Special High 50+
High-rise
apartment and
condo complexes
Source: General Plan Land Use Elements for jurisdictions in San Diego County (February 2020).
Note: This table represents a summary of typical land use categories, as defined by density. These categories are not necessarily representative of
a specific jurisdiction’s General Plan Land Use categories. Instead, they are meant to provide an overview of the type of land uses and densities
permitted in that jurisdiction. The squares identify a jurisdiction as supporting land use densities within the identified range (according to the
General Plan’s Land Use Element). However, a jurisdiction’s land use category might not include all the densities listed in that range. For example,
a jurisdiction’s Multi-Family Very High density category might support densities from 21 to 35 du/ac, but the High and Very High categories have
been marked with a square since the range covers both categories.
July 14, 2020 Item #6 Page 149 of 211
Table 64: Typical Land Use Categories and Permitted Density by Jurisdiction
Generalized
Land Use
(By Density)
Density
Range
(du/ac)
Typical Residential
Type Poway*
San
Diego
(City)*
San
Diego
(County)*
San
Marcos Santee Solana
Beach Vista
Single-family
Estate/Rural <1 unit
per acre
Very low-density
housing where
agricultural is
predominant
Very Low 0-1
Single-family
homes on large
lots in rural areas
Low 1-3
Single-family
homes on large
lots
Medium 3-6
Single-family
homes on
medium-sized lots
High 6-14 Smaller single-
family homes
Multi-Family
Low 6-15
Town homes,
duplexes,
condominiums,
and small single-
story apartments
Medium 15-20
One and two-
story apartment
complexes
High 20-30
Two and three-
story apartment
complexes
Very High 30-50
Large multi-story
apartment and
condo complexes
Special High 50+
High-rise
apartment and
condo complexes
Source: General Plan Land Use Elements for jurisdictions in San Diego County (February 2020).
Note: This table represents a summary of typical land use categories, as defined by density. These categories are not necessarily representative of
a specific jurisdiction’s General Plan Land Use categories. Instead, they are meant to provide an overview of the type of land uses and densities
permitted in that jurisdiction. The squares identify a jurisdiction as supporting land use densities within the identified range (according to the
General Plan’s Land Use Element). However, a jurisdiction’s land use category might not include all the densities listed in that range. For
example, a jurisdiction’s Multi-Family Very High density category might support densities from 21 to 35 du/ac, but the High and Very High
categories have been marked with a square since the range covers both categories.
*Indicates jurisdiction with very low, or no minimum density standards in land use or zoning ordinance.
July 14, 2020 Item #6 Page 150 of 211
B. Zoning Ordinance
The zoning ordinance implements the General Plan by establishing zoning districts that correspond
with General Plan land use designations. Development standards and permitted uses in each zoning
district are specified to govern the density, type, and design of different land uses for the protection
of public health, safety, and welfare (Government Code, Sections 65800-65863). The Fair Housing
Act does not pre-empt local zoning laws. However, the Act applies to municipalities and other local
government entities and prohibits them from making zoning or land use decisions or implementing
land use policies that exclude or otherwise discriminate against protected persons, including
individuals with disabilities. Another way that discrimination in zoning and land use may occur is
when a seemingly neutral ordinance has a disparate impact, or causes disproportional harm, to a
protected group. Land use policies such as density or design requirements that make residential
development prohibitively expensive, limitations on multi-family housing, or a household occupancy
standard may be considered discriminatory if it can be proven these policies have a disproportionate
impact on minorities, families with children, or people with disabilities.
Several aspects of the zoning ordinance that may affect a person’s access to housing or limit the
range of housing choices available are described below. As part of the Housing Element update,
jurisdictions are required to evaluate their land use policies, zoning provisions, and development
regulations and make proactive efforts to mitigate any constraints identified. However, the following
review is based on the current zoning ordinances as of the writing of this AI.
1. Definition of Family
A community’s zoning ordinance can potentially restrict access to housing for households failing to
qualify as a “family” by the definition specified in the zoning ordinance. For instance, a landlord may
refuse to rent to a “nontraditional” family based on the zoning definition of a family.42 A landlord
may also use the definition of a family as an excuse for refusing to rent to a household based on
other hidden reasons, such as household size. Even if the code provides a broad definition, deciding
what constitutes a “family” should be avoided by jurisdictions to prevent confusion or give the
impression of restrictiveness.
California court cases43 have ruled that a definition of “family” that: 1) limits the number of persons
in a family; 2) specifies how members of the family are related (i.e. by blood, marriage or adoption,
etc.), or (3) defines a group of not more than a certain number of unrelated persons as a single
housekeeping unit is invalid. Court rulings stated that defining a family does not serve any legitimate
or useful objective or purpose recognized under the zoning and land planning powers of the
jurisdiction, and therefore violates rights of privacy under the California Constitution. A zoning
ordinance also cannot regulate residency by discriminating between biologically related and unrelated
persons. Furthermore, a zoning provision cannot regulate or enforce the number of persons
constituting a family.
42 Most Zoning Ordinances that define families limit the definition to two or more individuals related by kinship,
marriage, adoption, or other legally recognized custodial relationship.
43 City of Santa Barbara v. Adamson (1980), City of Chula Vista v. Pagard (1981), among others.
July 14, 2020 Item #6 Page 151 of 211
The cities of Carlsbad (2011), Del Mar (2014), National City (2011) and San Marcos (2012) amended
or removed the definition of “family” from their zoning ordinances. As of February 2020, only the
City of Solana Beach includes a definition of “family” in its zoning ordinance that constitutes a
potential impediment to fair housing choice. The City defines “family” as “Two or more persons
living together as a bona fide single housekeeping unit. This definition of a family excludes
individuals. Such a definition can be considered an impediment because it may give landlords the
opportunity to deny renting single-family or multi-family dwelling units to single persons.
2. Density Bonus Ordinance
California Government Code Section 65915 includes requirements for local governments to provide
density bonuses and incentives for housing developers that agree to develop affordable housing
units. Density bonus requirements are regularly updated at the state level and must then be adopted
by local jurisdictions to comply with state law. The most recent changes to California density bonus
law went into effect in January 2020. Because of this, while most San Diego County jurisdictions
have density bonus provisions in their zoning ordinances, all cities and the County of San Diego
must review their regulations to ensure they continue to remain in compliance with state law.
3. Parking Requirements
Communities that require an especially high number of parking spaces per dwelling unit can
negatively impact the feasibility of producing affordable housing by reducing the achievable number
of dwelling units per acre, increasing development costs, and thus restricting the range of housing
types constructed in a community. Typically, the concern for high parking requirements is limited to
multi-family, affordable, or senior housing. The basic parking standards for jurisdictions in San
Diego County are presented in Table 65. Many jurisdictions offer reductions in parking
requirements in conjunction with density bonuses for affordable and senior housing.
Most jurisdictions in the county have comparable parking requirements. However, Coronado,
Imperial Beach, La Mesa, and Lemon Grove have parking standards for multi-family uses that do
not distinguish between parking required for smaller units (one or two bedrooms) and larger units
(three or more bedrooms). Because smaller multi-family units are often the most suitable type of
housing for seniors and persons with disabilities, requiring the same number parking spaces as larger
multi-family units can be a constraint on the construction of units intended to serve these
populations. Several of these cities, however, do offer reduced parking standards for housing
projects serving specific populations, such as senior housing or affordable housing projects.
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Table 65: Off-Street Parking Requirements
Jurisdictions SF MF ADU 1br 2br 3br 4+br Guest Space
Carlsbad 2 1.51 2 2 2 0.25 to 0.32 --3
Chula Vista 24 1.5 2 2 2 -- 1
Coronado5 26 2 2 2 2 -- --3--
Del Mar 27 1 2 2 3 0.25 1
El Cajon 2 1.5 2 2 2 0.258 1
Encinitas 2 to 39 2 2 2.5 2.5 0.25 1
Escondido 2 1.5 1.75 2 2 0.25 1
Imperial Beach10 2 1.5-2 1.5-2 1.5-2 1.5-2 -- 2
La Mesa 211 2 2 2 2 4/10 --
Lemon Grove 2 2 2 2 2 0.25 1
National City 212 1.3 1.5 1.5 1.5 0.513 1
Oceanside 214 1.5 2 2 2 0.1 to 0.2515 --
Poway 2 1.5 to 1.75 2.25 2.75 to 3 2.75 to 3 -- 1
San Diego City 16 2 1.0 to 1.75 1.75 to 2.25 2.0 to 2.5 2.0 to 2.5 --17 1
San Diego County 2 1.5 1.5 2 2 0.2 1
San Marcos 218 1.5 2 2 2 0.33 1
Santee 2 1.5 2 2 2 0.25 --
Solana Beach 2 1.5 2 2 2 0.25 1
Vista 219 2 2 2.5 2.5 0.3320 1
*Notes: ADU=accessory dwelling unit; bdrm = bedroom
1. Within the Village outside the Coastal Zone, parking required is 1.0 space per studio or one- bdrm unit and 1.5 spaces per unit
with two or more bdrms.
2. For projects up to 10 units, required guest parking is 0.3 spaces per unit; 0.25 spaces per unit for projects larger than 10 units.
3. Parking for the primary unit also serves the ADU.
4. 1.0 additional space required for each bdrm over four bdrms.
5. For multiple-family dwellings in the R-5 Zone and affordable housing, 1.5 spaces per dwelling unit are required. For senior
housing, 1.0 parking space is required for each dwelling unit.
6. For houses over 5,000 sf, 1.0 additional uncovered space is required.
7. For single-family dwellings with three or more bedrooms, 1.0 additional on-site parking space is required, including 2.0 garage
parking spaces.
8. 1.0 visitor space per unit is required in the RM-6000 zone.
9. 3.0 spaces required for dwelling units in excess of 2,500 square feet.
10. Residential units in the R-1-6000, R-1-3800, R-1500, R-2000, R-3000, and R-3000-D zones require 2.0 spaces per unit (including
ADUs, where allowed); and residential dwelling units in the C-1, C-2, C-3, MU-1 and MU-2 zones require 1.5 spaces per unit.
11. 5.0 spaces required on lots with long driveways and panhandle/easement access lots.
12. 3.0 spaces required per dwelling unit for units with more than 2,500 square feet in floor area, plus 1.0 space per bdrm proposed
over four bdrms.
13. Additional 0.25 spaces for each unit over 20.
14. For inland and downtown D Districts, 3.0 spaces are required for houses over 2,500 sf.
15. For multifamily projects with four to 10 units,1.0 space per unit is required. For projects with more than 10 units, 1.0 space per
unit plus 20 percent of the total number of units is required.
16. 1.0 space per bdrm required for single dwellings with five or more bdrms in campus impact areas. 1.0 space per bdrm, less 1.0
space also required per occupant age 18 and over in high occupancy single dwellings. Lower range of multi-family requirement is
for units in transit areas or lower income units. Higher range of multi-family requirement is for units in parking impact areas.
17. Guest spaces are required at a rate of 15-20 percent of total units with Planned Development Permits in specified communities.
18. Dwellings over 3,000 sf required three spaces.
19. Plus 2.0 - 2.5 guest spaces in semi-rural subdivisions.
20. For units with two or more bdrms, 0.5 guest space per unit is required.
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4. Short-Term Rentals
The rising popularity of home-sharing websites such as Airbnb and HomeAway in recent years has
led to significant increases in homes being offered on a short-term basis to generate rental income.
Homes may be offered as “home-shares,” where the primary resident offers one or more rooms to
visitors while remaining on site, or whole homes may be rented on a daily or weekly basis. Short-
term rentals are particularly popular in coastal locations, which have a robust demand for tourist
accommodations. While the impact of short-term rentals on housing availability and affordability is
still being evaluated, there is evidence that short-term rentals have a negative effect on housing
affordability by changing the way residential properties are used and reducing housing availability for
local residents.
San Diego jurisdictions vary in their approach to short-term rentals. The cities of Carlsbad, Chula
Vista, Del Mar, Encinitas, Imperial Beach, Oceanside, and Solana Beach explicitly allow short-term
rentals in at least some zones. With the exception of Imperial Beach, these cities require permits for
short-term rentals, and specify that short-term rentals must meet various performance standards to
be allowed to operate. The City of Lemon Grove does not allow entire homes to be used as short-
term rentals but does permit home-sharing with a permit.
Other jurisdictions, including the cities of El Cajon, Escondido, La Mesa, National City, Poway, San
Marcos, Santee, and Vista, and the County of San Diego, do not explicitly address short-term rentals
in their adopted regulations; however, the County of San Diego requires short-term rentals to pay
transient occupancy taxes. The Santee City Council considered developing regulations for short-term
rentals at an April 2019 meeting, but determined that due to the low number of rentals in Santee and
lack of complaints to date about their operations, additional regulations were not necessary at the
time.
As of February 2020, there was no consensus on the status or appropriate manner of regulating
short-term rentals in the City of San Diego. While the most recent (2017) City Attorney opinion on
short-term rentals notes that they are prohibited in single-family residential zones as a “commercial
use” and not specifically defined or expressly permitted in any other zone. In response to the City
Attorney’s opinion, the San Diego City Council adopted an ordinance allowing short-term rentals
with permits in some zones, but rescinded the new regulations in October 2018. While the City
Council has expressed a desire to adopt clear regulations for short-term rentals, as of the writing of
this report there have been no new regulations put in place and short-term rentals in the City of San
Diego continue to operate in a legal grey area.
The City of Coronado prohibits “transient rentals,” including short-term rentals, in residential zones.
July 14, 2020 Item #6 Page 154 of 211
C. Variety of Housing Opportunity
To ensure fair housing choice in a community, a zoning ordinance should provide for a range of
housing types, including single-family, multi-family, second dwelling units, mobile homes, licensed
community care facilities, employee housing for seasonable or migrant workers as necessary, assisted
living facilities, emergency shelters, supportive housing, transitional housing, and single room
occupancy (SRO) units. Table 66 provides a summary of each jurisdiction’s zoning ordinance as it
relates to ensuring a variety of housing opportunities.
1. Single- and Multi-Family Uses
Single- and multi-family housing types include detached and attached single-family homes, duplexes
or half-plexes, townhomes, condominiums, and rental apartments. Zoning ordinances should
specify the zones in which each of these uses would be permitted by right. All of the jurisdictions in
San Diego County accommodate the range of residential uses described above without a use permit,
although the City of Imperial Beach does require a site plan review by the Planning Commission for
developments with five or more units.
Zoning ordinances should also avoid “pyramid or cumulative zoning” (e.g. permitting lower-density
single-family uses in zones intended for higher density multi-family uses). Pyramid or cumulative
zoning schemes could limit the amount of lower-cost multi-family residential uses in a community
and be a potential impediment to fair housing choice. Most jurisdictions in the San Diego region
have some form of pyramid zoning and permitting single-family residential uses in multi-family
zones is the most prevalent example. The cities of Coronado, Lemon Grove, Oceanside, Poway, San
Marcos, and Santee prohibit single-family residential uses in higher-density, multi-family zones.
Allowing or requiring a lower density use in a zone that can accommodate higher density uses is
regulated by State law (SB 2292, also known as the Dutra Bill). A local government is required to
make a finding that an action that results in a density reduction, rezoning, or downzoning is
consistent with its Housing Element, particularly in relation to the jurisdiction’s ability to
accommodate its share of regional housing needs.
2. Accessory Dwelling Units
Accessory dwelling units (ADUs), also called second dwelling units or granny flats, are attached or
detached dwelling units that provide complete independent living facilities for one or more persons,
including permanent provisions for living, sleeping, cooking and sanitation. Accessory dwelling units
may be an alternative source of affordable housing for lower income households and seniors. These
units typically rent for less than apartments of comparable size.
California law requires local jurisdictions to adopt ordinances that establish the conditions under
which ADUs are permitted (Government Code, Section 65852.2). A jurisdiction cannot adopt an
ordinance that totally precludes the development of ADUs unless the ordinance contains findings
acknowledging that allowing second units may limit housing opportunities of the region and result in
adverse impacts on public health, safety, and welfare. An amendment to the State’s ADU law in
2003 requires local governments to use a ministerial, rather than discretionary, process for approving
July 14, 2020 Item #6 Page 155 of 211
ADUs (i.e. ADUs otherwise compliant with local zoning standards can be approved without a
public hearing) and allows jurisdictions to count second units towards meeting their regional
housing needs goals. A ministerial process is intended to reduce permit processing time frames and
development costs because proposed ADUs that are in compliance with local zoning standards can
be approved without a public hearing. All jurisdictions in the county currently permit second
dwelling units via a variety of review processes such as a zoning clearance or an administrative
permit in at least some zones.
