Assessment of Fair Housing Assessment of Fair Housing June 2020 Submitted to the U.S. Department of Housing and Urban Development Mark A. Kern, Chairman St. Clair County Board TABLE OF CONTENTS CONTENTS Executive Summary ........................................................................................................................1 Introduction..................................................................................................................................1 Definitions....................................................................................................................................1 Community Participation Process ...................................................................................................3 Analysis...........................................................................................................................................5 A. Demographic Summary...........................................................................................................5 B. Segregation/Integration and Racially/Ethnically Concentrated Areas of Poverty....................6 1. Geographic Analysis ............................................................................................................7 2. Determinants of Segregation/R/ECAPs .............................................................................15 3. Publicly Supported Housing...............................................................................................16 4. Determinants of Segregation/R/ECAPs Related to Publicly Supported Housing...............21 C. Disparities in Access to Community Assets and Exposure to Adverse Community Factors 22 1. Disparities in Access to Community Assets.......................................................................23 2. Exposure to Adverse Community Factors..........................................................................32 3. Determinants of Disparities in Access to Community Assets and Exposure to Adverse Community Factors................................................................................................................36 D. Disability and access.............................................................................................................37 1. Population Profile...............................................................................................................37 2. Housing Accessibility .........................................................................................................39 3. Integration and Olmstead: Enabling Persons with Disabilities to Live in Apartments and Houses instead of Institutions and Other Segregated Settings..............................................40 4. Disparities in Access to Community Assets and Exposure to Adverse Community Factors ...............................................................................................................................................40 5. Disability and Access Issues Determinants .......................................................................41 E. Fair housing compliance and infrastructure ..........................................................................42 1. Unresolved Charges or Findings........................................................................................42 2. Fair Housing or Civil Rights Agencies and Organizations..................................................42 3. Fair Housing Compliance and Infrastructure Determinants ...............................................42 Fair Housing Goals and Priorities..................................................................................................43 A. Summary of Goals.................................................................................................................43 B. Goal Descriptions..................................................................................................................44 Address deteriorating infrastructure in low-to-moderate income areas..................................44 Increase the supply of accessible housing units for persons with disabilities........................44 Research new “crime free housing ordinances” to determine potential fair housing impact..44 Address lead based paint hazards to ensure existing affordable homes are safe and healthy for families..............................................................................................................................45 Support access to credit for affordable home ownership.......................................................46 Pursue coordinated anti-poverty strategies to alleviate economic pressures that contribute to continued segregation and lack of housing choice ................................................................46 Prepare for uncertain future flood insurance requirements....................................................47 If rental housing investments are made, make an effort to align these investments with IHDA or OneSTL FHEA areas of opportunity ..................................................................................47 Coordinate workforce investment activities to reduce the mismatch in worker skills and employer requirements ..........................................................................................................48 Continue to provide coordinated fair housing education through IGD ...................................49 Participation in regional efforts such as the OneSTL plan and other future planning efforts.50 EXECUTIVE SUMMARY INTRODUCTION This Assessment of Fair Housing (formerly known as an Analysis of Impediments to Fair Housing) is designed to affirmatively further fair housing for the residents of St. Clair County by promoting the availability of housing choice for all. The requirement for an Assessment of Fair Housing is found in the HUD Consolidated Plan regulations (24 CFR 91.225 (a)(1)) which state that: “each jurisdiction is required to submit a certification that it will affirmatively further fair housing, which means that it will conduct an analysis to identify impediments to fair housing choice within the jurisdiction, take appropriate actions to overcome the effects of any impediments identified through that analysis, and maintain records reflecting the analysis and actions in this regard.” This Assessment of Fair Housing (AFH) follows a revised format published by HUD as part of new proposed rule to assist HUD program participants (such as St. Clair County) in planning for fair housing outcomes and meeting the statutory obligation to affirmatively further fair housing, while still including the core information traditionally included in an Analysis of Impediments to Fair Housing (AI.) The updated HUD approach to affirmatively furthering fair housing sets out four clear fair housing goals for all communities to ensure greater opportunities to for all Americans: 1) Reduce segregation, and build on the nation’s increasing racial, geographic and economic diversity. 2) Eliminate racially and ethnically concentrated areas of poverty. 3) Reduce disparities in access to important community assets such as quality schools, job centers, and transit. 4) Narrow gaps that leave families with children, people with disabilities, and people of different races, colors, and national origins with more severe housing problems, aka., disproportionate housing needs. DEFINITIONS For the purposes of this report, the St. Louis region includes the following counties: The City of St. Louis, St. Louis County, St. Charles, Franklin, and Jefferson in Missouri, and Madison, Monroe, and St. Clair in Illinois. All data, unless otherwise noted, uses this geographic definition for the St. Louis region. This eight-county region is consistent with how the East West Gateway Council of Governments defines the region and allows the St. Clair County Affirmatively Furthering Fair Housing report to align with the St. Louis region’s Fair Housing Equity Assessment (FHEA), produced in July 2013 by the Metropolitan St. Louis Equal Housing and Opportunity Council (EHOC) as part of the OneSTL Regional Plan for Sustainable Development. The FHEA assessment addresses issues of racial disparities and access to opportunities throughout the St. Page 1 of 50 Louis region. The current Racially and/or Ethnically Concentrated Areas of Poverty (R/ECAPs) referenced throughout this report for St. Clair County and the St. Louis, MO-IL region are taken from the FHEA. The alignment with this regional report is critical as housing choice concerns cross jurisdictional boundaries. While St. Clair County’s authority stops at the borders of the jurisdiction, individuals and families searching for housing may look more broadly, and regional pressures or opportunities may affect their housing choices. The R/ECAPs referenced throughout this report are Racially and/or Ethnically Concentrated areas of Poverty – areas with high poverty rates and a non-white majority