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HomeMy WebLinkAboutPR 18281: AMENDMENT OF RES. 12-031 FAIR HOUSING ACTIVITY STATEMENT-TEXAS INTEROFFICE MEMORANDUM HOUSING AND NEIGHBORHOOD REVITALIZATION To: John Comeaux, P.E., Interim City Manager , C From: Mary Essex, Grants Program Administrator Ln E Date: April 7, 2014 Re: P.R. 18281 RECOMMENDATION: It is recommended that City Council adopt PR No. 18281 authorizing the amendment of Resolution No. 12 -031 that authorized the Fair Housing Activity Statement — Texas (FHAST) form that was approved by the Texas State Land Office on October 29, 2011. BACKGROUND: The Fair Housing Activity Statement -Texas (FHAST) form is for Round 2.2 funding and will be used for future projects for the disaster recovery project. It is intended to demonstrate the commitment by communities to review the Analysis of Impediment, and implement action plans for the improvement of fair housing in our area. All applicants for Round 2.2 funding were required to submit a FHAST form to the Texas General Land Office. The 2011 FHAST form has been amended as follows: The completed FHAST form with supporting documentation hereto as Exhibit "B" can be reviewed in City's Secretary Office. # Page # Impediment # Highlighted Item # Description 1 4 3 2 Various fair housing activities throughout the year. 2 5 4 2 Port Arthur's Anti - NIMBYISM Guidelines. 3 6 5 1 Comprehensive Plan, Zoning Ordinance, and Subdivision Ordinance for infrastructure improvements. 4 6 5 2 Diagnostic Report — Comprehensive Plan, Zoning Ordinance, and Subdivision Ordinance. 5 6 5 3 Fair Housing Training for staff and elected officials. 6 7 5 5 Infrastructure improvements for Hurricane Ike Disaster Round I. 7 7 5 8 Infrastructure projects are ADA compliant and address other legacy discrimination issues. Included will be an attachment of Americans with Disabilities Act Transition Plan. 8 9 5 12 Chapter 42 of the City's Code of Ordinance — Flood Damage Prevention. 9 9 5 14 the City and Southeast Texas Regional Planning Commission worked together to rebuild homes for participants in Hurricane Ike Disaster Round I. 10 9 5 15 Infrastructure programs funded with disaster recovery funds should be designed to be fully accessible to persons with disabilities. See Attachment #8 11 10 6 3 Impacted agencies that provide certification are affirmatively furthering fair housing as required by federal law. See Attachment #3 12 11 6 5 Port Arthur published on its website a non - compliance fair housing policy statement consistent with the language of the State and how complaints will be processed as detailed in the attached City's Code of Ordinance, see attachment #4. A log will be maintained for all fair housing complaints. PR 18281 # Page # Impediment # Highlighted Item # Description 13 12 7 2 Reviewing Comprehensive Plan, Zoning Ordinance, and Subdivision Ordinance that includes a long term plan for housing growth and redevelopment. 14 13 9 3 Reviewing Comprehensive Plan, Zoning Ordinance, and Subdivision Ordinance as part of an effort to comply with Fair Market Housing Guidelines and streamline our permitting and enforcement efforts with respect to impediments to special needs persons. 15 14 12 12 Section 3 program that meets the requirements of federal law and regulations regarding potential job creation at the impacted neighborhood level and use of federal funds to hire local LMI eligible persons. BUDGETARY /FISCAL EFFECT: N/A STAFFING /EMPLOYEE EFFECT: Housing Administration, Grant Management and Community Work Group. SUMMARY: It is recommended that City Council adopt PR No. 18281 authorizing the amendment of Resolution No. 12 -031 that authorized the Fair Housing Activity Statement — Texas (FHAST) form that was approved by the Texas State Land Office on October 29, 2011. • PR 18281 P. R. 18281 4/7/14 ME /DF RESOLUTION NUMBER A RESOLUTION FOR CITY COUNCIL TO AUTHORIZE THE AMENDMENT OF RESOLUTION NO. 12 -031 THAT AUTHORIZED THE FAIR HOUSING ACTIVITY STATEMENT -TEXAS (FHAST) FORM FOR THE DISASTER RECOVERY PROGRAM FOR ROUND 2.2 FUNDING. WHEREAS, the City of Port Arthur has been approved for Round two (2) of the State's Hurricane CDBG Disaster Recovery program; and WHEREAS, all applicants for Round 2.2 funding were required to submit a FHAST form to the Texas General Land Office; and WHEREAS, the FHAST form was intended to demonstrate the commitment by communities to review the Analysis of Impediment, and implement action plans for the improvement of fair housing in our city; and WHEREAS, the City has amended the FHAST form to identify the Fair Housing Activity Statement Accomplishments in