Desert Hot Springs City Council
November 1, 2022

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Table B-9
City of Desert Hot Springs
Disabled Householders: 2015-2019
Household Disability Status Number Percent
Households with one or more persons with a disability 2,760 26.3% Households with no persons with a disability 7,716 73.7% Total 10,476 100.0%
Source: 2015-2019 American Community Survey 5-Year Estimates, Table B22010, Receipt of Food Stamps/SNAP in the Past 12 Months by Disability Status for Household

6. Limited English Proficiency (LEP) Protected Class
a. Background
LEP refers to a person’s limited ability to read, write, speak, or understand English. Individuals who are LEP are not a protected class under the federal Fair Housing Act. Nonetheless, the Act prohibits housing providers from using LEP selectively based on a protected class or as a pretext for discrimination because of a protected class. The Act also prohibits housing providers from using LEP in a way that causes an unjustified discriminatory effect. b. LEP Households
A “Limited English speaking household” is one in which no member 14 years old and over (1) speaks only English at home or (2) speaks a language other than English at home and speaks English “Very well.”
Respondents were asked to indicate their English-speaking ability based on one of the following categories: “Very well,” “Well,” “Not well,” or “Not at all.” Those who answered “Well,” “Not well,” or “Not at all” are sometimes referred to as “Less than ‘very well.’” After data are collected for each person in the household, the limited English-speaking household variable is calculated by checking if all people 14 years old and older speak a language other than English. If so, the calculation checks the English-speaking ability responses to see if all people 14 years old and older speak English “Less than ‘very well.’” If all household members 14 and over speak a language other than English and speak English “Less than ‘very well,’” the household is considered part of this group that may be in need of English language assistance.

There are an estimated 751 limited English speaking households residing in Desert Hot Springs.

The vast majority –90% - of limited English speaking households speak Spanish.

Refer to Table B-10 for data on the number and percentage of limited English speaking households.

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Table B-10
City of Desert Hot Springs
Limited English Speaking Households: 2015-2019
Households Speaking
Limited EnglishSpeaking HouseholdsPercent of all Limited EnglishSpeaking Households Spanish 676 90.0%
Other Indo-European Languages 94 1.2%
Asian and Pacific Island Languages 52 6.9%
Other Languages 14 1.9%
Total 751 100.0%
Source: U.S. Census Bureau; American Community Survey, 2015-2019 5-Year Estimates, Table B16002, Household Language by Household Limited English Speaking Status c. Primary Language
In California, “primary language” is a protected class. Primary language means that people whose first language is not English are protected from housing discrimination. Tenants have the right to use their preferred language and private housing providers do not have to provide a translator, but they must speak with a translator if the tenant has one. Tenants whose first language is not English should not be treated differently, harassed, or refused housing/services.

7. Source of Income Discrimination
The California Fair Employment and Housing Act (FEHA) protects people from housing discrimination. The latest amendment to the law regarding source of income protections adds people using a federal, state, or local housing subsidy to this list of protected groups. This means, beginning on January 1, 2020, housing providers, such as landlords, cannot refuse to rent to someone, or otherwise discriminate against them, because they have a housing subsidy, such as a Section 8 Housing Choice Voucher, that helps them to afford their rent.

The new law prohibits discrimination against any applicant because the applicant is using a federal, state, or local housing subsidy to assist with paying rent. Section 8 Housing Choice Vouchers, the HUD- VASH program, Homelessness Prevention and Rapid Re-Housing Programs, Housing Opportunities for Persons with AIDS and security deposit assistance programs, among others, all fall within the scope of the new law’s protection. This list of protected subsidies also includes locally funded subsidy programs created by cities, counties and public agencies to address growing homelessness.

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E. DEFINING THE REGION FOR CITY TO REGION COMPARISONS

1. HUD’s CBSA “Region”
The HUD Index of Dissimilarity data and access to opportunity indicators define a Region based on the United States Office of Management and Budget (OMB) Core Based Statistical Areas (CBSAs) definition. The OMB defines a Core Based Statistical Area as one or more adjacent counties or county equivalents that have at least one urban area of at least 10,000 people plus adjacent territory that has a high degree of social and economic integration with the core as measured by commuting ties.

The “Region,” for purposes of HUD’s tables, indices, and dot density maps, encompasses all the cities and unincorporated communities located in Riverside and San Bernardino Counties, a vast geographic area of some 27,408 square miles. The distance from the city halls of Blythe (Riverside County) and Ontario (San Bernardino County) is 188 miles, a 3 hour drive. The distance from the city halls of Needles (San Bernardino County) and Rancho Cucamonga (San Bernardino County) is 215 miles, a 3 and 1/2 hour drive.

2. Council of Governments Regions
Three “regional” governments operate in this vast Region used by HUD in its assessment of fair housing tables.

The San Bernardino Associated Governments (SANBAG) is an association of local San Bernardino governments and includes 25 member jurisdictions. The “region” includes four distinct sub regions: desert, mountain, east valley and west valley.

The Western Riverside Council of Governments (WRCOG) includes representatives from 17 cities, the Riverside County Board of Supervisors, the Eastern and Western Municipal Water Districts, and the Morongo Band of Mission Indians.

The Coachella Valley Association of Governments (CVAG) is a California joint powers authority made up of the cities of Blythe, Cathedral City, Coachella, Desert Hot Springs, Indian Wells, Indio, La Quinta, Palm Desert, Palm Springs, and Rancho Mirage; the County of Riverside; and two Indian Tribes: Agua Caliente Band of Cahuilla Indians and Cabazon Band of Mission Indians.

3. TCAC/HCD’s Inland Empire Region
This Region includes the counties of Riverside and San Bernardino and the non-rural areas of Imperial County.

The former chief demographer for the County of Riverside explained to the City’s consultant that a question exists regarding the meaningfulness and applicability of the TCAC/HCD Opportunity Mapping Tool to the City of Desert Hot Springs as currently calculated. The primary issue is the size of the metropolitan area which includes the Counties of Riverside and San Bernardino plus portions of Imperial County. As has been noted this is an area of over 27,000 square miles. This is an area that is larger than many states or, to put it into perspective, it is 3,000 square miles larger than West Virginia the state with the closest land mass to this three-county area.

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Also, Desert Hot Springs is located in the Coachella Valley an area that does not associate itself with the Inland Empire, which is more an identity of the western region of this two County area, which is more directly linked to the Los Angeles and Orange County metropolitan area. Even within the Coachella Valley, there is a cluster of cities from Palm Springs to Coachella, while Desert Hot Springs sits alone nearly 11 miles away from its closest neighbor Palm Springs.

4. Riverside County
Riverside County is roughly divided into eastern and western halves by the San Jacinto and Santa Rosa Mountains. A deep valley known as the San Gorgonio Pass, framed by the San Jacinto and San Gorgonio Mountains, creates an accessible corridor linking these two halves. The San Bernardino and Little San Bernardino Mountains form a portion of the northern boundary while numerous mountain ranges, including those in the Santa Rosa Wilderness and Cleveland National Forest, among others, serve as boundaries along the southern and western edges of the county. These eastern and western halves of the county are distinguished by their physical characteristics as well as their historic growth patterns.

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Exhibit B-1
San Bernardino Associated Governments

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Exhibit B-2
Western Riverside Council of Governments

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Exhibit B-3
Coachella Valley Cities and Spheres of Influence

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Exhibit B-4
City of Desert Hot Springs and Sphere of Influence

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The western portion of the county is roughly half the size of the eastern half and is bounded by the Santa Ana Mountains and Cleveland National Forest on the west and the San Jacinto Mountains and the San Bernardino National Forest on the east. Compared to eastern Riverside County, the western portion of the county contains the greatest concentration of population and has experienced the greatest growth pressures. The majority of this population is concentrated in the incorporated cities of Corona, Riverside, Beaumont, Banning, Norco, Lake Elsinore, Perris, Hemet, San Jacinto, Moreno Valley, Calimesa, Canyon Lake, Murrieta, and Temecula.

The eastern portion of Riverside County is bounded by the Colorado River on the east and the Santa Rosa and San Jacinto Mountains on the west. This portion of the county is distinguished from the western portion of the county by its desert terrain and relatively less populated and congested communities. The vast majority of eastern Riverside County's population is concentrated in the Coachella Valley.

The Joshua Tree National Park, known for its rich desert habitat, forms a permanent natural boundary at the northern end of the Coachella Valley. The Whitewater River, a seasonal river which forms in the San Bernardino Mountains, flows through the Coachella Valley and eventually into the Salton Sea at the Valley’s southern end. The City of Blythe is located in the Palo Verde Valley along the Colorado River, which provides the source for one of the most productive agricultural regions in the county.

5. The Ideal Region
Because of the vast geography encompassed by “Regions” described above and the differences in the characteristics between Riverside County and San Bernardino County and between western Riverside County and the Coachella Valley, no ideal “region” exists for purposes of comparing Desert Hot Springs to the “region.”
The ideal region would be the Coachella Valley if all the appropriate data were produced for this geographic area as an entity. However, data pertaining to fair housing issues are limited for this ideal region.

Consequently, by default the City has selected different regions based on the data available:

CBSA, Riverside County, and Coachella Valley.

F. SEGREGATION/INTEGRATION ANALYSIS
For the purposes of the AFFH rule, “segregation” “means a condition in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area. 24 C.F.R. § 5.152 [emphasis added} For the purposes of the AFFH rule, “integration” “means a condition in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin,

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or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area. 24 C.F.R. § 5.1522 [emphasis added] The AFFH rule does not define the meanings of “high concentration” and “not high concentration”.

1. Diversity Index
HCD’s AFFH Data Viewer provides diversity index maps for 2010 and 2018 populations by block group. According to Esri Demographics, the diversity index summarizes racial and ethnic diversity. The index shows the likelihood that two people, chosen at random from the same area, belong to different racial or ethnic groups. The index ranges from 0 (no diversity) to 100 (complete diversity). For example, a diversity index of 59 means there is a 59 percent probability that two people randomly chosen would belong to different race or ethnic groups.

As shown in Exhibit B-5, in 2010, most of the City had relatively high diversity (diversity index 70- 85). Census tract 445.17, on the northern City boundary, scored lower on the diversity index (48.6), which overlaps with the Mission Lakes Country Club. The highest diversity index scores were seen in two block groups (445.072, 445.102) in the central City along Palm Drive.

In 2018, most of the City remained in the same range for diversity index (70-85) as 2010, and CT 445.17 still had a lower score of 55.3. However, more areas in the central City saw higher diversity index scores (above 85) along Palm Drive and to the west. The City has become more diverse from 2010 to 2018. Compared to other cities in the western Coachella Valley, Desert Hot Springs has overall higher diversity index ratings throughout the City.

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Exhibit B-5
City of Desert Hot Springs Diversity Index (2010) – Block Group

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Exhibit B-6
City of Desert Hot Springs Diversity Index (2018) – Block Group

6.2. Dissimilarity Index Measures Segregation/Integration a. Explanation of Dissimilarity Index
The Dissimilarity Index, according to HUD’s Assessment of Fair Housing Tool for Local Governments, measures the degree to which two groups are evenly distributed across a geographic area and is a commonly used measure for assessing residential segregation between two groups. The analysis is typically conducted for a city or county based on the racial and ethnic distribution of the population within the census tracts that comprise the jurisdiction. A census tract is a standardized geographic unit with a population of approximately 4,000. Census tracts provide a standardized geographic unit to report census data and compare change over time. The boundaries of census tracts remain the same from one census to the next and only change if there is a major increase or decrease in the population.

The values of the Dissimilarity Index range from 0 to 100. An index value of 0 indicates that a city is completely integrated when measuring for example the distributions of Whites and Blacks, while an index value of 100 indicates the city is completely segregated. The value of the Dissimilarity

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Index is based on the proportion of the two groups within each census tract relative to the distribution of the two groups in the city. It is not based on the proportion of the two groups within the city. Table B-11 provides an example that helps to explain the DI.

In each of these hypothetical cities, there are 15,600 Whites (97.5%) and 400 Blacks (2.5%).

Because of the small proportion (2.5%) of Blacks, these cities could be labelled as “segregated.” However, the Dissimilarity Index for these cities ranges from 0 to 100.

Table B-11
Dissimilarity Index Example
City A City B City C
Census Tract White Black White Black White Black
100 3,900 100 0 200 0 200
101 3,900 100 0 200 3,900 100
102 3,900 100 7,800 0 3,900 100
103 3,900 100 7,800 0 7,800 0
Total 15,600 400 15,600 400 15,600 400
Dissimilarity Index 0 100 50
The difference in the values of the Dissimilarity Index is based on the distribution of the White and Black populations within each of the census tracts. In City A with a Dissimilarity Index of 0, the proportion of Whites and Blacks in each census track is the same. In City B with a Dissimilarity Index of 100, all the Whites are in two census tracts and all the Blacks are in two census tracts.

In City C with a Dissimilarity Index of 50, there is one census tract that is exclusively Black, one census tract that is exclusively White, and two tracts where the proportion of Blacks to White is the same and is relative to the city’s proportion of the two groups.

HUD suggests that a Dissimilarity Index value of less than 40 generally indicates low segregation, while values between 40 and 54 generally indicates moderate segregation, and values between 55 and 100 generally indicates a high level of segregation, as shown in Table B-12.

Table B-12
Levels of Segregation
Dissimilarity
Index Value Level of Segregation
< 40 Low Segregation
40 - 54 Moderate Segregation
> 54 High Segregation
b. Regional Dissimilarity Index
As previously explained, HUD’s “regional” dissimilarity index encompasses all the cities and unincorporated communities located in Riverside and San Bernardino Counties.

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HUD data shows that the Region currently experiences a Moderate Level of Segregation among all four groups: Non-White/White, Black/White, Hispanic/White and Asian or Pacific Islander/White. The trends analysis shows that three groups moved from a low to moderate segregation level between 1990 and 2010: Non-White/White; Hispanic/White; and Asian or Pacific Islander/White. Refer to Table B-13.

The Brown University database does not have a DI for Riverside County.

Table B-13
Riverside/San Bernardino Counties Region
Dissimilarity Indices: 1990, 2000, and 2010
Source: HUD Table 3, Racial/Ethnic Dissimilarity Trends HUD note below on Table 3:

In Table 3, the current dissimilarity indices for 2010 exclude multiracial individuals, while the 1990, 2000, and 2010 trend racial data from the Brown Longitudinal Tract Database includes multiracial individuals in the racial categories.

Data Source: Decennial Census, 2010; Brown Longitudinal Tract Database (LTDB) based on decennial census data, 2010, 2000 & 1990. Decennial Census data are Block-group level and LTDB data are census tract level. a.c.City of Desert Hot Springs Dissimilarity Index
Brown University has constructed Dissimilarity Indices for the nation’s cities for the same time period and using the same data sources as HUD. The Dissimilarity Indices for the City of Desert Hot Springs cover years 2000 and 2010. Data are unavailable for 1990.

Table B-14
City of Desert Hot Springs
Index of Dissimilarity
Groups 2000 2010
White-Black/Black-White 13.6 21.1
White-Hispanic/Hispanic-White 22.3 26.3
White-Asian/Asian-White 12.1 11.4
Black-Hispanic/Hispanic-Black 14.8 11.6
Black-Asian/Asian-Black 9.4 10.4
Hispanic-Asian/Asian-Hispanic 14.9 17.0
Source: Brown University
Racial/Ethnic Dissimilarity Index 1990 2000 2010
Non-White/White 32.92 38.90 41.29
Black/White 43.74 45.48 47.66
Hispanic/White 35.57 42.40 43.96
Asian or Pacific Islander/White 33.17 36.31 43.07

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All of the indices are at a low level of segregation. Consequently, the Dissimilarity Index reveals no significant segregation patterns between any two racial/ethnic groups is not a fair housing issue affectingin the City from 2000 to 2010.

Table B-15 shows the percentage distributions of the population by race and ethnicity in 2010 and 2015-2019. Because the racial/ethnic composition of the City in the 2015-2019 period is similar to that of 2010, the Dissimilarity Index should continue to show a low level of segregation during the 5-year period.