population. Current R/ECAPs identified in this report are taken from the HUD R/ECAP Database. Previous consolidated plans have used a local source, the OneSTL FHEA report, which specifically defines an R/ECAP in the following way: “a census tract that consists of 50 percent or higher non-white population and has a family poverty rate of at least 40 percent or 300 percent of the area’s mean family poverty rate, whichever is lower. According to Census ACS (S1702) data, the St. Louis region mean family poverty rate is 9.95 percent, so 300 percent of that mean family poverty rate is 29.85 percent family poverty rate.” Throughout this study, the terms white, black/African-American, Asian, Hispanic, American Indian/Alaska Native, and Native Hawaiian/Pacific Islander are used consistent with the practices and data of the U.S. Census Bureau. Page 2 of 50 COMMUNITY PARTICIPATION PROCESS St. Clair County conducted an extensive community participation process for St. Clair County’s 2020-2024 Consolidated Plan, Program Year 2020 Annual Action Plan, Citizen Participation Plan and Assessment of Fair Housing. The process included of extensive public outreach, multiple public hearings, and consultation with dozens of agencies, groups, and organizations involved in the development of affordable housing, creation of job opportunities for low-and moderate-income residents, and/or provision of services to children, elderly people, people with disabilities and homeless people. St. Clair County conducted a needs assessment survey and a budgeting exercise to gather citizen input into what the County’s priority needs are. Four public meetings, a comprehensive needs assessment survey, and a budget exercise survey were all conducted in advance of producing a draft Consolidated Plan, Program Year 2020 Annual Action Plan, Citizen Participation Plan and Assessment of Fair Housing so that the results of the citizen participation process could directly guide goal setting. The Coronavirus pandemic outbreak unfortunately limited the number of in- person meetings that could be held in 2020. Public hearings were held on the following dates and times at the locations listed: • March 3, 2020 10:00 am at the Smithton Village Hall • March 3, 2020 4:00 pm at the Fairview Heights City Hall • March 4, 2020 10:00 am at the St. Clair County IGD Annex Conference Center • March 5, 2020 4:00 pm at the Washington Park Village Hall A complete draft of this plan was made available for public review and comment for a 30-day period beginning June 18, 2020. The availability of both the draft plan and the final Consolidated Plan, Program Year 2020 Annual Action Plan, Citizen Participation Plan and Assessment of Fair Housing are advertised in the local newspaper and the complete documents are available for review on the County’s website: www.co.st-clair.il.us/departments/grants/development/Pages/default.aspx and in print form at the offices of the St. Clair County Intergovernmental Grants Department (19 Public Square, Suite 200, Belleville, Illinois 62220-1624), various public libraries, senior/community centers, and village/city halls throughout the County. It could be made available in a form accessible to people with impaired vision and to non-English speaking residents upon request. Public hearings to present and receive comments on the draft 2020—2024 Consolidated Plan/Program Year 2020 Annual Action Plan/Citizen Participation Plan/Assessment of Fair Housing/Section was held virtually on June 16, 2020 at 10:00 AM via Facebook St. Clair County Intergovernmental Grants Department page. Page 3 of 50 Finally, in order to produce this Assessment of Fair Housing, St. Clair County also directly reached out to several agencies and service providers in the jurisdiction and region who have expertise in affirmatively furthering fair housing. These organizations included: • The Metropolitan St. Louis Equal Housing and Opportunity Council • Land of Lincoln Legal Assistance Foundation • Living Independently Now Center • Chestnut Health Systems Page 4 of 50 ANALYSIS A. DEMOGRAPHIC SUMMARY TABLE 1: RACE/ETHNICITY St. Clair County, IL St. Louis, MO-IL Region Number Percent Number Percent Total Population 263,463 2,589,094 White 168,903 64.1% 1,925,442 74.4% Black/African-American 79,351 30.1% 508,359 19.6% Asian 3,751 1.4% 70,290 2.7% Hispanic 10,507 3.0% 78,700 3.9% SOURCE: ACS 2018 5-year estimates tables B02001 and B02001l TABLE 2: FOREIGN BORN NATIONAL ORIGIN (TOP 10 ST. CLAIR COUNTY NATIONS) St. Clair County, IL St. Louis, MO-IL Region Number % Total Population Number % Total Population Total Population 263,463 2,589,094 Mexico 1,804 0.68% 14,445 0.55% Philippines 719 0.22% 4,497 0.20% Vietnam 574 0.15% 4,292 0.28% China, excluding Hong Kong and Taiwan 350 0.14% 4,184 0.37% Korea 338 0.14% 2,915 0.16% India 285 0.13% 11,871 0.58% Germany 274 0.11% 2,866 0.15% England 261 0.10% 1,605 0.05% Canada 217 0.10% 9,381 0.11% Honduras 186 0.08% 897 0.14% SOURCE: ACS 2018 5-year estimates table B05006 Page 5 of 50 TABLE 3: LIMITED ENGLISH PROFICIENCY (TOP 10 ST. CLAIR COUNTY LANGUAGES) St. Clair County, IL St. Louis, MO-IL Region Number % Total Population Number % Total Population Total Population 263,463 2,589,094 Spanish or Spanish Creole: 1,959 0.74% 17,201 0.68% Vietnamese: 237 0.13% 2,225 0.15% Chinese: 233 0.07% 1,184 0.23% Thai: 171 0.07% 1,501 0.02% Korean: 124 0.07% 1,612 0.08% German: 100 0.06% 632 0.05% Tagalog: 95 0.05% 484 0.04% African languages: 81 0.04% 337 0.07% Japanese: 79 0.03% 3,671 0.02% Russian: 71 0.02% 5,459 0.07% SOURCE: ACS 2018 5-year estimates table B16001 TABLE 4: DISABILITY TYPE St. Clair County, IL St. Louis, MO-IL Region Number Percent Number Percent Civilian, non-inst population 262,528 2,589,094 Hearing difficulty 16,136 6.15% 151,118 5.84% Vision difficulty 16,942 6.45% 157,821 6.10% Cognitive difficulty 16,808 6.40% 156,715 6.05% Ambulatory difficulty 17,134 6.53% 158,828 6.13% Self-care difficulty 17,031 6.49% 158,584 6.13% Independent living difficulty 14,011 5.34% 131,002 5.06% SOURCE: ACS 2018 5-year estimates tables B99182, B99183, B99184, B99185, B99186, B99187 Page 6 of 50 B. SEGREGATION/INTEGRATION AND RACIALLY/ETHNICALLY CONCENTRATED AREAS OF POVERTY B. SEGREGATION/INTEGRATION AND RACIALLY/ETHNICALLY CONCENTRATED AREAS OF POVERTY 1. GEOGRAPHIC ANALYSIS MAP 1: RACE/ETHNICITY 2018 – ST. LOUIS, MO-IL REGION Page 7 of 50 MAP 2: RACE/ETHINICITY 2018 – ST. CLAIR COUNTY Page 8 of 50 MAP 3: RACE/ETHNICITY 2010 – ST. LOUIS, MO-IL REGION (2010 R/ECAPS) Page 9 of 50 MAP 4: RACE/ETHNICITY 2010 – ST. CLAIR COUNTY (2010 R/ECAPS) Page 10 of 50 MAP 5: NATIONAL ORIGIN – ST. CLAIR COUNTY Page 11 of 50 MAP 6: LIMITED ENGLISH PROFICIENCY – ST. CLAIR COUNTY Page 12 of 50 TABLE 5: R/ECAP RACE/ETHNICITY St. Clair County, IL St. Louis, MO-IL Region Number Percent Number Percent Total Population in R/ECAPs 33,643 94,248 White 1,384 4.1% 10,523 11.2% Black/African-American 31,649 94.1% 80,842 85.7% Asian 112 0.3% 242 0.3% Hispanic 1,436 4.3% 4,112 4.4% SOURCE: ACS 2018 5-year estimates tables B02001 and B02001l TABLE 6: R/ECAP TOP FOREIGN BORN NATIONAL ORIGIN St. Clair County, IL St. Louis, MO-IL Region Number % R/ECAPPopulation Number % R/ECAPPopulation Total Population in R/ECAPs 33,643 94,248 Mexico 74 0.22% 607 0.64% Philippines 15 0.04% 15 0.02% Vietnam 2 0.01% 42 0.04% China, excluding Hong Kong and Taiwan 0 0.00% 9 0.01% Korea 6 0.02% 13 0.01% India 0 0.00% 38 0.04% Germany 8 0.02% 15 0.02% England 0 0.00% 0 0.00% Canada 38 0.11% 54 0.06% Honduras 0 0.00% 36 0.04% SOURCE: ACS 2018 5-year estimates table B05006 TABLE 7: R/ECAP TOP LIMITED ENGLISH PROFICIENCY St. Clair County, IL St. Louis, MO-IL Region Number % R/ECAPPopulation Number % R/ECAPPopulation Total Population in R/ECAPs 33,643 94,248 Spanish or Spanish Creole: 73 0.22% 845 0.90% Vietnamese: 147 0.44% 559 0.59% Chinese: 147 0.44% 454 0.48% Thai: 0 0.00% 4 0.00% Korean: 0 0.00% 7 0.01% German: 0 0.00% 30 0.03% Tagalog: 0 0.00% 4 0.00% African languages: 28 0.08% 379 0.40% Japanese: 12 0.04% 12 0.01% Russian: 0 0.00% 2 0.00% SOURCE: ACS 2015 5-year estimates table B16001. 