substantially the same form as attached hereto as Exhibit "A "; and WHEREAS, the completed FHAST form with the supporting documentation hereto as Exhibit "B" can be reviewed in City's Secretary Office. NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PORT ARTHUR: Section 1. THAT the facts and opinions in the preamble are true and correct. Section 2. THAT the City Council approves the amended City of Port Arthur's Fair Housing Activity Statement — Texas Form (" FHAST Form ") in substantially the same form as PR 18281 attached hereto as Exhibit "A ". Section 3. THAT a copy of the caption of this Resolution be spread upon the minutes of the City Council. READ, ADOPTED AND APPROVED this day of April, A.D., 2014 at a Regular Meeting of the City Council of the City of Port Arthur, Texas by the following vote: AYES: MAYOR: COUNCILMEMBERS: NOES: MAYOR ATTEST: APPROVED FOR AVAILABILITY OF FUNDS: - A/t SHERRI BELLARD, CITY SECRETARY DEB RAH ECHOLS, DIRECTOR OF FINANCE APPROVED FO • FORM: 1/ I I" • =Now VAL TIZENO, CITYYTTORNEY APPROVED FOR ADMINISTRATION: JOHN A. COMEAUX, P.E., INTERIM CITY MANAGER PR 18281 EXHIBIT "A" PR 18281 CITY OF PORT ARTHUR FAIR HOUSING ACTIVITY STATEMENT ACCOMPLISHMENTS Impediment #1 Protected classes may experience disparities in home mortgage lending and high cost loans. ACCOMPLISHMENT: NO LOCAL ACTION IS REQUIRED 2 dipiewonw Impediment #2 There is inadequate information available to the real estate community, governments and the public about fair housing requirements and enforcement procedures. ACCOMPLISHMENT: NO LOCAL ACTION IS REQUIRED 3 Impediment #3 The public is not sufficiently aware of their Fair Housing rights and how to obtain the assistance necessary to protect those rights. 1. Consistent with the Fair Housing Act, the State of Texas, and funded sub - recipients should continue to promote and conduct events to celebrate April as Fair Housing Month, and direct sub - recipients to do the same. These events can demonstrate support for fair housing and build awareness. ACCOMPLISHMENT: An annual Fair Housing Conference is sponsored by the Cities of Port Arthur, Beaumont, and Orange in the month of April. The Conference speakers inform the public about Fair Housing rights, credit counseling and the responsibilities of homeownership. Proclamations are issued annually by the City Council declaring April as "Fair Housing Month "; see Attachment #1 for Proclamations and the agendas for the Fair Housing Conferences. See Attachment #3 for pictures of Fair Housing posters in City Hall. 2. Consistent with the Fair Housing Act, the State of Texas and funded sub - recipients have historically conducted fair housing activities as various times of the year and should continue to fund, depending on sufficient appropriations, or collaborate with public and private agencies, organizations and groups to plan and conduct fair housing activities. The City of Port Arthur commits to improving its Fair Housing dialogues throughout the year with local stakeholders like the Port Arthur Housing Authority, mortgage lenders, contractors, realtors, and potential first time home buyers to discuss housing opportunities in the City of Port Arthur. Impediment #4 Not in my Backyard" (NIMBY) may be an impediment to fair housing in Texas communities. 1. NIMBY opposition needs to be anticipated and planning and outreach should occur on the front end of projects. To mitigate defensive and reactive responses, planning should include strategies for education, outreach and marketing that provide accurate information and promote the positive aspects and benefits of affordable housing to build support among community residents. 4 2. The Department of Housing and Urban Development (HUD) provides extensive information about Fair Housing and examples at www.hud.gov. Generally communities should consider: • Working with local officials, editorial boards, religious and civic organizations and other community leaders to initiate education programs. • Seeking opportunities to present information to community organizations by requesting to be placed on their meeting agendas. • Including a visit to the Group Home residence as part of an education program. • Answering all questions. • Talking with local neighborhood leaders, including elected representatives, and setting up a neighborhood meeting. • Setting up a liaison committee consisting of advocates, group residents, and neighborhood residents to discuss issues. • Identifying areas that meet AFFH targets where the community supports development, has worked with community groups and potentially uses funds to assist the development of