Imperial Beach is the only jurisdiction with adopted findings allowing it to preclude second units.
Second units are allowed by-right within the City’s R-3000, R-2000, and R-1500 residential zones.
However, the City Council determined that allowing second units in R1-6,000 and R1-3,800 zones is
not in the best interest of public health, safety, and welfare and adopted findings to preclude second
units in those zones.
3. Mobile Home Parks
Provisions for mobile home parks vary among the San Diego County jurisdictions. Some
jurisdictions have designated mobile home park zones specifically to provide for this type of housing
(Carlsbad, Chula Vista, La Mesa, National City, Oceanside, Poway, San Marcos, and Vista). The City
of Encinitas provides for mobile home parks in its Mobile Home Park zone, and in higher density
zones upon issuance of a Conditional Use Permit, while the City of San Diego has a mobile home
park overlay zone to preserve existing sites. Other jurisdictions allow mobile home parks in some
residential zones with a Conditional Use Permit or Site Development Permit (Escondido, Imperial
Beach, City of San Diego, Poway, San Diego County, Santee, and Solana Beach). El Cajon, Santee
and Vista have Mobile Home Park Overlay Zones that permit new mobile home parks and the
expansion of current parks with a CUP or Site Development Plan. Coronado, Del Mar, and Lemon
Grove have no provisions for mobile home parks in their Zoning Ordinances.
July 14, 2020 Item #6 Page 156 of 211
Table 66: Variety of Housing Opportunity
Housing
Type Carlsbad Chula
Vista Coronado Del Mar El Cajon Encinitas
Single-family P P P P P P
Multi-family P P P P P P
Second
Dwelling Units P P P P P P
Mobile Home
Parks P P P P
Manufactured
Housing P P P P P P
Residential
Care Facilities
(≤6 persons)
P P P P P P
Residential
Care Facilities
(≥6 persons)
C C C C C C
Emergency
Shelters P5 P P P P C
Transitional
Housing P P P P P P
Supportive
Housing P P P P P P
SRO C3 P C P P
Farmworker/
Employee
Housing
P/C6 C P P
Notes: P – permitted by right; C – Conditionally permitted. ___ - Potential impediments.
1. Permitted but with a potential impediment.
2. Second units are allowed by-right within the City’s R-3000, R-2000, and R-1500 residential zones. However, they
are prohibited in the R1-6,000 and R1-3,800 zones.
3. Referred to as “managed living units.”
4. Referred to as “transient lodging.”
5. Emergency shelters with no more than 30 beds or persons is allowed by right in the M and P-M zones and are
conditionally allowed with more than 30 beds or persons in the same zones.
6. “Large farmworker housing complexes” are conditionally permitted: otherwise farmworker housing is permitted by
right.
7. Similarly permitted as similar uses in the same zone.
July 14, 2020 Item #6 Page 157 of 211
Table 66: Variety of Housing Opportunity
Housing
Type Escondido Imperial
Beach La Mesa Lemon
Grove
National
City Oceanside
Single-family P P P P P P
Multi-family P P1 P P P P
Second
Dwelling Units P P2 P P P P
Mobile Home
Parks C C C C P
Manufactured
Housing P P P P P P
Residential
Care Facilities
(≤6 persons)
P P P P P P
Residential
Care Facilities
(≥6 persons)
C C C C C C
Emergency
Shelters P P P P P P
Transitional
Housing P P P P P
Supportive
Housing P P P P
SRO C4 C C P P1
Farmworker/
Employee
Housing
P1 P P
Notes: P – permitted by right; C – Conditionally permitted. ___ - Potential impediments.
1. Permitted but with a potential impediment.
2. Second units are allowed by-right within the City’s R-3000, R-2000, and R-1500 residential zones. However, they
are prohibited in the R1-6,000 and R1-3,800 zones.
3. Referred to as “managed living units.”
4. Referred to as “transient lodging.”
5. Emergency shelters with no more than 30 beds or persons is allowed by right in the M and P-M zones and are
conditionally allowed with more than 30 beds or persons in the same zones.
6. “Large farmworker housing complexes” are conditionally permitted: otherwise farmworker housing is permitted by
right.
7. Similarly permitted as similar uses in the same zone.
July 14, 2020 Item #6 Page 158 of 211
Table 66: Variety of Housing Opportunity
Housing
Type Poway San Diego
City
San Diego
County
San
Marcos Santee Solana
Beach Vista
Single-family P P P P P P P
Multi-family P P P P P P P
Accessory
Dwelling Units P P P P P P P
Mobile Home
Parks C C C P C P P
Manufactured
Housing P P P P P P P
Residential
Care Facilities
(≤6 persons)
P P P P P P P
Residential
Care Facilities
(≥6 persons)
C1 C P/C C C C C
Emergency
Shelters P P P P P P
Transitional
Housing P P P/C1 P P P P1
Supportive
Housing P P P/C1 P P P P
SRO C3 P P/C C C C P
Farmworker/
Employee
Housing
P P1/C P1 C P P
Notes: P – permitted by right; C – Conditionally permitted. ___ - Potential impediments.
1. Permitted but with a potential impediment.
2. Second units are allowed by-right within the City’s R-3000, R-2000, and R-1500 residential zones. However, they
are prohibited in the R1-6,000 and R1-3,800 zones.
3. Referred to as “managed living units.”
4. Referred to as “transient lodging.”
5. Emergency shelters with no more than 30 beds or persons is allowed by right in the M and P-M zones and are
conditionally allowed with more than 30 beds or persons in the same zones.
6. “Large farmworker housing complexes” are conditionally permitted: otherwise farmworker housing is permitted
by right.
7. Similarly permitted as similar uses in the same zone.
July 14, 2020 Item #6 Page 159 of 211
4. Manufactured Housing
State law requires local governments to permit manufactured or mobile homes meeting federal
safety and construction standards on a permanent foundation in all single-family residential zoning
districts (Section 65852.3 of the California Government Code). All jurisdictions in San Diego
County comply with this requirement. Mobile homes offer an affordable housing option to many
low- and moderate-income households. To further preserve the affordability of mobile homes,
several cities in San Diego County, including Chula Vista and Santee, have adopted rent control
policies and ordinances for mobile homes.
5. Licensed Residential Care Facilities
The Lanterman Developmental Disabilities Services Act (Sections 5115 and 5116) of the California
Welfare and Institutions Code declares that mentally and physically disabled persons are entitled to
live in normal residential surroundings. The use of property for the care of six or fewer persons with
mental disorders or disabilities is required by law. A State-authorized, certified or authorized family
care home, foster home, or group home serving six or fewer persons with disabilities or dependent
and neglected children on a 24-hour-a-day basis is considered a residential use to be permitted in all
residential zones. No local agency can impose stricter zoning or building and safety standards on
these homes (commonly referred to as “group” homes) of six or fewer persons with disabilities than
are required of the other permitted residential uses in the zone.
All jurisdictions in San Diego County comply with the Lanterman Act and conditionally permit
larger residential care facilities serving seven or more residents in residential zones.
The Lanterman Act covers only licensed residential care facilities. The California Housing Element
law also addresses the provision of transitional and supportive housing, which includes non-licensed
housing facilities for persons with disabilities. This topic is discussed later.
6. Emergency Shelters
An emergency shelter is a facility that provides temporary shelter and feeding of indigents or disaster
victims, operated by a public or non-profit agency. State law requires jurisdictions to identify
adequate sites for housing which will be made available through appropriate zoning and
development standards to facilitate and encourage the development of a variety of housing types for
all income levels, including emergency shelters and transitional housing (Section 65583(c)(1) of the
Government Code). Recent changes in State law (SB 2) require that local jurisdictions make
provisions in the zoning code to permit emergency shelters by right in at least one zoning district
where adequate capacity is available to accommodate at least one year-round shelter. Local
jurisdictions may, however, establish standards to regulate the development of emergency shelters.
At the writing of this report, 18 of the 19 jurisdictions in the county allow emergency shelters by
right consistent with State law. The following jurisdictions: Carlsbad (2012), Chula Vista (2018),
Coronado (2014), Del Mar (2013), El Cajon (2015), Encinitas (2019), Escondido (2013), Imperial
Beach (2012), La Mesa (2019), Lemon Grove (2019), National City (2011), Oceanside (2013), San
Diego City (2016), San Diego County (2010), San Marcos (2012), Santee (2019), Solana Beach (2014)
and Vista (2012) have amended their zoning ordinances to permit emergency shelters, consistent
July 14, 2020 Item #6 Page 160 of 211
with the provisions of SB 2. However, as of February 2020, the city of Poway did not have adequate
provisions for emergency shelters in their zoning ordinance.
The City of Poway does not allow emergency shelters by right in any zone. The currently adopted
Housing Element (2013-2020 cycle) acknowledges the need to update the City’s zoning ordinance to
allow year-round emergency shelters in compliance with state law, but no amendment to the zoning
ordinance had been completed as of February 2020.
Furthermore, recent changes to State law require additional changes to the Emergency Shelter
provisions:
AB 139 (Emergency and Transitional Housing) – parking for shelter staff only; definition of
sufficient capacity
AB 101 (Low Barrier Navigation Center) – housing for homeless or at-risk homeless while
waiting to transition to permanent housing
Jurisdictions must update their Zoning Ordinances to comply with State law. The City of Encinitas
updated their zoning ordinance in 2019 to comply with AB 139.
7. Transitional and Supportive Housing
State law (AB 2634 and SB 2) requires local jurisdictions to address the provisions for transitional
and supportive housing. Under Housing Element law, transitional housing means buildings
configured as rental housing developments, but operated under program requirements that require
the termination of assistance and recirculation of the assisted unit to another eligible program
recipient at a predetermined future point in time that shall be no less than six months from the
beginning of the assistance (California Government Code Section 65582(h)).
Supportive housing means housing with no limit on length of stay, that is occupied by the target
population and is linked to an onsite or offsite service that assists the supportive housing resident in
retaining the housing, improving his or her health status, and maximizing his or her ability to live
and, when possible, work in the community. Target population means persons with low incomes
who have one or more disabilities, including mental illness, HIV/AIDS, substance abuse, or other
chronic health condition, or individuals eligible for services provided pursuant to the Lanterman
Developmental Disabilities Services Act (Division 4.5 [commencing with Section 4500] of the
Welfare and Institutions Code) and may include, among other populations, adults, emancipated
minors, families with children, elderly persons, young adults aging out of the foster care system,
individuals exiting from institutional settings, veterans, and homeless people (California
Government Code Sections 65582(f) and (g)).
Accordingly, State law establishes transitional and supportive housing as a residential use and
therefore local governments cannot treat it differently from other similar types of residential uses
(e.g., requiring a use permit when other residential uses of similar function do not require a use
permit). Of the County’s 19 jurisdictions, 17 had amended their zoning ordinances to include these
provisions for transitional and supportive housing as of February 2020.
July 14, 2020 Item #6 Page 161 of 211
The County of San Diego amended the Zoning Ordinance in 2010 to distinguish between group
care facilities for six or fewer people (family care home) and group care facilities for seven or more
(group care). For facilities serving six or fewer persons, a transitional or supportive housing project
that requires state community care licensing would be considered a family care home by the County.
For facilities serving seven or more persons, a transitional or supportive housing project that
requires state community care licensing would be considered a group care facility, which is permitted
in RC, C31, C34, C35, C37, and C46 zones and with a Major Use Permit in A70, A72, and all other
residential zones.
The City of La Mesa has historically treated transitional housing for the homeless as "residential care
facilities" or "community care facilities" in their zoning ordinance. Supportive housing is not
expressly addressed in the Zoning Ordinance. The City recognizes that it must update its ordinance
to comply with state requirements for transitional and supportive housing, but had not completed
amendments to its zoning code as of the writing of this report.
The City of Vista amended its zoning code in 2015 to allow supportive housing subject to
development standards applicable to residential uses in the same zone. The City permits transitional
housing facilities for battered women and children (serving six or fewer clients) in all residential
zones. Other transitional housing facilities are permitted only in the City’s RM zone.
The County of San Diego and City of La Mesa do not fully comply with all of the requirements of
SB 2 in their treatment of transitional and supportive housing, and their zoning ordinances will need
to be further amended in order to maintain consistency with State law.
8. Single-Room Occupancy (SRO)
AB 2634 also mandates that local jurisdictions address the provision of housing options for
extremely low-income households, including Single Room Occupancy units (SRO). SRO units are
one room units intended for occupancy by a single individual. It is distinct from a studio or
efficiency unit, in that a studio is a one-room unit that must contain a kitchen and bathroom.
Although SRO units are not required to have a kitchen or bathroom, many SROs have one or the
other.
As of February 2020, the cities of Del Mar and La Mesa do not have adequate SRO provisions in
their zoning ordinances.
9. Farmworker Employee Housing
The California Employee Housing Act requires that housing for six or fewer employees be treated as
a single-family residential use. The Employee Housing Act also requires that housing for agricultural
workers consisting of 36 beds or 12 units be treated as an agricultural use and permitted where
agricultural uses are permitted in the same way that other agricultural uses are permitted in that zone.
No conditional use permit, zoning variance, or other discretionary zoning clearance can be required
for these employee housing developments that is not required of any other agricultural activity in the
same zone. The permitted occupancy in employee housing in a zone allowing agricultural uses must
include agricultural employees who do not work on the property where the employee housing is
July 14, 2020 Item #6 Page 162 of 211
located. Compliance with these requirements among participating jurisdictions is summarized in
Table 67. Some jurisdictions allow employee housing for six or fewer employees as a single-family
residential use but have not updated their zoning ordinance to explicitly permit this use in
accordance with the California Housing Act.
Escondido permits a caretaker’s residence for farmworkers deriving the majority of their income
from employment on the premises in most residential zones that allow agriculture, but does not
specify that farmworker employee housing is allowed in all zones where commercial agricultural use
is permitted.
The City of La Mesa has no agricultural zones but allows agricultural uses in some single-family
residential zones. However, the City considers agricultural uses in these zones accessory the the
residential uses and not commercial in nature, with the agricultural products intended for
consumption by the household. As such, provisions for farmworker employee housing in these
residential zones that allow accessory agricultural use is not required by State law. The City
recognizes that it should amend the Zoning Ordinance to clarify the types of non-commercial
agricultural activities allowable in the single-family zones as accessory uses.
The City of Solana Beach does not have any agricultural zones, there are no agricultural operations
within Solana Beach, and no full-time agricultural workers reside in the City. Because of this, the
City argues that other affordable housing options provided by the City can serve the housing needs
of farmworkers as well, and there is not a need to specifically provide for farmworker employee
housing within the City.
July 14, 2020 Item #6 Page 163 of 211
Table 67: Farmworker Employee Housing by Jurisdiction
Jurisdiction
Commercial
Agricultural
Zoning / Uses
Permits
Farmworker Housing in
Zoning Ordinance
Compliance with
Employee Housing
Act
Carlsbad Yes Yes Yes
Chula Vista Yes Yes Yes
Coronado No n/a No
Del Mar No n/a No
El Cajon Yes Yes Yes
Encinitas No n/a Yes
Escondido Yes No No
Imperial Beach No n/a Yes
La Mesa No n/a No
Lemon Grove No n/a No
National City No n/a No
Oceanside Yes Yes No
Poway Yes Yes No
San Diego (City) Yes Yes No
San Diego (County) Yes Yes No
San Marcos Yes Yes No
Santee Yes Yes No
Solana Beach No n/a No
Vista Yes Yes Yes
D. Building Codes and Occupancy Standards
1. Building Codes
Building codes, such as the California Building Standards Code44 and the Uniform Housing Code are
necessary to protect public health, safety, and welfare. However, local codes that require substantial
improvements to a building might not be warranted and deter housing construction and/or
neighborhood improvement.
The California Building Standards Code is published every three years by order of the California
legislature. The Code applies to all jurisdictions in the State of California unless otherwise annotated.
Adoption of the triennial compilation of Codes is not only a legal mandate, it also ensures the
highest available level of safety for citizens and that all construction and maintenance of structures
44 California Building Standards Code, adopted by the a Building Standards Commission, is actually a set of uniform
building, electrical, mechanical, and other codes adopted by professional associations such as the International
Conference of Building Officials, and amended to include California-specific requirements.