Table B-15
City of Desert Hot Springs
Population by Race and Ethnicity: 2010-2019
Race/Ethnicity 2010 2015-2019
Non-Hispanic White 34.4% 30.4%
Non-Hispanic Black 7.5% 9.2%
Hispanic 52.7% 54.5%
Asian 2.3% 3.0%
Other 3.1% 2.9%
Total 100.0% 100.0%
Source: U.S. Census 2010 and American Community 5-
Year Estimates 2015-2019
For Riverside County, the Hispanic population represents 48.9% of the total population while the non-Hispanic, White population comprises 35.3% of the total population.

The comparable figures for the Asian and Black/African American populations are 6.3% and 6.1%.

The City’s ethnic/racial composition does not deviate significantly from the County, and may have lower segregation levels compared to the County based on the Dissimilarity Index.

7.3. Isolation Index for Race and Ethnicity
a. Explanation of Isolation Index
The Isolation Index is the percentage of same-group population in the census tract where the average member of a racial/ethnic group lives. It has a lower bound of zero (for a very small group that is quite dispersed) to 100 (meaning that group members are entirely isolated from other groups). It should be kept in mind that this index is affected by the size of the group -- it is almost inevitably smaller for smaller population groups, and it is likely to rise over time if the group becomes larger.

By way of elaboration, the Isolation Index is a frequently used measure of residential segregation.

Conceptually, it is an “exposure measure” of segregation, meaning that it measures the degree of potential contact or possibility of interaction between the members of a racial or ethnic group with members of their and other racial and ethnic groups, or inversely the degree to which they are likely to interact only with members of their group.

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Scores are produced for combinations of racial and ethnic groups, such as White/Black and Hispanic/Asian. Scores can also be generated measuring the degree members of a racial or ethnic group live with members of their own racial and ethnic group. This combination of members of their own racial and ethnic group measures the degree to which people reside in a segregated neighborhood. These can be interpreted as saying, for example, the average Asian lives in a neighborhood that is X percent Asian.

The values of the Isolation Index range from 0 to 100. A value greater than 60 is often taken to mean “highly segregated;” a value between 40 and 60 is interpreted as being “moderately segregated;” while a value lower than 40 is interpreted as “not segregated.” However, there is no specific statistical standard for these category labels.

It should be kept in mind, as previously explained, that the index is affected by the size of the population group. Groups that represent a large portion of the total population will have higher scores, while those making up very small portions of the population will have lower scores. b. Desert Hot Springs Isolation Index
The figures below indicate that Hispanics live in areas that are population heavily by Hispanics. • Asian/Asian 3.4 Not segregated
• Black/Black 9.1 Not segregated
• White/White 39.6 Not segregated
• Hispanic/Hispanic 56.0 Moderately segregated
Thus, the average Hispanic lives in an area where over 56% of the residents are fellow Hispanics.

It needs to be kept in mind that Hispanics represent 55% of Desert Hot Spring’s total population.

According to the Neighborhood Segregation map (UC Berkeley, 2019) on the AFFH Data Viewer, most of the City consists of Latinx-White neighborhoods, while two census tracts (CT 445.09 and CT 445.10) are identified as 3 Group Mixed (Black-Latinx-White). Hispanic majority tracts were found in most developed areas of the City, with a sizeable gap of 10% to 50% in dominance value.

White majority tracts were found only in the northern City, with a relatively low dominance value of 16.04% though as high as 59.02% in CT 445.17 overlapping with the Mission Lakes Country Club. This could be a reflection of an overall increase in Hispanic population over the last decade in the City, as shown in Table B-1 above.

On the other hand, Asians and Blacks make up a very small portion (<10%) of the population, resulting in very low values. Whites who make up slightly over 30% of the population live in areas that have a proportion of Whites slightly greater than their share of the total population.

Specifically, the average White lives in an area where nearly 40% of the population is White.

Because the Isolation Index values are similar to the percentages of each group, n None of the population groups are considered to live in a heavily segregated neighborhood. This is consistent with the overall increase in non-White population throughout the City from 2010 to 2018, even including the northern portion, which saw an increase in diversity during this time

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period. The highest percentages of non-White populations are seen in tracts south of Pierson Boulevard and along Palm Drive.

8.4. Divergence Index for Race and Ethnicity
According to a UC Berkeley study:

The Divergence Index compares the relative proportions of racial groups (or any other groups) at smaller and larger geographies, looking for the degree of “divergence” between the two geographies, such as between a census tract and a county. For example, consider a census tract with the following racial distribution:
76% Black,

11.9% Latino,

9.3% White, and

2.8% Asian
Now what if that census tract is situated within a CBSA [Core Based Statistical Area] with the following racial distribution:

11.9% Black,

10.8% Latino,

66.7% White, and

10.6% Asian
Such a census tract will have a very high observed level of segregation as measured by the Divergence Index because it "diverges" so greatly from the surrounding region, especially in terms of the differences in proportion of Black residents. Indeed, the formula results show that this tract’s Divergence Index value is 1.21.

To calculate the metropolitan CBSA (county, or city) score, the scores for each tract in the region are added, but weighed by the tract’s population. In this case of the tract and region described above, the region’s CBSA Divergence Index score is 0.2642 as of 2010 (this happens to be the San Francisco-Oakland-Fremont CBSA).

The lowest possible value of the Divergence Index is "0" when the demographics of a geography does not differ, or diverge, from that of the larger geography, suggesting no segregation, whereas higher values suggest higher divergence, and hence higher segregation. As the Divergence Index is a relatively novel measure of segregation, as of yet, there is no established set of ranges to demarcate the level of segregation in the relevant academic literature.

Stephen Menendian, Arthur Gailes, Samir Gamhirt, The Roots of Structural Racism:

Twenty-First Racial Segregation in the United States, June 21, 2021, page 30 The Divergence Index calculates three levels of segregation:
§ High segregation
§ Low-medium segregation
§ Racially Integrated

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The UC Berkeley interactive mapping tool shows that Divergence Index Scores for Desert Hot Springs range from 0.0277 to 0.1594, with higher scores indicating higher segregation. The mapping tool reveals that the City has a low to medium segregation level and is racially integratedin 2020. The mapping tool also indicated that the segregation mainly occurs between the two largest racial groups in the City in 2020: Hispanic (61%) and White (28%).

9.5. Households with a Disabled Member
Table B-16 compares for each census tract –
§ The census tract percentage of all households residing in the City § The census tract number of households with a disabled member as a percentage of all the City’s households with a disabled member
The percentages are very similar, a fact that demonstrates there is not a high concentration of disabled householders residing in any given census tract. A high concentration would exist if, for example, the census tract number of households represented 20% of all the City’s households but the census tract had 40% all households with a disabled member.

Table B-16
City of Desert Hot Springs
Segregation/Integration Analysis of Households with a Disabled Member Census Tract
Households
w/ Disabled
Member
All
Households
Census Tract
Percentage1
Citywide
Percentage2
445.07 736 2,341 25.9% 28.5%
445.09 396 1,537 17.0% 15.3%
455.10 547 2,261 25.1% 21.2%
445.15 385 1,035 11.5% 14.9%
445.18 520 1,849 20.5% 20.1%
Total 2,584 9,023 100.0%
1Census tract total households as a percentage of all households within City (2,341/9,023) 2Households with disabled member as % of all households with disabled member (736/2,584) Source: 2015-2019 American Community Survey 5-Year Estimates, Table B22010, Receipt of Food Stamps/SNAP in the Past 12 Months by Disability Status for Households Note: ACS data is only available for entire Census Tracts regardless of the city boundary.

Therefore, the data in the above table only includes data for Census Tracts entirely within the City of Desert Hot Spring or where a majority of the Census Tract is within the City boundaries. As a result, the total household count of 9,023 is less than the city-wide total of 10,476.

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10.6. Households with Children (Familial Status)
Table B-17 shows the number and percentage of households with children living in each census tract. The table also shows the total number and percentage of all households living in each census tract.

The comparison of the percentages shows that they are very similar, a fact that demonstrates there is not a high concentration of households with children. As noted in preceding #6, a high concentration would exist if, for example, the census tract number of households represented 20% of all the City’s households but the census tract had 40% all households with children.

Table B-17
City of Desert Hot Springs
Segregation/Integration Analysis of Households with Children Census
Tract
Households
w/ Children
All
Households
Census Tract
Percentage1
Citywide
Percentage2
445.07 721 2,341 25.9% 26.9%
445.09 375 1,537 17.0% 14.0%
455.10 709 2,261 25.1% 26.4%
445.15 407 1,035 11.5% 15.2%
445.18 469 1,849 20.5% 17.5%
Total 2,681 9,023 100.0%
1Census tract total households as a percentage of all households within City (2,341/9,023)
2Households with children as % of all households with children (721/2,681) Source: U.S. Census Bureau; American Community Survey, 2015-2019 5-Year Estimates, Table DP02 Selected Social Characteristics
G. INTEGRATION/SEGREGATION BY INCOME (PATTERNS AND TRENDS) Income levels at the regional and local level are analyzed with respect to:
§ Median household incomes
§ Low and moderate income population
§ Income inequality

1. Median Household Incomes
Table B-18 shows that the median household income of Riverside and San Bernardino Counties increased by almost $10,000 and $8,000, respectively, between 2010-2014 and 2015-2019. By comparison, the City’s median household income actually dropped by $3,000 during the same period. In fact, the Desert Hot Springs median household income is 50% of Riverside County’s.

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Table B-18
Median Household Income by Area: 2010-2014 and 2015-2019 Area 2010-2014 2015-2019
Riverside County $57,768 $67,005
San Bernardino County $55,845 $63,362
Desert Hot Springs $36,326 $33,046
Source: American Community Survey 5-Year Estimates, Table B19013 Median Household Income Past 12 Months (in inflation adjusted dollars)
During the decade it appears that lower income households represented a large, if unknown, share of all households that moved to Desert Hot Springs. Poverty-level income households also contributed to the City’s low median household income. The Assessment of Fair Housing programs emphasize the need to implement poverty-reducing strategies.

2. Low/Moderate Income Population
Table B-19 presents HUD’s low /moderate income data for Riverside County and San Bernardino County for two periods: 2006-2010 and 2011-2015. HUD has not updated the data.

Table B-19
Low Mod Income Population by County
County
2006-2010 2011-2015
#Low/Mod
Low/Mod
Universe
Percent
Low/Mod #Low/Mod
Low/Mod
Universe
Percent
Low/Mod
Riverside 864,234 2,080,075 41.5% 914,600 2,264,300 40.4% San Bernardino 852,270 1,963,880 43.4% 894,835 2,043,435 43.8% Source: U.S. Department of Housing and Urban Development, 2006-2010 and 2011-2015 Low and Moderate Income Summary Data
During the two periods, the percentage of the population with low/moderate incomes barely changed. In 2011-2015, approximately 40% and 44% of Riverside County’s and San Bernardino County’s population had low/moderate incomes.

Low and moderate incomes refer to households with annual incomes that are less than 80% of the County median household income. In 2015, a 4-person low/moderate income household living in Riverside County had an income of $53,600.

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In contrast, approximately two-thirds of the City’s population had low/moderate incomes in both time periods. In 2011-2015, eight of the 13 block groups had a low/moderate income percentage higher than the city-wide average. Refer to Table B-20.

Future housing production consistent with the RHNA will gradually reduce the City’s low/moderate income percentage. The RHNA allocation by income group is as follows:
§ Above Moderate 54%
§ Moderate !18%
§ Lower 28%
Table B-20
City of Desert Hot Springs
Low/Mod Income Comparison 2006-2010 and 2011-2015
2006-2010 2011-2015
Census
Tract
Block
Group
Number
Low/Mod
Low/Mod
Universe
Percent
Low/Mod
Number
Low/Mod
Low/Mod
Universe
Percent
Low/Mod
445.07 1 1,125 2,125 52.9% 2,575 3,795 67.9%
445.07 2 2,120 3,490 60.7% 2,595 3,570 72.7%
445.09 1 2,850 4,070 70.0% 3,440 4,025 85.5%
445.10 1 1,250 2,275 54.9% 2,505 3,555 70.5%
445.10 2 1,790 2,765 64.7% 1,800 2,165 83.1%
445.15 1 2,420 3,170 76.3% 2,610 4,020 64.9%
445.16 1 1,525 2,480 61.5% 1,615 2,575 62.7%
445.16 2 2,770 3,760 73.7% 2,825 4,150 68.1%
445.17 1 780 1,745 44.7% 835 2,400 34.8%
445.18 1 1,180 2,145 55.0% 750 1,545 48.5%
445.18 2 2,060 3,315 62.1% 2,695 3,920 68.8%
445.21 1 515 1,015 50.7% 685 905 75.7%
445.22 1 2,785 4,575 60.9% 2,715 5,060 53.7%
Total 23,170 36,930 62.7% 27,645 41,685 66.3%
Source: U.S. Department of Housing and Urban Development, 2006-2010 and 2011-2015 Low and Moderate Income Summary Data

3. Income Inequality
The income gap between the rich and the poor has been rising in regions, cities and the country.

According to the Pew Research Center:

Income inequality may be measured in a number of ways, but no matter the measure, economic inequality in the U.S. is seen to be on the rise. One widely used measure – the 90/10 ratio – takes the ratio of the income needed to rank among the top 10% of earners in the U.S. (the 90th percentile) to the income at the threshold of the bottom

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10% of earners (the 10th percentile). In 1980, the 90/10 ratio in the U.S. stood at 9.1, meaning that households at the top had incomes about nine times the incomes of households at the bottom. The ratio increased in every decade since 1980, reaching

12.6 in 2018, an increase of 39%.

Source: Pew Research Center, Trends in Income and wealth Inequality, January 9, 2020, page 11
In 2010-2014, the 90/10 ratios in Riverside County and Desert Hot Springs were 9.6 and 9.2, respectively. By 2015-2019, the Riverside County ratio increased to 11.5 while that of the City remained the same at 9.2. Thus, income inequality grew in Riverside County but not in Desert Hot Springs.

Table B-21 shows that the statewide ratio exceeds that of all southern California counties. The reason is that the Bay Area has a high 90/10 ratio, meaning that region has a greater income inequality than SoCal.

Table B-21
Income Inequality Measures by Region and Area: 2015-2019 Region/Area 90th Percentile 10th Percentile 90-10 Ratio Statewide $262,000 $21,000 12.3
Inland Empire $190,000 $20,000 9.7
Riverside County $182,000 $16,000 11.5
Orange County $289,000 $25,000 11.8
Los Angeles County $234,000 $20,000 11.8
Desert Hot Springs $88,000 $9,600 9.2
Table Household Income in the Past 12 Months (in 2019 Inflation Adjusted Dollars) Calculations by William F. Gayk, Ph.D.

Note: Inland Empire includes Imperial, Riverside and San Bernardino Counties Source: Public Policy Institute of California, Income Inequality in California, January 2020, 2 pages
Desert Hot Springs’ 90/10 ratio is low at 9.2 which means that the gap between the income groups living in the City is narrow compared to the Region and individual counties. Income inequality is not an issue in Desert Hot Springs as the 90/10 ratio is low and stable.

H. RACIALLY/ETHNICALLY CONCENTRATED AREAS OF POVERTY

1. Background
To assist communities in identifying racially or ethnically-concentrated areas of poverty (R/ECAPs), HUD developed a census tract-based definition of R/ECAPs. The definition involves thresholds for racial/ethnic concentration and poverty:
§ A non-White population of 50% or more

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§ A poverty rate that exceeds 40% or is three or more times the regional poverty rate, whichever rate is lower
For the CBSA Region, the three times poverty rate is 44.4%. For Riverside County alone it is

41.1%.

Census tracts with this extreme poverty that satisfy the racial/ethnic concentration threshold are deemed by HUD to be R/ECAPs.

2. Problems Associated with Segregation and Concentrated Poverty HUD explains the importance of the R/ECAP analysis in the following terms:

A large body of research has consistently found that the problems associated with segregation are greatly exacerbated when combined with concentrated poverty.

Neighborhoods of concentrated poverty may isolate residents from the resources and networks needed. Concentrated poverty has also been found to have a long-term effect on outcomes for children growing up in these neighborhoods related to a variety of indicators, including crime, health and education and future employment and lifetime earnings. An R/ECAP analysis is consistent with addressing concerns raised in the legislative history of the Fair Housing Act. The 1968 Kerner Commission on Civil Disorders acknowledged that “segregation and poverty” create “a destructive environment.” [Emphasis added}
Source: U.S. Department of Housing and Urban Development, AFFH Rule Guidebook, December 13, 2015, page 68

3. Regional Analysis of R/CAPs – 1990 to 2010
In 1990, there were a total of eight R/ECAP areas in the Region. Six of the R/ECAPs were adjacent to each other and located within the City of San Bernardino. Mecca, in unincorporated Riverside County, was the other R/ECAP and consisted of two contiguous census tracts.