multi - family affordable housing. ACCOMPLISHMENT: INte City of Port Arthur's Planning Moment conducts P develoment meetings every Wednesday at 1:30 p.m. firsidentill developers. The Planning Department will schedule neigIRIBMINEIgs, as gralt citizens who have concerns, comments or objections to any new development pr to Port Arthur. See Attachment #2 that includes the Anti - NIMBYISM, Not in my Backyard, guidelines that were based on the City's adopted Codes and Ordinances and a Pre - development mng form. Impediment #5 Certain governmental policies and practices may not meet current HUD policy concerning affirmatively furthering fair housing. Jurisdictions should act to ensure that their policies and procedures affirmatively further fair housing, address mal- distribution of resources, and that they do not unnecessarily impact housing choice. 1. As part of certifying that a community is affirmatively furthering fair housing, jurisdictions that have long -term infrastructure plans should review them to determine if the plan promotes racial concentrations or otherwise inadvertently result in disparate treatment of members of protected classes. While not intended to direct a community to hire a 5 consultant, it is anticipated that a community will review its long -term infrastructure plans as part of this recommended action. In reviewing the project list (Appendix F of the Phase 1 Al) there are many projects that are listed as being of community -wide benefit. The records do not indicate the actual location of projects or provide adequate discussion of how the projects benefit the entire community. ACCOMPLISHMENT: 2. As it has been determined under federal law that Fair Housing applies to all federal housing and community development funds, to reduce "siloing" the fair housing component into only housing - related programs, fair housing should be considered in all activities for all local community planning staff. ACCOMPLISHMENT: 3. It would be beneficial for local elected officials to require senior staff of any subrecipient such as a city or county - including managers and attorneys -to receive available Fair Housing training within the first 12 months of their employment or engagement. ACCOMPLISHMENT: 4. As part of what is usually a common initial training by the associations that provide education opportunities for newly- appointed board members or newly - elected council or commissioners court members of cities and counties, the state should request that training include specific information on the Fair Housing Act -with a discussion of affirmatively furthering fair housing obligations. Accomplishment: No local action is required at this time 6 5. Local communities should consider limiting the concentration of infrastructure improvements like wastewater treatment, solid waste disposal, or similar necessary but not desirable infrastructure projects in residential areas where there are concentrations of protected classes. Accomplishment: Infrastructure improvements are based on the needs of the community and not restricted to residential areas with a high concentration of protected classes. Please see the attached Diagnostic Report which includes infrastructure improvements. 6. Communities electing to provide publicly financed housing incentives should be requested to call for recipients to engage in affirmative marketing. Accomplishment: Port Arthur doesn't provide publicly financed housing projects. As an incentive for large project developments, the City Council may waive permit fees and water tap fees. Please see attached Port Arthur's Marketing Analysis. 7. If a jurisdiction is a non - entitlement community, when working in LMI areas to replace roads or other infrastructure, the jurisdiction should consider making application for additional sources of funding to provide assistance to repair substandard housing associated with the Project (i.e., TDHCA or HUD). Accomplishment: Not Applicable, Port Arthur is an entitlement community. 