July 14, 2020 Item #6 Page 164 of 211
meets the highest standards of quality. Most jurisdictions in the San Diego region have adopted the
2019 California Building Standards Code, with the exception of National City, which has adopted
the 2016 California Building Code. Other codes commonly adopted by reference within the region
include the California Mechanical Code, California Plumbing Code, California or National Electric
Code, Uniform Housing Code, and California Fire Code. Less common are the California Uniform
Code for the Abatement of Dangerous Buildings, the Urban-Wildland Interface Code, and the
Uniform Code for Building Conservation. Most jurisdictions have amended portions of these codes
to reflect non-arbitrary local conditions including geographical and topographic conditions unique to
each locality. Although minor amendments have been incorporated to address local conditions, no
additional regulations have been imposed by the city or county that would unnecessarily add to
housing costs or otherwise impede fair housing choice.
2. Occupancy Standards
Disputes over occupancy standards are typical tenant/
landlord and fair housing issues. Families with children
and large households may face discrimination in the
housing market, particularly in the rental housing market,
because landlords are reluctant or flatly refuse to rent to
such households. Establishing a strict occupancy standard,
either by the local jurisdictions or by landlords on the
rental agreements, may be a violation of fair housing
practices.
In general, no state or federal regulations govern occupancy standards. The State Department of
Fair Employment and Housing (DFEH) uses the “two-plus-one” rule in considering the number of
persons per housing unit – two persons per bedroom plus an additional person. Using this rule, a
landlord cannot restrict occupancy to fewer than three persons for a one-bedroom unit or five
persons for a two-bedroom unit, etc. While DFEH also uses other factors, such as the age of the
occupants and size of rooms, to consider the appropriate standard, the two-plus-one rule is generally
followed.
Other guidelines are also used as occupancy standards. The Uniform Housing Code (Section 503.2)
requires that a dwelling unit have at least one room which is not less than 120 square feet in area.
Other habitable rooms, except kitchens, are required to have a floor area of not less than 70 square
feet. The Housing Code further states that where two persons occupy a room used for sleeping
purposes, the required floor area should be increased at a rate of 50 square feet for each occupant in
excess of two. There is nothing in the Housing Code that prevents people from sleeping in the living
or dining rooms, as long as these rooms have a window or door meeting all the provisions of the
California Building Code for emergency egress. The Fire Code allows one person per 150 square feet
of “habitable” space. These standards are typically more liberal than the “two-plus-one” rule. For
example, three people could sleep in a one-bedroom apartment where the bedroom is at least 120
square feet; and where the living/dining area is at least 170 square feet, an additional three people
could sleep there. Therefore, a 290-square foot one-bedroom apartment can accommodate up to six
persons or a two-bedroom 410-square foot apartment can sleep up to nine persons.
“2+1” Rule
Most State and federal housing programs
use the “2+1” rule as an acceptable
occupancy standard. The appropriate
number of persons per housing unit is
estimated at two persons per bedroom plus
an additional person. For example, a two-
bedroom unit could have five occupants.
July 14, 2020 Item #6 Page 165 of 211
A review of occupancy standards for jurisdictions within the San Diego region revealed that none of
the jurisdictions overtly limit the number of people who can occupy a housing unit. As previously
discussed, court rulings stated a Zoning Ordinance cannot regulate residency by discrimination
between biologically-related and unrelated persons. None of the jurisdictions in the county have a
definition of “family” in their Zoning Ordinance with references to how members of a family are
related or the maximum number of members in the household. However, the definition of “family”
in the Solana Beach zoning ordinance excludes individuals. Such a definition can be considered an
impediment because it may give landlords the opportunity to deny renting single-family or multi-
family dwelling units to single persons.
E. Affordable Housing Development
In general, many minority and special needs households are disproportionately affected by a lack of
adequate and affordable housing in a region. While affordability issues are not directly fair housing
issues, expanding access to housing choices for these groups cannot ignore the affordability factor.
Insofar as rent-restricted or non-restricted low-cost housing is concentrated in certain geographic
locations, access to housing by lower-income and minority groups in other areas is limited and can
therefore be an indirect impediment to fair housing choice. Furthermore, various permit processing
and development impact fees charged by local government results in increased housing costs and
can be a barrier to the development of affordable housing. Other policies and programs, such as
inclusionary housing and growth management programs, can either facilitate or inhibit the
production of affordable housing. These issues are examined in the subsections below.
1. Siting of Affordable Housing
The San Diego region has a large inventory of rent-restricted multi-family housing units. The
distribution of these units, however, is highly uneven throughout the region, with dense clusters of
assisted housing located in central San Diego, National City, Chula Vista and Escondido (see Figure
13 on page 91). Almost three-quarters (71.4 percent) of the region’s rent-restricted multi-family
housing stock is concentrated in these four cities. Jurisdictions with the highest concentration of
rent-restricted multi-family housing units (as measured by the ratio of rent-restricted units to total
housing units) include National City (12.1 percent), San Marcos (5.4 percent) and Carlsbad (4.3
percent) (see Table 68). Jurisdictions with the lowest concentration of rent restricted multi-family
units (as measured by the number of restricted units per 500 housing units) are Del Mar (0.0), Solana
Beach (0.0), Encinitas (2.9), and Lemon Grove (5.4).
July 14, 2020 Item #6 Page 166 of 211
Table 68: Rent-Restricted Multi-Family Housing Units by Jurisdiction
Jurisdiction
Rent
Restricted
Units
Total Housing
Units (2019)
% of
Housing
Stock Rent
Restricted
% of All Rent
Restricted
Units in County
Rent
Restricted
Units per 500
Housing Units
Urban County
Coronado 142 9,740 1.5% 0.4% 7.3
Del Mar 0 2,625 0.0% 0.0% 0.0
Imperial Beach 129 10,074 1.3% 0.3% 6.4
Lemon Grove 98 9,114 1.1% 0.2% 5.4
Poway 704 16,917 4.2% 1.8% 20.8
San Marcos 1,729 32,126 5.4% 4.4% 26.9
Solana Beach 0 6,569 0.0% 0.0% 0.0
Unincorporated Areas 2,215 178,844 1.2% 5.6% 6.2
Entitlement Cities
Carlsbad 2,037 47,080 4.3% 5.2% 21.6
Chula Vista 2,545 85,535 3.0% 6.5% 14.9
El Cajon 1254 36,148 3.5% 3.2% 17.3
Encinitas 152 26,495 0.6% 0.4% 2.9
Escondido 1,559 48,833 3.2% 4.0% 16.0
La Mesa 566 26,869 2.1% 1.4% 10.5
National City 2,097 17,264 12.1% 5.3% 60.7
Oceanside 1,307 65,902 2.0% 3.3% 9.9
San Diego 21,937 545,645 4.0% 55.7% 20.1
Santee 578 21,100 2.7% 1.5% 13.7
Vista 349 32,580 1.1% 0.9% 5.4
Total County 39,398 1,219,460 3.2% 100.0% 16.2
Source: California Department of Finance, 2019; HUD, California Housing Partnership, and participating jurisdictions.
July 14, 2020 Item #6 Page 167 of 211
2. Development Fees
Housing construction imposes certain short- and long-term costs upon local government, such as
the cost of providing planning services and inspections. As a result, San Diego County jurisdictions
rely upon various planning and development fees to recoup costs and ensure that essential services
and infrastructure are available when needed. Planning fees for the County of San Diego and its
jurisdictions are summarized in Table 69. As shown, fees vary widely based on the needs of each
jurisdiction.
Table 69: Planning Fees by Jurisdiction
Jurisdiction General Plan
Amendment CUP Variance Tract Map Parcel
Map
Zone
Change
Carlsbad $4,677-$6,747 $4,913 $3,098 $8,193 $3,678 $5,373-
$7,279
Chula Vista $20,0001 $11,0001 $9,0001 $10,0001 $2,5001 $10,0001
Coronado $5,0001 $3,533 $3,846 -- $1,703 $5,0001
Del Mar $10,0001 $8,513 $5,370 $6,250 $5,240 $10,0001
El Cajon $3,505 $5,195 $1,025 $6,225 +
$74/lot
$3,625 +
$26/lot $4,125
Encinitas $13,0001 $6,000 $3,810 $13,000 +
650/lot $4,555 $20,0001
Escondido $5,185-$9,880 $3,050 $2,030 $4,107-
$6.905 $2,635 $3,900-
$5,100
Imperial Beach $5,000 $2,000 $1,800 $2,500 $2,000 $3,000
La Mesa $15,179 $2,095-
$4,150
$2,097-
$4,127 $7,557 $5,859 $13,730
Lemon Grove $3,000 $1,500 $750 $4,500 $2,700 $1,000
National City $5,500 $3,700 $3,700 $4,000 $3,000 $5,500
Oceanside $10,000-
$15,0001 $5,0001 $4,0001 $8,0001 $3,0001 $8,000-
$15,0001
Poway $1,917 $3,299 $799 $4,174 $2,711 $1,917
San Diego City $12,0001 $8,0001 $8,0001 $10,0001 $10,0001 $12,0001
San Diego County $16,2271 $10,2241 $3,9451 $19,0991 $11,7111 $10,8721
San Marcos $2,500 $3,476 $564 $2,690 +
$50/lot $2,090 $872
Santee $13,0001 $15,000-
$20,0001 $2,5001 $16,0001 $6,0001 $13,0001
Solana Beach $10,0001 $8,660 $6,555 $14,000 $10,725 $10,0001
Vista $9782 $7,430 $3,119 $6,719-
$9,253 $4,368 $9,621
Source: Participating jurisdictions, 2020.
Notes:
1. Indicates initial deposit amount. Actual fee is full cost recovery.
July 14, 2020 Item #6 Page 168 of 211
3. Development Impact Fees
Jurisdictions also charge a variety of impact fees to offset the cost of providing the infrastructure
and public facilities required to serve new development. Until 1978, property taxes were the primary
revenue source for financing the construction of infrastructure and improvements required to
support new residential development. The passage of Proposition 13 in 1978 has limited a local
jurisdiction’s ability to raise property taxes and significantly lowered the ad valorem tax rate,
increasing reliance on other funding sources to provide infrastructure, public improvements, and
public services. An alternative funding source widely used among local governments in California is
the development impact fee, which is collected for a variety of improvements including water and
sewer facilities, parks, and transportation improvements.
To enact an impact fee, State law requires that the local jurisdiction demonstrate the “nexus”
between the type of development in question and the impact being mitigated by the proposed fee.
Also, the amount of the fee must be roughly proportional to the impact caused by the development.
Nevertheless, development impact fees today have become a significant cost factor in housing
development. Jurisdictions in San Diego County have imposed a variety of impact fees for new
development (Table 70).
Table 70: Development Impact Fees by Jurisdiction
Parks Transportation/
Traffic
Public Facilities/
Sewer Public Art
Carlsbad
Chula Vista
Coronado
Del Mar
El Cajon
Encinitas
Escondido
Imperial Beach
La Mesa
Lemon Grove
National City
Oceanside
Poway
San Diego City
San Diego County
San Marcos
Santee
Solana Beach
Vista
Source: Participating jurisdictions, 2015.
July 14, 2020 Item #6 Page 169 of 211
The contribution of fees to home prices varies temporally as well as spatially. When times are good,
housing production tends to lag behind demand, especially in coastal markets. Housing prices during
such periods are chiefly affected by the balance between supply and demand and are much less
affected by construction and development costs. When economic times are bad and demand is
weak, housing prices are more sharply affected by the prices of construction inputs, including fees.
The strength of the economy and housing market also determines the degree of fee shifting and who
ultimately pays fees. During strong economic times, it is the final homebuyer or renter who ends up
paying housing development fees; the builder or developer is mostly an intermediary. During
recessionary periods, the burden of paying fees may be shifted backwards to the landowner.
4. Linkage Fees
A linkage fee is a development impact fee applied to non-residential development. This fee can be
used by local governments to support affordable housing construction and it is applied in
recognition of the housing needs of lower-income workers who often are employed by end users of
new development. Linkage fees can facilitate de-concentration of affordable housing development
and reduce the negative social and environmental effects of jobs-housing imbalances in a region if
the use of this funding is combined with a policy that requires the scattering of affordable units
throughout a community and/or require concurrent construction of market-rate and affordable
units in new development.
Currently, the City of San Diego is the only jurisdiction that charges a linkage fee to non-residential
development to offset the cumulative effects of non-residential development on affordable housing
and transportation. The underlying purpose of the City of San Diego’s linkage fee is to ensure that
new office, retail, research and development, manufacturing, warehouse, and hotel development pay
a fair share of the subsidies necessary to house the low-income employees related to such
development. The fees are placed in the San Diego Housing Trust Fund and can be utilized to assist
the construction of affordable housing units located anywhere within the boundaries of the City of
San Diego. The Municipal Code establishes a mechanism to ensure a geographic nexus between the
location of new jobs and the expenditure of revenue for housing projects.45
F. Other Land Use Policies, Programs, and Controls
Land use policies, programs, and controls can impede or facilitate housing development and can
have implications for fair housing choice in a community. Inclusionary housing policies and
redevelopment project areas can facilitate new affordable housing projects, while growth
management programs can impede new affordable housing development. Jurisdictions that have not
sought Article 34 authority may also be prevented from directly engaging in affordable housing
development. Table 71 identifies jurisdictions that are affected by or have adopted land use policies,
programs, and controls that may have a negative impact on housing development and fair housing
choice.
45 For more information, see Chapter 9, Article 8, Division 6 of the San Diego Municipal Code.
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Table 71: Land Use Policies and Controls by Jurisdiction
Jurisdictions Article 34 Growth
Management
Inclusionary
Housing
Carlsbad
Chula Vista
Coronado
Del Mar
El Cajon
Encinitas
Escondido
Imperial Beach
La Mesa
Lemon Grove
National City
Oceanside
Poway
San Diego City
San Diego County
San Marcos
Santee
Solana Beach
Vista
1. Article 34
Article 34 of the State Constitution requires a majority vote of the electorate to approve the
development, construction, or acquisition by a public body of any “low rent housing project” within
that jurisdiction. In other words, for any projects to be built and/or operated by a public agency
where at least 50 percent of the occupants are low-income and rents are restricted to affordable
levels, the jurisdiction must seek voter approval known as “Article 34 authority” to authorize that
number of units. Several jurisdictions within the San Diego region have obtained Article 34 authority
to be directly involved in the development, construction, or acquisition of low-rent housing.
Carlsbad voters approved an Article 34 measure to allow no more than 200 units of senior low
income housing in November 1980; this authority has only been exercised twice since voter
approval. The City of Chula Vista currently has 24 remaining Article 34 units allotted and on
November 7, 2006 voters approved authority for an additional 1,600 units. No projects requiring
Article 34 authority have been proposed in Del Mar, therefore, residents have not been asked to
vote on a referendum to allow the City to develop, construct, or acquire affordable housing. The
City of El Cajon has voter approval for senior projects only and complies with Article 34 for all
other housing types. In 1978, La Mesa residents voted to provide the City with authority to develop,
acquire, or construct 200 senior units under Article 34. To date, the City has used 128 units of its
Article 34 authority for the development of La Mesa Springs and has a remaining capacity of 72
units. Voters in the City of San Diego approved Measure M in 2016 to allow the City to develop,
July 14, 2020 Item #6 Page 171 of 211
construct, or acquire up to 49,180 affordable units, an increase in 38,680 units over the previous
number of allowable units. The voters of the City of Vista approved Proposition W in 1980,
authorizing the development of up to 95 low-income, rental housing units per year without going to
a public vote.
In the past, Article 34 may have prevented certain projects from being built because seeking voter
approval for such activities was controversial and difficult. In practice, most public agencies have
learned how to structure projects to avoid triggering Article 34, such as limiting public assistance to
49 percent of the units in the project. Furthermore, the State legislature has enacted Sections 37001,
37001.3, and 37001.5 of the Health and Safety Code to clarify ambiguities relating to the scope of
the applicability of Article 34.
In 2018, two State Senators introduced legislation to repeal Article 34 as Senate Constitutional
Amendment 1 (SCA 1). The California Senate passed SCA 1 in September 2019 by unanimous vote.
If passed by the California Assembly, the amendment can be placed on the ballot for potential
approval by California voters.