2015 is the most recent year available for this data set at the tract level. Page 13 of 50 There are three St. Clair R/ECAP areas as identified by HUD. These are: • The downtown East St. Louis area, consisting of Census Tracts 5009, 5011,5012 5045, and 5046 and including portions of East St. Louis, National City, and Brooklyn. This R/ECAP has a low population density and is crossed by both highways and railroad tracks. • The Alorton/Centreville/Sauget/Cahokia area, consisting of Census Tracts 5025, 5026.03, 5027, and 5028. This recap has been expanded in the past 5 years. • The Washington Park area, consisting of Census Tracts 5004, 5005, and 5022; including portions of East St. Louis and Washington Park. This R/ECAP borders the Emerson Park neighborhood, which has seen significant transit-oriented development in the past 20 years, including professionally managed affordable housing and a new grocery store. • Eastern East St. Louis area bordering Fairview Heights. This R/ECAP is a new addition to the local list and consists solely of tract 5014. The R/ECAP areas in St. Clair County are clustered close together near the Mississippi river and the core of the St. Louis, MO-IL region. When planning for affirmatively furthering fair housing, it is also important to note areas with a high concentration of minority households that are not designated R/ECAPs. A striking example of this is Fairmont City, just north of East St. Louis and Washington Park, which can be seen in the maps above and which is predominantly Hispanic (with a good number of Limited English Proficiency residents who speak Spanish.) Additionally, there are many Hispanic households south of East St. Louis in Cahokia, and there is a high concentration of black/African-American households throughout East St. Louis, despite parts of eastern East St. Louis not being included in the R/ECAP areas. It is important that future investments in these potentially vulnerable areas bordering R/ECAPs are made in a way that builds off the assets and strengths of these neighborhoods to create mixed income areas of high opportunity. Page 14 of 50 2. DETERMINANTS OF SEGREGATION/R/ECAPS SIGNIFICANCE FACTOR / OF IMPACT ON DETERMINANT SEGREGATION BASIS FOR SELECTED SIGNIFICANCE LEVEL Land use and Land use and zoning laws, while significant on a regional level (for example, zoning laws requiring large residential lots to discourage affordable housing) do not seem to be zoning laws Not Significant the primary determinants of R/ECAPs in St. Clair County. In the past, residential real estate steering and redlining did play a role in the creation of segregated neighborhoods and R/ECAPs. However, while past Residential real damage remains, real estate steering is not as significant estate steering Not Significant today as many other factors, such as economic pressures. Patterns of community opposition Moderately Significant Community opposition in the form of NIMBYism continues to be a problem throughout the St. Louis, MO-IL region and St. Clair County. Economic pressures Highly Significant While R/ECAPs throughout the nation were often created through discriminatory policies such as redlining, currently economic pressures – such as unaffordable rents or land development costs – are highly significant in keeping R/ECAPs segregated. In St. Clair County, there are a number of economic pressures: 1) household housing cost burden is already high, preventing households from moving to higher rent areas outside R/ECAPs; 2) land development costs are high in low-to-moderate income neighborhoods, in part due to deteriorated infrastructure; 3) property taxes in many areas are high due to a lack of municipal tax base, discouraging development and making home ownership challenging to afford; and 4) uncertainties over future flood insurance requirements and associated costs discourages development in parts of St. Clair County where R/ECAPs are located Municipal or State services and amenities Highly Significant Due to historic disinvestment and insufficient municipal income, Infrastructure in low and low-moderate income areas of St. Clair County lags behind the rest of the jurisdiction. Existing infrastructure issues, such as storm water drainage problems and inadequate streets and sidewalks, increases the cost of developing new housing in these areas, and decreases the quality of life for those already living in these areas, further exacerbating patterns of segregation. Page 15 of 50 3. PUBLICLY SUPPORTED HOUSING TABLE 8: PUBLICLY SUPPORTED HOUSING IN ST. CLAIR COUNTY St. Clair County Number of Units Percent of Total Units Public Housing 3,004 2.51% Project Based Section 8 606** 0.51% Other Multifamily 278 0.23% Housing Choice Vouchers 2,578 2.15% Public Housing 3,004 2.51% SOURCES: HUD AFFH DATA SPREADSHEETS, *ACS 2018 5-YEAR ESTIMATES TABLE DP04 ** THIS NUMBER IS SIGNIFICANTLY LOWER THAN PREVIOUS HUD ESTIMATES AND MAY NOT BE ACCURATE TABLE 9: PUBLICLY SUPPORTED HOUSING BY RACE/ETHNICITY St. Clair County % White % Black/African- American % Hispanic % Asian Public Housing 6.10% 92.97% 0.47% 0% Project Based Section 8 30.62% 67.09% 0% 0% Other Multifamily 16.77% 82.06% 0.45% 0% Housing Choice Vouchers 10.99% 84.54% 1.93% 0% SOURCE: HUD AFFH DATA SPREADSHEETS TABLE 10: PUBLICLY SUPPORTED HOUSING IN R/ECAPS St. Clair County Units In R/ECAPs Total PubliclySupported Units Percent of PubliclySupported Units Public Housing 2,697 3,004 89.78% Project Based Section 8 408 606** 67.33% Other Multifamily 216 278 77.70% Housing Choice Vouchers 505 2,578 19.59% SOURCE: HUD AFFH Data Spreadsheets ** This number is significantly lower than previous HUD estimates and may not be accurate As seen in the tables above, a significant percentage of public housing units (90%) are located within R/ECAPs. Public housing residents are likely to be black/African-American and living in poverty, so public housing residents themselves contribute to a Census Tract being identified as an R/ECAP. Today, there are models and financing tools for developing public housing as part of larger, mixed-income communities including market rate housing, which helps deconcentrate poverty. However, many of the public housing projects in St. Clair County were originally developed in the 1960s and 1970s, and, given the demand for public housing units remains high and funds for rehabilitation and redevelopment are hard to come by, it is difficult to make significant changes. Page 16 of 50 MAP 7: PUBLICLY SUPPORTED HOUSING BY TYPE AND NUMBER OF UNITS Page 17 of 50 MAP 8: HOUSING CHOICE VOUCHER USE PATTERNS WITH R/ECAPS The map above shows that Housing Choice Voucher holders tend to be clustered in areas near R/ECAPs. Additionally, very few Housing Choice Voucher holders live in areas such as O’Fallon with stronger housing markets. The Cahokia area has a high percentage of Housing Choice Voucher holders. The proximity to public transportation and the affordability of housing are likely contributors to voucher holders choosing to live there. Page 18 of 50 There is a great demand for affordable housing in the St. Clair County, as demonstrated by the waiting lists for Public Housing and the Section 8 Housing Choice Voucher (HCV) Programs, as shown below in the wait list summary report by location and bedroom size for the Public Housing Program and the Section 8 HCVP as of May 31, 2020. As of the date of the report, there were 6,946 households on the Section 8 HCVP wait list (this is an unduplicated count). Although the Section 8 HCVP wait list is not separated by bedroom size needed (it is a single combined list), the number of families by number of bedrooms needed is tracked for planning and informational purposes and is provided below: TABLE 11: HOUSING CHOICE VOUCHER WAIT LIST (MAY 31, 2020) 1 BR 2 BR 3 BR 4 BR 5 BR 6 BR Total Number of Applicants(UnduplicatedCount) 2,801 2,320 1,435 333 52 5 6,946 SOURCE: St. Clair County Housing Authority SCCHA maintains a site-based waiting list for its Public Housing Program. There are eighteen (18) separate wait lists. Applicants can apply for as many locations as they desire, as long as they meet the occupancy designation requirements for the location and the location has units of appropriate size given family composition. For example, some locations are designated for senior citizens only (those applicants age 62 and older). Other designations include “Elderly only”, which targets applicants age 62 and older or applicants who have a disability, Non-senior disabled only, which are reserved for individuals under the age of 62 with a disability, and general occupancy or family developments. The waiting lists for the Public Housing Program also demonstrate a strong demand for affordable housing. Since applicants can be on multiple public housing waiting lists at the same time, the numbers shown at the bottom of the chart below as “Grand Totals” are inflated because of the duplicated counts. However, the numbers shown as “Totals” in the far-right column reflect the unduplicated count of applicants for that particular location. These numbers demonstrate a strong need for affordable housing in St. Clair County. Page 19 of 50 TABLE 12: PUBLIC HOUSING WAIT LIST BY LOCATION AND BEDROOM SIZE (MAY 31, 2020) 1 BR 2 BR 3 BR 4 BR 5 BR TOTAL ADELINE JAMES -CENTREVILLE 2 0 0 0 0 2 AMBER COURT BELLEVILLE 481 20 0 0 0 501 BEL PLAZA 2 -47TH ST 418 0 0 0 0 418 BEL-PLAZA 1 -CHURCH ST 362 0 0 0 0 362 BLUFFSIDE APARTMENTS 362 653 406 72 0 1,493 CLAYTON MANOR 428 164 99 30 0 721 ERNEST SMITH -CENTREVILLE 1,212 415 30 30 5 1,692 FULLERTON -SWANSEA 544 2 0 0 0 546 GARDENWOOD APARTMENTS 1,033 640 495 1 0 2,169 HAWTHORNE-ALORTON 1,216 716 291 37 1 2,261 HERITAGE MANOR 248 775 483 1 0 1,507 JEFFERSON SQUARE 2 1,463 4 0 0 1,469 LAKEVIEW APARTMENTS 493 370 235 0 0 1,098 PVT MATHISON -CENTREVILLE 1,252 590 115 32 0 1,989 RICKERT STATION 10 5 0 0 0 15 SMITHTON 225 13 388 29 0 655 THOMAS TERRY