8. Most infrastructure projects take into account items like curb cuts, sidewalks, hearing and visually impaired indicators at intersections. When approving non - federally funded projects, similar special needs construction should be required for infrastructure improvements. Projects should also address other legacy discrimination issues, such as accessibility in public areas like courthouses, community centers and other high traffic areas. Accomplishment: Fort Arthur currently requires t "ations for non - federally- funded infrastructure projects are compliant with the Americans with Disability Act, ADA. Please see Attachment #8 — Americans with Disabilities Act Transition Plan. 9. Each jurisdiction applying for Community Development Block Grant funds or other federal housing and community development funds should submit a Fair Housing Activities 7 Statement — Texas (FHAST) with their application, reviewing their infrastructure needs and housing needs and how the proposed activity promotes fair housing or results in more equitable treatment of protected classes. Projects with community -wide benefits should be accompanied by explicit commitments on the part of the local jurisdictions to undertake additional activities to affirmatively further fair housing along a monitoring and reporting process. Accomplishment: Port Arthur submitted a FHAST form to the Texas General Land Office in 2011 see Attachment #9. 10. As part of the non - housing disaster recovery program, jurisdictions should consider low - income areas and areas populated principally by members of protected classes to determine the potential for flooding and consider making infrastructure expenditures to help protect the impacted communities - including colonias. Accomplishment: Port Arthur has reviewed low to moderate - income, LMI, areas and areas populated principally by members of protected classes, and prioritized infrastructure expenditures to help protect the impacted communities - including colonias. The City of Port Arthur has no colonias and not considered in the process. 11. If applicable, all policies should be reviewed regarding denying applicants' access to disaster recovery CDBG funds if their residence is located in the flood plain. If the policy does not allow participation by restricting building in flood plains, then the policy should be assessed to see if alternative housing programs could be implemented for the residents. Local jurisdictions should analyze the results and see if protected classes are more frequently harmed by flood plain restrictions. This action does not apply to the GLO CDBG Disaster Relief Fund that limits property purchase "unless TXCDBG receives satisfactory evidence that the property to be purchased was not constructed or purchased by the current owner after the property site location was officially mapped and included in a designated flood plain." Accomplishment: Not Applicable- The City of Port Arthur has not and will not deny any applicants access to disaster recovery CDBG funds if their residence is located in the flood plain. 12. When an entire community is in a flood plain, the community should establish clear standards that allow for proper elevation or relocation, and that also allows for visitability /special needs considerations consistent with state [3] and federal law. 8 Accomplishment: he City of Port Arthur will fgMpw FEMA s (CFR 44, Executive p er ` . ° 0) for constructionip Special Flood Hazard Areas. Please see page 28 if the Diagnos , rt concerning the 100 Year Floodplaindlipmeallestriction. See chment #5 for Chapter 42 of the City's Code of Ordinances — Flood Damage Prevention. 13. Local jurisdictions that accommodated the relocation of disaster survivors resulting in concentrations of protected class survivors in specific areas should establish Moving to Opportunity Programs and include renters in their Moving to Opportunity Programs as defined under Round 2. Accomplishment: Not applicable 14. Consistent with the process established in the Conciliation Agreement, local jurisdictions and state agencies should work together to determine a demographic and economic profile of victims of the natural disaster and establish goals for assisting these populations in no less that the proportions they were impacted by the disaster. These goals should be performance goals and disaster recovery funds should be extended incrementally in a manner to ensure that these populations are equitably assisted with benefits. Accomplishment: The City of Port Arthur is working with the Southeast Texas Regional Planning Commission to reconstruct homes that were damaged during Hurricane Ike. Port Arthur has completely utilized Phase 1 of the Hurricane Ike Disaster funds which constructed 250 single family homes. Phase II of the Hurricane Ike Disaster will build an additional 250 single family homes throughout the City. 15. All infrastructure programs funded with disaster recovery funds should be designed so that any publicly accessible infrastructure projects and associated facilities are fully accessible to persons with disabilities Accomplishment: 1111121111110covery funds were used to purchase and install commercial buildings that were damaged during Hurricane Ike, ghout the City. ith thiMWEEMPIEVERINIMEIMIKstinitids. ne Ike Round 2 reel DA guidelMihment #8 for a copy of Port AMMINIPMEMErPlan. 