2. Growth Management Programs
Growth management programs facilitate well-planned development and ensure that the necessary
services and facilities for residents are provided. However, a growth management program may act
as a constraint if it prevents a jurisdiction from addressing its housing needs, which could indirectly
impede fair housing choice. These programs range from general policies that require the expansion
of public facilities and services concurrent with new development, to policies that establish urban
growth boundaries (the outermost extent of anticipated urban development), to numerical
limitations on the number of dwelling units that may be permitted annually. Of the county’s 19
jurisdictions, eight have adopted Growth Management Programs. While the programs are intended
to manage growth, the programs are highly variable in detail.
The City of Carlsbad has a growth management program that establishes a maximum amount of
dwelling units for each quadrant of the City, and also includes performance standards that require
services and infrastructure to be provided to meet the demands of new development. However, the
City of Carlsbad is also recognized as having one of the State’s most effective inclusionary housing
policies with a proven affordable housing production track record.
Chula Vista’s Growth Management Program establishes thresholds for eleven areas including traffic,
police, fire and emergency services, schools, libraries, parks and recreation, water, sewer, drainage,
air quality, and economics.
The Encinitas General Plan Land Use Element includes restrictions on residential construction
based on average citywide density, which have been identified as obsolete. While the City’s adopted
Housing Element acknowledges the need to revise the Land Use Element to eliminate these policies
as part of its affordable housing implementation program, amendments to the Land Use Element to
eliminate these growth management policies have not yet been adopted. Encinitas requires voter
approval to increase residential density or modify land use from non-residential zoning. However, in
2018 a California judge temporarily suspended this requirement to allow the City to adopt land use
changes included in the City’s 2013-2021 Housing Element.
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Escondido requires voter approval for all proposals to increase residential density or non-residential
intensity (such as through general plan amendments). However, the City does not require voter
approval for increase in density in cases where affordable housing is involved to ensure compliance
with housing law.
In 1979, the City of San Diego implemented a Tier System to manage growth. Under this system,
the Urban Core would develop first, then the outlying urban area, and finally the Future Urbanizing
Area which is now being developed. Growth is managed in the unincorporated areas of San Diego
County through the Multiple Species Conservation Plan (MSCP) and establishment of residential
buildout ceilings and large minimum lot sizes (40 acres in some cases) within several community
planning areas.
Residential growth management requirements in San Marcos require new development in the city to
ensure funding and timely construction of all threshold public facilities or services, as required by
location.
Solana Beach voters passed Proposition T in 2000, which requires voter approval to change, alter, or
increase General Plan residential land use categories. Because the City can meet its RHNA
requirements under existing land use designations, it does not consider the growth management plan
an impediment to affordable housing.
The cities of Coronado, Del Mar, El Cajon, Imperial Beach, La Mesa, Lemon Grove, National City,
Oceanside, Poway, Santee, and Vista have not adopted growth management programs.
State housing law mandates a jurisdiction facilitate the development of a variety of housing to meet
the jurisdiction’s fair share of regional housing needs. Any growth management measure that would
compromise a jurisdiction’s ability to meet its regional housing needs may have an exclusionary
effect of limiting housing choices and opportunities of regional residents or concentrating such
opportunities in other areas of the region.
3. Inclusionary Housing Programs
Inclusionary housing describes a local government’s requirement specifying a percentage of new
housing units be reserved for, and affordable to, lower- and moderate-income households. The goal
of inclusionary housing programs is to increase the supply of affordable housing commensurate with
new market-rate development in a jurisdiction. This can result in an improved regional jobs-housing
balances and foster greater economic and racial integration within a community. The policy is most
effective in areas experiencing rapid growth and a strong demand for housing.
Inclusionary programs can be voluntary or mandatory. Voluntary programs typically require
developers to negotiate with public officials but do not specifically mandate the provision of
affordable units. Mandatory programs are usually codified in the zoning ordinance and developers
are required to enter into a development agreement specifying the required number of affordable
housing units or payment of applicable in-lieu fee46 prior to obtaining a building permit.
46 An in-lieu fee is the payment of a specified sum of money instead of constructing the required number of affordable
housing units. The fee is used to finance affordable housing elsewhere in a community.
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In San Diego County, 10 jurisdictions had adopted inclusionary housing programs as of February
2020. All programs in the county can be described as mandatory because they require dedication of a
fixed percentage of proposed units affordable to lower or moderate income households or payment
of an in-lieu fee used to build new affordable housing units in the jurisdiction. Inclusionary housing
programs in the county vary considerably by jurisdiction.
The City of Carlsbad requires 15 percent of all base residential units within any Master Plan/Specific
Plan community or other qualified subdivision (currently seven units or more) to be restricted and
affordable to lower-income households.
Chula Vista requires the provision of 10 percent (five percent low-income and five percent
moderate-income) affordable housing within projects of 50 or more dwelling units.
The City of Coronado’s inclusionary housing program requires that parcel or subdivision maps
involving two or more lots or two or more dwelling units provide 20 percent of the total units in the
development for rent to lower-income households. Under this program no inclusionary units have
been constructed by market-rate developers as of the writing of this report; however, in-lieu fees
collected from these developers have contributed to the expansion of affordable housing in the City
through the Community Development Agency programs.
The City of Del Mar Assistance Program requires that certain housing developments pay an in-lieu
fee or set aside some of units for affordable housing. In-lieu fees are placed in a Housing Assistance
Reserve and used to provide rental subsidies to low-income households.
The City of Encinitas requires residential development to provide 15 percent of units for low-
income households or 10 percent for very low-income households unless exempted or an alternative
for providing affordable units is approved.
The City of El Cajon’s affordable housing requirement was based on its redevelopment housing
requirement. However, with the dissolution of redevelopment in California, this requirement is no
longer applicable. The City’s Housing Element includes an action to evaluate the need for a citywide
inclusionary housing ordinance, but the City had not adopted an updated ordinance as of February
2020.
National City’s affordable housing requirement was also part of its redevelopment program, which
was eliminated in 2011 by changes to state law. Remaining redevelopment funds earmarked for
affordable housing are used to increase, maintain, and preserve affordable housing for low- and
moderate-income households.
The City of Oceanside requires new residential development to include 1015 percent affordable
units or play an in-lieu fee. The City of Poway requires new residential development to make 15
percent of units affordable to low-income households, 20 percent affordable to moderate-income
households, or pay an in-lieu fee. The City of San Diego requires all residential development of two
or more units to pay an Inclusionary Affordable Housing Fee or provide affordable units on site,
unless exempt.
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In October 2018 the County Board of Supervisors directed staff to prepare an economic analysis
and criteria for a potential General Plan Amendment to create an affordable housing program
and/or an inclusionary housing ordinance. To date the Board has not taken further action on these
potential amendments.
San Marcos requires residential development to provide 15 percent of units as affordable or pay an
in-lieu fee, depending on the size of the development. The City of Solana Beach requires residential
development of five or more units to set aside 15 percent as affordable units.
The City of Vista eliminated their inclusionary housing requirements in 2015.
G. Policies Causing Displacement or Affect Housing
Choice of Minorities and Persons with Disabilities
Local government policies could result in displacement or affect representation of minorities or the
disabled.
1. Reasonable Accommodation
Under State and Federal laws, local governments are required to “reasonably accommodate” housing
for persons with disabilities when exercising planning and zoning powers. Jurisdictions must grant
variances and zoning changes if necessary to make new construction or rehabilitation of housing for
persons with disabilities feasible, but are not required to fundamentally alter their zoning ordinance.
Although most local governments are aware of State and federal requirements to allow reasonable
accommodations, if specific policies or procedures are not adopted by a jurisdiction, disabled
residents may be unintentionally displaced or discriminated against. Lemon Grove is the only
jurisdiction in the region that had not adopted a formal reasonable accommodation procedure as of
February 2020.
Currently, most of the cities with adopted reasonable accommodations procedures (with the
exception of Escondido, La Mesa, National City, Oceanside, and Santee) have a definition of
disabled person in their Zoning Ordinance. A jurisdiction’s definition of a disabled person can be
considered an impediment to fair housing if it is not consistent with the definition of disability
provided under the Fair Housing Act. The Act defines disabled person as “those individuals with
mental or physical impairments that substantially limit one or more major life activities.” All of the
definitions used by San Diego jurisdictions are consistent with the Fair Housing Act and are not
considered an impediment.
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H. Local Housing Authorities
In the San Diego region, the HUD Housing Choice Voucher program is administered by six
different local housing authorities, two of which also oversee a public housing program. The
following housing authorities only administer housing choice vouchers: Carlsbad, Encinitas,
Oceanside, and National City. The housing authorities for the City and County of San Diego also
own and manage public housing in addition to administering the Housing Choice Voucher program.
The availability and use of Housing Choice Vouchers and public housing units must also adhere to
fair housing laws. Most local housing authorities in the county have adopted priorities or preferences
for Housing Choice Vouchers and/or public housing. Typically, families with children, elderly
families, disabled families, and veterans are given preferences.
Section 16(a)(3)(B) of the United States Housing Act (Housing Act) mandates that public housing
authorities adopt an admissions policy that promotes the deconcentration of poverty in public
housing. HUD emphasizes that the goal of deconcentration is to foster the development of mixed-
income communities within public housing. In mixed-income settings, lower income residents are
provided with greater access to employment and information networks.
For Housing Choice Vouchers, the Housing Act mandates that not less than 75 percent of new
admissions must have incomes at or below 30 percent of the Area Median Income. The remaining
balance of 25 percent may have incomes up to 50 percent of the Area Median Income. For public
housing, the Housing Act mandates that not less than 40 percent of new admissions must have
incomes at or below 30 percent of the Area Median Income. The balance of 60 percent of new
admissions may have incomes up to 50 percent of the Area Median Income.
I. California Environmental Quality Act (CEQA)
CEQA is California's broadest environmental law as it applies to all discretionary projects proposed
to be conducted or approved by a public agency, including private projects that require government
approval. The primary purpose of CEQA is to disclose to the public the significant environmental
effects of a proposed project. CEQA also requires that public agencies disclose to the public the
decision making process utilized to approve projects and is intended to enhance public participation
in the environmental review process.
In October 2011, the Governor signed into law SB 226, which allows for streamlined CEQA review
for certain infill development projects, including some Transit Oriented Developments (TODs).
The statute allows an exemption or limited environmental review of projects that meet certain
criteria and are consistent with earlier policy documents such as General Plans, Specific Plans, or
Master Plans. Subsequent environmental review of qualifying projects is limited to new or
substantially greater impacts not adequately addressed in an earlier CEQA document.
The streamlined environmental process allowed by SB 226 makes it possible for the environmental
impacts of documents like a General Plan, Specific Plan, or Master Plan area to be analyzed long
before a physical development project is proposed. Because SB 226 does not include a time limit,
CEQA’s environmental review and public comment requirements could be satisfied by a document
prepared years prior to the proposal of a specific development proposal. Because infill and TOD
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projects are often proposed in under-served, lower-income and minority neighborhoods, the
disjointed disclosure of potential environmental impacts resulting from SB 226 has potential for
disproportionate adverse impacts on protected classes.
J. Community Representation and Participation
Adequate community involvement and representation is important to overcoming and identifying
impediments to fair housing. Decisions regarding housing development in a community are typically
made by the City Council or Board of Supervisors and applicable Planning Commissions. The
Council or Board members are elected officials and answer to the constituents. Planning
Commissioners are residents appointed by the Council or Board and often serve an advisory role.
In addition to the City Council, Board of Supervisors, and Planning Commission, most jurisdictions
have appointed commissions, committees, and task forces to address specific issues. Commissions
dealing directly with housing issues are most common in the region’s 19 jurisdictions; however, only
National City and the City of San Diego have commissions that specifically address special housing
needs and only the City and County of San Diego have commissions specifically addressing the
housing needs of persons with disabilities or families with children. These issues are often addressed
in the remaining jurisdictions as part of a standing commission.
Community participation can be limited or enhanced by actions or inaction by a public agency.
According to the results of the Fair Housing Survey, ten San Diego residents reported being
discriminated against by a government staff person.
A broader range of residents may feel more comfortable approaching an agency with concerns or
suggestions if that agency offers sensitivity or diversity training to its staff members that typically
interface with the public. In addition, if there is a mismatch between the linguistic capabilities of
staff members and the native languages of local residents, non-English speaking residents may be
unintentionally excluded from the decision making process. Another factor that may affect
community participation is the inadequacy of an agency or public facility to accommodate residents
with various disabilities.
Most jurisdictions in San Diego County have bi-lingual capabilities to serve Spanish-speaking
residents, and many have multi-lingual capabilities. For example, the City of El Cajon offers services
in Arabic. The HUD Programs Administration Office at the City of San Diego accommodates
Spanish, Arabic and Tagalog speakers, and San Diego (City) has other multilingual capabilities upon
request. The cities of Escondido, Oceanside and Vista, as well as the County of San Diego, have
contracts with various language lines and are able to accommodate all languages. And the City of
San Marcos has multi-lingual capabilities in Vietnamese, Farsi, Mandarin, Russian, Ukrainian, Arabic,
Armenian, Afrikaans and Sign Language, in addition to Spanish. In addition, the city halls of all
participating jurisdictions and the County Administration Buildings are accessible to persons with
disabilities.
The City of San Diego and the County of San Diego also have Community Planning Groups
(CPGs) made up of local stakeholders that advise decision makers on land use issues. Planning
group members are elected to their positions and their input to decision makers is nonbinding. The
2017/2018 San Diego County Grand Jury received a complaint that City of San Diego CPGs delay
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hearing agenda items as a way to de facto restrict growth in the communities they represent. The
Grand Jury found that membership of many CPGs in the City may not appropriately reflect diversity
with community and that the City had not taken sufficient action to address fair community
representation on CPGs. The Grand Jury recommended a number of actions to address these issues,
including developing methods and providing resources to improve recruiting to CPGs that could
result in more diverse membership, and considering more close monitoring of CPG meetings by
City staff to preclude requests for inappropriate project additions or modifications that could delay
developments.
Most jurisdictions in the county do not offer periodic sensitivity or diversity training for staff
personnel. However, some jurisdictions do send their employees to periodic trainings. For example,
both the City of Carlsbad and the City of Escondido send their employees to Respectful Workplace
Training every two years. The City of Oceanside requires its Housing Staff to attend periodic
trainings regarding Fair Housing Discrimination (Section 504 – Reasonable Accommodation
training); these trainings are organized by North County Lifeline. The City of San Diego covers
harassment and discrimination topics in its mandatory New Employee Orientation. In addition, a
number of training opportunities (including EEO issues, sexual harassment prevention, reasonable
accommodations, and customer service) are available to its supervisory employees. The County of
San Diego provides at periodic training for its employees covering inclusion, diversity, age
discrimination, cultural competency, unconscious bias. Furthermore, the City of Santee conducts
mandatory training on a bi-annual basis. Topics covered in the mandatory training include: the types
of behaviors that would constitute discrimination, harassment and/or retaliation as defined by the
City of Santee; definitions of the types of behaviors that create a hostile, offensive and/or
intimidating work environment; and what to do if an employee believes such behaviors have
occurred in the workplace.
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his chapter provides an overview of the institutional structure of the housing industry with
regard to fair housing practices. In addition, this chapter discusses the fair housing services
available to residents in San Diego County, as well as the nature and extent of fair housing
complaints received by the fair housing providers. Typically, fair housing services encompass the
investigation and resolution of housing discrimination complaints, discrimination auditing/testing,
and education and outreach, including the dissemination of fair housing information.
Tenant/landlord counseling services are usually offered by fair housing service providers, but are
not considered fair housing services.
A. Fair Housing in the Homeownership Market
Part of the American dream involves owning a home in the neighborhood of one's choice. Not all
Americans, however, have always enjoyed equal access to homeownership due to credit market
distortions, “redlining,” steering, and predatory lending practices. This sub-section analyzes potential
impediments to fair housing in the home ownership sector.
1. The Homeownership Process
The following discussions describe the process of homebuying and likely situations when a
person/household may encounter housing discrimination. However, much of this process occurs in
the private housing market, over which local jurisdictions have little control or authority to regulate.
The recourse lies in the ability of the contracted fair housing service providers in monitoring these
activities, identifying the perpetrators, and taking appropriate reconciliation or legal actions.
Advertising
The first thing a potential buyer is likely to do when they consider buying a home is search
advertisements either in magazines, newspapers, or the Internet to get a feel for what the market
offers. Advertisements cannot include discriminatory references, such as the use of words
describing:
Current or potential residents;
Neighbors or the neighborhood in racial or ethnic terms;
Adults preferred;
Perfect for empty-nesters;
Conveniently located by a Catholic Church; or
Ideal for married couples without kids.