In 2000, the Region added six R/ECAPs (three in the City of San Bernardino, two in the City of Riverside and one in the City of Barstow) for a total of 12 R/ECAPs as two census tracts were removed between 1990 and 2000 because they no longer met the threshold criteria.

In 2010, there were 21 R/ECAPs as two census tracts were removed and 11 added. Of the 21 R/ECAPs 14 were located in San Bernardino County and seven in Riverside County. The City of San Bernardino had 12 R/ECAPs and 11 of the 12 were adjacent to one another near the downtown. The cities of Barstow and Victorville each had one R/ECAP. In Riverside County, the cities of Riverside, Beaumont and Indio each had one R/ECAP while the City of Moreno Valley and the unincorporated community of Mecca each had two R/ECAPs.

Within the Region, the highest concentration of racial/ethnic minority populations and poverty was within the 11 contiguous census tracts located in the City of San Bernardino.

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4. Riverside County R/ECAPs – 2015-2019
According to the Riverside County 6th Cycle Housing Element Update, Riverside County has several census tracts that are considered R/ECAPs, including tracts immediately adjacent to the Salton Sea, the area near Desert Hot Springs, Meadowbrook, the neighborhoods southwest of Hemet, and portions of the cities of Riverside and Moreno Valley.3 Within the Coachella Valley, the Salton Sea R/ECAP area encompasses the unincorporated, census-designated communities of Thermal, Mecca, North Sore, and Oasis, and their surrounding areas. The Desert Hot Springs R/ECAP census tract is located southwest of the city and also includes a portion of land within Desert Hot Springs city limits that are not considered a R/ECAP.

The County’s review of HUD’s diversity index found that the Desert Hot Springs tract had a 10.5 percent rate of unemployment in 2018, which is in 100th percentile for unemployment measured by CalEnviroScreen. This high rate of unemployment may be attributed to a concentrated retiree population or may indicate severe challenges accessing or securing employment. Another notable trend in this R/ECAP is the higher rates of asthma and cardiovascular disease, which may be a result of poor air quality. The County found, on average, the City of Desert Hot Springs is in the 2nd percentile for pollution burden in the 78th percentile for population characteristics, in comparison to the 2nd percentile and 95th percentile, respectively, in the adjacent County R/ECAP (see Tables B-22 and B-23). This demonstrates that population characteristics as an indicator of quality of life may be more telling than pollution burden.

Table B-2222
Pollution Burden Adjacent to Desert Hot
Springs
Pollutant Percentile
Ozone 94th
PM 2.5 5th
Diesel PM 9th
Pesticides 2nd
Toxic Releases 3rd
Traffic 13th
Drinking Water Contaminants 29th
Lead in Housing 52nd
Cleanups 0
Groundwater Threats 0
Hazardous Waste 27th
Impaired Water 0
Solid Waste 0
Total 2nd
Source: Riverside County 6th Cycle Housing
Element Table P-28C.
3 Riverside County 6th Cycle Housing Element Update, Appendix P, Figure P-6.

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Table B-2323
Population Characteristics Adjacent to
Desert Hot Springs
Characteristic Percentile
Asthma 79th
Low Birth Rate 68th
Cardiovascular Disease 92nd
Education 86th
Linguistic Isolation 59th
Poverty 95th
Unemployment 100th
Housing Burden 84th
Total 95th
Source: Riverside County 6th Cycle Housing
Element Table P-28D.

In order to address discrepancies in access to services or conditions that promote healthy lifestyles and improve quality of life, the County set forth meaningful actions to create community working groups to identify areas of concern and review strategies to improve conditions for all residents in R/ECAP areas.4 These actions include, but are not limited to: 5 • Establish community working groups to enable residents to prioritize their concerns and work toward solutions.
• Prepare community plans for communities in need of focused investment. • Identify staff time to focus on securing funding to implement and advance area plans. • Revise Policy 2.3 of the Eastern Coachella Valley Area Plan to prioritize investment and affordable development in areas of need.

Since 2010, the number of R/ECAPs located in Riverside County has decreased from seven to three. Table B-22 provides estimates of the population with poverty level incomes and the minority population. The RE/ECAPs are located in Blythe, Indio, and Riverside.

The R/ECAP located in the City of Riverside is located near UC Riverside. College towns frequently appear to have high poverty rates, often inflated by the presence of students in the population. The City of Riverside in its 2019 Analysis of Impediments to Fair Housing Choice adjusted the poverty rate because of the influence of students and determined it was below 40%.

Table B-22
Riverside County R/ECAPs: 2015-2019
4 Table P-30 Factors That Contribute to Fair Housing Issues in Riverside County, Riverside County 6th Cycle Housing Element Update.
5 Per Riverside County Action H-27 of 6th Cycle Housing Element Update.

APPENDIX B ASSESSMENT OF FAIR HOUSING
B-43
Poverty Status/Race and Ethnicity Census Tract
Poverty Status 453.03 461.02 465
Total Population for whom poverty status is determined 2,639 1,746 2,749 Below poverty level population for whom poverty status is determined 1,116 808 1,241
Percent Below Poverty Level 42.3% 46.3% 45.1%
Percent Minority
Race/Ethnicity
Not Hispanic or Latino
White alone 109 332 1,807
Black or African American alone 0 161 673
American Indian and Alaska Native alone 0 0 25
Asian alone 80 5 2,902
Native Hawaiian and Other Pacific Islander alone 0 0 88 Some other race alone 0 36 41
Two or more races 0 26 560
Hispanic or Latino 2,450 1,321 3,316
Total 2,639 1,881 9,412
Minority Population 2,530 1,549 7,605
Percent Minority 95.9% 82.3% 80.8%
Source: 2015-2019 American Community Survey 5-Year Estimates, Table B01003, Total Population; Table B17020 Poverty Status in the Past 12 Months by Age and Table B03002 Hispanic or Latino by Race

5. City of Desert Hot Springs
As discussed above, There there According to HUD R/ECAP mapping and are were no R/ECAPs located in Desert Hot Springs in 1990, 2000, and 2010 according to the R/ECAPs map by HUD (updated February 9, 2018). Both the HUD map and HCD’s AFFH Data Viewer there are show that two census tracts in Desert Hot Springs are designated as R/ECAPs (CT 445.07 and CT 445.09) (see Exhibit B-7). CT 445.07 is generally bounded by Pierson Boulevard to the north, Palm Drive to the east, Two Bunch Palms Trail to the south, and N. Indian Canyon Drive to the west. CT 445.09 is generally bounded by 8th Street to the north, Ambrosio Drive to the east, Pierson Boulevard to the south, and vacant land to the west.

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Exhibit B-7
City of Desert Hot Springs R/ECAPS
The portion of CT 445.07 that is within the City’s boundaries consists primarily of single-family residences and large swaths of vacant lands. The portions that border Palm Drive and Pierson Boulevard consist of commercial and retail uses. CT 445.09 consists primarily of single-family residences. Also of note is a mix of commercial/retail and public uses, including Desert Hot Springs High School, Fire and Police Departments, and City Hall. Table B-24 provides a comparison of population characteristics of the two R/ECAP CTs and the City of Desert Hot Springs, and is summarized below:

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• Approximately 40% of the City’s total population reside in the two R/ECAP CTs; • The City’s White only population percentage of 27.5 is comparable to the White only population percentage of 28.8 in the R/ECAP CTs;
• The City has a Hispanic or Latino only population percentage of 56.4 , which is 11.8 percentage points lower than the R/ECAP CTs population percentage of 68.2; • The average median household income within the two R/ECAP CTs is $29,250, which is $8,568 lower than the City’s median household income;
• The two R/ECAPS have the least positive outcomes on the education and economic scores, and have one of the more positive outcomes on the environmental score. • Both R/ECAPS are considered areas of High Segregation and Poverty.

Table B-24
R/ECAP Characteristics
CT 445.07 CT 445.09 Desert Hot
Springs
Population1 7,840 4,580 32,716
Race and Ethnicity1
White alone, Not Hispanic 2,104 1,473 8,997
Hispanic or Latino alone 5,713 2,757 18,452
Black or African American alone 421 545 3,173
American Indian or Alaska Native alone 159 108 458
Asian alone 121 72 1,145
Housing1,2
Total Housing Units 2,515 1,762 11,7022
Total Occupied Housing Units 2,300 1,630 10,7082
Income and Poverty1,3
Median Household Income $31,6943 $26,8063 $37,8181
Percent of Population in Poverty 36.2%3 36%3 24%1
TCAC Opportunity Areas4
Composite Score High Segregation
and Poverty
High Segregation
and Poverty
Education Score 0.28 0.28 NA
Economic Score 0.22 0.06
Environmental Score 0.87 0.86

1. 2020 U.S. Census

2. U.S. Department of Finance, Table E-5 Population and Housing Estimates 2022.

3. AFFH Data Viewer

4. California Tax Credit Allocation Committee (TCAC) scores are from 0.0-1.0, 1.0 being most positive outcomes. All scores are by census tract.

The City has created programs to develop place-based strategies to encourage community conservation and improvements in these areas of lower opportunity and concentrated poverty. As set forth in Programs 5.4 and 5.9, these strategies shall focus on community revitalization and public participation that include the following:
• Targeted investment in areas of most need focused on improving community assets such as schools, recreational facilities and programs, social service programs, parks, streets,

APPENDIX B ASSESSMENT OF FAIR HOUSING
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active transportation and infrastructure;
• Develop a proactive code enforcement program that targets areas of concentrated rehabilitation needs, results in repairs, and mitigates potential cost, displacement and relocation impacts on residents;
• Target acquisition and rehabilitation to vacant and blighted properties in neighborhoods of concentrated poverty;
• Recruit residents from areas of concentrated poverty to serve on boards, committees, task forces and other local government decision-making bodies; • Expand access to community meetings, including addressing language barriers, meeting times.

However, the latest data source for both maps are 2009-2013. Table B-23 shows that according to the 2015-2019 ACS data, eEight of the nine census tracts have minority populations exceeding 50%. However, none of the census tracts have a poverty rate equal to or more than the R/ECAP threshold of 40%. Thus, CT 445.07 and CT 445.09 are not considered R/ECAPs after 2015 based on the HUD methodologythe existence of an R/ECAP in the City is not a fair housing issue.

However, all areas in these two tracts are designated as TCAC Areas of High Segregation and Poverty in 2020 and 2021, as discussed below under Section J. CVAG Region and City Access to Opportunity Analysis. Refer to Table B-23.

6. Areas of Affluence
HCD defines “areas of affluence” as census tracts/neighborhoods in which 80% of the population is White, not Hispanic and the median household income is $125,000 or more. Desert Hot Springs does not have an area of affluence. In 2015-2019, there are 18 census tracts/neighborhoods located in the Region (Riverside County) in which 80% or more of the population is White, not Hispanic. However, only one census tract in the Region had a median household income of $125,000 or more: #456.08 which is located in the City of La Quinta. Two additional census tracts had an 80% White, not Hispanic population and median household incomes just below $125,000 – CT 451.25 ($123,792) located in Indian Wells and CT 449.21 ($116,875) located in Rancho Mirage.

Table B-23
City of Desert Hot Springs
Racially/Ethnically Concentrated
Areas of Poverty: 2015-2019
Census
Tract
Total
Population
Poverty Percent
Rate Minority
445.07 6,817 36.20% 78%
445.09 3,693 36.00% 70%
445.10 6,649 34.80% 72%
445.15 3,971 31.00% 76%
445.16 6,109 21.00% 78%
445.17 2,435 6.70% 24%
445.18 5,302 22.50% 58%

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445.21 1,332 30.50% 58%
445.22 3,812 26.80% 54%
Source: 2015-2019 American Community Survey 5-
Year Estimates, Table B01003, Total Population;
Table B17020 Poverty Status in the Past 12 Months
by Age and Table B03002 Hispanic or Latino by Race
I. DISPARITIES IN Regional Access to Opportunity

1. HUD Access to Opportunity Data
HUD used a two-stage process for developing the data needed to analyze disparities in access to opportunity. The first stage involves quantifying the degree to which a neighborhood offers features commonly viewed as important opportunity indicators. In the second stage, HUD compares these rankings across people in particular racial and economic subgroups to characterize disparities in access to opportunities. To focus the analysis, HUD developed methods to quantify a selected number of the important opportunity indicators in every neighborhood. These dimensions were selected because existing research suggests they have a bearing on a range of individual outcomes.

Invariably, these opportunity indicators do not capture all that is encompassed in an individual’s or a family’s access to opportunity. In quantifying opportunity indicators, HUD is quantifying features of neighborhoods for the purpose of assessing whether significant disparities exist in the access or exposure of particular groups to these quality of life factors. While these important dimensions are identified by research as important to quality of life, the measures are not without limitations. HUD constrained the scope of HUD-provided data to those that are closely linked to neighborhood geographies and could be measured consistently at small area levels across the country. For example, HUD's measure of school performance only reflects elementary school proficiency. It does not capture academic achievement for higher grades of schooling, which is important to a community's well-being, but may not be as geographically tied to individual neighborhoods as elementary schools.

2. Description of Opportunity Indicators
a. Low Poverty Index
The low poverty index captures poverty in a given neighborhood. The index is based on the poverty rate and the census tract level. Values are inverted and percentile ranked nationally. The resulting values range from 0 to 100. The higher the score, the less exposure to poverty in a neighborhood.
b. School Proficiency Index
The school proficiency index uses school-level data on the performance of 4th grade students on state exams as a means to identify the neighborhoods having high-or low performing elementary schools.. The school proficiency index measures the percent of 4th grade students proficient in reading and math on state test scores for up to three schools within 1.5 miles of a census tract’s

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block-group’s centroid. The source of the HUD school data is the Great Schools Rating. Values are percentile ranked and range from 0 to 100. The higher the score, the higher the school system quality is in a neighborhood.
c. Jobs Proximity Index
The Jobs Proximity Index quantifies the accessibility of a given neighborhood as a function of its distance to all job locations in a CBSA, with the larger employment centers weighted more heavily.

In effect, the index measures the physical distances between place of residence and location of jobs. The job locations are positively weighted by the size of the employment and inversely weighted by the labor supply residing in that location. Values are percentile ranked at the CBSA level with values ranging from 0 to 100. The higher the index value, the better the access to employment opportunities for the residents in a neighborhood. d. Labor Market Engagement Index
The Labor Market Engagement Index is based on three factors: unemployment rate, labor force participation rate and educational attainment (the percent of the population with a bachelor’s degree or higher). Values are percentile ranked nationally and range from 0 to 100 with the higher the score the higher the labor force participation and human capital in a neighborhood. e. Low Transportation Cost Index
This index is based on estimates of transportation costs for a family that meets the following description: a 3-person single-parent family with income at 50% of the median income for renters for the region (i.e. CBSA). Transportation costs are expressed as a percent of income for renters.

Values range from 0 to 100. Higher values mean lower transportation costs in that neighborhood.

Transportation costs may be low for a variety of reasons, including greater access to public transportation and the density of homes, services, and jobs in the neighborhood and surrounding community.
f. Transit Trips Index
This index is based on estimates of transit trips taken by a family that meets the following description: a 3-person single-parent family with income at 50% of the median income for renters for the Region. Annual transit trips are modeled for renters. Index values range from 0 to 100.

Higher scores indicate that residents in the neighborhood/census tract are more likely to utilize public transit. The index controls for income such that a higher index value will often reflect better access to public transit.
g. Environmental Health Index
The environmental health index summarizes potential exposure to harmful toxins at the neighborhood level (census tracts). This index combines standardized EPA estimates of air quality carcinogenic, respiratory and neurological hazards. Values range from 0 to 100. The higher the value, the better is the environmental quality of a neighborhood.