APARTMENTS 865 354 74 9 14 1,316 WASHINGTON PARK 603 514 7 0 0 1,124 GRAND TOTAL 10,084 6,949 2,628 241 20 19,223* SOURCE: St. Clair County Housing Authority * Includes 0 and 6 bedrooms, not represented in the table. Page 20 of 50 Siting decisions for LIHTC housing, including discretionary incentives in QAPs Community resistance to publicly supported housing in particular areas Siting decisions for LIHTC housing, including discretionary incentives in QAPs Community resistance to publicly supported housing in particular areas 4. DETERMINANTS OF SEGREGATION/R/ECAPS RELATED TO PUBLICLY SUPPORTED HOUSING SIGNIFICANCE FACTOR / OF IMPACT ON DETERMINANT SEGREGATION BASIS FOR SELECTED SIGNIFICANCE LEVEL Land use and zoning laws Not Significant Land use and zoning laws, while significant on a regional level (for example, zoning laws requiring large residential lots to discourage affordable housing) do not seem to be the primary determinants of siting public housing in St. Clair County. Siting decisions for Public Housing Moderately Significant Moderately Significant Moderately Significant Regional collaboration or the lack thereof Highly Significant The St. Louis region is a fragmented one, with many units of local government across two states, making coordinated investment decisions challenging. Recent regional planning efforts such as OneSTL and the Fair Housing Equity Assessment are a step in the right direction. Much of the public housing in St. Clair County is located near or within R/ECAPs. However, the majority of the public housing was built in the 1960s and 1970s – and therefore the siting decisions were also made in the past. Historically, LIHTC housing developments have tended to be clustered in low-to-moderate income urban core areas, which are also areas with large minority concentrations. There is a legitimate role for LIHTC investment in weak market, high poverty areas if the investment is geared toward rebuilding and catalyzing a private market. However, there has not historically been a balance of LIHTC affordable housing sited in more affluent or high opportunity neighborhoods. In recent years, however, the Illinois Housing Development Authority (IHDA) is moving toward a Qualified Allocation Plan (QAP) that preferences Areas of Opportunity in the hopes of deconcentrating affordable housing. Community opposition in the form of NIMBYism continues to be a problem throughout the St. Louis, MO-IL region and St. Clair County. Page 21 of 50 C. DISPARITIES IN ACCESS TO COMMUNITY ASSETS AND EXPOSURE TO ADVERSE COMMUNITY FACTORS C. DISPARITIES IN ACCESS TO COMMUNITY ASSETS AND EXPOSURE TO ADVERSE COMMUNITY FACTORS TABLE 13: ST. CLAIR COUNTY ACCESS AND EXPOSURE INDICES School ProficiencyIndex Job Access Index Labor Market Index Transit Index PovertyIndex Environmental Health Hazard Index Total Pop All 57 56 47 39 50 64 White 63 55 57 30 60 73 Black/African- American 46 54 29 55 32 45 Hispanic 53 59 42 34 43 56 Asian 62 59 62 26 64 75 Pop in Poverty All 47 54 28 52 28 46 White 59 57 46 36 49 69 Black/African- American 41 52 18 60 17 35 Hispanic 48 67 37 37 31 45 Asian 54 55 41 34 50 56 TABLE 14: REGIONAL ACCESS AND EXPOSURE INDICES (ONESTL FHEA) School ProficiencyIndex Job Access Index Labor Market Index Transit Index PovertyIndex Environmental Health Hazard Index Total Pop All 56 51 57 32 56 60 White 64 51 63 23 63 62 Black/African- American 27 49 32 64 31 56 Hispanic 52 54 55 37 52 59 Asian 66 59 72 40 67 60 Pop in Poverty All 38 52 38 50 34 39 White 53 53 50 29 49 50 Black/African- American 23 49 24 71 19 29 Hispanic 40 55 43 43 35 40 Asian 47 58 62 56 51 39 Page 22 of 50 1. DISPARITIES IN ACCESS TO COMMUNITY ASSETS EDUCATION MAP 9: ST. CLAIR COUNTY SCHOOL PROFICIENCY INDEX WITH R/ECAPS Page 23 of 50 MAP 10: REGIONAL SCHOOL PROFICIENCY INDEX (ONESTL FHEA) School proficiency index is measured on the block group level and uses elementary school data on reading and math state standardized test scores. It is important to note that standardized test scores give a very limited and incomplete picture of the quality of education available at any given school – and, in addition, many schools (such as magnet or charter schools) have larger district catchment areas and do not draw students from the immediate neighborhoods. Despite these measurement flaws, however, broad conclusions can still be drawn about access to high performing schools within St. Clair County. In general, children living in and around R/ECAPs are less likely to have access to a high performing school than children living in areas with higher home values such as the O’Fallon or Shiloh areas. Page 24 of 50 ACCESS TO JOBS MAP 11: ST. CLAIR COUNTY JOB ACCESS INDEX WITH R/ECAPS Page 25 of 50 MAP 12: REGIONAL JOB ACCESS INDEX (ONESTL FHEA) The job access index measures the accessibility of a neighborhood to job locations. It summarizes the accessibility of a given residential neighborhood as a function of its distance to all job locations, with distance to larger employment centers weighted more heavily. Jobs are distributed throughout St. Clair County, with major employers including Scott Air Force Base, Memorial Hospital, St. Elizabeth Hospital, and Southwestern Illinois College. Several R/ECAPs have higher job accessibility scores, most likely due to a combination of St. Clair County employers located near R/ECAPs (such as Casino Queen) and the fact that St. Clair County R/ECAPs are located near downtown St. Louis across the river in Missouri (downtown St. Louis is also accessible from East St. Louis via Metrolink light rail.) Unfortunately, however, the geographic proximity of jobs to a neighborhood does not mean that neighborhood residents are able to find employment, as shown in the maps on the following pages. Existing jobs may be unavailable (i.e. filled by commuters from other parts of the region) or may be out of reach to unemployed residents due to the need for additional skills building or job training programs. Page 26 of 50 MAP 13: ST. CLAIR COUNTY LABOR MARKET INDEX WITH R/ECAPS Page 27 of 50 MAP 14: REGIONAL LABOR MARKET INDEX (ONESTL FHEA) The labor market engagement index provides a summary description of the relative intensity of labor market engagement in a neighborhood based upon the level of employment, labor force participation and educational attainment. The areas with lowest labor market engagement index correspond with areas of high minority population and R/ECAPs. According to the 2013-2018 American Community Survey (S2301), 12,419 persons in St. Clair County are unemployed, equating to an overall unemployment rate of 9.5%. Additionally, out of the population 25 years and older, 7.8% do not have a high school diploma and 26.5% have either a high school diploma or GED but no college. These individuals could potentially benefit from job training or mentorship programs in order to enter the labor market or obtain a higher paying job. Page 28 of 50 IGD’s Employment and Training (ET) Group currently coordinates the Workforce Investment Act (WIA) Program in St. Clair, Clinton, Monroe, Randolph and Washington Counties. Local Workforce Area (LWA) #24 provides employment and training services through the Mid-America Workforce Investment Board, comprised of businesses, economic development, education, labor and community-based organizations, and partners in local One-Stop Centers. The partners include: ● St. Clair County Intergovernmental Grants Department, ● St. Clair County Housing Authority, ● St. Clair County Adult Education, ● Local Community Colleges, ● Programs and Services for Older Persons (operated by Southwest Illinois College), ● Illinois Department of Human Services (TANF), ● Illinois Department of Human Services (ORS), ● Illinois Department of Employment Security, and ● Members of local businesses that represent local hiring opportunities; which make up a majority of the Workforce Investment Board. Page 29 of 50 PUBLIC TRANSPORTATION MAP 15: ST. CLAIR COUNTY TRANSIT INDEX WITH R/ECAPS Page 30 of 50 MAP 16: REGIONAL TRANSIT INDEX (ONESTL FHEA) Public transportation in St. Clair County is provided via the St. Clair County Transit District and operated through a partnership with Metro Transit (Bi-State Development Agency). Metro Transit operates bus and Metrolink light rail service, with Metrolink serving key employment centers in St. Clair County such as Memorial Hospital and Scott Air Force Base as well as employment centers and points of interest in Missouri. R/ECAPs tend to be well-served by public transportation, and the existence of a public transportation infrastructure is an important asset to build from. However, as can be seen on the regional map, areas outside of the urban core – including areas with well- performing schools and large numbers of service, retail, and entry-level jobs – often are not well- served by public transportation, limiting the extent to which public transportation can serve as a reliable bridge between high poverty and low poverty areas. Additionally, bus service is