In a survey of online listings for homes available for purchase in San Diego County in March 2020, a
limited number of advertisements included potentially discriminatory language. Of the total 526
T
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listings surveyed, 103 listings included references to something other than the physical description of
the home or included amenities and services (Table 72). All of the potentially discriminatory
advertisements were targeted specifically at families through the identification of quality school
districts, nearby schools, and available family amenities.
Table 72: Potential Discrimination in Listings of For-Sale Homes
Discrimination Type Number of
Listings Potentially Discriminatory Language
No Discriminatory Language 423 --
Household Size/Family
Related 103
The right home for a new couple looking to grow
Home is located in a safe neighborhood with a lot of kids
Easiest walk to local high-rated schools
Perfect backyard ready for the family and entertaining!
This home is right next to the ocean, perfect for an active family
Note: Examples are direct quotes from the listings (including punctuation and emphasis).
Source: realtor.com, accessed March 2020.
Lending
Initially, buyers must find a lender that will qualify them for a loan. This part of the process entails
an application, credit check, ability to repay, amount eligible for, choosing the type and terms of the
loan, etc. Applicants are requested to provide a lot of sensitive information including their gender,
ethnicity, income level, age, and familial status. Most of this information is used for reporting
purposes required of lenders by the Community Reinvestment Act (CRA) and the Home Mortgage
Disclosure Act (HMDA). Chapter 4 of this AI provides a detailed analysis of HMDA data for the
San Diego region.
Real Estate Agents
Real estate agents may act as agents of discrimination. Some unintentionally, or possibly
intentionally, may steer a potential buyer to particular neighborhoods by encouraging the buyer to
look into certain areas; others may choose not to show the buyer all choices available. Agents may
also discriminate by who they agree to represent, who they turn away, and the comments they make
about their clients.
The California Association of REALTORS® (CAR) has included language on many standard forms
disclosing fair housing laws to those involved. Many REALTOR® Associations also host fair
housing trainings/seminars to educate members on the provisions and liabilities of fair housing laws,
and the Equal Opportunity Housing Symbol is also printed on all CAR forms as a reminder.
Covenants, Conditions, and Restrictions (CC&Rs)
Covenants, Conditions, and Restrictions (CC&Rs), are restrictive promises that involve voluntary
agreements, running with the land with which they are associated and are listed in a recorded
Declaration of Restrictions. The Statute of Frauds (Civil Code Section 1624) requires them to be in
writing, because they involve real property. They must also be recorded in the County where the
property is located in order to bind future owners. Owners of parcels may agree amongst
themselves as to the restrictions on use, but in order to be enforceable they must be reasonable.
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The California Department of Real Estate reviews CC&Rs for all subdivisions of five or more lots,
or condominiums of five or more units. This review is authorized by the Subdivided Lands Act and
mandated by the Business Professions Code, Section 11000. The review includes a wide range of
issues, including compliance with fair housing law. The review must be completed and approved
before the Department of Real Estate will issue a final subdivision public report. This report is
required before a real estate broker or anyone can sell the units, and each prospective buyer must be
issued a copy of the report. If the CC&Rs are not approved, the Department of Real Estate will
issue a “deficiency notice”, requiring the CC&Rs be revised. CC&Rs are void if they are unlawful,
impossible to perform or are in restraint on alienation (a clause that prohibits someone from selling
or transferring his/her property). However, older subdivisions and condominium/townhome
developments may contain illegal clauses that are enforced by the homeowners associations.
As California laws regarding Accessory Dwelling Units (ADUs) have substantially changed in recent
years, many jurisdictions are encountering issues with homeowners associations that have CC&Rs
that require HOA approval for such construction.
Homeowners Insurance Industry
Without insurance, banks and other financial institutions lend less. For example, if a company
excludes older homes from coverage, lower income and minority households who may only be able
to afford to buy in older neighborhoods may be disproportionately affected. Another example
includes private mortgage insurance (PMI). PMI obtained by applicants from Community
Reinvestment Act (CRA) protected neighborhoods is known to reduce lender risk. Redlining of
lower income and minority neighborhoods can occur if otherwise qualified applicants are denied or
encouraged to obtain PMI.47
2. National Association of REALTORS® (NAR)
The National Association of REALTORS® (NAR) has developed a Fair Housing Program to
provide resources and guidance to REALTORS® in ensuring equal professional services for all
people. The term REALTOR® identifies a licensed professional in real estate who is a member of
the NAR; however, not all licensed real estate brokers and salespersons are members of the NAR.
Code of Ethics
Article 10 of the NAR Code of Ethics provides that “REALTORS® shall not deny equal
professional services to any person for reasons of race, color, religion, sex, handicap, familial status,
national origin, sexual orientation, or gender identity. REALTORS® shall not be parties to any plan
or agreement to discriminate against a person or persons on the basis of race, color, religion, sex,
handicap, familial status, national origin, sexual orientation, or gender identity.”
Additionally, Standard of Practice Article 10-1 states that, “When involved in the sale or lease of a
residence, REALTORS® shall not volunteer information regarding the racial, religious or ethnic
composition of any neighborhood nor shall they engage in any activity which may result in panic
selling, however, REALTORS® may provide other demographic information.” Standard of
47 “Borrower and Neighborhood Racial Characteristics and Financial Institution Financial Application Screening”;
Mester, Loretta J; Journal of Real Estate Finance and Economics; 9 241-243; 1994
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Practice 10-3 adds that “REALTORS® shall not print, display or circulate any statement or
advertisement with respect to selling or renting of a property that indicates any preference,
limitations or discrimination based on race, color, religion, sex, handicap, familial status, national
origin, sexual orientation, or gender identity.”
Diversity Certification
NAR has created a diversity certification, “At Home with Diversity: One America” to be granted to
licensed real estate professionals who meet eligibility requirements and complete the NAR “At
Home with Diversity” course. The certification will signal to customers that the real estate
professional has been trained on working with diversity in today’s real estate markets. The
coursework provides valuable business planning tools to assist real estate professionals in reaching
out and marketing to a diverse housing market. The NAR course focuses on diversity awareness,
building cross-cultural skills, and developing a business diversity plan.
3. California Department of Real Estate (DRE)
The California Department of Real Estate (DRE) is the licensing authority for real estate brokers
and salespersons. As noted earlier, not all licensed brokers and salespersons are members of the
National or California Association of REALTORs®.
The DRE has adopted education requirements that include courses in ethics and in fair housing. To
renew a real estate license, each licensee is required to complete 45 hours of continuing education,
including three hours in each of the four mandated areas: Agency, Ethics, Trust Fund, and Fair
Housing. The fair housing course contains information that will enable an agent to identify and
avoid discriminatory practices when providing real estate services to clients.
The law requires, as part of the 45 hours of continuing education, completion of five mandatory
three-hour courses in Agency, Ethics, Trust Fund Handling and Fair Housing and Risk
Management. These licensees will also be required to complete a minimum of 18 additional hours
of courses related to consumer protection. The remaining hours required to fulfill the 45 hours of
continuing education may be related to either consumer service or consumer protection, at the
option of the licensee.
4. California Association of REALTORS® (CAR)
The California Association of Realtors (CAR) is a trade association of realtors statewide. As
members of organized real estate, realtors also subscribe to a strict code of ethics as noted above.
CAR has recently created the position of Equal Opportunity/Cultural Diversity Coordinator. CAR
holds three meetings per year for its general membership, and the meetings typically include sessions
on fair housing issues. Current outreach efforts in the Southern California area are directed to
underserved communities and state-licensed brokers and sales persons who are not members of the
CAR.
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REALTOR® Associations Serving San Diego County
REALTOR® Associations are generally the first line of contact for real estate agents who need
continuing education courses, legal forms, career development, and other daily work necessities.
The frequency and availability of courses varies amongst these associations, and local association
membership is generally determined by the location of the broker for which an agent works.
Complaints involving agents or brokers may be filed with these associations.
Monitoring of services by these associations is difficult as detailed statistics of the education/services
the agencies provide or statistical information pertaining to the members is rarely available. The
following associations serve San Diego County:
Greater San Diego Association of REALTORS (SDAR)
North County Association of REALTORS (NSDCAR)
Pacific Southwest Association of REALTORS (PSAR)
B. Fair Housing in the Rental Housing Market
1. Rental Process
Advertising
Like with ad listings for for-sale homes, rental advertisements cannot include discriminatory
references. A total of 524 rental listings were surveyed in March 2020 and 123 advertisements were
found to contain potentially discriminatory language (Table 73). The problematic language typically
involved references to household size, familial status, schools or children (49 ads) and pets (74 ads).
Under California’s fair housing law, source of income is a protected class. It is, therefore, considered
unlawful to prefer, limit, or discriminate against a specific income source for a potential homebuyer.
Until 2020, source of income protection did not include Section 8 assistance. In 2019, the State
passed SB 329 (effective January 1, 2020), making Section 8 and other public assistance as legitimate
source of income for rents.
Rental advertisements with references to pets in San Diego County were a significant issue in the
listings surveyed. Persons with disabilities are one of the protected classes under fair housing law,
and apartments must allow “service animals” and “companion animals,” under certain conditions.
Service animals are animals that are individually trained to perform tasks for people with disabilities
such as guiding people who are blind, alerting people who are deaf, pulling wheelchairs, alerting and
protecting a person who is having a seizure, or performing other special tasks. Service animals are
working animals, not pets. Companion animals, also referred to as assistive or therapeutic animals,
can assist individuals with disabilities in their daily living and as with service animals, help disabled
persons overcome the limitations of their disabilities and the barriers in their environment.
Persons with disabilities have the right to ask their housing provider to make a reasonable
accommodation in a “no pets” policy in order to allow for the use of a companion or service animal.
However, in the case of rental ads that specifically state “no pets,” some disabled persons may not
be aware of their right to ask for an exception to this rule. Because of this, a person with a disability
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may see themselves as limited in their housing options and a “no pets” policy could, therefore, be
interpreted as potentially discriminatory. Of the rental listings surveyed, 74 ads included language to
specifically ban pets.
Table 73: Potential Discrimination in Listings of Homes for Rent
Discrimination Type Number of
Listings Potentially Discriminatory Language
No Discriminatory
Language 401 --
Disability Related 74
No dogs allowed in home
Only a small dog may be considered.
No pets
Pets are not accepted, especially dogs.
Only one pet allowed, preferably small.
Additional deposit for pet may be required
NO PETS ALLOWED
Household Size/Family
Related 49
Close distance to downtown close to shopping centers freeways
and schools
Good for a couple and baby
Its located near schools and shopping centers
with our convenient location to schools
Great neighborhood- close to schools!
Good for a couple and baby
Easy walk to some of the best schools!
Located in the highly rated Poway School District
Big pool and spa perfect for a family and entertaining
Close to Woodland Park Middle School
Big house with plenty of room for a couple wanting to expand
their family
Notes:
1. Examples are direct quotes from the listings (including punctuation and emphasis).
2. Ads may contain multiple types of potentially discriminatory language.
Source: www.craigslist.org, accessed March 2020.
Responding to Ads
Differential treatment of those responding to advertisements is a growing fair housing concern. In a
2011 study conducted nationally, comprehensive audit-style experiments via email correspondence
were used to test for racial discrimination in the rental housing market. This study was particularly
unique because it tested for two variables – discrimination based on race and social class. By
responding to online rental listings using names associated with a particular racial/ethnic group and
varying message content grammatically to indicate differing levels of education and/or income (i.e.
social class), researchers found that, overall, Blacks continued to experience statistically significant
levels of discrimination in the rental housing market. This discrimination was even more
pronounced when the housing inquiry was made to look like it originated from a Black individual of
a lower social class.48
48 Do Landlords Discriminate in the Rental Housing Market? Evidence from an Internet Field Experiment in U.S.
cities. Andrew Hanson and Zackary Hawley. May 2011.
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Viewing the Unit
Viewing the unit is the most obvious place where the potential renters may encounter discrimination
because landlords or managers may discriminate based on race or disability, or judge on appearance
whether a potential renter is reliable or may violate any of the rules.
In a follow up to the study discussed above, researchers developed an experiment to test for subtle
discrimination. Subtle discrimination is defined as unequal treatment between groups that occurs but
is difficult to quantify, and may not always be identifiable through common measures such as price
differences. Researchers found that, in general, landlords replied faster and with longer messages to
inquiries made from traditional “white” names. The study also found that landlords were more likely
to use descriptive language, extend invitations to view a unit, invite further correspondence, use
polite language, and make a formal greeting when replying to e-mail inquiries from a white home
seeker.49
Credit/Income Check
Landlords may ask potential renters to provide credit references, lists of previous addresses and
landlords, and employment history/salary. The criteria for tenant selection, if any, are typically not
known to those seeking to rent. Many landlords often use credit history as an excuse when trying to
exclude certain groups. Legislation provides for applicants to receive a copy of the report used to
evaluate applications.
The study on subtle discrimination mentioned earlier found no statistically significant evidence of
discrimination in using language related to fees, asking for employment or rental history, or
requesting background information.
The Lease
Typically, the lease or rental agreement is a standard form completed for all units within the same
building. However, the enforcement of the rules contained in the lease or agreement may not be
standard for all tenants. A landlord may choose to strictly enforce the rules for certain tenants based
on arbitrary factors, such as race, presence of children, or disability.
Lease-related language barriers can impede fair housing choice if landlords and tenants do not speak
the same language. In California, applicants and tenants have the right to negotiate lease terms
primarily in Spanish, Chinese, Tagalog, Vietnamese or Korean. If a language barrier exists, the
landlord must give the tenant a written translation of the proposed lease or rental agreement in the
language used in the negotiation before the tenant signs it.50 This rule applies to lease terms of one
month or longer and whether the negotiations are oral or in writing.
49 Subtle Discrimination in the Rental Housing Market: Evidence from E-mail Correspondence with Landlords.
Andrew Hanson, Zackary Hawley, and Aryn Taylor. September 2011.
50 California Civil Code Section 1632(b)
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Security Deposit
A security deposit is typically required. To deter “less-than-desirable” tenants, a landlord may ask
for a security deposit higher than for others. Tenants may also face discriminatory treatment when
vacating the units. For example, the landlord may choose to return a smaller portion of the security
deposit to some tenants, claiming excessive wear and tear. A landlord may also require that persons
with disabilities pay an additional pet rent for their service animals, a monthly surcharge for pets, or
a deposit, which is also a discriminatory act.
During the Tenancy
During tenancy, the most common forms of discrimination a tenant may face are based on familial
status, race, national origin, sex, or disability. Usually this type of discrimination appears in the form
of varying enforcement of rules, overly strict rules for children, excessive occupancy standards,
refusal to make a reasonable accommodation for handicapped access, refusal to make necessary
repairs, eviction notices, illegal entry, rent increases, or harassment. These actions may be used as a
way to force undesirable tenants to move on their own without the landlord having to make an
eviction.
2. California Apartment Association (CAA)
The California Apartment Association has developed the California Certified Residential Manager
(CCRM) program to provide a comprehensive series of courses geared towards improving the
approach, attitude and professional skills of on-site property managers and other interested
individuals. The CCRM program consists of 31.5 hours of training that includes fair housing and
ethics along with the following nine course topics:
Preparing the Property for Market
Professional Leasing Skills and the Application Process
The Move-in Process, Rent Collection and Notices
Resident Issues and Ending the Tenancy
Professional Skills for Supervisors
Maintenance Management: Maintaining a Property
Liability and Risk Management: Protecting the Investment
Fair Housing: It’s the Law
Ethics in Property Management
The CAA supports the intent of all local, State, and federal fair housing laws for all residents without
regard to color, race, religion, sex, marital status, mental or physical disability, age, familial status,
sexual orientation, or national origin. Members of the CAA agree to abide by the provisions of their
Code for Equal Housing Opportunity.
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3. National Association of Residential Property Managers
(NARPM)
The National Association of Residential Property Managers promotes a high standard of property
management business ethics, professionalism and fair housing practices within the residential
property management field. NARPM is an association of real estate professionals who are
experienced in managing single-family and small residential properties. Members of the association
adhere to a strict Code of Ethics to meet the needs of the community, which include the following
duties:
Protect the public from fraud, misrepresentation, and unethical practices of property
managers.
Adhere to the Federal Fair Housing Stature.