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3. Analysis of CBSA Regional Access to Opportunity
Table B-24 provides the score for each of the seven indicators for the regional population and the population with incomes below the poverty line by race and ethnicity. It is important to remember that the higher the score the more access to opportunity – a score of 65 compared to 50 demonstrates, for example, better access to public transit, The values of the indices are best understood as an “interval” level of measurement, similar to a thermometer. It can be said that 90 degrees is hotter than 45 degrees but not twice as hot. A “ratio” level of measurement which has a true zero such as pounds is needed so it can be said that 90 pounds is twice the weight of 45 pounds.
a. Low Poverty
As expected all racial/ethnic populations with incomes below the poverty line are more exposed to poverty than the regional population. This probably also is true for Desert Hot Springs because the City’s poverty rate exceeds that of Riverside County and San Bernardino County. In addition, five census tracts have poverty exceeding 30%. b. School Proficiency
Also as expected all racial and ethnic populations below the federal poverty line live in neighborhoods with poor performing schools compared to the regional population. In fact, the neighborhoods where income-poor Black Non-Hispanic and Hispanic households live have particularly low scores.

The five elementary schools in Desert Hot Springs also are low performing. Great Schools rates the schools a 4 on a scale of 1 to 10.
c. .Labor Market Engagement
Again, the population below the federal poverty line has lower scores than the regional population. None of the scores are 50 or higher. The regional Asian or Pacific Islander population has the highest score at 43.02.
d. Transit/Low Transportation Cost
For both indices, the scores of the population below the federal poverty line are higher than the regional population. The scores demonstrate closer proximity and use of public transit. e. Jobs Proximity
Jobs proximity scores are generally the same for the regional population and the population below the federal poverty line. Only three of the 10 possible scores exceed a score of 50, however. f. Environmental Health

APPENDIX B ASSESSMENT OF FAIR HOUSING
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Environmental health scores are generally the same for the regional population and the population below the federal poverty line. Nine of the 10 possible scores exceed a score of 50.

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Table B-2524
Regional (CBSA) Access to Opportunity Index Scores
(Riverside-San Bernardino-Ontario,
CA) Region
Low
Poverty
Index
School
Proficiency
Index
Labor
Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 52.61 53.16 34.50 37.96 25.75 49.50 61.98 Black, Non-Hispanic 42.80 43.79 27.18 42.55 31.82 49.72 52.97 Hispanic 37.51 41.01 24.20 43.12 32.68 47.81 52.59
Asian or Pacific Islander, Non-Hispanic 60.42 59.23 43.02 41.92 29.18 48.25 52.51 Native American, Non-Hispanic 41.19 45.54 25.06 36.84 26.34 50.16 61.60 Population below federal poverty line
White, Non-Hispanic 38.39 44.64 25.55 38.74 29.20 49.95 62.31 Black, Non-Hispanic 27.15 35.04 17.39 43.48 34.78 48.95 51.90 Hispanic 23.78 34.76 16.42 44.76 36.54 49.34 52.37
Asian or Pacific Islander, Non-Hispanic 42.30 44.82 30.51 45.00 37.05 51.32 49.15 Native American, Non-Hispanic 30.24 39.41 20.61 39.17 32.05 52.23 58.72 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; NATA Note 2: Refer to the Data Documentation for details (www.hudexchange.info).

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J. CVAG REGION AND CITY ACCESS TO OPPORTUNITY ANALYSIS

1. CVAG Regional Analysis
The TCAC/HCD Opportunity Mapping Tool designates neighborhoods – meaning census tracts –into one of the following six resource categories:
§ Highest
§ High
§ Moderate
§ Low
§ High Segregation & Poverty
Tract-level indices were summed to the jurisdictional-level by SCAG using area-weighted interpolation. Using 2013-2017 American Community Survey population data, SCAG determined the share of each jurisdiction’s population in each of these five categories.

Table B-25 shows the number of people living in each of the five neighborhood resource categories while Table B-26 shows the percentage.

By far, Palm Desert has the largest number of people living in the highest resource neighborhoods – 41,336 out of CVAG regional total of 72,434. La Quinta at 18,215 people has the second largest number of persons living in the highest resource neighborhoods. Palm Springs, La Quinta, and Rancho Mirage have the largest populations living in the high resource neighborhoods.

On the other hand, the largest number of people living in high segregation and poverty and low resource neighborhoods call Coachella home. Desert Hot Springs (13,264) and Cathedral City (12,607) have the second and third highest numbers of people living in high segregation and poverty neighborhoods.

On a percentage basis, Indian Wells, Palm Desert and La Quinta have the highest percentages of people living in high resource and highest resource neighborhoods. The numbers and percentages reveal that the neighborhoods with the best access to opportunity are geographically concentrated within the CVAG Region.

The highest percentages of people living in high segregation and poverty and low resource neighborhoods call Coachella and Desert Hot Springs home. Because of the large geographic areas encompassed within these neighborhoods, the obvious question emerges whether each of these cities should have been allocated more than a modest lower income RHNA. The “social equity adjustment” was the tool employed by SCAG to account for disparities in access to opportunity across the region:

Assigning a higher social equity adjustment based on Opportunity Indices will result in a higher percentage of affordable housing units to areas that have higher resources.

Concurrently, it will assign a lower percentage of affordable housing in areas where they

APPENDIX B ASSESSMENT OF FAIR HOUSING
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is already an overconcentration. Because Opportunity Indices consider factors such as access to lower wage jobs, poverty rates, and school proficiency, the social equity adjustment in the RHNA methodology will result in factors beyond simply household income distribution. This additional adjustment will help to adjust the disparity in access to fair housing across the region, furthering the AFFH objective required in State housing law.

Southern California Association of Governments, Final RHNA Allocation Methodology, March 5, 2020, page 5
Whether this adjustment really accounts for the realities on the ground in cities like Desert Hot Springs and Coachella is debatable. As noted above, the adjustments are made in terms of percentages. In terms of numbers, Coachella was allocated approximately 2,000 and Desert Hot Springs 1,100 lower income housing units, respectively.

Table B-2625
CVAG Neighborhood Resource Categories by City (Number)
Jurisdiction
High
Segregation
& Poverty
Low
Resource
Moderate
Resource
High
Resource
Highest
Resource
Total
Population
Cathedral City 12,607 0 30,841 5,002 0 48,450
Coachella 24,853 11,252 7,435 0 0 43,540
Desert Hot Springs 13,264 164 8,966 978 0 23,372
Indian Wells 0 0 0 0 8,585 8,585
Indio 1,249 10,218 48,207 11,390 3,023 74,087
La Quinta 439 0 1,329 16,784 18,215 36,767
Palm Desert 0 0 0 4,601 41,336 45,937
Palm Springs 62 50 17,122 33,190 433 50,857
Rancho Mirage 0 0 2.083 14,692 842 17,737
Total 52,474 21,684 116,703 86,037 72,434 349,332
Percent 15.0% 6.2% 33.4% 24.6% 20.8% 100.0%
Source: Southern California Association of Governments, Final RHNA Methodology Data Appendix, Population within TCAC Resource Areas, page 44, March 5, 2020

APPENDIX B ASSESSMENT OF FAIR HOUSING
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Table B-2726
CVAG Neighborhood Resource Categories by City (Percent) Jurisdiction
High
Segregation
& Poverty
Low
Resource
Lowest
Resource
(Seg/Pov+Low
Resource)
Moderate
Resource
High
Resource
Highest
Resource
Cathedral City 26.0% 0.0% 26.0% 63.7% 10.3% 0.0%
Coachella 57.1% 25.8% 82.9% 17.1% 0.0% 0.0%
Desert Hot Springs 56.8% 0.7% 57.5% 38.4% 4.5% 0.0%
Indian Wells 0.0% 0.0% 0.0% 0.0% 0.0% 100.0%
Indio 14.3% 12.0% 26.3% 56.7% 13.4% 3.6%
La Quinta 1.2% 0.0% 1.2% 3.6% 45.6% 49.5%
Palm Desert 0.0% 0.0% 0.0% 0.0% 10.0% 90.0%
Palm Springs 0.1% 0.1% 0.2% 33.7% 65.3% 0.9%
Rancho Mirage 0.0% 0.0% 0.0% 15.8.% 79.5% 4.7%
Total Percent 15.0% 6.2% 33.4% 24.6% 20.8% 100.0%
Source: Southern California Association of Governments, Final RHNA Methodology Data Appendix, Population within TCAC Resource Areas, page 44, March 5, 2020

2. Desert Hot Springs Census Tract/Neighborhood Analysis Nine census tracts cover all or a portion of land that is located within the City limits. As shown in Exhibit B-8, One census tract (CT 445.17) is classified as High OpportunityResource, which overlaps with the Mission Lakes Country Club. However, as described in Appendix C, the majority of the developed land within the census tract is located in unincorporated territory. Most of the land in CT 445.17 within the City limits is zoned Open Space – Conservation, due to significant hillsides, Coachella Valley Multiple Species Conservation Plan designations and similar factors.

Two census tracts – 445.16 and 445.18 are designated as moderate Moderate Resourceopportunity.

Two census tracts – 445.21 and 445.22 are designated as low Low Resourceopportunity. Note that a portion of CT 445.18 is designated as Low Resource in the northern City.

Four census tracts are designated as High Segregation And & Poverty: 445.07; 445.09; 445.10; and 445.15. These areas are in the central City and coincide with the Hispanic Majority Tracts.

Based on 2009-2013 HUD data, CT 445.07 and CT 445.09 were also designated R/ECAPs.

However, based on analysis in Section H.5 above, tThe four two census tracts are do not meet the thresholds of racially/ethnically concentrated areas of poverty, howeverbased on 2015-2019 ACS data. In all four census tracts, the minority population represents 50% of more of the total population. The poverty rates, however, do not reach the R/ECAP threshold of 40%, ranging between 31% and 36.2%.

APPENDIX B ASSESSMENT OF FAIR HOUSING
B-55
Exhibit B-887
City of Desert Hot Springs TCAC Opportunity Areas (2021)

3. Regional Minority Population Trends
Desert Hot Springs is not unusual for having almost all of its census tracts with 50% or more of the population belonging to a minority population group. In fact, it is highly probable that the majority of Riverside County’s census tracts have a minority population percentage exceeding 50% or more. Table B-27 shows in that in 2020 (62.5%) and 2030 (63.8%) the minority population comprises almost two-thirds of Riverside County’s population.

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Table B-2827
Riverside County Population Growth: 2020-2030
Race/Ethnicity 2020 2030
Net Gain
2020-2030
Percent
Change
Hispanic or Latino 1,160,908 1,318,755 157,847 13.6%
Not Hispanic or Latino
White Alone 918,867 986,706 67,839 7.4%
Black or African American Alone 146,861 168,404 21,543 14.7% American Indian and Alaska Native Alone 12,095 13,435 1,340 11.1% Asian Alone 148,270 166,613 18,343 12.4%
Native Hawaiian and Pacific Islander Alone 6,720 7,334 614 9.1% Two or More Races 55,578 66,821 11,243 20.2%
Total 2,449,299 2,728,068 278,769 11.4%
Source: Demographic Research Unit, California Department of Finance, March 2021.

In several census tracts/neighborhoods, it will be important to implement poverty-reducing strategies; including placed-based strategies. Poverty, according to the Community Action Partnership (War on Poverty agency) is considered a contributing factor to housing and socioeconomic problems.

K. DISPROPORTIONATE HOUSING NEEDS

1. Background
For purposes of the Assessment of Fair Housing -
Disproportionate housing needs refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden, severe cost burden, overcrowding, and substandard housing conditions…. 24 CFR 5.154 [Emphasis added]
Source: U.S. Department of Housing and Urban Development, AFFH Rule Guidebook, December 13, 2015, page 79
No threshold measures are given by HUD to enable jurisdictions to determine what a “significant disparity” is.

The categories of housing need, therefore, include:
§ Cost Burden
§ Severe Cost Burden

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§ Overcrowding
§ Substandard Housing Conditions

2. Indicators of Disproportionate Housing Needs
ACS data are unavailable on the cost burdens and substandard housing conditions experienced by the different protected classes (e.g., race, national origin, disability, familial status). Data are available on overcrowding by race and ethnicity.
a. Extremely Low Income by Race and Ethnicity
Table B-28 shows that the percentages of extremely low income Black and Hispanic households are considerably higher than the White and Asian households. This may very well mean that Black and Hispanic households experience disproportionate cost burdens and severe cost burdens when compared to White and Asian households.
b. Extremely Low Income Households by Tenure
Nearly 37% of all renters have extremely low incomes compared to less than 10% of owners.

Thus, fair housing protected groups that live in renter-occupied housing are more likely than owners to experience disproportionate housing needs.

Table B-2928
City of Desert Hot Springs
Extremely Low Income Households by Race/Ethnicity: 2012-2016 Race and Ethnicity
Total
Households
Extremely
Low
Households
Percent
Extremely Low
Income
Households
White, Non-Hispanic 4,060 720 17.7%
Black, Non-Hispanic 769 304 39.5%
Asian and Other, Non-Hispanic 463 95 20.5%
Hispanic 3,980 1,125 28.3%
Total 9,272 2,244 24.2%
Renter-occupied 5,050 1,865 36.9%
Owner-occupied 4,225 385 9.1%
Total 9,275 2,250 24.3%
Source: Southern California Association of Governments, Pre-Certified Local Housing Data, August 2020, based on CHAS Data 2012-2016

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c. Very Low Income Cost Burdens by Income
Table B-29 describes the number of very low income renter and owner households that experience cost burden and severe cost burden. For renters, housing cost is gross rent (contract rent plus utilities). For owners, housing cost is "select monthly owner costs", which includes mortgage payment, utilities, association fees, insurance, and real estate taxes.

Among very low renters, 83.2% are cost burdened and 65.7% are severely cost burdened. The data also demonstrate that about 68% of all very low income owners are cost burdened and 43% are severely cost burdened.

This means that the renter households within each protected group are more likely to be cost burdened and severely cost burdened than there owner counterparts.

Table B-30 shows that for Riverside County extremely low income renters and owners experience essentially the same percentages of cost burdens as the City’s householders. There is one exception, however. Almost 54% of the County’s extremely low income owners are severely cost burdened compared to 43% of the City’s householders.

Table B-3029
City of Desert Hot Springs
Very Low Income (<50% AMI)
Cost Burden and Severe Cost Burden
By Tenure: 2013-2017
Tenure
Total Low
Income
(<50% AMI)
Number
Cost
Burdened
Percent
Cost
Burdened
Number
Severely Cost
Burdened
Percent
Severely Cost
Burdened
Renters 3,000 2,495 83.2% 1,970 65.7%
Owners 1,060 720 67.9% 460 43.4%
Total 4,060 3,215 79.2% 2,430 59.9%
Note: Low/moderate income means less than 80% of the area median income Cost burden = 30% or more of income spent on housing costs Severe cost burden = 50% or more spent on housing costs Source: Comprehensive Housing Affordability Strategy (“CHAS”) Data, based on 2013-2017 American Community Survey and 2010 Census

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Table B-3130
Riverside County
Very Low Income (<50% AMI)
Cost Burden and Severe Cost Burden
By Tenure: 2013-2017
Tenure
Total Low Income
(<50% AMI)
Number
Cost
Burdened
Percent
Cost
Burdened
Number
Severely Cost
Burdened
Percent
Severely Cost
Burdened
Renters 89,950 75,110 83.5% 57,615 64.1%
Owners 69,480 49,050 70.6% 37,385 53.8%
Total 159,430 124,160 77.9% 95,000 59.6%
Note: Low/moderate income means less than 80% of the area median income Cost burden = 30% or more of income spent on housing costs Severe cost burden = 50% or more spent on housing costs Source: Comprehensive Housing Affordability Strategy (“CHAS”) Data, based on 2013-2017 American Community Survey and 2010 Census
d. Overcrowding by Race and Ethnicity
While American Indian and Alaska Native households experience the highest level of overcrowding, there are relatively few of these households. Hispanics experience disproportionate housing need with respect to overcrowding. There are a higher percentage of overcrowded Hispanic households than experienced by White, Asian and Black households.

Refer to Table B-31.

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Table B-3231
City of Desert Hot Springs
Disproportionate Housing Needs Analysis
Overcrowding by Race and Ethnicity
Race/Ethnicity
Number of
Households
Number
Overcrowded
Percent
Overcrowded
Hispanic 4,556 729 16.0%
Some Other Race Alone 875 101 11.5%
Black/African American 1,202 108 9.0%
Asian 306 32 10.5%
White Alone, Not Hispanic or Latino 4,194 165 3.9%
Two or More Races 247 20 8.1%
American Indian/Alaska Native 75 13 17.3%
Native Hawaiian/Pacific Islander 14 0 0.0%
Total 11,469 1,168 10.2%
Source: U.S. Census Bureau; American Community Survey, 2015-2019 5-Year Estimates, Table B25014 B-I, Occupants Per Room
For Riverside County, 13.9% of the Hispanic households are overcrowded, a percentage that is lower than the City. However, the County’s overcrowding rate (15.9%) experienced by Some Other Race Alone householders is higher than that of Desert Hot Springs (11.5%). Refer to Table B-32.