infrequent late at night when shift workers may be going to work or returning home, and public safety concerns may discourage people from walking to and from transit stations after dark. Page 31 of 50 2. EXPOSURE TO ADVERSE COMMUNITY FACTORS EXPOSURE TO NEIGHBORHOOD POVERTY MAP 17: ST. CLAIR COUNTY POVERTY INDEX WITH R/ECAPS Page 32 of 50 MAP 18: REGIONAL POVERTY INDEX (ONESTL FHEA) The HUD poverty index depicted in the maps above captures the depth and intensity of poverty in a given neighborhood by measuring both family poverty rates and public assistance receipts. The lowest values on the poverty index (shown in yellow on the maps) correspond with high family poverty rates and high percentages of public assistance recipients. These high poverty areas also tend to correspond to R/ECAPs. The St. Clair County Access and Exposure Indices demonstrates some of the racial and ethnic disparities in exposure to poverty. In St. Clair County, white persons have a poverty exposure index of 60, while black/African-American persons have a poverty exposure index of 32 and Hispanics a poverty exposure index of 43. It is important to note that racial and ethnic disparities in the poverty exposure index do not go away even when controlling for family poverty levels. In St. Clair County, white families under the poverty line have a poverty exposure index of 49, which is still significantly higher (i.e., less poor) than black/African-American families under the poverty line (exposure index of 17) and Hispanic families under the poverty line (exposure index of 31.) In other words, a poor white family in St. Clair County is more likely to live in a neighborhood with a mixture of incomes than a poor black/African-American family in St. Clair County, who are more likely to live in an area of highly concentrated poverty. Page 33 of 50 ENVIRONMENTAL HEALTH HAZARDS MAP 19: ST. CLAIR COUNTY ENVIRONMENTAL HAZARD INDEX WITH R/ECAPS Page 34 of 50 MAP 20: REGIONAL ENVIRONMENTAL HAZARD INDEX (ONESTL FHEA) The environmental health hazard index summarizes potential exposure to harmful toxins. Exposure is modeled as a function of the volume of toxic industrial releases from the EPA's Toxic Release Inventory, the EPA toxicity assessment of the release chemicals, and the distance to the toxic release facility. As is to be expected, areas around the urban core and heavy industrial areas have the lowest index measures (i.e., the highest potential health risk) and more rural areas have the highest index measures (i.e., the lowest potential health risk). In other words, persons living in the urban core are more likely to be affected by potential health hazards. Since R/ECAPs also tend to be located in the urban core, poor and minority populations are likely to be exposed to environmental health hazards (along with other population groups.) Page 35 of 50 3. DETERMINANTS OF DISPARITIES IN ACCESS TO COMMUNITY ASSETS AND EXPOSURE TO ADVERSE COMMUNITY FACTORS SIGNIFICANCE FACTOR / OF IMPACT ON DETERMINANT SEGREGATION BASIS FOR SELECTED SIGNIFICANCE LEVEL Presence and location of proficient schools Highly Significant School quality is important for individual success. Additionally, higher quality “in demand” schools and districts tend to drive up real estate prices in surrounding neighborhoods, potentially pricing County IGD can’t affect school/district quality, IGD can assist with affordability in desirable neighborhoods. School assignment policies Not Significant Availability, frequency, and reliability of public transportation Moderately Significant The availability of public transportation is a major asset within R/ECAPs. That said, infrequent service outside the urban core and later at night (for shift workers) prevents public transportation from serving as a reliable bridge between high poverty and low poverty areas. Location of employers Moderately Significant Regional collaboration or the lack thereof Highly Significant The St. Louis region is a fragmented one, with many units of local government across two states, making coordinated investment decisions challenging. Recent regional planning efforts such as OneSTL and the Fair Housing Equity Assessment are a step in the right direction. families out of asset-rich areas. While St. Clair There is no evidence that school assignment policies are a significant determinant above and beyond the presence and location of proficient schools. While employers are located throughout St. Clair County and the region, there is a need for additional job training to ensure that the existing workforce is prepared for available jobs as well as additional affordable housing near major employment centers. Page 36 of 50 D. DISABILITY AND ACCESS D. DISABILITY AND ACCESS According to 2013-2018 American Community Survey data on disability rates, 33,496 St. Clair County residents, or 13% of civilian, non-institutionalized persons, have a disability. Of these 33,496 residents, approximately 5.1% are youth under the age of 18, 20.9% are adults ages 1864, and 75.1% are seniors 65 years of age or older. For the purposes of the American Community Survey, residents who report having any one (or multiple) of six disability types (hearing difficulty, vision difficulty, cognitive difficulty, ambulatory difficulty, self-care difficulty, or independent living difficulty) are considered to have a disability. Additionally, approximately 10% of the persons on the SCCHA Public and income-restricted housing wait lists indicate that they have a disability (all SCCHA voucher and other multifamily housing is for seniors, which means the likelihood of a disability is much higher). The majority of these cases do not equate to the need for fully accessible units, but rather more commonly a need for a ground floor unit due to the inability to climb stairs on a regular basis due to health issues. There is considered to be a relatively low level of need for fully-accessible units related to wheelchair use (estimated at five percent (5%) of less of current applicants). The public housing resident population shows that approximately 34% of households report having a disability. 1. POPULATION PROFILE TABLE 15: DISABILITY TYPE St. Clair County, IL St. Louis, MO-IL Region Number Percent Number Percent Civilian, non-inst population 257,597 2,171,222 100% Hearing difficulty 8,735 3.39% 82,516 3.80% Vision difficulty 5,867 2.28% 53,068 2.44% Cognitive difficulty 11,439 4.44% 121,160 5.58% Ambulatory difficulty 19,322 7.50% 167,519 7.72% Self-care difficulty 7,293 2.83% 62,112 2.86% Independent living difficulty 11,532 4.48% 115,632 5.33% SOURCE: ACS 2018 5-YEAR ESTIMATES TABLE S1810 TABLE 16: PERSONS WITH DISABILITIES BY AGE RANGE St. Clair County, IL St. Louis, MO-IL Region Number Percent Number Percent Civilian, non-inst population 257,597 2,171,222 Under 5 with disabilities 164 0.06% 1,116 0.05% 5-17 with disabilities 1,870 0.73% 24,178 1.11% 18-64 with disabilities 18,031 7.00% 165,095 7.60% 65+ with disabilities 13,431 5.21% 130,266 6.00% SOURCE: ACS 2018 5-YEAR ESTIMATES TABLE S1810 Page 37 of 50 MAP 21: DISABILITY TYPES AND R/ECAPS As depicted in the map above, persons with disabilities in St. Clair County are geographically dispersed throughout the county. Areas on the map that appear to have a high concentration of persons with disabilities tend to correlate with areas of St. Clair County that have higher population density. Page 38 of 50 2. HOUSING ACCESSIBILITY TABLE 17: PERSONS WITH DISABILITIES IN PUBLICLY SUPPORTED HOUSING St. Clair County, IL Percent with Disability (Households) Public Housing 34% Project-Based Section 8 71% Other Multifamily 61% Housing Choice Voucher Program 39% SOURCE: St. Clair County Housing Authority Approximately ten percent of the persons on the wait lists (Public Housing and Section 8 HCVP) indicate that they have a disability, approximately the same amount who list themselves as elderly. All project-based Section 8 and Multifamily housing in St. Clair County is senior housing, which leads to what appears to be a disproportionately high percentage of households with disabilities. Computer software does not permit the extrapolation of exact numbers, but staff insight gained from experience indicates that the most common declared disability is in the “other” category. Many, if not most of these are related to mental health. “Mobility” impairment is the second most declared disability / accessibility. The majority of these cases do not equate to the need for fully accessible units, but rather more commonly a need for a ground floor unit due to the inability to climb stairs on a regular basis due to health issues. There is considered to be a relatively low level of need for fully-accessible units related to wheel-chair use (estimated at five percent (5%) of less of current applicants). Vision and hearing impairments are the least declared disabilities among applicants estimated at two percent (2%) or less of the applicant pool and, again, many of these applicants are not seeking or in need