16. Consistent with the Conciliation Agreement, family and elderly public housing units damaged or destroyed by the disaster should be reconstructed or repaired in a manner that affirmatively furthers fair housing utilizing disaster recovery funds within 24 months of approval of the initial application for disaster recovery assistance for the local jurisdiction. Accomplishment: Not applicable, the City of Port Arthur has no family and elderly public housing units that were damaged or destroyed by the disaster that still need repair. 9 Impediment #6 Governmental entities at all levels do not appear to have been proactive in the enforcement of both the Fair Housing Act and the obligation to affirmatively further fair housing. The State and subrecipients should implement a robust and effective structure for identifying and pursuing suspected violations. 1. Given the potential for increase in Fair Housing enforcement action by federal and state agencies and private organizations, an ongoing fair housing testing program for areas that receive federal housing and community development funds could be beneficial to protect state agencies and sub - recipients from potential repayment. Fair housing enforcement is a valid use of CDBG funding and can be used to establish testing programs by agencies trained in HUD testing procedures. The state, or local jurisdictions combining together, should consider conducting tests in areas that include the following: steering in sales and rental; the denial of and different terms and conditions based on race, national origin, familial status, and disability in sales and rental; predatory and disparate terms and conditions in lending and insurance; and foreclosure modification schemes targeting minority neighborhoods. The state should also consider education to applicable entities on self- testing and self- correction. Accomplishment: The City of Port Arthur will cooperate with the State or Regional programs and /or Public Housing Authorities and non - profits on testing programs for Fair Housing violations. 2. TDHCA should, as a pilot program, allocate funds to independent third parties or a combined jurisdiction team identified in point 1 of this section to provide similar testing to determine if additional enforcement is necessary. Accomplishment: No local action is required at this time. 3. Impacted agencies that provide certification that they are affirmatively furthering fair housing as required by federal law, should consider publishing a public document on enforcement that provides the public and communities with a clear description (and chart) of the state and Federal Fair Housing Act. Accomplishment: Fair Housing posters have been placed in Port Arthur City Hall, set `chment #3 for pictures of Fair Housing posters. The Fair Housing symbol has been placed on the City's Housing Assistance application and forms. Updated Housing Assistant brochures include the name and contact telephone number fog di e City of Port Arthur Fair Housing Administrator. 4. Each community should place on its website (if one is available) the contact, at the local, state, and federal levels, for reporting a Fair Housing complaint, if citizens believe they were victims of housing discrimination. 10 Accomplishment: Port Arthur has placed on its website, www.portarthur.net, the local, state, and federal contact information for reporting a Fair Housing complaint, if a citizen believes he /she was a victim of housing discrimination. The website will include links to The Texas Workforce Commission, Texas General Land Office, Texas Department of Housing and Community Affairs, and the Department of Housing and Urban Development. Please see attachment #6 for website information. 5. Each local jurisdiction should publish on its website a clear statement, approved jointly by TDHCA, expressing the jurisdiction's obligation to affirmatively further fair housing and providing a method for reporting suspected noncompliance to the state and to HUD. The jurisdiction's contact person should be able to refer to clear local Fair Housing procedures for the complaint process, keep logs and records of all inquiries, allegations, complaints and referrals. These reports should be sent to the appropriate funding agency. Where these reports show that a jurisdiction has administered programs inconsistently with the Al and had the effect of discouraging applications from members of protected classes who are deemed eligible under the plan for assistance, affirmative marketing plans should be developed and submitted to the appropriate agency. Accomplishment: Port Arthur has published on its website a policy statement consistent with the language of the State. The City's Fair Housing will follow its established Fair Housing Complaint process as detailed in the City's Code of Ordinance, see Attachment #4. Port Arthur will maintain a log of all fair housing complaints. Impediment #7 Many local jurisdictions have zoning codes, land use controls, and administrative practices that may impede fair housing choice and fail to affirmatively further fair housing. 