Table B-3332
Riverside County
Disproportionate Housing Needs Analysis
Overcrowding by Race and Ethnicity
Race/Ethnicity
Number of
Households
Number
Overcrowded
Percent
Overcrowded
Hispanic 273,613 37,958 13.9%
Some Other Race Alone 124,289 19,811 15.9%
Black/African American 48,046 2,577 5.4%
Asian 42,378 2,201 5.2%
White Alone, Not Hispanic or Latino 344,446 6,616 1.9%
Two or More Races 18,694 1,321 7.1%
American Indian/Alaska Native 5,856 361 6.2%
Native Hawaiian/Pacific Islander 1,898 217 11.4%
Total 859,220 71,062 8.3%
Source: U.S. Census Bureau; American Community Survey, 2015-2019 5-Year Estimates, Table B25014, Occupants Per Room

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e. Homeless
The 2019 Point in Time (PIT) Homeless Count for the Region comprised of Riverside County and San Bernardino County was 5,411 sheltered and unsheltered persons: 2,811 in Riverside County and 2,607 in San Bernardino County.

Disproportionate needs are experienced by the Black population and individuals with disabilities.

In Riverside County, the Black population represents 16% of all homeless persons. Individuals with disabilities (substance abuse and mental health conditions) comprise 38% of all homeless persons.

In San Bernardino County, Blacks comprise 19% of the homeless population. Persons with disabilities also have disproportionate needs as they represent 40% of the County’s homeless population
In Desert Hot Springs, the homeless population was 68 persons in 2019. Disproportionate needs were experienced by people who identify with “multiple races,” as they represented 42% of all the City’s homeless persons. Disabled persons also had disproportionate needs.

L. DISPLACEMENT RISK
Displacement risk factors include, but are limited, to:
§ Constructive evictions
§ Expiration of national and state eviction moratoriums § Foreclosures
§ ELI/severely cost burdened households
A constructive eviction occurs when a landlord takesactions that interfere with the tenant's use and enjoyment of the premises such as cutting off the tenant’s utilities or other essential services; harassing the tenant, whether verbally, physically, or emotionally; or blocking the tenant’s access to the unit, such as changing the locks.

The County of Riverside removed constructive eviction as an impediment to fair housing because there was insufficient publicly available data to support inclusion of this landlord-tenant issue as an impediment to fair housing choice.

Source: County of Riverside Economic Development Agency, Analysis of Impediments to Fair Housing Choice 2019-2021, June 2019. pages 11-12
In the past six years (FY 2014/2015 to 2019/2020), Desert Hot Springs residents made 5,759 tenant/landlord related calls. Eviction related calls ranked fourth among the issues prompting the calls to the FHCRC:
§ Repairs 1,410 24%
§ Notices 898 16%

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§ Lease/rental terms 674 12%
§ Eviction 414 7%
Although ranked fourth, evictions could pose a displacement risk to many households as an average of 70 eviction related calls are made per year. The City will work with the FHCRC to identify the eviction related issues associated with the calls and the resources available to address the issues (Program 5.6).

Although eviction moratoriums are in place, CalMatters estimated that 10,000 evictions happened in the State during a 9-month period. There were 112 confirmed evictions in Riverside County and 898 in San Bernardino County,.

Foreclosures have greatly diminished since 2010. Here were 686 foreclosures in 2010 compared to 47 in 2018. As a consequence, the displacement risk associated with foreclosures is not as severe as it was a decade ago.

Severely cost burdened extremely low income households are at a high risk of displacement because they face serious difficulties each month to pay the rent. When they can’t make the rent payment, they may be forced to move to a motel or temporarily live with friends or relatives. If their financial circumstances don’t improve, homelessness could be the only option available to them.

According to the 2013-2017 CHAS data, 14% of Riverside County’s renters had extremely low incomes and were spending 50% or more of their income on rent (N=35,000). In San Bernardino County, the comparable figures were 16% and 40,380 ELI households.

The displacement risk in Desert Hot Springs is more acute when compared to the two counties:
29% of all the City’s ELI households were severely cost burdened (N=1,515).

The Urban Displacement Project (UDP) is a research and action initiative of the University of California Berkeley and the University of Toronto. UDP conducts community-centered, datadriven, applied research toward more equitable and inclusive futures for cities, and contributed the Sensitive Communities map to HCD’s AFFH Data Viewer. Communities are designated sensitive if “they currently have populations vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost.” The following characteristics define vulnerability:
• Share of very low-income residents is above 20%; and
• The tract meets two of the following criteria:
o Share of renters is above 40%,
o Share of people of color is above 50%,
o Share of very low-income households (50% AMI or below) that are severely rent burdened households is above the county median,
o They or areas in close proximity have been experiencing displacement pressures (percent change in rent above County median for rent increases), or o Difference between tract median rent and median rent for surrounding tracts above median for all tracts in county (rent gap).

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According to the UDP map on the AFFH Data Viewer, almost the entire City, except census tract 445.17 that overlaps with the Mission Lakes Country Club, is designated as vulnerable to displacement. This is consistent with and likely due to the City’s characteristics of generally lower household income and higher percentages of people of color. Note that the areas identified as vulnerable to displacement not only covers Hispanic Majority Tracts, but also some White Majority Tracts.

The City will work with the Housing Authority, FHCRC, and Lift to Rise to develop ways to mitigate displacement risk.

The United Lift Rental Assistance Program was a coordinated effort between County of Riverside Housing Authority, Inland SoCal United Way, and Lift To Rise to keep Riverside County families and residents housed by providing one-time direct rental assistance to households that are behind on rent payments due to the ongoing COVID-19 pandemic. The program lasted from June until November, 2020 and assisted 10,000 households.

Riverside County allocated $33 million of federal funds for the program – $30 million from the Coronavirus Aid, Relief, and Economic Security (CARES) Act and $3 million from the Community Development Block Grant (CDBG) program – making it one of the most generous emergency rental assistance programs in the state in terms of funding per capita.

Among pre-eligible applicants for rental assistance, nearly 37% reported being at least three months behind on rent payments. The more months behind in rent, the more difficult it is to pay off the balance, and the more likely it is that the household will eventually face eviction. At the time of application 79% of pre-eligibleapplicants stated that they would not be able to pay rent in July.

According to the data, 12% of pre-eligible applicants have already received an eviction notice in the past three months. While some cities had issuedemergency eviction moratoriums, these did not offer protections from the financial obligations of renters, leaving those who are behind on rent vulnerable to eviction.

On May 8, 2021, the City hosted at City Hall a Rental Assistance Event. United Way, Lift to Rise and Riverside County described the rental assistance program, which includes payment of up to 12 months of back rent and three months of future rent.

M. FAIR HOUSING ENFORCEMENT, OUTREACH AND RESOURCES ANALYSIS

1. Fair Housing Enforcement
a. Background
HUD’s AFFH Rule Guidebook states the following regarding the lack of private fair housing outreach and enforcement:

The term “local private fair housing outreach and enforcement” refers to outreach and enforcement actions by private individuals and organizations, including such actions as fair housing education, conducting testing, bring lawsuits, arranging and implementing settlement agreements. A lack of private enforcement is often the result of a lack of resources or a lack of awareness about rights under fair housing and civil rights laws, which can lead to underreporting of discrimination, failure to take advantage of remedies under the law, and the continuation of discriminatory practices. Activities to raise awareness may include technical training for housing industry representatives and

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organizations, education and outreach activities geared to the general public, advocacy campaigns, fair housing testing and enforcement.

Source: U.S. Department of Housing and Urban Development, AFFH Rule Guidebook, December 13, 2015, page 212
The City is required to identify local and regional fair housing or civil rights agencies and organizations that provide fair housing information, outreach, and enforcement, and to describe their capacity to assist in fair housing analysis and investigation. b. Analysis
The enforcement of fair housing laws is accomplished by HUD, the California Department of Fair Employment and Housing (DFEH) and the Fair Housing Council of Riverside County, Inc. (FHCRC).

The DFEH is responsible for enforcing state fair housing laws that make it illegal to discriminate.

The DFEH may file signed complaints with HUD if the matter falls within the jurisdiction of that agency. As a substantially equivalent agency, DFEH’s findings are usually accepted by HUD. (A state or local agency may be certified as substantially equivalent after it applies for certification and HUD determines that the agency administers a law that provides substantive rights, procedures, remedies and judicial review provisions that are substantially equivalent to the Fair Housing Act. Typically, once certified, HUD will refer complaints of housing discrimination that it receives to the state or local agency for investigation.) Locally, the FHCRC takes part in a variety of activities to fight housing discrimination, such as free educational workshops, outreach to the community, and the investigation of housing discrimination complaints. The capacity of the FHCRC enables it to provide fair housing information, outreach, and enforcement to 24 cities and communities located in Riverside County plus the unincorporated area of the County.

FHCRC includes a total of 14 staff: two Housing Counselors, five Fair Housing Counselors, one Program Manager, one Fair Housing Testing Coordinator, one Fair Housing Outreach Specialist, one Accountant, an Executive Director and two administrative staff members. FHCRC also has two interns.

The funding that supports the efforts of the FHCRC includes CDBG funds received from participating jurisdictions within its service area and grant funds such as HUD’s Fair Housing Initiatives Program (FHIP). The City is a cooperating city in the Urban County CDBG Program.

The County of Riverside annually allocates CDBG funds to the FHCRC.

FHIP provides funds to eligible organizations through competitive grants under three initiatives that are designed to prevent or eliminate discriminatory housing practices and inform individuals of their rights and responsibilities under the Fair Housing Act. In FY 2020, the FHIP program awarded $40 million in grants to 110 organizations to meet the objectives under one or more of

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the core program initiatives: enforcing the Fair Housing Act under the Private Enforcement Initiative, educating the public and industry stakeholders on fair housing under the Education and Outreach Initiative, and building organizational capacity under the Fair Housing Organizations Initiative.

HUD provides FHAP funding annually on a noncompetitive basis to state and local agencies that enforce fair housing laws that are substantially equivalent to the Fair Housing Act. FHAP agencies support a variety of fair housing administrative and enforcement activities, including complaint investigation, conciliation, administrative and/or judicial enforcement; training; implementation of data and information systems; and education and outreach.

The FHCRC was awarded a FHIP Private Enforcement Initiative (PEI) grant of $360,000 and a FHIP Education and Outreach Initiative (EOI) grant of $125,000 to undertake various enforcement, education and outreach activities that promote Fair Housing. The activities are designed to minimize and eliminate impediments to fair housing choice. Specifically, FHCRC conducts systemic investigations, provides technical assistance to municipalities regarding compliance with fair housing laws, and provide fair housing education to the population of Riverside County.

FHCRC’s proposed activities include conducting fair housing tests on rentals, sales and design and construction; hosting the Annual Housing Conference during National Fair Housing Month; creating partnerships with local agencies and three partnerships with universities and colleges, conducting town hall meetings to connect the public with housing professionals and industry leaders, conduct trainings, create new educational materials in various languages and systemic investigations which will help remove barriers to fair housing.

The FHCRC provides a full range of services including:
§ Anti-discrimination
§ Landlord/tenant counseling
§ First time homebuyer seminars
§ Foreclosure prevention
§ Loan modification
§ Back-to-Work FHA
§ Training
Additionally, the FHCRC completed a Cultural Diversity Grant through the National Association of REALTORs (NAR) for the Inland Valleys Association of REALTORs (IVAR) members to attend the 2020 and 2021 Housing Conferences.

FHCRC is also a certified continuing education credit training organization through the California Department of Real Estate.

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2. Housing Discrimination Complaints
Between FY 2014-2015 and FY 2019-20, FHCRC received 198 fair housing related inquiries from Desert Hot Springs residents. Of the cases opened, 90 cases (45%) involved allegations of discrimination based on physical disability; 35 cases (18%) based on national origin; and 21 cases (11%) based on mental disability.

In 2018, a fair housing complaint involving national origin and familial status was settled. There were over 80 complainants involved in this case, which initially began in 2014. The City continued partnering with the FHCRC to investigate complaints placed through phone or walk-in complaints at the local office in Palm Springs.

FHCRC conducted a fair housing presentation in Desert Hot Springs in October of 2016 in which seven persons attended and 25 pieces of fair housing literature were distributed. FHCRC staff also attended and hosted a booth at the Desert Hot Springs Resource Fair, in October of 2015.

Most recently, FHCRC staff attended the DHS Housing Element Workshop in September of 2019 and the Housing Webinar in May of 2020. Also, FHCRC conducted outreach at various locations throughout Desert Hot Springs and distributed over 300 pieces of fair housing educational literature from 2015 to present.

HUD’s San Francisco Regional Office reported 12 housing discrimination complaints filed by Desert Hot Springs residents in the seven year period from January 1, 2014 to December 31, 2020. The basis for seven of the 12 complaints was disability. Disability and retaliation were the bases for one complaint. And sex and disability were the bases for one complaint.

3. Civil Rights Institute of Inland Southern California (CRI) The Civil Rights Institute of Inland Southern California (CRI) is a non-profit 501(c)(3) currently under construction in Downtown Riverside and will serve as a repository that will include exhibit and archival space for historical civil rights documents, artifacts, videos and audio recordings of all of the communities and regions surrounding Riverside County. The CRI will be located in a five-story building which also includes a large conference room, an office for the Fair Housing Council of Riverside County Inc. and 72 units of affordable housing.

Although the CRI will have a significant focus on African American contributions to the civil rights movement, its purpose is to include and embrace all ethnic communities and perspectives. The proposed activities that the CRI will provide include:
§ Providing public programming and children’s programs focusing on civil rights and the region’s civil rights history
§ Program exhibits and performances that support civil rights activities § Housing an archive and library of regional civil right materials § Conducting oral history projects and support the production of civil rights audio and video productions through the media center
§ Recognizing the region’s civil rights leaders and their impacts

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4. Other Fair Housing Enforcement Agencies Located in the Region In Los Angeles County, there are two fair housing enforcement agencies: Housing Rights Center and the Fair Housing Foundation. They serve cities located in Ventura County, Los Angeles County, and Orange County.

In Orange County, there is one fair housing enforcement agency: Fair Housing Council of Orange County. It serves cities located in Orange County.

The Inland Fair Housing and Mediation Board serve cities located in San Bernardino County and Imperial County.

5. Conclusion
No fair housing issue exists because of the lack of an organization to enforce fair housing laws.

The FHCRC provides a full range of fair housing services and is the City’s fair housing provider.

N. FAIR HOUSING ISSUES AND CONTRIBUTING FACTORS
The research and analysis demonstrates that the following are not fair housing issues:
§ Integration and segregation patterns and trends
§ Racially or ethnically concentrated areas of poverty
Fair housing issues exist because of –
§ Disproportionate housing needs
§ Disparities in access to opportunity
Disproportionate housing needs are experienced by Hispanic (cost burdens, overcrowding) and Black householders (cost burdens).

It is unclear if there is sufficient evidence to declare displacement risk a fair housing issue.

Nonetheless, the City has included a Displacement Risk Program (Program 5.6) in Section II of the 2021-2029 Housing Element.

1. Contributing Factors to Disproportionate Housing Needs a. Cost Burdens
The specific factors that contribute to the disproportionate housing needs are unclear.

Cost burdens are a function of two components: household income and housing costs. The household income of some Hispanic and Black households is not enough for them to afford market rate rents. For example, a monthly income of $5,000 is needed to afford a monthly rent of $1,500 ($5,000 X .30 = $1,500).

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It also is possible, but cannot be proven with the available data, that a contributing factor could be that lower cost rental opportunities become unavailable to Hispanic and Black households because of housing discrimination. Thus, the contributing factor could force these households to live in housing that is more costly and thereby create a housing cost burden.

The analysis of disproportionate housing needs must also consider the racial and ethnic composition of the households who are receiving housing assistance. Data on this characteristic is unavailable for the City. However, an indicator of the City’s racial/ethnic makeup of the families receiving housing is data from the Housing Authority of the County of Riverside.