of units that have been modified with accessibility features to accommodate their disability. They simply note their disability on the application form. The public housing resident population is reflective of the applicant pool. Approximately twenty percent (20%) report having a disability. The percentage breakdown between “other”, mobility, vision and hearing is found by staff to be very similar to applicant population. SCCHA is operating under a Section 504 / ADA Accessibility Self-Evaluation and Accessibility Transition Plan that was professionally completed in September 2012. Most exterior areas at public locations have already been modified to meet ADA accessibility standards. Where the work has not yet been completed, it is planned for completion within the next one to three years, subject to fund availability. SCCHA’s overall housing inventory meets the minimum of five percent (5%) of units accessible to households with mobility impairments and two percent (2%) of units with modifications to accommodate applicants with vision and hearing impairments. As stated earlier, most of SCCHA’s public housing inventory was built more than fifty (50) years ago, when accessibility requirements were for the most part non-existent. Over the years, when SCCHA completed substantial renovations at a public housing property, it provided for the required accessibility standards. Unit conversions / modifications are “projected” under SCCHA’s Transition Plan at locations that have not yet undergone substantial rehabilitation. In addition to maintaining the required number of accessible units in its overall inventory, SCCHA, as required by law, affirmatively responds to individual resident requests for reasonable accommodation for unit modifications related to their disability. This is done on an on-going basis, with each request being Page 39 of 50 reviewed on a case-by-case basis. SCCHA has demonstrated its commitment to meet the accessibility needs of current residents in any manner reasonably possible. 3. INTEGRATION AND OLMSTEAD: ENABLING PERSONS WITH DISABILITIES TO LIVE IN APARTMENTS AND HOUSES INSTEAD OF INSTITUTIONS AND OTHER SEGREGATED SETTINGS There have been several court cases in recent years regarding the Olmstead Rule – or the extent to which persons with disabilities reside in segregated settings (i.e., psychiatric hospitals, developmental centers, board and care homes, nursing homes, etc.) instead of integrated settings (apartments, family homes, etc.). As a result there are multiple initiatives throughout the state to assist with integrating persons with disabilities into the community in supportive housing settings. For example, Chestnut Health Systems partners with the Illinois Department of Mental Health to prioritize individuals discharging from state operated facilities (segregated settings) into an appropriate setting in the community with supports to assure success. 4. DISPARITIES IN ACCESS TO COMMUNITY ASSETS AND EXPOSURE TO ADVERSE COMMUNITY FACTORS As depicted in Map 21, persons with disabilities in St. Clair County are geographically dispersed throughout the county. Areas on the map that appear to have a high concentration of persons with disabilities tend to correlate with areas of St. Clair County that have higher population density in general. As such, there is no reason to believe that persons with disabilities are systematically denied access to community assets or exposed to adverse community factors. That said, there is a need for more affordable, accessible housing in St. Clair County – especially in high opportunity, asset-rich areas – to ensure persons with disabilities continue to have a range of housing choices. Based on discussions with service providers, persons living with disabilities have a wide range of housing opportunities ranging from intensive settings to meet the high needs of persons with disabilities supported throughout the community. Those who require a less intense setting but may benefit from 24 hour protective oversight may qualify for supervised housing settings where staff are available around the clock in the event a person with disabilities requires support any time of day or night. For those individuals who can manage in a residential setting with minimal support where a community support worker visits weekly, a supported housing setting can work closely with individuals to assure their success in housing. Depending on the housing program benefits, rental subsidies may be available through the Continuum of Care (CoC) programs offered by HUD. In addition, agencies have partnered with public housing authorities (PHAs) to develop supportive housing for those with disabilities. Some of the programs available to communities for rental subsidies include HUD Section 811 projects, mainstream PHA housing choice vouchers, CoC projects consisting of rental assistance and supportive housing programs and rental housing support programs. Page 40 of 50 Many individuals and advocates encounter regulatory barriers in multiple communities. These barriers include new “crime free housing” efforts that have come under fire by local Fair Housing entities. These efforts in the form of local ordinances are being challenged because they have the potential to restrict individuals from accessing/maintaining housing. Communities that haven’t been educated often struggle with NIMBY (not in my backyard) issues and publicly express distain for these individuals residing in their communities. In rural areas of the state, many individuals with disabilities face barriers associated with low housing stock available throughout the community as well as transportation issues due to geography of communities making it difficult for individuals to reach much needed services. 5. DISABILITY AND ACCESS ISSUES DETERMINANTS SIGNIFICANCE FACTOR / OF IMPACT ON DETERMINANT SEGREGATION BASIS FOR SELECTED SIGNIFICANCE LEVEL Lack of assistance for housing accessibility modifications Moderately significant While assistance for accessibility modifications exists through St. Clair County IGD, the need outpaces the resources available. Lack of access to government services Not Significant Inaccessible public buildings, sidewalks, or other infrastructure Moderately Significant Due to historic disinvestment and insufficient municipal income, Infrastructure in low and low- moderate income areas of St. Clair County lags behind the rest of the jurisdiction. Existing infrastructure issues, such as storm water drainage problems and inadequate streets and sidewalks, increases the cost of developing new housing in these areas, and decreases the quality of life for those already living in these areas, further exacerbating patterns of segregation. Page 41 of 50 E. FAIR HOUSING COMPLIANCE AND INFRASTRUCTURE E. FAIR HOUSING COMPLIANCE AND INFRASTRUCTURE 1. UNRESOLVED CHARGES OR FINDINGS St. Clair County does not have any unresolved charges or letters of finding from HUD. 2. FAIR HOUSING OR CIVIL RIGHTS AGENCIES AND ORGANIZATIONS Fair housing and civil rights agencies and organizations operating within the St. Clair County jurisdiction outside of IGD that may assist in fair housing analysis and investigation, or who otherwise have expertise in affirmatively furthering fair housing for their clients, include: • The Metropolitan St. Louis Equal Housing and Opportunity Council • Land of Lincoln Legal Assistance Foundation • Living Independently Now Center • Chestnut Health Systems Additionally, the St. Clair County IGD supports a variety of fair housing activities. IGD also offers housing counseling and education and promotes fair housing throughout St. Clair County. Additionally, the Housing Resource Center (HRC) also operates under the IGD umbrella. HRC operates Continuum of Care Programs for the homeless and near homeless, as well as administers fair housing and other housing counseling and education efforts. 