1. The law anticipates that ordinances creating disparate impact should also be reviewed for change. If a disparate impact is determined to exist by the local jurisdiction, it could repeal or amend the restriction, use public funds to offset the cost through homebuyer assistance programs, or waive fees or other offsets to make the home more affordable. Accomplishment: The City of Port Arthur is reviewing its Comprehensive Plan, Zoning and Subdivision Ordinances as part of the effort to comply with Fair Market Housing Guidelines and streamline our permitting and enforcement efforts. Please see a copy of the Diagnostic Report that ensure the City's zoning codes, land use controls and administrative practice affirmatively further fair housing. 2. To help limit concentrations that could be considered impediments to affirmatively furthering fair housing, jurisdictions that have long term planning documents for housing growth or redevelopment, or revitalization plans, should consider allowing or encouraging 11 mixed income affordable housing in the plan and provide incentives for development of this type of housing in areas that are not concentrated. Accomplishment: The City of Port Arthur is reviewing its Comprehensive Plan, Zoning and Subdivision Ordinances as part of the effort to comply with Fair Market Housing Guidelines and streamline our permitting and enforcement efforts. Please see a copy of the Diagnostic Report which includes a long term plan for housing growth. 3. Local jurisdictions seeking CDBG Disaster Recovery funds from the state should consider offering expedited permitting and review processes for affordable housing projects within high opportunity target zones. Accomplishment: Port Arthur received CDBG Disaster Recovery funds for infrastructure improvements. Affordable housing projects are administered through the South East Texas Regional Planning Commission (SETRPC). Impediment #8 Inadequate planning for re- housing after an emergency situation creates a situation where persons who are uninsured or under - insured, low income, or special needs can be displaced for long periods of time. 1. Some legislators, the Sunset Commission, and communities acknowledge that while temporary disaster housing is a federal program, Texas should continue to provide guidance to local governments on additional planning that needs to be done as part of the emergency preparedness planning to most efficiently work with FEMA. Accomplishment: No local action is required at this time. 2. As much of what FEMA has previously offered is travel trailers or manufactured housing, local governments should review their zoning requirements or other land use provisions that restrict temporary housing or housing on an existing lot during the building process and look at potential waivers that do not risk or negatively impact health, safety, and welfare during a period after disasters so that low income persons can move back to their existing communities with temporary housing while waiting for redevelopment. Accomplishment: Port Arthur has reviewed its zoning requirements and other land use provisions and has provided waivers or other accommodations for post- disaster housing. Impediment #9 There are impediments in public and private actions and private attitudes to housing choice for persons with disabilities. 12 1 To meet federal Fair Housing requirements for zoning and neighborhood uses, jurisdictions should look to determine if there are direct or indirect limitations in codes that would prevent facilities or personal residences from providing assistance or communities of choice or service- enriched environments that directly impact special needs persons. 2 Local jurisdictions should work to ensure that zoning or code requirements do not unnecessarily impose stricter commercial building requirements, such as emergency access or protection services, on group homes, thereby dramatically increasing housing costs for persons with special needs. 