There are 8,364 households receiving tenant-based rental assistance in the County. Of this number, 34.3% are Black/African American and 26.5%% are Hispanic. The Black/African American population comprises 6% of Riverside County’s population whereas the Hispanic population represents 47% of the County’s population.

There are 456 households living in public housing. Of this number, 27.6% are Black/Africa American and 54.8% are Hispanic.
b. Overcrowding
Hispanics are disproportionately impacted by overcrowding. In comparison to other populations, Hispanic householders have large families and live in multigenerational households.

A recent analysis of overcrowded housing among Latino households included the following recommendations:

Municipalities should address explicitly Latino housing needs in their housing action plan, especially the availability ofaffordable housing
Latino housing needs should be identified and represented in municipal housing strategic action plans. Primary among these needs isaffordable housing. The availability of affordable housing is a critical concern for manysuburban communities and ought to be addressed collaboratively as a regional issue.The cost of housing has implications for all residents—not just Latinos—yet research in this area specific to Latinos is necessary to identify how their needs may be distinct.One example of Latino housing needs is thedemand for large housing units. Census data suggests that Latinos are more likely than non-Latinos to live in multi-generational households, so the availability of large, affordable housing units is critical.

A potentially important opportunity for local governments to take Latino housing concerns into account is when planning documents are drawn up for new developments.

Source: Latinos United, by Benjamin J. Roth, Bajo el Mismo Techo: The Latino Community in Suburban Chicago: An Analysis of Overcrowded Housing, page 21 Riverside County’s Hispanic overcrowding rate is 13.9%. In contrast, the City’s Hispanic overcrowding rate is 16%.

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Although Hispanics experience disproportionate needs regarding overcrowding, the City’s affordable housing stock serves large families well. The following tax credit rental affordable housing developments contain apartment units meeting the space needs of large families:
§ Arroyo de Paz I: 20 3-bedroom units and 12 4-bedroom units § Arroyo de Paz II: 12 3-bedroom units and 8 4-bedroom units § Brisas de Paz: 25 3-bedroom units
§ Verbena Crossing: 48 3-bedroom units
§ Desert Horizons: 11 3-bedroom units
Altogether these five developments contain 116 3-bedroom units and 20 4-bedroom units.

2. Contributing Factors to Disparities in Access to Opportunity According to the AFFH Rule:

Preparation of an AFH could be an important step in reducing poverty among groups of persons who share characteristics protected by the Fair Housing Act. The focus and purpose of the AFH is to identify, and to begin the process of planning to overcome, the causes and contributingfactors that deny or impede housing choice and access to opportunity based on race, color, religion, sex, national origin, familial status, and disability.

Federal Register July 16, 2015, page 42283
Increasing the number of families with incomes above the poverty level will help to alleviate housing problems such as severe cost burdens (and, perhaps, cost burdens) and overcrowding.

Poverty reduction strategies focused at the neighborhood level also will help to enhance access to opportunity.

The Community Action Partnership (CAP) has concluded that poverty contributes to several problems. According to the CAP:

The primary contributing factors to poverty (labeled as such instead of causes, since there is not comprehensive evidence for, or agreement on, what the various causes are) in Riverside County appear to be (in no specific order):

Employment (availability of jobs, or wages paid in the available jobs) Lack of higher educational/vocational skill attainment, race (especially in connection with Hispanic or Latino, Black/African American, and Native American individuals/families); and
The high cost of living (demonstrated by needs identified in such areas as housing, utility bills, health care, transportation, food, etc.).

From community members and key informant interviews, the policy issues expressed as contributing factors included:

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Income eligibility thresholds that are far too low, which therefore disqualify residents in need from receiving services, and
Restrictive regulations and costs for developing affordable housing.

Conditions ensuing from these contributing factors are evidenced in the priority needs which have been identified. Among the priority needs are utility assistance and housing assistance.

Source: County of Riverside Community Action Partnership, 2020-2021 Community Action Plan, submitted to California Department of Community Services and Development/Community Services Block Grant, pages 11 and 12 O. FAIR HOUSING PRIORITIES, GOALS AND STRATEGIES
The fair housing priorities, goals and strategies are set forth in the context of the following:
§ Findings and conclusions drawn from the research and analysis conducted to prepare the Assessment of Fair Housing.
§ Findings and conclusions drawn from completion of the Assessment of Housing Needs (Appendix A), especially in regard to cost burdens, severe cost burdens, overcrowding and the special needs of the elderly, families with children, female householders, and large families.
§ City’s share of the regional lower income housing need (N=1,104 housing units) § Findings and conclusions drawn from the analysis conducted on the sites inventory to affirmatively further fair housing in Part F, Appendix C Sites Inventory and Analysis. § Fair housing services, resources and experience of the staff at the Fair Housing Council of Riverside County, Inc.

1. Priorities
§ Addressing the disproportionate housing needs experienced by Hispanic and Black households.
§ Producing affordable housing that accommodates the housing needs of fair housing protected groups such as the elderly, frail elderly, disabled, families, and veterans.
§ Increasing the community’s awareness of fair housing (e.g., renters, on-site property managers, City staff (Planning, Housing, and Code Enforcement), and City commissions.

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2. Goals
§ Enhance the City’s ability to affirmatively further fair housing through the implementation of effective strategies, outreach to County Departments and agencies including the Community Outreach Branch of the Department of Public Social Services, and Coachella Valley Association of Governments (CVAG) § Reduce poverty by increasing incomes so that cost burdens and overcrowding are reduced, particularly for the population living in neighborhoods with the lowest resources.

3. Strategies
§ Adopt a policy that new affordable housing developments must implement an Affirmative Fair Housing Marketing Plan, a plan that describes specific steps that will be taken by developers to ensure that renters and buyers who are unlikely to apply for housing without special outreach have equal access to housing opportunities available in new housing developments.

Refer to Attachment A for an example.
§ Develop and implement a poverty reduction strategy focused on the neighborhoods with the lowest access to opportunity as identified by the TCAC/HCD Opportunity Mapping Tool.

Attachment B describes the City’s poverty reduction strategy and placed-based strategies to improve access to opportunity.
§ Develop and implement mobility strategies which fall within the capabilities of the City.

Attachment C describes the mobility strategies.

The action programs to implement the priorities, goals, and strategies to affirmatively further fair housing are described in Section II.

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Attachment A
City of Desert Hot Springs
Affirmative Fair Housing Marketing Plan
A. Targeting. Identify the segments of the eligible population which are least likely to seek housing without special outreach efforts.
a. Consider the current racial and ethnic composition of Desert Hot Springs. b. Also consider language barriers (especially Hispanic population in the City) and income eligibility requirements.
c. Obtain the assistance of the Fair Housing Council of Riverside County, Inc. to develop targeting efforts.

B. Outreach. Outline an outreach program which includes special measures designed to attract those groups identified as least likely to seek housing and other efforts designed to attract persons from the total population.
a. Community Contacts. The affordable housing developer should list at least one community organization that serves each group determined to be least likely to seek housing and who has agreed to help the developer in their marketing efforts. In the plan include the name of the contact person, contact information, experience working with the target population as well as the number and languageof materials to be provided to such agencies.
b. Media. The housing developer should specify the particular means of advertising to reach a target group and the reasoning behind the particular type of advertising.

Advertisements should include the fair housing logo.
c. If the immediate housing market area is not demographically diverse enough to draw applicantsconsidered “least likely to apply” then an expanded housing market area should be used.

C. Indicators. Describe the indicators to be used to measure the success of the marketing program.
a. Recording information on how an individual heard about the housing and why they decided toseek that housing will provide useful data for the evaluation process. b. In addition, comparing the number of units now occupied by persons previously determined tobe “least likely to apply” and the number of people least likely to apply on the waiting list prior to and after the marketing process is a starting place for the evaluation.

D. Staff Training. Demonstrate the capacity to provide training and information on fair housing laws and objectives to sales or rental staff.

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Attachment B
City of Desert Hot Springs
Poverty Reduction Strategy
And
Place-Based Strategies to Improve Access to Opportunity

1. American Rescue Plan Policies
State, County and City efforts to reduce poverty cannot match the impact of those of the federal government. The American Rescue Plan poverty reduction efforts will more than likely lower the poverty rate in 2021 and 2022 to below 30% for all census tracts/neighborhoods located in Desert Hot Springs, including those with the lowest resources. Housing concerns such as severe cost burdens and overcrowding can be mitigated when households experience income gains. It is unlikely that severe cost burdens and overcrowding can be reduced by housing production, including affordable housing production, alone. Household incomes need to increase in conjunction with the production of housing in order to reduce the number of severely cost burdened lower income households.

The City will work with the County and sub-regional agencies to ensure that neighborhood residents are aware of the American Rescue Plan programs and existing programs such as the Earned Income Tax Credit (EITC).

The Urban Institute projects that for 2021 the American Rescue Plan Act will reduce the national poverty rate by one-third. Furthermore, the Urban Institute projects that poverty would fall 42% for Black, non-Hispanic people and 39% for Hispanic people compared with 34% for white, nonHispanic people, thus reducing the disparities in poverty rates for Black, non-Hispanic people and Hispanic people relative to white, non-Hispanic people.

The Urban Institute explains that four key pieces of the legislation will each have direct impacts on families’ economic resources.

Unemployment insurance (UI) benefits: The UI elements of the American Rescue Plan build on and extend the legislation passed in December 2020. Before the passage of the December bill, many unemployed people were set to exhaust their benefits at the end of the year. The December legislation provided 11 additional weeks of benefits and added $300 a week to regular state benefit amounts through the middle of March 2021. This new legislation adds another 25 weeks of benefits (almost six months), including the additional $300 a week, from mid-March through September 6, 2021. The new legislation would also extend the special pandemic UI program for people who do not usually qualify for UI (self-employed and gig workers) from its previous expiration date in March to September.

Supplemental Nutrition Assistance Program (SNAP or “food stamps”) benefits: The SNAP aspects of the American Rescue Plan also build on the legislation passed in December 2020, which increased the maximum monthly SNAP benefit 15% through June 30, 2021. The American Rescue Plan extends the period for increased SNAP benefits by three months, to September 30, 2021.

Recovery Rebate Payments: The legislation provides a one-time payment of $1,400 ($2,800 for married couples), with an additional $1,400 for each dependent. Unlike previous legislation, this legislation allows dependents of any age to be eligible for the rebate, not only children under age

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17. The payments begin to phase out at income levels of $75,000 for single filers, $112,500 for head-of-household filers (such as single parents with children), and $150,000 for married couples.

The lower income and poverty income families living in the City’s lowest resource neighborhoods will be eligible for the full recovery payments.

Child Tax Credit: The legislation makes several changes to the child tax credit for tax year 2021.

It makes the credit fully refundable, increases the amount to $3,600 per child under age 6 and $3,000 per child age 6 and older, allows the credit to be taken on behalf of a 17-year-old (the prior maximum age was 16), and provides for monthly advance payments of the credit beginning in July.

The increased amount of the credit (the additional $1,000 or $1,600 per child above the currentlaw amount of $2,000) begins to phase out at income levels of $75,000 for single filers, $112,500 for head-of-household filers, and $150,000 for married couples. Half of the credit would be issued in advance payments beginning in July 2021; the remaining credit would be delivered in 2022.

The lower income and poverty income families living in the City’s lowest resource neighborhoods will be eligible for the full child tax credits.

Additional antipoverty effects, the Urban Institute has explained, would likely arise from other provisions aimed at addressing economic hardship, including increasing funding for rental assistance; the Low-Income Home Energy Assistance Program; and the Special Supplemental Nutrition Program for Women, Infants, and Children, as well as exempting a portion of UI income received in 2020 from federal income taxation.

Estimates have been made that the child tax credit will reduce poverty by half. When combined with the State’s new stimulus aid, the payments could lift millions of Californians out of poverty.

California’s Golden State Stimulus package includes $600 one-time payments to households receiving the state’s earned income tax credit.

Sources:

Cal Matters, ‘Revolutionary’ Federal Stimulus Bill Could Cut California Poverty by Half, March 11, 2021, Author: Jackie Botts, 8 pages
Parolin, Zachary, Sophie Collyer, Megan A. Curran, and Christopher Wimer. 2021. "The Potential Poverty Reduction Effect of the American Rescue Plan." Center on Poverty and Social Policy, Columbia University. www.povertycenter.columbia.edu/news-internal/2021/presidentialpolicy/bideneconomic-relief-proposal-poverty-impact The Century Foundation, The American Rescue Plan Could Cut Child Poverty in Half, March 9, 2021, 3 pages
Urban Institute, 2021 Poverty Projections: Assessing Four American Rescue Plan Policies, March 2021, 15 pages; Authors: Laura Wheaton, Sarah Minton, Linda Giannarelli and Kelly Dwyer

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The TCAC/HCD Opportunity Tool includes three measures which are associated with poverty:
§ Poverty: % of the population with income above 200% of the federal poverty line § Student Poverty: % of students not receiving free or reduce-price lunch § Poverty Tracts: census tracts with at least 30% of the population falling under the federal poverty line
Within the City’s lowest resource census tracts/neighborhoods, the American Rescue Plan will likely –
§ Increase the population with income above the 200% of the federal poverty line § Reduce the student poverty
§ Lower the poverty rate below 30% in all of the lowest resource neighborhoods With reduced food insecurity and more income, the secondary benefits of the American Rescue Plan could be better academic performance (math proficiency, reading proficiency) and an increase in high school graduation rates.

In the aggregate, the American Rescue Plan policies will lead to improvements in several of the opportunity mapping measures and could lift some of the City’s lower resource neighborhoods to a moderate resource category and thereby improve access to opportunity.

The City will work with the Community Action Partnership to ensure that families living in the lowest resource neighborhoods are aware and make use of the programs available through the American Rescue Plan. Information also will be disseminated on existing programs that benefit poverty income families such as the Earned Income Tax Credit (EITC).

2. Earned Income Tax Credit (EITC)
The earned income tax credit (EITC) provides substantial support to low- and moderate-income working parents, but very little support to workers without qualifying children (often called childless workers). Workers receive a credit equal to a percentage of their earnings up to a maximum credit.

Both the credit rate and the maximum credit vary by family size, with larger credits available to families with more children. After the credit reaches its maximum, it remains flat until earnings reach the phase out point. Thereafter, it declines with each additional dollar of income until no credit is available (figure 1).

By design, the EITC only benefits working families. Families with children receive a much larger credit than workers without qualifying children. (A qualifying child must meet requirements based on relationship, age, residency, and tax filing status.) In 2020, the maximum credit for families with one child is $3,584, while the maximum credit for families with three or more children is $6,660.

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In contrast to the substantial credit for workers with children, childless workers can receive a maximum credit of only $538. Moreover, the credit for childless workers phases out at much lower incomes. Also, childless workers must be at least 25 and not older than 64 to qualify for a subsidy—restrictions that do not apply to workers with children. As a result of these tighter rules, 97 percent of benefits from the credit go to families with children.

Source: The Tax Policy Center, Briefing Book: Key Elements of the U.S. Tax System, What is the Earned Income Tax Credit, page 2
EITC is one of the most efficient anti-poverty programs Unclaimed EITC dollars are never spent on local business, fewer jobs are created or supported, fewer wages are paid, and eventually less tax revenue goes to state and local governments.

Based on conservative estimates of an EITC non-filer rate of 20% and 75% of the tax credit received by filers, the Riverside County negative consequences include:
§ EITC Returns Unclaimed: 71,643
§ Average EITC: $1,892
§ Unclaimed EITC Payments: $135,547,000
§ 80% Spent Locally: $108,437,600
§ Foregone Output: $161,135,715 (multiplier effect)
§ Foregone Jobs: 1,033
§ Foregone Labor Income: $56,722,365
Antonio Avalos, Ph.D., University Business Center, California University, Fresno, The Costs of Unclaimed Earned Income Tax Credits to California’s Economy: Update of the “Left on the Table” Report, March 2015, 28 pages
Consequently, it is important that poverty income householders living in low resource neighborhoods become aware of the benefits of filing for the EITC.

Table B-33 shows the 2021 EITC parameters.

Chart B-1 is a graph showing how the EITC works.