Protect the fiduciary relationship of the Client.
Treat all Tenants professionally and ethically.
Manage the property in accordance with the safety and habitability standards of the
community.
Hold all funds received in compliance with state law with full disclosure to the Client.
NARPM offers three designations to qualified property managers and property management firms:
1. Residential Management Professional, RMP ®
2. Master Property Manager, MPM ®
3. Certified Residential Management Company, CRMC ®
Various educational courses are offered as part of attaining these designations including the
following fair housing and landlord/tenant law courses:
Ethnics (required for all members every four years)
Habitability Standards and Maintenance
Marketing
Tenancy
ADA Fair Housing
Lead-Based Paint Law
4. Western Manufactured Housing Communities Association
(WMA)
Western Manufactured Housing Communities Association (WMA) is a nonprofit organization
created in 1945 for the exclusive purpose of promoting and protecting the interests of owners,
operators and developers of manufactured home communities in California. WMA assists its
members in the operations of successful manufactured home communities in today's complex
business and regulatory environment. WMA has over 1,700 member parks located in all 58 counties
of California.
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WMA offers an award winning manager accreditation program as well as numerous continuing
education opportunities. The Manufactured Home Community Manager (MCM) program is a
manager accreditation program that provides information on effective community operations.
WMA’s industry experts give managers intensive training on law affecting the industry, maintenance
standards, HCD inspections, discrimination, mediation, disaster planning, and a full range of other
vital subjects.
C. Fair Housing Services
In general, fair housing services include the investigation and resolution of housing discrimination
complaints, discrimination auditing and testing, and education and outreach, including the
dissemination of fair housing information such as written material, workshops, and seminars.
Landlord/tenant counseling is another fair housing service that involves informing landlords and
tenants of their rights and responsibilities under fair housing law and other consumer protection
regulations, as well as mediating disputes between tenants and landlords. This section reviews the
fair housing services available in San Diego County, the nature and extent of fair housing
complaints, and results of fair housing testing/audits.
1. CSA San Diego County (CSA)
The CSA San Diego County (CSA), is an agency whose mission is to actively support and promote
fair housing through education and advocacy. CSA provides the following fair housing related
services:
Tenant-Landlord mediation
Fair housing counseling and dispute mediation
Educational fair housing seminars for tenants and landlords (English and Spanish and other
languages upon request)
Services to tenants, landlords, and apartment managers
Real estate and rental practice discrimination audits
Free rental housing handbooks in English, Spanish, and Arabic
Legal services and advocacy
Enforcement of fair housing laws through conciliation, litigation, or administrative referrals.
CSA assists residents and reports fair housing data for the cities of:
Chula Vista El Cajon National City
La Mesa Santee Unincorporated East County
2. Legal Aid Society of San Diego (LASSD)
The Legal Aid Society of San Diego (LASSD) provides fair housing services to guarantee equal
housing opportunity for San Diego City and County residents. LASSD provides support through
outreach, education, and enforcement of both federal and state fair housing laws. To receive
services provided by LASSD the act of housing discrimination must have occurred within the
County of San Diego. The LASSD Housing Team is the only full service resource in the County,
July 14, 2020 Item #6 Page 188 of 211
providing counseling, direct legal intervention and in-Court representation for eligible San Diego
County residents. LASSD provides the following services:
Assist or advise eligible clients
Educate community groups and tenants to increase awareness of tenant’s rights and the
workings of the judicial system
Conduct outreach
Assist tenants in organizing themselves to take legal action
LASSD is currently under contract with the City of San Diego to provide fair housing services.
However, the agency assists residents throughout the County and the cities of:
Carlsbad Coronado Del Mar
Encinitas Escondido Imperial Beach
Lemon Grove Oceanside Poway
San Diego San Marcos Solana Beach
Vista San Diego County
3. Overall Service Coverage
Overall, the region is well served by multiple agencies for fair housing services. However, residents
may find it hard to navigate the service system and identify the appropriate agency for contact. A
jurisdiction’s contract for fair housing service providers may also change year to year. To ensure the
public is well aware of available services, the SDRAFFH and local jurisdictions should update their
websites and outreach materials frequently. Furthermore, consistent recordkeeping formats would
assist in the compilation and analysis of fair housing data across agencies.
D. California Department of Fair Employment and
Housing (DFEH)
The California Department of Fair Employment and Housing (DFEH) investigates complaints of
employment and housing discrimination based on race, sex, religious creed, color, national origin,
medical condition (cured cancer only), ancestry, physical or mental disability, marital status, or age
(over 40 only). DFEH also investigates complaints of housing discrimination based on the above
classes, as well as children/age, and sexual orientation.
DFEH established a program in May 2003 for mediating housing discrimination complaints, which
is a first for the State of California and is the largest fair housing mediation program in the nation to
be developed under HUD’s Partnership Initiative with state fair housing enforcement agencies. The
program provides California’s tenants, landlords, and property owners and managers with a means
of resolving housing discrimination cases in a fair, confidential, and cost-effective manner. Key
features of the program are: 1) program is free of charge to the parties; and 2) mediation takes place
within the first 30 days of the filing of the complaint, often avoiding the financial and emotional
costs associated with a full DFEH investigation and potential litigation.
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After a person calls in for a complaint, an interview takes place, documentation is obtained and
issues are discussed to decide on the course to proceed. Mediation/conciliation is offered as a viable
alternative to litigation. If the mediation/conciliation is successful, the case is closed after a brief
case follow-up. If the mediation/conciliation is unsuccessful, the case is then referred to DFEH or
HUD. If during case development further investigation is deemed necessary, testing may be
performed. Once the investigation is completed, the complainant is advised of the alternatives
available in proceeding with the complaint, which include: mediation/ conciliation, administrative
filing with HUD or DFEH, referral for consideration to the Department of Justice, Civil Rights
Division, Housing and Civil Enforcement Section, or referral to a private attorney for possible
litigation.
E. Fair Housing Statistics
As part of the enforcement and tracking services provided by the above mentioned fair housing
service providers, intake and documentation of all complaints and inquiries result in the compilation
of statistics provided to each jurisdiction in the form of quarterly and annual reports. However,
because the various agencies that provide fair housing services in the County each have their own
intake forms, the amount and specificity of available fair housing data is highly uneven throughout
the County and difficult to use for regional comparisons and analyses. The following sections
summarize fair housing statistics in San Diego County using available data and sources.
1. CSA San Diego County (CSA)
Housing Discrimination Complaints
Between FY 2014 and FY 2018, CSA provided fair housing services to approximately 1,000 San
Diego County residents per year—for a total of 6, 276 clients over the five-year period (Table 74).
The majority of CSA’s clients during this period came from El Cajon (35 percent), Chula Vista (21
percent), and the unincorporated County.
Table 74: CSA Clients Served (FY 2014-2018)*
Jurisdiction Clients Served
FY 2014-2019 % of Total
Carlsbad 192 3%
Chula Vista 1,329 21%
El Cajon 2,191 35%
La Mesa 611 10%
National City 688 11%
Santee 276 4%
Unincorporated 989 16%
Total Clients 6,276 100%
Source: CSA San Diego, February 2020.
*Data provided only for FY 2014 and FY 2015 for Carlsbad and the Unincorporated
communities.
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Statistics reported throughout San Diego County indicate that low-income persons, regardless of
race, are the most frequently impacted by fair housing issues. The vast majority of CSA’s clients (95
percent) between FY 2014 and FY 2018 were either extremely low or very low income (Table 75).
Consistent with the demographic makeup of the region, White residents represented a substantial
proportion of clients served (41 percent, Table 76). However, there is some indication that fair
housing issues disproportionately affect certain racial/ethnic groups. For example, Black residents
made up less than an average 4.1 percent of the population in the cities that CSA serves (Table 76),
but represented 10 percent of fair housing clients served.
Table 75: CSA Clients Served by Income Level (FY 2014-2018)*
Income 2014-15 2015-16 2016-17 2017-18 2018-19 Total Percent
Extremely Low Income
(<30% AMI) 1,410 1,474 890 843 587 5,204 83%
Low Income
(<50% AMI) 152 111 104 113 294 774 12%
Moderate Income
(<80% AMI) 31 35 15 13 68 162 3%
>80% AMI 40 24 24 10 38 136 2%
Total Clients 1,633 1,644 1,033 979 987 6,276 100%
Source: CSA San Diego, February 2020.
*Data provided only for FY 2014 and FY 2015 for Carlsbad and the Unincorporated communities
Table 76: CSA Clients Served by Race/Ethnicity (FY 2014-2018)*
Income 2014-15 2015-16 2016-17* 2017-18 2018-19 Total Percent
Race
Hispanic 527 561 423 395 486 2,392 38%
Non- Hispanic 1,106 1,083 610 584 500 3,883 62%
Total Clients 1,633 1,644 1,033 979 986 6,275 100%
Ethnicity
White 757 741 402 373 269 2,542 41%
Black/African American 175 171 90 100 92 628 10%
Asian 27 32 45 38 22 164 3%
Hawaiian/Pacific Islander 32 18 5 19 75 149 2%
American Indian/Alaska Native 7 5 2 44 106 164 3%
Other/Multi-Racial 635 677 489 405 423 2,629 42%
Total Clients 1,633 1,644 1,033 979 987 6,276 100%
Source: CSA San Diego, February 2020.
*Data provided only for FY 2014 and FY 2015 for Carlsbad and the Unincorporated communities
Education and Outreach Efforts
CSA conducts regular workshops and educational presentations, including general Fair Housing
workshops and those specifically held to educate and address the needs of small property owners.
Workshops and presentations cover a wide range of issues including tenant and landlord rights and
responsibilities, notices to vacate, substandard conditions, and foreclosures.
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Additionally, as members of the Newcomer Network, which provides resources to new and non-
English speaking immigrants/refugees, CSA commits to providing services to the local immigrant
community. These include helping develop and distribute resource guides for this community such
as the English as a Second Language (ESL) Resource Guide, and being a resource for
landlord/tenants’ rights, hate crime prevention and immigration advocacy. To remain involved and
up-to-date on issues concerning fair housing, CSA attends the quarterly meetings and serves on the
steering committee of the San Diego Regional Alliance for Fair Housing (SDRAFFH). During these
meetings CSA and other fair housing providers discuss challenges, resources and strategies for
addressing fair housing in San Diego County.
2. Legal Aid Society San Diego (LASSD)
Housing Discrimination Complaints
Between FY 2014 and FY 2018, LASSD served over 19,000 San Diego County residents (Table 77).
The majority of LASSD client households during this five-year time period resided in the City of San
Diego (53 percent), El Cajon (nine percent) and Oceanside (eight percent).
Table 77: LASSD- Clients Served (FY 2014-2018)
Jurisdiction Clients Served
FY 2014-2019 % of Total
Carlsbad 323 2%
Chula Vista 1,494 8%
Coronado 38 0%
Del Mar 17 0%
El Cajon 1,646 9%
Encinitas 116 1%
Escondido 861 4%
Imperial Beach 341 2%
La Mesa 597 3%
Lemon Grove 310 2%
National City 557 3%
Oceanside 1,452 8%
Poway 81 0%
San Diego 10,303 53%
San Marcos 287 1%
Santee 224 1%
Solana Beach 21 0%
Vista 658 3%
Total Clients 19,326 100%
Source: Legal Aid Society San Diego, February 2020.
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The vast majority of clients served by LASSD were lower income (87 percent) and white (66
percent) (Table 77 and Table 78). Based on the data reported by LASSD, fair housing issues
disproportionately affected some San Diego County residents. For example, Black residents made
up less than five percent of the total County population, yet represented 24 percent of fair housing
complainants.
Table 78: LASSD- Clients Served by Income Level (FY 2014-2018)*
Income 2014-15 2015-16 2016-17 2017-18 2018-19* Total Percent
Extremely Low Income
(<30% AMI) 5,603 5,177 5,187 5,256 2,542 23,765 54%
Low Income
(<50% AMI) 3,193 3,233 3,214 2,985 1,541 14,166 32%
Moderate Income
(<80% AMI) 653 813 875 682 362 3,385 8%
>80% AMI 459 467 544 579 315 2,364 5%
Total Clients 9,908 9,690 9,820 9,502 4,760 43,680 100%
Source: LASSD, February 2020.
* Only includes data for Q1 and Q2 of FY2018-19
Table 79: LASSD- Clients Served by Race/Ethnicity (FY 2014-2018)
Race and Ethnicity 2014-15 2015-16 2016-17 2017-18* 2018-19 Total Percent
Race
Hispanic 1,138 1,134 1,160 1,144 1,231 5,807 29%
Non- Hispanic 2,673 2,655 2,854 2,860 2,977 14,019 71%
Total Clients 3,811 3,789 4,014 4,004 4,208 19,826 100%
Ethnicity
White 2,532 2,532 2,651 2,610 2,782 13,107 66%
Black/African American 897 926 980 970 968 4,741 24%
Asian 152 141 159 137 117 706 4%
Hawaiian/Pacific Islander 0 0 0 0 0 0 0%
American Indian/ Alaska Native 33 51 38 54 50 226 1%
Other/Multi-Racial 197 139 186 238 291 1,051 5%
Total Clients 3,811 3,789 4,014 4,009 4,208 19,831 100%
Source: LASSD, February 2020.
Education and Outreach Efforts
LASSD works to stop housing discrimination, ensuring equal housing opportunities for all people in
the City and County of San Diego; through outreach, education, and enforcement of Federal and
State Fair Housing Laws. They provide free help for those who qualify that are having housing
problems or questions about their rights as a tenant, as well as, those who have questions about their
security deposits.
LASSD also meets monthly with the City of San Diego and Housing Opportunities Collaborative in
order to evaluate service gaps and to ensure an adequate level of service is available to all residents.
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In addition, LASSD has established a Fair Housing Hotline to ensure its Fair Housing services are
readily available to the community and that a resident may promptly report any act of housing
discrimination that may have occurred. Walk-in services are also offered at three office locations in
San Diego County- Southeast, Midtown, and North County.
F. Fair Housing Testing
The purpose of fair housing testing is to determine if, and to what extent, discriminatory business
practices exist in apartment rental housing and related markets. In response to the recommendation
from the previous AI, some jurisdictions have begun to conduct fair housing testing routinely.
Other jurisdictions contracted for fair housing testing for the purpose of this AI report in order to
provide additional information on potential housing discrimination in their communities. However,
it should be noted that since fair housing testing was not conducted consistently and systematically
by all jurisdictions, more findings of discriminatory practices in one community that conducts
regular fair housing tests cannot be interpreted as having more extensive housing discrimination,
compared to other communities that have not conducted testing as frequently.
1. Methodology
Methodologies may vary, but generally, testing involves volunteer testers screened for
appropriateness and then trained. Training may include an overview and history of fair housing
laws, methodology of testing, and reinforcement of the qualities needed in a tester. Those qualities
include objectivity, reliability, flexibility and the ability to maintain confidentiality throughout the
project. A practice test and/or role-playing a site visit are also included to assure that testers are fully
prepared. The project supervisor will find apartment vacancies by viewing advertisements on Craig’s
List, For Rent Magazine, other rental guides and online resources. A matched pair of testers, one
representing the variable being tested, and the other as a control are then assigned and given their
identity for each project.
Legal Aid Society provided the results of Fair Housing Testing between FY 2016 and FY 2018 in
the cities of Carlsbad, Encinitas, Escondido, Oceanside, San Diego City, Vista, and San Diego
County. All testing was done in the rental market. Detailed breakdown of tests by jurisdiction and
testing variables can be found in Table 9.
2. Testing Results
Carlsbad: Between FY 2017 and FY 2018, Carlsbad tested for discrimination on the basis of
disability, familial status, sexual orientation, and race. Of the 47 sites tested, four showed unequal
treatment to the potential renter, three on the basis of disability (reasonable accommodation) and
one on the basis of sexual orientation.
Encinitas: In Encinitas, during tests conducted in FY 2016 through FY 2018, only one out of 13
sites showed some disparity in treatment when testing for sexual orientation.
Escondido: Between FY 2016 and FY 2018, 53 sites were tested in Escondido for discrimination
on the basis of disability, familial status, sexual orientation, and race. Of the 53 tests, eight showed
July 14, 2020 Item #6 Page 194 of 211
disparate treatment. Five showed unequal treatment when testing for disability (reasonable
accommodation) and three showed unequal treatment on the basis of sexual orientation.