3 Local jurisdictions should consider coordinating with the legislatively created Housing and Health Services Coordination Council for best practices on working with supportive services. Accomplishment: The City of Port Arthur is reviewing its Comprehensive Plan, Zoning and Subdivision Ordinances as part of the effort to comply with Fair Market Housing Guidelines and streamline our permitting and enforcement efforts with respect to impediments to special needs persons. Impediment #10 There are barriers to mobility and free housing choice for Housing Choice Voucher holders including: inadequate tenant counseling services and mobility assistance, failure of PHAs to apply for the FMR pilot demonstration funds, and government policies, procedures, and regulations that tend to decrease participation by private housing providers and to restrict available housing to "racially or low- income populated neighborhoods" with little access to economic, educational, or other opportunity. No local action beyond compliance with Round 2 Housing Guidelines is currently required but communities are encouraged to work with local public housing authorities to understand and overcome these impediments. Impediment #11 Loss of housing stock in Hurricanes Dolly and Ike compounded the shortage of affordable housing in disaster recovery areas. This shortage is particularly acute in safe, low- poverty neighborhoods with access to standard public services, job opportunities and good schools. Accomplishment: No local action is required at this time. TDHCA will develop a statewide strategic plan including guidance for local jurisdictions on the following Action Steps. 13 Impediment #12 Lack of financial resources for both individuals and housing providers limits Fair Housing choice. Using an effective program under Section 3 of the Housing and Urban Development Act of 1968 may help members of protected classes gain economic opportunities necessary to allow them to exercise fair housing choice. Accom lishment: The City of Port Arthur has in place a Section 3 program that meets the deral law and regulations regarding potential job creation at the impacted neighborhood level and the use of federal funds to hire local Low to Moderate income, LMI, eligible persons. See Attachment #7 for copy of the City's Section 3 Plan. Impediment #13 Location and lack of housing accessibility and visitability standards within political jurisdictions limits fair housing choice for persons with disabilities. Accomplishment: Please see a copy of the Diagnostic Report that reviews the City's housing construction for compliance. Impediment #14 Many colonias residents live in developments that have insufficient infrastructure and protections against flooding and are impacted by flooding beyond events like Hurricanes Dolly and Ike. Accomplishment: Port Arthur does not have any colonias. Impediment #15 Minority neighborhoods in disaster areas are primarily served by non - regulated insurance companies that do not adhere to underwriting guidelines and may be discriminated against in the provision of insurance. Texas has passed aggressive statues to prevent insurance "redlining." National research indicates that protected classes face unwarranted disparities in the cost of insurance, the amount of coverage, and cancellation of policies without notice to the homeowner. No local action is required at this time. Impediment #16 Many jurisdictions do not have adequate Analysis of Impediments to Fair Housing or Fair Housing Plans, and do not keep sufficient records of their activities. Accomplishment: Port Arthur has completed an Analysis of Impediments to Fair Housing Plans, see Attachment #8. Alternative or additional Local Action Steps developed by Port Arthur: The City of Port Arthur has identified other impediments and action steps in its formal Al that include the following: 14 1. In relation to Impediment #1 of the City of Port Arthur AI, the City will meet with local financial institutions regarding Home Mortgage Disclosure Act (HMDA) activity, as well as continue the City's support of public /private partnerships to address community lending needs for lower income citizens as committed to in this FHAST Form as well. 2. In relation to Impediments #3 of the City of Port Arthur AI, the City will coordinate with the Port Arthur Housing Authority to continue to educate and inform landlords of Section 8 voucher program. 3. In relation to Impediments #4 of the City of Port Arthur, AI, the City will support partnerships with local banks and insurers to encourage financial investment in low wealth and protected class neighborhoods. 15 EXHIBIT "B" CAN BE REVIEWED IN THE CITY SECRETARY'S OFFICE