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Table B-3433
EITC 2021 Parameters
Credit
Rate
(Percent)
Minimum
Income for
Maximum Credit
Maximum
Credit
Phase-out Rate
(Percent)
Phase-out Range[1]
Beginning
Income
Ending
Income
No children [2] 15.3 9,820 1,502 15.3 11,610 21,427
One child 34 10,640 3,618 15.98 19,520 42,158
Two children 40 14,950 5,980 21.06 19,520 47,915
Three children 45 14,950 6,728 21.06 19,520 51,464
[1] Beginning in 2002, the values of the beginning and ending points of the phase-out range were increased for married taxpayers filing jointly. The values for these taxpayers were $1,000 higher than the listed values from 2002-2004, $2,000 higher from 2005-2007; $3,000 higher in 2008; $5,000 higher in 2009; $5,010 higher in 2010; $5,080 higher in 2011; $5,210 higher in 2012; $5,340 higher in 2013; $5,430 higher in 2014; $5,520 higher in 2015; $5,550 higher in 2016; $5,590 higher in 2017; $5,690 higher for families with children and $5,680 for families without children in 2018; $5,790 for families with children and $5,800 for families without children in 2019; $5,890 higher in 2020; $5,950 higher for families with children and $5,940 higher for families without children in 2021. [2] Parameters for filers with no custodial children at home ("childless" filers) were updated on March 19, 2021 to reflect the temporary expansion of the Earned Income Tax Credit enacted as part of the American Rescue Plan Act of 2021.

Table does not reflect all elements of the 2021 expansion, such as those relating to eligibility age and eligibility for post-secondary students, former foster children, and homeless youth. For additional information, see Congressional Research Service, "The American Rescue Plan Act of 2021 (ARPA; H.R. 1319) Title IX Subtitle G—Tax Provisions Related to Promoting Economic Security," updated March 1, 2021.

Sources: 1975-2003: Joint Committee on Taxation; Ways and Means Committee, 2004

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Chart B-1
Earned Income Tax Credit (EITC) Parameters
Earned Income Tax Credit 2020

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3. Place-Based Poverty Reduction Strategies
a. Poverty Measures and Poverty Thresholds
Measuring poverty is a two-step process:
§ Establishing a poverty threshold which is the amount of money needed to achieve a minimum level of material well-being.
§ Estimating families’ cash and non-cash resources and comparing them to the poverty threshold to determine whether a family is below it and, therefore, defined as “poor”.

Examples of official federal 2020 poverty thresholds are:
§ 1 person less than 65 years of age $13,465
§ 2 people, householder less than 65 years of age $17,331 § 3 people, 1 child less than 18 years of age $20,832
§ 4 people, 2 children less than 18 years of age $26,246 b. Community Action Partnership
The County of Riverside Community Action Partnership uses census data to identify poverty pockets in its services territory. Outreach is done in these areas, and partnerships and community projects are then developed to target and engage these high-needs communities. Additional distressed communities are brought to light through the countywide community needs assessmentsor demand for services. The County of Riverside Community Action Partnership utilizes its CAP Mobile to provide services and information to remote, rural communities.

The City will undertake the following strategies and actions to improve the well-being of the most income-poor pockets:

The City staff will work cooperatively with the Community Action Partnership staff to determine:
§ The criteria and census/ACS data used to identify pockets of poverty § The City staff will then complete research to identify the pockets of poverty that exist in Desert Hot Springs (using block or block group data). § The City staff will prepare a profile of information on housing, demographics, and wellbeing (health insurance, use of SNAP, use of public assistance). § The City staff will then work with the CAP staff to deliver in-house services and community projects that will provide beneficial impacts to the residents of the pockets of poverty.

The County of Riverside Community Action Partnership service delivery system follows three parallel avenues: 1) programs directly administered by CAP Riverside (in-house); 2) programs funded by the County of Riverside Community Action Partnership through a Request for Proposal (RFP) process (subcontracted); and 3) programs established as “demonstration” programs.

Participants are encouraged to cross-enroll in programs to maximize resources for achieving selfsufficiency.

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In-house programs include:
§ Energy Services (utility bill payment assistance, energy conservation education, and home weatherization services);
§ Alternative Dispute Resolution (mediation, arbitration, peer mediation training, and community education workshops);
§ Pre- Apprenticeship Programs (youth workplace mentor / job training program); § On-the-job training for veterans (Veterans Education and Employment Program); § Earned Income Tax Credit (EITC),
§ Free Tax Preparation Program (Volunteer Income Tax Assistance - VITA), and year-round free tax-preparation;
§ Saving for Success (an asset-building savings match program for buying a home, continuing education or starting/expanding a business); and § Disaster preparedness and relief (Cool /Warm Centers, etc.). c. County of Riverside Anti-Poverty Strategy
The County of Riverside adopts an anti-poverty strategy as a key component of the 2019-2024 Consolidated Plan. Poverty reducing activities adopted as part of the strategy include, but are not limited, to:
§ Encourage economic development and economic opportunity in the low and moderate income areas
§ Provide Job Training and Life Skills Development
§ Provide programs and services offering education and wealth building opportunities
d. Targeted Mortgage Credit Certificate (MCC) Program
The program provides incentives for higher income homebuyers to purchase homes in high poverty neighborhoods. The County MCC Program targets the following Desert Hot Springs census tracts: 445.07, 445.09, 445.10, 445.15, 445.21, and 472.01.

An MCC is a federal income tax credit designed to assist low income households to afford home ownership. With an MCC, the qualified homebuyer is eligible to write off a portion of the annual interest paid on the mortgage as a special tax credit, not to exceed $2,000, during each year that they occupy the home as their principal residence. The portion or amount of thetax credit is equal to the mortgage credit rate on the MCC (for example 35%) multiplied by the annual interest paid. This credit reduces the federal income taxes of the buyer, resulting in an increase in the buyer’s net earnings. Increased buyer income results in increased buyer capacityto qualify for the mortgage loan. The MCC has the potential of saving the MCC holder thousandsof dollars over the life of the loan.

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An incentive to attract buyers to the MCC target areas in Desert Hot Springs is that the maximum purchase price is $480,527. Outside of target areas the maximum purchase price is $393,158.

Inside the target area, the maximum income is $105,420. Outside the target area it is $86,595.

Both the maximum purchase price and maximum income limits may attract moderate income households to neighborhoods with the lowest resources. Overtime neighborhoods could improve their Opportunity Mapping indicators and measures such as median home values and, perhaps, educational attainment.
e. At-Risk Housing Monitoring
Housing Element law requires jurisdictions to provide an analysis and program for preserving affordability of assisted housing developments for the next 10 years. Based on City records and information from the California Housing Partnership Corporation, in the next 10 years (up to 2031) no assisted housing developments in Desert Hot Springs are at risk of losing their affordability status.

Although the City has not identified any housing units at risk of converting to market rate housing during the planning period, City staff will monitor the status of existing and future affordable housing developments. Should any of the properties become at risk of converting to market rate, the City will work with property owners, interest groups, and the State and federal governments to conserve the affordable housing stock.

Table B-34 lists the City’s affordable rental stock and shows the census tract and block group location. All affordable housing projects are at a low risk of conversion to market rate housing.

Table B-3534
City of Desert Hot Springs
Affordable Housing Projects
Property Address
Low
Income
Units
Total
Units
Funding
Source
Census
Tract
Block
Group
Casa del Sol & Casa West
Apartments (Site A)
66555 Fourth St. 154 156 LIHTC/USDA 445.09 1
Desert Horizon Apartments 66789 Two Bunch Palms Trail 43 44 LIHTC/USDA 445.16 2 Arroyo de Paz I Apartments 66765 Two Bunch Palms Trail 59 60 LIHTC 445.16 2 Arroyo de Paz II Apartments 66765 Two Bunch Palms Trail 34 34 LIHTC 445.16 2 Brisas de Paz 65921 Flora Avenue 61 62 LIHTC 445.07 1
Desert Hot Springs Portfolio -
(Linda Vista Site A)
67200 Hacienda Avenue, 97 99 LIHTC 445.10 1
Hacienda Hills 67150 Hacienda Avenue 59 60 LIHTC 445.10 1 Verbena Crossing Apartments 66950 Ironwood Drive 94 96 LIHTC 445.10 2 Desert Hot Springs 11190 Mesquite Avenue 20 79 HUD 445.09 1

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Attachment C
Description of Mobility Strategies

1. County of Riverside Housing Authority Housing Opportunity Area Maps The City will coordinate with the Housing Authority to implement mobility strategies. At a minimum, the City will post on its website the Housing Opportunity Area Maps and describe the workshops to be conducted during the 8-year planning period by the Fair Housing Council of Riverside County, Inc.

The Housing Authority’s Housing Choice Voucher Administrative Plan explains that guidance and materials are offered to assist a family in selecting a housing unit. The staff indicates to families that they should consider proximity to employment, public transportation, schools, shopping and the accessibility of services.

During briefings sessions the Housing Authority encourages families to move to high opportunity areas by explaining the advantages of moving to an area that may offer better quality housing, education and employment opportunities. The Housing Authority provides families with Housing Opportunity Area Maps that cover the Coachella Valley and western Riverside County.

2. Information on Source of Income Discrimination
In addition, the City will provide residents with information explaining that California law prohibits source of income discrimination. The California Fair Employment and Housing Act (FEHA) prohibits housing providers, such as landlords, to refuse to rent to someone, or otherwise discriminate against them, because they have a housing subsidy, such as a Section 8 Housing Choice Voucher, that helps them to afford their rent.

Awareness of that State law prohibiting source of income discrimination will expand the neighborhoods in which Section 8 Housing Choice Voucher holders may seek rental housing.

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APPENDIX C SITES INVENTORY AND ANALYSIS
A. GOVERNMENT CODE REQUIREMENTS
In Government Code Section 65580(f) the California legislature finds and declares that - Designating and maintaining a supply of land and adequate sites suitable, feasible, and available for the development of housing sufficient to meet the locality’s housing need for all income levels is essential to achieving the state’s housing goals ….

Guidance on how to complete the sites inventory and analysis is provided by HCD in the following Guidebook:

California Department of Housing and Community Development, Housing Element Site Inventory Guidebook, June 10, 2020, 44 pages
According to HCD’s Guidebook:

The purpose of the housing element’s site inventory is to identify and analyze specific land (sites) that is available and suitable for residential development in order to determine the jurisdiction’s capacity to accommodate residential development and reconcile that capacity with the jurisdiction’s Regional Housing Need Allocation (RHNA). The site inventory enables the jurisdiction to determine whether there are sufficient adequate sites to accommodate the RHNA by income category. A site inventory and analysis will determine whether program actions must be adopted to “make sites available” with appropriate zoning, development standards, and infrastructure capacity to accommodate the new development need.

Sites are suitable for residential development if zoned appropriately and available for residential use during the planning period. If the inventory demonstrates that there are insufficient sites to accommodate the RHNA for each income category, the inventory must identify sites for rezoning to be included in a housing element program to identify and make available additional sites to accommodate those housing needs early within the planning period.

The land inventory must identify sites that –
§ Can be developed for housing within the 8-year planning period of 2021 to 2029 § Sufficient to provide for a jurisdiction’s share of the regional housing need for each income level – lower, moderate and above moderate
B. CRITERIA THAT DETERMINE “ADEQUATE” HOUSING SITES
Several criteria must be satisfied by a site to be deemed “adequate” to accommodate Desert Hot Springs share of the RHNA (regional housing needs allocation). For example, sites should be neither too small nor too large and they should be zoned at densities that are appropriate to accommodate the RHNA by income group.

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1. Types of Sites
A “site” is a parcel or group of parcels that can accommodate a portion of the City’s RHNA. There are many types of sites including:
§ Vacant sites zoned for residential use
§ Vacant sites zoned for nonresidential use that allow residential development § Residentially zoned sites that are capable of being developed at a higher density (non-vacant sites, including underutilized sites)
§ Sites owned or leased by a city, county, or city and county § Sites zoned for nonresidential use that can be redeveloped for residential use including a program to rezone the site to permit residential use § Pending, approved, or permitted development
All of the sites listed in the City’s inventory are vacant. None of the sites are owned or leased by a public agency. The moderate and above moderate income sites are located within areas having approved Specific Plans.

2. Residential Densities Appropriate to Accommodate the Lower Income RHNA According to HCD, the housing element statute allows jurisdictions to use higher density as a proxy for lower income affordability, as long as certain statutory requirements are met. Parcels must be zoned to allow sufficient density to accommodate the economies of scale needed to produce affordable housing. To make this determination, the statute allows the jurisdiction to either demonstrate that the zoning allows a specific density set forth in the statute (known as a default density) or to provide an analysis demonstrating the appropriateness of the zoned densities of the sites identified to accommodate the lower income RHNA.

The City’s default density is “at least” 30 dwelling units per acre. “At least”, according to HCD, means the density range allowed on the parcel by the zone has to include the default density. For example, if a jurisdiction has a default density of 30 units per acre and the zone allows for range of 20 – 30 dwelling units per acre, the zoning is considered appropriate to accommodate the RHNA for lower income households.

The City has two zones that permit a density of “at least” 30 dwelling units per acre: R-H and MUC:
§ Residential High
The Residential High (R-H) designation allows for multiple unit developments between 20 and 30 units per acre. This designation is primarily located near transit lines and commercial centers that offer convenient services and amenities to residents. The Zoning Ordinance permits a building height of two to four stories. § Mixed Use Corridor
Mixed-use development refers to an integration of residential and commercial uses as part of a cohesive development plan, with the residential component either in the same building as the commercial (vertical mixed use) or on an adjacent lot with a clear relationship to the commercial use (horizontal mixed use). Mixed-use projects must include a viable neighborhood-serving retail and service component.

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The MU-C Zone permits housing with densities between 20 and 30 dwelling units per acre.

The Zoning Ordinance permits a building height of two to four stories.

3. Size of Sites
To be deemed adequate to accommodate housing for lower income households, the size of sites should be neither too small nor too large.
a. “Small” Sites Are Inadequate
A parcel smaller than one half acre is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible.

None of the sites included in the City’s sites inventory are smaller than one half acre. b. “Large” Sites Are Inadequate
Parcels larger than 10 acres, according to HCD, are considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on such sites was successful during the prior planning period, or there is other evidence that the site is realistic and feasible for lower income housing.

None of the sites included in the City’s sites inventory are larger than 10 acres.

4. No Net Loss Law
The “no net loss” law encourages cities to identify in the land inventory sites with a total housing unit capacity that exceeds the RHNA allocation for each income group. HCD provides the following guidance:

To comply with the No Net Loss Law, as jurisdictions make decisions regarding zoning and land use, or development occurs, jurisdictions must assess their ability to accommodate new housing in each income category on the remaining sites in their housing element site inventories. A jurisdiction must add additional sites to its inventory if land use decisions or development results in a shortfall of sufficient sites to accommodate its remaining housing need for each income category.

To ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period, it is recommended the jurisdiction create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower income RHNA. Jurisdictions can also create a buffer by projecting site capacity at less than the maximum density to allow for some reductions in density at a project level.

Source: California Department of Housing and Community Development, Housing Element Site Inventory Guidebook, June 10, 2020, page 22

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5. Sites to Affirmatively Further Fair Housing
AB 686 requires a jurisdiction’s site inventory “…shall be used to identify sites throughout the community, consistent with…” its duty to affirmatively further fair housing. The identified sites must be evaluated relative to segregation and integration, racially and ethnically concentrated areas of poverty, areas of affluence, access to opportunity, and disproportionate housing needs.

HCD has stated that the California Tax Credit Allocation Committee/California Department of Housing and Community Development Opportunity Maps are one possible resource that jurisdictions may use to identify “low” resource areas and “areas of segregation and concentration”.

Another resource for identifying “acceptable” compared to “non-acceptable” neighborhoods as a location for affordable housing is HUD’s definition of “racially/ethnically concentrated areas of poverty.” The data presented in Appendix B – Assessment of Fair Housing – demonstrates that Desert Hot Springs has no R/ECAPs. TCAC/HCD uses a 30% poverty threshold compared to HUD’s poverty threshold of 40%.

C. SITES TO ACCOMMODATE THE ABOVE MODERATE INCOME RHNA OF 2,081

HOUSING UNITS
The Skyborne and Tuscan Hills Specific Plans are the primary sites that accommodate the RHNA above moderate income housing need of 2,081 housing units. There is additional low density residential vacant land and vacant land in other approved Specific Plans such as Highland Falls and Two Bunch Palms. However, Skyborne is identified as a site because it is currently under development and Tuscan Hills is likely to commence development sooner than the other Specific Plans. In addition, as described below, a number of smaller-scale tracts and infill lots are available to meet the RHNA allocation for above moderate income households. Together Skyborne and Tuscan Hillsthese sites have sufficient housing to accommodate the above moderate income RHNA.