Oceanside: Oceanside tested for discrimination based on disability, familial status, sexual
orientation, and race. Of the 47 sites tested, eight sites showed disparate treatment; six due to
disability (reasonable accommodation) and two due to familial status. .
San Diego City: The City of San Diego conducted a total of 114 audit tests between FY 2016 and
FY 2018. The following variables were tested in the rental housing market: disability (reasonable
accommodation and reasonable modification), familial status and national origin. When testing for
discrimination in San Diego, it was more likely to find disparate treatment requesting reasonable
accommodations. Of the 13 sites tested that had disparate treatment, 11 of them were due to
reasonable accommodations. Additionally, one site had unequal treatment due to familial status and
one due to national origin,
San Marcos: Of the 28 audit tests conducted in the City of San Marcos between FY 2016 through
FY 2018, two sites had discriminatory treatment- one based on sexual orientation and one based on
race. The City also tested for familial status and disability (reasonable accommodation) but no
discriminatory treatment was found.
Vista: In the 43 fair housing audits conducted in the City of Vista, four variables were tested:
disability (reasonable accommodation and reasonable modification), sexual orientation, and race.
The tests found that individuals were discriminated against on the basis of disability (reasonable
accommodation) (two cases) and race (one case).
San Diego Urban County: Testing was conducted in the County with a total of 118 sites tested for
familial status, race, and disability (reasonable accommodation). Disparate treatment was found at 16
sites for all variables: five cases for familial status, six cases for race, and five cases for disability.
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Table 80: Fair Housing Audit Testing FY 2016-2018
City FY Test Variable Test
Market
Total #
of Sites
Findings
Differential
Treatment Inconclusive No Differential
Treatment
Total % Total % Total %
Carlsbad
2017 Dis-RA Rental 15 1 4% 1 4% 13 54%
2017 Familial Status Rental 1 0 0% 0 0% 1 4%
2017 Sexual Orientation Rental 8 1 4% 0 0% 7 29%
2018 Dis-RA Rental 15 2 9% 3 13% 10 43%
2018 Dis-RM Rental 1 0 0% 0 0% 1 4%
2018 Race Rental 7 0 0% 0 0% 7 30%
Total 47 4 9% 4 9% 39 83%
Encinitas
2016 Dis-RA Rental 1 0 0% 0 0% 1 25%
2016 Familial Status Rental 3 0 0% 0 0% 3 75%
2017 Dis-RA Rental 1 0 0 0 0 1 0.25
2017 Sexual Orientation Rental 3 1 0.25 0 0 2 0.5
2018 Dis-RA Rental 3 0 0 0 0 3 0.6
2018 Race Rental 2 0 0 0 0 2 0.4
Total 13 1 8% 0 0% 12 92%
Escondido
2016 Dis-RA Rental 10 0 0% 1 7% 9 60%
2016 Familial Status Rental 3 0 0% 0 0% 3 20%
2016 Familial Status Rental 2 0 0% 1 7% 1 7%
2017 Dis-RA Rental 8 2 11% 0 0% 6 32%
2017 Sexual Orientation Rental 11 3 16% 0 0% 8 42%
2018 Dis-RA Rental 7 3 16% 0 0% 4 21%
2018 Dis-RM Rental 5 0 0% 0 0% 5 26%
2018 Race Rental 7 0 0% 0 0% 7 37%
Total 53 8 15% 2 4% 43 81%
July 14, 2020 Item #6 Page 196 of 211
Table 80: Fair Housing Audit Testing FY 2016-2018
City FY Test Variable Test
Market
Total #
of Sites
Findings
Differential
Treatment Inconclusive No Differential
Treatment
Total % Total % Total %
Oceanside
2016 Dis-RA Rental 10 2 13% 2 13% 6 40%
2016 Familial Status Rental 4 1 7% 0 0% 3 20%
2016 Familial Status Rental 1 1 7% 0 0% 0 0%
2017 Dis-RA Rental 8 3 19% 0 0% 5 31%
2017 Sexual Orientation Rental 8 0 0% 0 0% 8 50%
2018 Dis-RA Rental 6 1 6% 1 6% 4 25%
2018 Dis-RM Rental 5 0 0% 0 0% 5 31%
2018 Race Rental 5 0 0% 0 0% 5 31%
Total 47 8 17% 3 6% 36 77%
San Diego City
2016 Dis-RA Rental 27 4 9% 6 13% 17 36%
2016 Familial Status Rental 14 0 0% 3 6% 11 23%
2016 Familial Status Rental 6 1 2% 2 4% 3 6%
2017 Dis-RA Rental 21 3 14% 1 5% 17 81%
2018 Dis-RA Rental 24 4 9% 3 7% 17 37%
2018 Dis-RM Rental 1 0 0% 0 0% 1 2%
2018 National Origin Rental 21 1 2% 0 0% 20 43%
Total 114 13 11% 15 13% 86 75%
San Marcos
2016 Familial Status Rental 4 0 0% 0 0% 4 80%
2016 Familial Status Rental 1 0 0% 1 20% 0 0%
2017 Dis-RA Rental 5 0 0% 2 20% 3 30%
2017 Sexual Orientation Rental 5 1 10% 0% 4 40%
2018 Dis-RA Rental 9 0 0% 0 0% 9 69%
2018 Race Rental 4 1 8% 0 0% 3 23%
Total 28 2 7% 3 11% 23 82%
July 14, 2020 Item #6 Page 197 of 211
Table 80: Fair Housing Audit Testing FY 2016-2018
City FY Test Variable Test
Market
Total #
of Sites
Findings
Differential
Treatment Inconclusive No Differential
Treatment
Total % Total % Total %
Vista
2016 Dis-RA Rental 9 0 0% 2 22% 7 78%
2017 Dis-RA Rental 8 2 13% 13% 6 13%
2017 Sexual Orientation Rental 8 0 13% 1 13% 7 13%
2018 Dis-RA Rental 10 0 0% 0 0% 10 50%
2018 Dis-RM Rental 2 0 0% 0 0% 2 10%
2018 Race Rental 8 1 5% 0 0% 7 35%
Total 45 3 7% 3 7% 39 87%
San Diego County
2016 Familial Status Rental 40 5 13% 10 25% 25 63%
2017 Race Rental 37 6 16% 4 11% 27 73%
2018 Dis-RA Rental 39 5 12% 0 0% 34 83%
2018 Familial Status Rental 1 0 0% 0 0% 1 2%
2018 Race Rental 1 0 0% 0 0% 1 2%
Total 118 16 14% 14 12% 88 75%
Source: LASSD, February 2020.
July 14, 2020 Item #6 Page 198 of 211
G. U.S. Department of Housing and Urban
Development
The U.S. Department of Housing and Urban Development (HUD) maintains a record of all housing
discrimination complaints filed in local jurisdictions. These grievances can be filed on the basis of race,
color, national origin, sex, disability, religion, familial status and retaliation. From October 1, 2014 to
September 30, 2019, 414 fair housing complaints in San Diego County were filed with HUD (Table 10).
About 44 percent of complaints filed were from residents of the City of San Diego. A fair number of
complaints were also filed from residents of Oceanside (11 percent) and Chula Vista (seven percent).
Overall, disability-related discrimination was the most commonly reported—comprising 53 percent of
all cases (Table 11). Complaints concerning race (12 percent), retaliation (10 percent), and familial status
(nine percent) were also regularly reported. Half of all complaints filed (50 percent or 206 cases) were
deemed to have no cause and another 28 percent (115 cases) were conciliated or settled.
July 14, 2020 Item #6 Page 199 of 211
Table 81: Basis for Discrimination of Fair Housing Cases filed with HUD (FY 2014-2018)*
Jurisdiction Color Disability Familial
Status
National
Origin Race Religion Retaliation Sex Total # of
Cases %
Carlsbad 1 11 1 0 3 1 0 0 17 14 3.4%
Chula Vista 1 18 5 3 2 1 4 1 35 29 7.0%
Coronado 0 2 0 0 0 0 0 0 2 2 0.5%
Del Mar 0 1 0 0 0 1 0 0 2 2 0.5%
El Cajon 0 10 10 6 5 3 2 3 39 25 6.0%
Encinitas 0 4 1 0 0 0 0 0 5 5 1.2%
Escondido 0 9 0 1 3 0 2 0 15 13 3.1%
Imperial Beach 0 4 1 0 2 0 2 1 10 7 1.7%
La Mesa 0 7 0 1 1 0 2 1 12 9 2.2%
Lemon Grove 0 3 0 0 0 0 0 0 3 3 0.7%
National City 0 10 0 0 1 0 2 0 13 11 2.7%
Oceanside 0 40 5 0 4 4 3 56 47 11.4%
Poway 0 2 0 0 0 2 0 1 5 4 1.0%
San Diego 1 122 14 17 30 4 24 24 236 183 44.2%
San Marcos 0 4 0 1 4 0 1 0 10 9 2.2%
Santee 0 6 1 0 1 0 2 1 11 9 2.2%
Solana Beach 0 3 0 1 0 0 1 0 5 4 1.0%
Vista 0 6 2 2 1 0 0 0 11 10 2.4%
Unincorporated 1 19 6 0 6 6 5 43 28 6.8%
Total 4 281 46 32 63 12 52 40 530 414 100.0%
% 0.8% 53.0% 8.7% 6.0% 11.9% 2.3% 9.8% 7.5% 100.0%
Source: U.S. Department of Housing and Urban Development, February 2020.
* Data represents HUD’s fiscal years (October 1-September 30)
July 14, 2020 Item #6 Page 200 of 211
Table 82: Closing Categories for Fair Housing Cases filed with HUD (FY 2014-2018)*
Dismissed
for Lack of
Jurisdiction
Unable to
Locate
Compliant
Compliant
Failed to
Cooperate
No Cause
Deter-
mination
FHAP
Judicial
Consent
Order
Complaint
Withdrawn
by
Complainant
Without
Resolution
Complaint
Withdrawn
by
Complainant
After
Resolution
Conciliation
/ Settlement
successful
N/A # of
Cases %
Carlsbad 0 0 0 5 2 6 1 14 3.4%
Chula Vista 0 0 0 11 1 1 4 11 1 29 7.0%
Coronado 0 0 0 1 0 0 0 1 0 2 0.5%
Del Mar 0 0 0 0 0 0 0 2 0 2 0.5%
El Cajon 0 0 0 12 0 0 3 6 4 25 6.0%
Encinitas 0 0 0 2 0 0 2 1 0 5 1.2%
Escondido 0 0 0 7 0 1 0 5 0 13 3.1%
Imperial Beach 0 0 0 4 0 1 0 1 1 7 1.7%
La Mesa 0 0 0 5 0 1 0 3 0 9 2.2%
Lemon Grove 0 0 0 1 0 0 1 0 1 3 0.7%
National City 0 0 0 6 0 0 2 3 0 11 2.7%
Oceanside 1 0 0 22 4 5 3 12 0 47 11.4%
Poway 0 0 0 3 0 0 1 0 0 4 1.0%
San Diego 5 0 4 101 0 4 8 47 14 183 44.2%
San Marcos 0 0 0 4 0 1 0 3 1 9 2.2%
Santee 0 0 0 4 0 0 1 3 1 9 2.2%
Solana Beach 0 0 0 3 0 0 0 1 4 1.0%
Vista 0 0 0 4 0 0 3 1 2 10 2.4%
Unincorporated 3 1 0 11 0 1 3 9 0 28 6.8%
Total County 9 1 4 206 5 15 33 115 26 414 100.0%
% 2.2% 0.2% 1.0% 49.8% 1.2% 3.6% 8.0% 27.8% 6.3% 100.0% Source: U.S. Department of Housing and Urban Development, February 2020. * Data represents HUD’s fiscal years (October 1-September 30)
July 14, 2020 Item #6 Page 201 of 211
H. Hate Crimes
Hate crimes are crimes that are committed because of a bias against race, religion, disability,
ethnicity, or sexual orientation. In an attempt to determine the scope and nature of hate crimes, the
Federal Bureau of Investigation’s (FBI) Uniform Crime Reporting Program collects statistics on
these incidents.
To a certain degree, hate crimes are an indicator of the environmental context of discrimination.
These crimes should be reported to the Police or Sheriff’s department. On the other hand, a hate
incident is an action or behavior that is motivated by hate but is protected by the First Amendment
right to freedom of expression. Examples of hate incidents can include name-calling, epithets,
distribution of hate material in public places, and the display of offensive hate-motivated material on
one’s property. The freedom guaranteed by the U.S. Constitution, such as the freedom of speech,
allows hateful rhetoric as long as it does not interfere with the civil rights of others. Only when these
incidents escalate can they be considered an actual crime.
Statistics compiled by the FBI found that a total of 479 hate crimes were committed in San Diego
County from 2013 to 2018 (Table 83). Race-based hate crimes were the most common (54 percent);
though, hate crimes motivated by sexual orientation (26 percent), and religion (19 percent) were also
commonly reported.
During the six-year period from 2013 to 2018, the incidence of reported hate crimes in all of San
Diego County was less than one per 1,000 people (0.15 per 1,000 persons). This figure has also
substantially declined from a decade earlier (the seven-year period from 2007 to 2013) when the
incidence of hate crimes in the County was 0.23 per 1,000 persons. Hate crime statistics varied
somewhat from jurisdiction to jurisdiction—with the cities of Del Mar (zero incidents), Solana
Beach (zero incidents), and Coronado (0.04) having the lowest incidence rates and the cities of
Imperial Beach (0.22), Escondido (0.17), Oceanside (0.16), and San Diego (0.16) having the highest
incidence rates. It should be noted that these statistics may also reflect a higher incidence of
reporting crime in certain communities, which consistently have very low overall crime rates.
July 14, 2020 Item #6 Page 202 of 211
Table 83: Hate Crimes (FY 2013-2018)
Jurisdiction
Race/
Ethnicity/
Ancestry
Religion Sexual
Orientation Disability Gender Gender
Identity Total % Incidence
Urban County Cities
Coronado 0 1 0 0 0 0 1 0.2% 0.04
Del Mar 0 0 0 0 0 0 0 0.0% 0.00
Imperial Beach 4 1 1 0 0 0 6 1.3% 0.22
Lemon Grove 2 0 1 0 0 0 3 0.6% 0.11
Poway 0 2 1 0 0 0 3 0.6% 0.06
Solana Beach 0 0 0 0 0 0 0 0.0% 0.00
Entitlement Jurisdictions
Carlsbad 10 5 1 0 0 0 16 3.3% 0.14
Chula Vista 8 3 6 0 0 0 17 3.5% 0.06
El Cajon 9 0 4 0 0 0 13 2.7% 0.12
Encinitas 4 4 0 0 0 0 8 1.7% 0.13
Escondido 23 2 1 0 0 0 26 5.4% 0.17
La Mesa 4 1 1 0 0 0 6 1.3% 0.10
National City 5 0 2 0 0 0 7 1.5% 0.11
Oceanside 19 5 5 0 0 0 29 6.1% 0.16
San Diego 102 51 72 0 0 7 232 48.4% 0.16
San Marcos 3 2 1 0 0 0 6 1.3% 0.06
Santee 5 1 2 0 0 0 8 1.7% 0.14
Vista 9 2 4 0 0 0 15 3.1% 0.15
Unincorporated 50 9 24 0 0 0 83 17.3% 0.02
Total County 257 89 126 0 0 7 479 100.0% 0.14
Percentage 53.7% 18.6% 26.3% 0.0% 0.0% 1.5% 100.0%
Source: U.S. Department of Justice Federal Bureau of Investigation, Crime Statistics, 2013-2018.
July 14, 2020 Item #6 Page 203 of 211
his chapter builds upon the previous analyses and presents a list of specific actions jurisdictions
in the region are planning to undertake in order to address the impediments. Impediments and
recommendations are grouped in the following categories:
A. Regional Impediments
The following is a summary of recommended actions to address regional impediments.
Impediments and recommended actions are modified to reflect current conditions, feasibility, and
past efforts.
1. Lending and Credit Counseling
Impediments: Hispanics and Blacks continue to be under-represented in the homebuyer
market and experienced large disparities in loan approval rates.
White applicants were noticeably overrepresented in the loan applicant pool, while Hispanics
were severely underrepresented. The underrepresentation of Hispanics was most acute in the
cities of Imperial Beach (-30 percent), Vista (-32 percent), and Escondido (-33 percent).