3. FAIR HOUSING COMPLIANCE AND INFRASTRUCTURE DETERMINANTS SIGNIFICANCE FACTOR / OF IMPACT ON DETERMINANT SEGREGATION BASIS FOR SELECTED SIGNIFICANCE LEVEL Unresolved violations of fair housing or civil rights laws Patterns of community opposition Support or opposition from public officials Lack of fair housing education Not Significant Moderately Significant Not Significant Moderately Significant St. Clair County does not have any unresolved charges or letters of finding from HUD. Community opposition in the form of NIMBYism continues to be a problem throughout the St. Louis, MO-IL region and St. Clair County. Public officials support affirmatively furthering fair housing, so this is not a significant factor. However, there is the risk of fair housing challenges arising from unintended consequences of policies such as “crime free housing ordinances” discussed earlier. While numerous fair housing education programs exist, the need for education -including education in languages such as Spanish for Limited English Proficiency residents of St. Clair County – remains. Page 42 of 50 FAIR HOUSING GOALS AND PRIORITIES A. SUMMARY OF GOALS TIME DETERMINANT GOAL PRIORITY FRAME METRIC Municipal or State services and amenities Address deteriorating infrastructure in low-to-moderate income areas High Ongoing Projects completed Lack of assistance for housing accessibility modifications Increase the supply of accessible housing units for persons with disabilities High Ongoing Projects completed Economic pressures Address lead based paint hazards to ensure existing affordable homes are safe and healthy for families High Ongoing Projects Completed Economic Pressures Support access to credit for affordable home ownership High Ongoing Projects Completed Economic Pressures Pursue coordinated anti-poverty strategies to alleviate economic pressures that contribute to continued segregation and lack of housing choice High Ongoing TBD Economic Pressures Prepare for uncertain future flood insurance requirements Medium Ongoing TBD Siting decisions for Public Housing While siting decisions made in the Low N/A N/A past are determinants, there is a high demand for public housing units and there is not enough funds available to redevelop these projects. Therefore, the HA addresses redevelopment projects on an annual basis, based on budgets. Siting decisions for LIHTC housing, including discretionary incentives in QAPs If rental housing investments are made, make an effort to align these investments with IHDA or OneSTL FHEA areas of opportunity Low N/A N/A Presence and location of proficient schools If rental housing investments are made, make an effort to align these investments with IHDA or OneSTL FHEA areas of opportunity Low N/A N/A Availability, frequency, and If rental housing investments are made, make an effort to align these investments with IHDA or Low N/A N/A Page 43 of 50 reliability of public transportation OneSTL FHEA areas of opportunity Location of employers Coordinate workforce investment activities to reduce the mismatch in worker skills and employer requirements Medium Ongoing Persons receiving assistance Patterns of community opposition Continue to provide coordinated fair housing education through IGD Medium Ongoing Track outreach/ education efforts and populations reached Lack of fair housing education Continue to provide coordinated fair housing education through IGD High Ongoing Track outreach/ education efforts and populations reached Regional collaboration or the lack thereof Participation in regional efforts such as the OneSTL plan and other future planning efforts. Medium Ongoing TBD B. GOAL DESCRIPTIONS ADDRESS DETERIORATING INFRASTRUCTURE IN LOW-TO-MODERATE INCOME AREAS The St. Clair County IGD will continue to annually provide municipalities and townships in St. Clair County with Community Development Block Grant funds to make public facility improvements in low and low-moderate income areas. These grants will improve streets, sidewalks, water and sewer lines, flood drainage improvements, new fire trucks/equipment and water towers. These improvements will assist in the stabilizing of low and low-moderate income areas. INCREASE THE SUPPLY OF ACCESSIBLE HOUSING UNITS FOR PERSONS WITH DISABILITIES Through the Community Development Block Grant, St. Clair County IGD provides grants to persons with disabilities to modify their homes to increase accessibility. Allowed modifications include interior and exterior ramps, doors, grab bars, installation of accessible baths or shower units, as well as other needed changes to make the disabled applicant’s home accessible. RESEARCH NEW “CRIME FREE HOUSING ORDINANCES” TO DETERMINE POTENTIAL FAIR HOUSING IMPACT While St. Clair County IGD does not have any jurisdiction over local “crime free housing ordinances,” the potential threat to fair housing requires that IGD track and understand these new policies. As such, IGD may further research these ordinances and the potential fair housing Page 44 of 50 consequences and through conversation with other political jurisdictions in the state of Illinois, if possible or appropriate, develop action steps accordingly. ADDRESS LEAD BASED PAINT HAZARDS TO ENSURE EXISTING AFFORDABLE HOMES ARE SAFE AND HEALTHY FOR FAMILIES Much of the housing stock in St. Clair County, especially in low and low-moderate income areas, was built before 1980 and thus has the potential for lead-based paint hazards. Families with children under six, the age group most susceptible to lead poisoning, sometimes must choose between affordable homes and healthy homes. St. Clair County completed its fifth lead hazard reduction grant from the U.S. Department of Housing and Urban Development. This grant was a 3-year 1.6 million dollar grant that was completed in September 2016. St. Clair County intends to continue addressing lead-based paint hazards through the following strategies: ● Evaluation—The St. Clair County Health Department, the Southern Illinois Healthcare Foundation, and the East Side Health District continued to conduct lead assessments, blood lead testing, and education. St. Clair County and the East Side Health District are partners in a grant with the Illinois Environmental Protection Agency for a U.S. Environmental Protection Agency (EPA) grant to distribute lead education materials and provide lead training to contractors. ● Education—The County continues to provide lead education, Chipper coloring books and brochures to the health departments to distribute to clients. The County also distributes lead hazard information through other partners, such as the Catholic Urban Programs, the Society of St. Vincent DePaul, St. Clair County Housing Authority, CDBG Operations Corporation and other non-profit housing and health agencies. These agencies used staff time to provide outreach and space to house the literature. ● General Housing Rehabilitation—The County’s Housing Rehabilitation Program opens its application process once a year based on available funding. Homeowners are able to apply for funding. The County Housing Rehabilitation Program application list is filled through a lottery system and there are no guarantees that households with EBL children will be chosen. However, once the County learns of EBL children or households with lead hazards, they become a priority. The County also continues to provide a low-interest loan program that is open year round. When a client is accepted into either the grant or low- interest loan program the County addresses lead hazards first. Since 1995 the County has submitted applications for HUD Lead Hazard Reduction Funds to address lead hazards in housing. ● Planning—There is still a significant need to reduce lead-based hazards in St. Clair County. St. Clair County has a higher rate of elevated blood lead levels than the United States as a whole. Furthermore, over half of St. Clair County housing units are at risk for lead-based paint hazards. Among housing units home to households with children age six and under, over 8,000 housing units are at risk for lead-based paint hazards. Because of these conditions, St. Clair County continues to apply for the lead hazard reduction grant from the Page 45 of 50 U.S. Department of Housing and Urban Development in order to continue addressing lead- based paint hazards and increasing access to housing without lead-based paint hazards. SUPPORT ACCESS TO CREDIT FOR AFFORDABLE HOME OWNERSHIP St. Clair County does not have the ability to regulate the private sector loan market, and there is little that can be done to increase access to traditional credit for low-income and minority home buyers in the private market. However, the County’s HOME program offers loans and grants directly to homebuyers to help with associated closing costs and down payments. In this program, lending institutions are encouraged to provide financing to potential homebuyers. The County requires that extremely low-, low-and moderate-income homebuyers receive approved homebuyer counseling services to participate in its homeowner assistance program. The County will continue to utilize both existing nonprofit organizations and new groups to provide additional counseling services for budgeting, home purchase and maintenance, as well as fair housing counseling. The County has, and will continue, to make a concerted effort to market this assistance to low-moderate income clients. Additionally, St. Clair County IGD promotes credit access by referring individuals to Justine Petersen for credit services. PURSUE COORDINATED ANTI-POVERTY STRATEGIES TO ALLEVIATE ECONOMIC PRESSURES THAT CONTRIBUTE TO CONTINUED SEGREGATION AND LACK OF HOUSING CHOICE While many factors related to poverty are beyond the control of County government, the County is committed to addressing poverty issues and improving the welfare and economic status of its residents wherever possible. Some of the services described in this plan are devoted primarily to helping those in poverty. Some, like Homeless Services, are basic elements of the “safety net” geared to those in most need. Others, like promotion of