Approval rates for Black and Hispanic applicants were well below the approval rates for
White and Asian applicants in the same income groups. Specifically, Black applicants
consistently had the lowest approval rates compared to other racial/ethnic groups in the
same income groups. The largest discrepancies (between loan approval rates for White and
Asian applicants versus Black and Hispanic applicants) in 2017 were recorded in the cities of
El Cajon, Encinitas, and San Marcos.
Black and Hispanic applicants continued to get higher-priced (subprime) loans more
frequently than White and Asian applicants.
Recommended Actions
Timeframe Carlsbad Chula Vista Encinitas El Cajon Escondido La Mesa National City Oceanside San Diego City San Diego Urban County San Marcos Santee Vista Coordinate with the Reinvestment
Task Force to receive annual
reporting from the Task Force on
progress in outreach and education.
Annually
T
July 14, 2020 Item #6 Page 204 of 211
2. Overconcentration of Housing Choice Vouchers
Impediments: Due to the geographic disparity in terms of rents, concentrations of Housing
Choice Voucher use have occurred.
El Cajon and National City continue to experience high rates of voucher use.
Recommended Actions
Timeframe Carlsbad Chula Vista Encinitas El Cajon Escondido La Mesa National City Oceanside San Diego City San Diego Urban County San Marcos Santee Vista Expand the affordable housing
inventory, as funding allows. Ongoing
Promote the Housing Choice
Voucher program to rental
property owners, in collaboration
with the various housing
authorities in the region.
Ongoing
Increase outreach and education,
through the fair housing service
providers, regarding the State’s new
Source of Income Protection (SB
329 and SB 222), defining Housing
Choice Vouchers as legitimate
source of income for housing.
These new housing laws went into
effect January 1, 2020.
By the end of 2020, and annually thereafter
3. Housing Options
Impediments: Housing choices for special needs groups, especially persons with
disabilities, are limited.
Housing options for special needs groups, especially for seniors and persons with disabilities,
are limited. Affordable programs and public housing projects have long waiting lists.
Approximately 23 percent of the applicant-households on the waiting list for Public Housing
and 22 percent on the waiting list for Housing Choice Vouchers include one disabled
member.
Approximately 10 percent of the applicant-households on the waiting list for Public Housing
and 11 percent on the waiting list for Housing Choice Vouchers are seniors.
July 14, 2020 Item #6 Page 205 of 211
Recommended Actions
Timeframe Carlsbad Chula Vista Encinitas El Cajon Escondido La Mesa National City Oceanside San Diego City San Diego Urban County San Marcos Santee Vista Increase housing options for
special needs populations,
including persons with disabilities,
senior households, families with
children, farmworkers, the
homeless, etc. Specifically, amend
the Zoning Code to address the
following pursuant to new State
laws:
Low Barrier Navigation
Center (AB 101)
Supportive Housing (AB
139)
Emergency Shelter for the
Homeless (AB 139)
Accessory Dwelling Units
(ABs 68, 671, 881, and 587
and SB 13)
See actions under Jurisdictional -
Specific Impediments – Public
Policies.
Review zoning provisions as part of the 6th cycle Housing Element update, due
April 15, 2021
Encourage universal design
principles in new housing
developments.
Ongoing
Educate city/county building,
planning, and housing staff on
accessibility requirements
Ongoing
Encourage inter-departmental
collaboration Ongoing
July 14, 2020 Item #6 Page 206 of 211
4. Enforcement
Impediments: Enforcement activities are limited.
Fair housing services focus primarily on outreach and education; less emphasis is placed on
enforcement.
Fair housing testing should be conducted regularly.
Recommended Actions
Timeframe Carlsbad Chula Vista Encinitas El Cajon Escondido La Mesa National City Oceanside San Diego City San Diego Urban County San Marcos Santee Vista Provide press releases to local
medias on outcomes of fair
housing complaints and litigation.
Semi-annually
Support stronger and more
persistent enforcement activity by
fair housing service providers.
Ongoing
Conduct random testing on a
regular basis to identify issues,
trends, and problem properties.
Expand testing to investigate
emerging trends of suspected
discriminatory practices
Conduct testing every other year or as warranted by emerging trends
July 14, 2020 Item #6 Page 207 of 211
5. Outreach and Education
Impediment: Today, people obtain information through many media forms, not limited to
traditional newspaper noticing or other print forms.
Increasingly fewer people rely on the newspapers to receive information. Public notices and
printed flyers are costly and ineffective means to reach the community at large.
Frequent workshops with targeted population should be conducted to allow for meaningful
discussions and dissemination of useful information.
Recommended Actions
Timeframe Carlsbad Chula Vista Encinitas El Cajon Escondido La Mesa National City Oceanside San Diego City San Diego Urban County San Marcos Santee Vista Education and outreach
activities to be conducted as a
multi-media campaign,
including social media such as
Facebook, Twitter, and
Instagram, as well as other
meeting/discussion forums
such as chat rooms and
webinars.
Ongoing
Involve neighborhood groups and
other community organizations
when conducting outreach and
education activities.
Ongoing
Include fair housing outreach as
part of community events. Ongoing
July 14, 2020 Item #6 Page 208 of 211
6. Racial Segregation and Linguistic Isolation
Impediment: Patterns of racial and ethnic concentration are present within particular areas
of the San Diego region.
In San Diego County, 15.4 percent of residents indicated they spoke English “less than very
well” and can be considered linguistically isolated.
The cities of National City, Chula Vista, El Cajon, and Escondido have the highest
percentage of total residents who spoke English “less than very well”. Most of these
residents were Spanish speakers.
Within San Diego County, there are RECAPs (Racially/Ethnically Concentrated Areas of
Poverty) scattered in small sections of Escondido, El Cajon, La Mesa, Lemon Grove,
National City, and Chula Vista. Larger RECAP clusters can be seen in the central/southern
portion of the City of San Diego.
Recommendations
Timeframe Carlsbad Chula Vista Encinitas El Cajon Escondido La Mesa National City Oceanside San Diego City San Diego Urban County San Marcos Santee Vista Diversify and expand the housing
stock to accommodate the varied
housing needs of different groups.
As part of the 6th cycle Housing Element update, evaluate the community’s
varied housing needs and adjust housing and land use policies to
accommodate the community’s Regional Housing Needs Assessment
(RHNA), by April 15, 2021
Promote equal access to
information for all residents.
Update LEP plan to reflect
demographic changes in
community per Executive Order
13166 of August 11, 2000.
Periodically but at least when new Census data becomes available
July 14, 2020 Item #6 Page 209 of 211
B. Jurisdiction-Specific Impediments
The following is a list of actions that will be taken to address jurisdiction-specific impediments
carried over from previous AIs. Impediments and recommended actions are modified to reflect
current conditions, feasibility, and past efforts.
1. Public Policies
Impediments: Various land use policies, zoning provisions, and development regulations
may affect the range of housing choice available.
Recent Changes to Density Bonus Law: The most recent changes to California density
bonus law went into effect in January 2020. Because of this, while most San Diego County
jurisdictions do include regulations allowing for density bonuses, jurisdictions must review
their regulations to ensure continued compliance with state law.
Definition of Family: The zoning ordinance of Solana Beach contains a definition of family
that may be considered discriminatory.
Accessory Dwelling Units: Most jurisdictions have not yet amended the ADU provisions
to comply with the recent changes to State law (e.g., SB 13, AB 68, AB 881, AB 587, and AB
671).
Emergency Shelters: The City of Poway does not have adequate provisions for emergency
shelters in their zoning ordinance. The currently adopted Housing Element for Poway
acknowledges the need to update the zoning ordinance, but no amendment has been
completed at this time.
Furthermore, recent changes to State law (AB 101 and AB 139) require additional revisions
to local zoning regulations regarding the provision of Low Barrier Navigation Centers
(LBNC) and emergency shelters. Specifically AB 139 requires the assessment of shelter
needs be based on the most recent Point-in-Time Count and the parking standards for
shelters be based on staffing levels.
Transitional and Supportive Housing: The County of San Diego, La Mesa, and Vista do
not fully comply with all of the requirements of SB 2. Furthermore, recent changes to State
law AB 139 requires supportive housing to be permitted by right where multi-family and
mixed uses are permitted. Jurisdictions should revise the zoning ordinance to specifically
state supportive housing as a by-right use.
Farmworker Housing/Employee Housing: Some jurisdictions allow employee housing
for six or fewer employees but have not updated their zoning ordinance to permit the use in
accordance with the California Housing Act.
July 14, 2020 Item #6 Page 210 of 211
Recommended
Actions
Zoning Amendments Needed Density Bonus Accessory Dwelling Units Emergency Shelters Zoning LBNC and ES Capacity and Parking Standards Transitional/ Supportive Housing Farmworker Employee Housing Definition of Family Carlsbad
Chula Vista
Coronado
Del Mar
El Cajon
Encinitas
Escondido
Imperial Beach
La Mesa
Lemon Grove
National City
Oceanside
Poway
San Diego City
San Diego County
San Marcos
Santee
Solana Beach
Vista
July 14, 2020 Item #6 Page 211 of 211
All Receive -Agenda Item # {p
F~r the Information of the: {city of
Carlsbad CI/.COUNCIL
Date :J.ll!L-cA V cc ..:::::_
CM_ CM _v'OCM (3) _:::::'
Council Memorandum
July 14, 2020
To:
From:
Via:
Re:
Honorable Mayor Hall and Members of the City Council
Gary Barberio, Deputy City Manager, Community Services
Nancy Melander, Program Manager .
Geoff Patnoe, Assistant City Manager (f;
Additional Materials Related to Staff Report Item No. 6 -Fiscal Years 2020-25
Analysis of Impediments to Fair Housing Choice for the City's Community
Development Block Grant Program
This memorandum provides a correction and additional information to Agenda Item No. 6 for the
City Council meeting on July 14, 2020.
1. The seventh WHEREAS clause in Exhibit 1 (Resolution), which read "WHEREAS, public
comments from the public review period and the public hearing, if any, have been
addressed through written response and included in the final Fiscal Years 2020-25
Analysis of Impediments;" is revised to eliminate the phrase "and the public hearing, if
any" and to read as follow:
"WHEREAS, public comments from the public review period have been.addressed
through written response and included in the Fiscal Years 2020-25 Analysis of
Impediments;"
The city conducted the Analysis of Impediments (Al) in compliance with HUD
requirements which does not require a public hearing nor does the city's CDBG Citizen
Participation Plan call for a public hearing.
2. There was a question regarding public participation and outreach to Carlsbad residents
during the development of the Al. Outreach tools included printed flyers mailed to
specific Carlsbad non-profits, agencies, social service providers, housing developers, and
the Carlsbad school district (for a total of 42 total organizations), an on line survey which
received 32 responses from Carlsbad residents, a written article in the San Diego Union
Tribune, a news broadcast on KUSI News, and a radio announcement on KPBS. Public
meeting information as well as hard copies of the draft document were provided at the
city's Housing Services counter as well as online on the city's Facebook page and website.
Community Services Branch
Community Development
1200 Carlsbad Village Way I Carlsbad, CA 92008-1949 I 760-430-2812 t
Honorable Mayor Hall and Members of the City Council
July 14, 2020
Page 2
3. On page 164, Attachment A of the staff report {Item No. 6, p. 176 of 211), under the
section titled "H . Local Housing Authorities," there was a question whether the
statement that the city's housing authority only administers housing choice vouchers, but
not a public housing program, is accurate because it does not acknowledge the city's
ownership of Tyler Court Senior Apartments. Tyler Court Senior Apartments, although
owned by the city, is not public housing in that it did not receive financial assistance
under nor is it subject to the regulations of the U.S. Housing Act of 1937, the fe~eral
program that established public housing throughout the country. However, all housing in
Carlsbad, whether publicly or privately owned and managed are subject to fair housing
laws. Residents who have a fair housing concern they cannot resolve through property
management or ownership may contact the city's fair housing provider, Legal Aid Society
of San Diego, for further assistance.
Currently, Tyler Court Senior Housing is managed by Western Senior Housing
Management Company (WSH). WSH conducts inspections of all units at Tyler Court on a
semi-annual basis, but due to the current COVID-19 pandemic, inspections have been
deferred for a later time. However, WSH is accepting and completing work orders for
urgent and emergency maintenance needs.
Attachment: A. Revised Resolution
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Jeff Murphy, Community Development Director
Mike Peterson, Community Development Assistant Director
Sheila Cobian, Assistant to the City Manager
David de Cordova, Principal Planner
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,
CALIFORNIA, APPROVING THE FISCAL YEARS 2020-25 ANALYSIS OF
IMPEDIMENTS TO FAIR HOUSING CHOICE FOR THE CITY'S COMMUNITY
DEVELOPMENT BLOCK GRANT PROGRAM.
Exhibit 1
WHEREAS, the Housing and Community Development Act of 1974 is the governing statute for
the city's Community Development Block Grant Program requiring that each federal entitlement
grantee certify to the satisfaction of HUD that an awarded federal grant will be carried out and
administered in accordance with the federal Fair Housing Act and the grantee will work diligently to
actively further fair housing choice; and
WHEREAS, the CDBG program is a fully funded federal program and does not impact the General
Fund;and
WHEREAS, to be eligible for CDBG funds, the jurisdiction must adopt an Analysis of
Impediments to affirmatively further the fair housing objectives of the Fair Housing Act of 1968, as
amended, which must be considered and accepted by the City Council of the City of Carlsbad; and
WHEREAS, to assist in the analysis the city solicited input from community members, service
providers, stakeholder interviews, and community workshops to assess the nature and extent of
impediments to fair housing; and
WHEREAS, the City Council of the City of Carlsbad, California has considered the Analysis of
Impediments for the period beginning July 1, 2020 and ending on June 30, 2025, as required for the
city's CDBG program; and
WHEREAS, the draft Analysis of Impediments was released for a 30-day public review period
which began on May 22, 2020, and concluded on June 20, 2020; and
WHEREAS, public comments from the public review period have been addressed through
written response and included in the final Fiscal Years 2020-25 Analysis of Impediments; and
Exhibit 1
WHEREAS, the City Council of the City of Carlsbad, California has taken all testimony into
account in considering the Analysis of Impediments for the Fiscal Years 2020-25 as required for the
city's CDBG program; and
WHEREAS, the City Council of the City of Carlsbad, California, approves the Fiscal Years 2020-
25 Analysis of Impediments for the city's CDBG program; and
WHEREAS, the City of Carlsbad is committed to continuing to provide a suitable living
environment and to expand economic opportunities for the city's low-income residents as is outlined
in the CDBG Program; and
WHEREAS, the City Council has taken all testimony into account.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as
follows:
1.
2.
That the above recitations are true and correct.
That the Fiscal Years 2020-25 Analysis of Impediments (Attachment A) is hereby
approved by the City Council.
3. That, on the city's behalf, the City Manager, or designee, is authorized to finalize the
city's Fiscal Years 2020-25 Analysis of Impediments as set forth in Attachment A and to
execute all appropriate related documents for the final Analysis of Impediments.
PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of
Carlsbad on the_ day of ___ ~ 2020, by the following vote, to wit:
AYES:
NAYS:
ABSENT:
MATT HALL, Mayor
BARBARA ENGLESON, City Clerk
{SEAL)
Community Development Department
Housing Services Division
July 14, 2020
Fiscal Years 2020-25 Analysis of
Impediments to Fair Housing Choice
Background
•Regional analysis with members of the SDRAFFH
•Five year assessment of the regional laws, ordinances,
statutes and administrative policies, as well as local
conditions
•Provides solutions and measures that will be pursued to
mitigate or remove identified impediments
Analysis of Impediments
•Five regional workshops; 63 attendees
•In-depth look at the regions demographic profiles and
household characteristics
•Action Plan was developed that identifies regional and
jurisdiction-specific impediments and required action
items
Carlsbad Specific Impediments
Impediments Actions
Recent changes to density bonus law Review and amend regulations to ensure compliance with the recent changes to California density bonus law
Accessory dwelling units policies Amend accessory dwelling units provisions to comply with recent
changes to state law.
Low barrier navigation centers and emergency shelter capacity
and parking standards
Review low barrier navigation centers and emergency shelters
provisions to comply with recent changes to state law.
Transitional and supportive housing Review and revise the zoning ordinance to comply with recent
changes to AB 139 requiring supportive housing to be permitted
by right where multifamily and mixed uses are permitted.
Community Development Department
Housing Services Division
June 16, 2020
FY 2020-21 Annual Action Plan
and CARES Act Supplemental Funding