home ownership, job creation and education, are more fundamental to the long term reduction of poverty. During the 2020-2024 Strategic Plan period, St. Clair County will undertake a number of initiatives that are consistent with the long-term approach to reducing poverty levels. The County will continue to allocate funding to public service activities through the CDBG program for the Housing Resource Center and other social service agencies. Other CDBG and HOME funded activities will assist lower income persons through such activities as home repair, homeownership assistance, public facilities infrastructure, and a senior/disabled person home accessibility improvement program. All of these activities benefit lower income persons and serve to improve their economic status and well-being. CDBG funds will also be allocated for business development supported activities resulting in the creation or retention of jobs which will be made available to low and moderate income persons. In addition, IGD administers the Community Services Block Grant (CSBG); Low Income Home Energy Assistance Program (LIHEAP); Weatherization Assistance Program; HUD Continuum of Care grants in conjunction with the St. Clair County Homeless Action Council; and Workforce Investment Opportunity Act (WIOA) programs. These grants provide funds for energy bill assistance, medical care, rental assistance, mortgage assistance, employment counseling and training, as well as housing repairs, housing rehabilitation, fair housing counseling, homebuyer Page 46 of 50 assistance and counseling, housing accessibility grants and other programs that meet the needs of extremely low, very low, low and moderate-income people in the community. PREPARE FOR UNCERTAIN FUTURE FLOOD INSURANCE REQUIREMENTS Residential investment in the American Bottoms area is threatened due to uncertainties over future flood insurance requirements. The Southwestern Illinois Flood Prevention District Council (FPD Council) was formed in July 2009 by Madison, Monroe and St. Clair counties in direct response to the Federal Emergency Management Agency’s (FEMA) announcement of its intention to deaccredit the 74-mile levee system protecting the St. Louis Metro East region. FEMA’s decision would effectively designate substantial portions of the American Bottom area of Southwestern Illinois as a Special Flood Hazard Area (SFHA) on new flood insurance rate maps. If issued as final maps, this classification would require all property owners – residents and businesses – to purchase flood insurance in order to get a mortgage. In order to address this potential challenge, regional leaders successfully sought authorization from the Illinois General Assembly to impose a ¼ percent sales tax to pay for any necessary improvements to the levee system and created independent Flood Prevention Districts (FPDs) within each county with the authority to collect the tax. Work on these improvements is currently underway. The FPD Council was formed by the three county FPDs as a joint venture to protect the lives, property and the economic vitality of the St. Louis Metro East region. IF RENTAL HOUSING INVESTMENTS ARE MADE, MAKE AN EFFORT TO ALIGN THESE INVESTMENTS WITH IHDA OR ONESTL FHEA AREAS OF OPPORTUNITY As is the case in many communities within the St. Louis, MO-IL Metro Area (the area for which Fair Market Rents are calculated), affordable housing rents are similar to market rate rents. As such, in many areas of St. Clair County, strategies focused on the preservation of existing affordable rental housing will often be more appropriate than strategies focused on the production of new affordable rental housing (since new affordable rental housing will not necessarily offer a lower cost housing option than the private market.) Additionally, affordable market rate rents allow St. Clair County to focus on strategies that preserve affordable home ownership: for example, home improvement assistance programs are in high demand and were cited during public meetings as high priority needs. In areas or situations where affordable rental housing development is appropriate – for example, to increase rental housing quality and safety, replace functionally obsolete housing, catalyze private market investment, and provide affordable rental options in stronger-market, high-opportunity communities – the Illinois Housing Development Authority offers financing tools for rental housing preservation and production to private developers. For all these reasons, St. Clair County IGD does not currently have plans to support rental housing during the 2020-2024 Consolidated Plan timeframe. However, if rental housing investments are made, St. Clair County IGD will make an effort to align these investments with IHDA or OneSTL FHEA areas of opportunity to ensure there is not a further concentration of publicly supported affordable housing. Page 47 of 50 COORDINATE WORKFORCE INVESTMENT ACTIVITIES TO REDUCE THE MISMATCH IN WORKER SKILLS AND EMPLOYER REQUIREMENTS IGD’s currently coordinates the Workforce Investment Opportunity Act (WIOA) Program in St. Clair, Clinton, Monroe, Randolph and Washington Counties. Local Workforce Area (LWA) #24 provides employment and training services through the Mid-America Workforce Investment Board, comprised of businesses, economic development, education, labor and community-based organizations, and partners in local One-Stop Centers. The partners include: ● St. Clair County Intergovernmental Grants Department, ● St. Clair County Housing Authority, ● St. Clair County Adult Education, ● Local Community Colleges, ● Programs and Services for Older Persons (operated by Southwest Illinois College), ● Illinois Department of Human Services (TANF), ● Illinois Department of Human Services (ORS), ● Illinois Department of Employment Security, and ● Members of local businesses that represent local hiring opportunities; which make up a majority of the Workforce Investment Board. Page 48 of 50 CONTINUE TO PROVIDE COORDINATED FAIR HOUSING EDUCATION THROUGH IGD St. Clair County follows policies and procedures that promote fair housing by ensuring outreach to all potentially eligible households, especially those least likely to apply for assistance. The County markets all programs, including housing rehabilitation and down payment assistance, in a manner consistent with affirmative marketing principles. ● The County will inform the public through the following, including, but not limited to: newspaper advertisements, websites, or other public notices, statements about Federal fair housing laws and our affirmative marketing policy included in program descriptions, lottery drawings, brochures, public hearings, Request for Proposals, contracts with developer/owners, notices to the Public Housing Authority and agencies providing programs and services to persons with special needs. ● The County will require each developer of HOME-assisted housing to adhere to these requirements and practices in order to carry out our affirmative marketing procedures and requirements. ● The County will require developers to use prescribed procedures to inform and solicit applications from persons in the housing market areas who are least likely to apply for the housing without special outreach ● The County will review affirmative marketing actions for compliance with all requirements. St. Clair County’s specific efforts to affirmatively market and further fair housing will include: ● Assist the Homeless Action Council (HAC) and will work with the Continuum of Care (COC) toward implementing the 10-year plan to end homelessness, coordinating HUD grant activities with HAC members. ● Provide CDBG funds to assist the Housing Resource Center (HRC) as a Public Service Project. ● Discuss the Fair Housing Act during annual plan hearings. ● Include fair housing as a topic in training sessions with area lenders and realtors during annual Homebuyer Assistance Meetings sponsored and conducted by the Community Development Group of IGD. ● Provide CDBG-funded accessibility grants for disabled persons. The County will continue to provide services to elderly and disabled persons referred by Living Independently Now Corporation (LINC), Division of Rehabilitation Services (DORS), and Programs and Services for Older Persons (PSOP). ● Provide various program brochures in Spanish. Page 49 of 50 PARTICIPATION IN REGIONAL EFFORTS SUCH AS THE ONESTL PLAN AND OTHER FUTURE PLANNING EFFORTS St. Clair County IGD commits to thinking regionally about how best to affirmatively further fair housing and participate in regional planning efforts such as OneSTL (which is complete) or similar future efforts. This Assessment of Fair Housing itself is a step toward a more comprehensive and regional approach to affirmatively furthering fair housing. The tables and maps in this assessment include comparisons of St. Clair County to the St. Louis, MO-IL region and are designed to align with the OneSTL Fair Housing Equity Assessment for the region. Page 50 of 50