1. Sales Prices
New single family housing in the master planned communities will probably have similar housing prices. As of March 2021, the pricing of yet to be built single family homes is approximately $350,000+, a price likely to increase in the years ahead as new phases of development are constructed.

Housing priced at $350,000 or more will necessitate above moderate incomes for most purchases.

The average household size of home owners living in the City is 2.7. The 3-person above moderate income limit in Riverside County is $81,300 or more. The annual income translates to a monthly income of $6,775. Using the ability to pay standard of 30% means that an affordable housing payment should not exceed $2,032.50 (.30 X $6,775).

APPENDIX C SITES INVENTORY AND ANALYSIS
C-5
A monthly income of approximately $7,440 will be needed to “afford” a new home with a purchase price of $350,000:
§ $350,000
§ 10% down payment
§ $315,000 loan
§ 2.75% interest rate
§ Monthly Payment
ü $1,286.00 Principal and Interest
ü $386.00 Property Taxes
ü $116.00 Hazard Insurance
ü $95.00 Private Mortgage Insurance
ü $350.00 HOA - Homeowner’s Association Fee
ü $2,233.00 [$7,440 x .30 = $2,232]
The monthly payment stated above may underestimate total cost because the interest rate is based on a borrower FICO score of 740 or higher. Borrowers with a lower FICO score will have a loan payment with a higher interest rate. It also is possible that in the years ahead interest rates may be generally higher due to inflation, strength of the economy leading to more purchasing power, more demand to buy homes and Federal Reserve monetary policy.

Skyborne sales price in the summer of 2021 have ranged between $350,000 and $375,000.

2. Skyborne Specific Plan
a. Project Background and History
The original project proposed for this site was the Olympus Golf Course Specific Plan No. 287 approved by the County of Riverside. This project was never constructed and the property was subsequently annexed into the City of Desert Hot Springs on January 2, 1993.

In 2004, following the annexation, the City approved the StoneRidge Specific Plan (original Specific Plan) for 2,140 residential units including the following entitlements: the StoneRidge Specific Plan, General Plan Amendment 02-04 (GPA), Change of Zone 02-04 (CZ), Development Agreement 01-04 (DA) and Tract Maps 32029 and 32030. An Environmental Impact Report was also prepared and adopted (SCH No. 2004061026) for the project and permits issued by the California Department of Fish and Wildlife and U.S. Army Corps of Engineers.

In 2006, the project name was changed from “StoneRidge” to “Skyborne” and construction began.

However, in 2008, the local and national housing markets experienced a sudden and rapid collapse. During the ensuing recession, construction stalled, home sales stopped and the property was eventually sold to the current owner.

As of today Villages I, II and III have recorded tract maps. The balance of the residential Villages (IV-IX) remain vacant but have active Tentative Tract Map approvals due to vesting derived from a Development Agreement between the owner and the City and a series of State-mandated time extensions. In order to develop, the Tentative Tract Maps must be recorded, and Development Review must be conducted for the home models. Following approval of the Development Review permit, building permits will be necessary for the individual homes within each Village. As described in Appendix D, Section G.1., the Development Review process addresses compliance with Zoning (and Specific Plan) standards, and can be approved by the Planning Director.

APPENDIX C SITES INVENTORY AND ANALYSIS
C-6
The approved Development Agreement for the project vests the master map for the entire site, thereby facilitating future sub-sections of the project, which are implementing the Villages in phases. The Development Agreement does not include any limitations for development, and in fact contains an aggressive schedule of performance for the housing units.

Other project components have also progressed since the original approval. Several are clustered along Karen Avenue and include an 11.7 acre parcel acquired by the Palm Springs Unified School District (PSUSD) for a future elementary school, creation of an adjacent 6-acre parcel containing land for a future public park development as well as the construction of a new fire station. In addition, perimeter road improvements have occurred, such as the dedication and full construction of Pierson Boulevard along the south boundary and partial width construction and dedication of Karen Avenue and Worsley Road along the east and west boundaries. b. Housing Capacity
Skyborne is a community of traditional single family neighborhoods with proposed and optional active adult residential villages. Standard single family residential lots of varying sizes range from 5,500 to 19,000 square feet. Active adult (55+) neighborhoods include smaller lots ranging in size from 3,400 to 4,500 square feet.

As of June 30, 2021, the 154 housing units in Village I had been constructed, All these housing units are credited toward meeting the 5th Cycle RHNA.

As of June 30, 2021, 53 housing units in Village II had been constructed. All these housing units are credited toward meeting the 5th Cycle Housing Element. The remaining 188 yet to be built dwellings in Village II are credited toward accommodating the 6th Cycle RHNA.

Table C-1 identifies the three project phases, the number of housing units in each of the 10 Villages, and the final and tentative tract maps associated with each Village. The 188 units in Village II are currently (2022) under construction and will be occupied in 2022 and 2023. Given the recent high level of activity, which generated 207 new homes through June 30 of 2021 and an additional 188 in 2022, and the current market in the western Coachella Valley, it is expected that 200 units per year will be developed during the planning period. This would result in 1,400 to 1,600 units of above moderate income residential development, and would meet 67 to 79 percent of the City’s above moderate income RHNA.

The Skyborne Villages II through X accommodate 1,786 above moderate income housing units.

Exhibit C-1 shows the locations and number of housing units in each Village.

APPENDIX C SITES INVENTORY AND ANALYSIS
C-7
Table C-1
City of Desert Hot Springs
Skyborne Specific Plan
Phase Villages
Number of
Housing Units
Residential
Density (du/ac)
Development
Status*
I I 0 4.7 Final
II 188 4.8 Final
III 286 5.0 Final
Subtotal 474
II IV 102 4.6 Tentative
V 411 5.0 Tentative
VI 154 4.6 Tentative
VII 85 4.6 Tentative
Subtotal 752
III VIII 137 4.0 Tentative
IX 241 3.4 Tentative
X 182 3.2 Tentative
Subtotal 560
Total 1,786

APPENDIX C SITES INVENTORY AND ANALYSIS
C-8
Exhibit C-1
Skyborne Specific Plan

APPENDIX C SITES INVENTORY AND ANALYSIS
C-9

3. Tuscan Hills Specific Plan
a. Project Background and History
Tuscan Hills is located along the north side of Pierson Boulevard, east of Foxdale Drive. (APN's 638-340-003, 005, 006, 007, & 638-330-001, 002, 003, & 632-270-006).

In 2019, the Tuscan Hills Specific Plan (02-16) was approved with approved TTM No. 36774 for future development. The approved TTM includes 564 single family residential lots. Other TTM will follow for entitlements for residential development. These TTMs will be accompanied by Development Review permits for the model homes, which is an analysis of conformance with the Zoning (and Specific Plan) standards for the project, as described in Appendix D. The housing production within the Tuscan Hills Specific Plan will be at market rate and it is expected that this housing type will meet the moderate and above moderate housing need.

The Specific Plan also has commercial components that include retail and hospitality uses. The commercial component will benefit the future residents of Tuscan Hills in that retail uses will be nearby, and this can minimize vehicle miles traveled (VMT) and help create an urban environment. The design standards encourage pedestrian activity and design features that will enhance the quality of living of future residents.

The Development Agreement is scheduled to go to City Council in October 2021June or July of 2022, and this process has generated interest from developers. The amendment is required to add the potential for 300± hotel rooms within the project, and contains no restrictions on development of housing.

Phasing for the Tuscan Hills Specific Plan project will be clearly established with the review of each tentative tract map for the project. The applicant has indicated thate “establishing phasing at the Project’s Specific Plan stage for such a large project is virtually impossible considering the ever-changing market demands.”
Single-family and multifamily uses will require a Development Permit subject to approval by either Director (administrative) or by the Planning Commission, with the decision on the final authority to be determined by the Community Development Director. b. Housing Capacity
Table C-2 describes the housing types by Planning Area, planning area size, and housing capacity.

Housing capacity is calculated at 80% of the maximum density. For example, the Low Residential designation is calculated at 4.8 du/ac instead of the up to 6 du/ac.

The housing capacity of the very low and low residential designations is 340 housing units. The 340 housing units accommodate a portion of the 6th Cycle RHNA above moderate income housing need. Given the production and sales history at the Skyborne site, it is expected that all of these units will be developed during the planning period, representing 16% of the City’s above moderate income RHNA.

APPENDIX C SITES INVENTORY AND ANALYSIS
C-10
Together the Skyborne and Tuscan Hills Specific Plans accommodate 2,126 above moderate income housing units, which exceed the RHNA allocation of 2,081 housing units.

Table C-2
Tuscan Hills Specific Plan
Description of Land Use by Planning Area and Housing Capacity Land Use
Designation Housing Type PlanningArea
Planning
Area Size
Housing
Capacity
Very Low
Residential1
DU/5 ac (VLR)
This land use provides an
intermediate density between
more typical residential densities
and open space lands. It provides
lots sufficient in size for rural and
estate development.

Lot-10 47.95 ac 10
Low Residential
Up to 6 du/ac
(LR)
The intent of this designationis to
encourage development
of single-family detached
residential, product in a planned
environment.
lot-3 36.85 ac 176
lot-4 23.02 ac 110
lot-5 9.17 ac 44
Together the Skyborne and Tuscan Hills Specific Plans accommodate 1,740 to 1,940 above moderate income housing units, which represents 84 to 93 percent of the RHNA allocation of 2,081 above moderate income housing units.

In addition, several other projects and infill lot construction are currently under way:
• Agua Dulce is a 126 lot subdivision located south of Two Bunch Palms Trail and west of Palm Drive. 53 units were built in the previous cycle. 73 units are currently under construction, which will complete the tract.
• Tract Map 32360 and 33643 consist of 41 lots located south of Pierson Boulevards, between Avenida Loreto and Cholla Drive, 10 of which have been completed, and 31 of which will be completed in the current planning period. • Watermarke/Tract 31235 consists of 11 units under construction on Avenida Dorado. • The City has seen a significant increase in infill lot single family home building permits throughout the City. In 2019, only 4 permits were issued. In 2021, more than 50 permits were issued. Given that the City has hundreds of undeveloped Low Density single family lots, and the market for housing is strong, it can be expected that the City will see between 25 and 50 infill single family homes annually throughout the planning period, resulting in between 200 and 400 new homes for above moderate income households.

With the inclusion of existing projects described above, the City has realistic capacity for between 2,035 and 2,340 new above moderate income units during the planning period, which will be sufficient to meet the City’s RHNA allocation.

APPENDIX C SITES INVENTORY AND ANALYSIS
C-11
Exhibit C-2
Tuscan Hills Specific Plan

APPENDIX C SITES INVENTORY AND ANALYSIS
C-12
D. SITES TO ACCOMMODATE THE MODERATE INCOME RHNA OF 688 HOUSING UNITS

1. Aventura Palms
Aventura Palms is an entitled 11576-unit condominium single-family residential development under the Rancho Descanso Specific Plan (October 14, 2021). The 76 housing units are identified as accommodating the moderate income housing need.

2. Marbella Villas
Marbella Villas is an entitled condominium development consisting of 402 housing units on a vacant 25 acre site (16 dus/ac). The property is identified as Assessor Parcel Nos. 656-030-005, -006, -007, and -008 and is located on the west side of Palm Drive north of 15th Avenue.

The applicant plans to construct the project in eight phases, beginning in late 2022, with an estimated completion in late Fall of 2025.

3. Tuscan Hills Specific Plan
Table C-3 describes the housing types by Planning Area, planning area size, and housing capacity. Exhibit C-3 shows the locations of each Planning Area.

The Tuscan Hills medium residential permits up to 15 du/ac. Housing capacity is calculated at 80% of the maximum density – that is, at 12 du/ac instead of 15 du/ac.

The total housing capacity of the medium density designation is 995 housing units.

Aventura Palms, Marbella Villas, and Tuscan Hills combine to accommodate 1,512 473 moderate income housing units, which exceeds the RHNA allocation of 688 housing units.

Table C-3
Tuscan Hills Specific Plan
Description of Land Use by Planning Area and Housing Capacity Land Use
Designation Housing Type PlanningArea
Planning
Area Size
Housing
Capacity
Medium
ResidentialUp to
15 du/ac (MR)
Allows a range of residential
products including single- family
attached or detached condominiums,
townhomes, zero-lot-line
configurations, and cluster
developments. In addition, this
category allows senior housing agerestricted multi-family communities designed to accommodate the
special needs of seniors.
lot-1, A 52.56 ac 626
lot-2 17.82 ac 213
Lot-6 13.05 ac 156

APPENDIX C SITES INVENTORY AND ANALYSIS
C-13
Aventura Palms, Marbella Villas, and Tuscan Hills combine to accommodate 1,473 moderate income housing units, which exceeds the RHNA allocation of 688 housing units. It is also possible that these sites will accommodate both moderate and above moderate income households, which will provide the City flexibility in accommodating its RHNA for both income categories.

E. SITES TO ACCOMMODATE THE LOWER INCOME RHNA OF 1,104 HOUSING UNITS Tables C-4 and C-5 list the sites that accommodate the lower income RHNA of 1,104 housing units. All the sites listed in Tables C-4 and C-5 have been identified in the previous two housing element cycles. However, these sites are zoned to allow multi-family housing by right, at a density of at least 20 units per acre, and at least 16 units per site, as required by law.

Table C-4 lists eight nine R-H zoned sites, a residential zone that permits new housing at densities in the range of 20 to 30 dwelling units per acre. Therefore, the housing capacity of the sites ranges from a low of 708 to a high of 1,061 housing units. In order to analyze the realistic capacity of these sites, the City considered similar affordable housing projects in the Coachella Valley, since no recent projects in the City provide information on likely housing density for affordable housing units for lower income households. The comparison with other jurisdictions is appropriate because the Coachella Valley is a series of small cities which border each other and which operate as a region. Desert Hot Springs is the western-most city, and is bordered by Palm Springs. All of the cities have similar residential densities and development patterns. Desert Hot Springs has more affordable land values than some of the other cities to the east, making it more attractive to affordable housing developers. As regards density, Desert Hot Springs’ R-H density is consistent with both surrounding cities’ high density residential densities, and the densities being developed in mixed use zones in other cities. The following projects are entitled and either completed, under construction, or pending construction.

Palm Springs
• Monarch Apartments, will provide 60 units affordable to very low and low income households on 3.6 acres, at a density of 17 units per acre. The project is fully funded and broke ground in October of 2021.
• Vista Sunrise II will provide 60 units of special needs housing for extremely low, very low and low income households on 1.5 acres, at a density of 40 units per acre. This project is being developed on a mixed use site which also includes medical clinics and offices operated by DAP Health. The project is fully funded and currently under construction.

Palm Desert
• Carlos Ortega Villas, consists of 72 units on 3.48 acres affordable to very low and low income households, at a density of 21 units per acre. The project was fully funded, built, and is currently operating.
• Vitalia, 270 units affordable to very low and low income households on 12 acres approved in 2021, at a density of 23 units per acre. The project is currently finalizing funding, and is expected to be under construction in 2023.
• Millennium SARDA site, 240 units affordable to very low and low income households on 10 acres, under contract in 2021, at a density of 24 units per acre. The project is approved and preparing construction drawings.

La Quinta
• Coral Mountain Apartments, constructed in 2018, provides 176 units on 11 acres for very low- and low-income households, at a density of 16 units per acre.

APPENDIX C SITES INVENTORY AND ANALYSIS
C-14
Indio
• Arroyo Crossing 1 is currently under construction, and provides 184 units on 6.4 acres affordable to very low and low income households, at a density of 29 units per acre. The project is within one of Indio’s mixed use zones, and includes a retail commercial building to serve the needs of residents of both Arroyo Crossing projects. The project is currently under construction, and occupancy is expected in late 2022 or early 2023. • Arroyo Crossing 2, will provide 216 units affordable to very low and low income households on 7.3 acres, at a density of 30 units per acre. The project was approved in 2021 and is currently finalizing funding. Construction is expected to follow completion of Arroyo Crossing 1, in 2024.

Coachella
• Pueblo Viejo Villas is a 105 unit project for lower income and disabled residents in the City’s mixed use core, which is being redeveloped for a mix of residential, civic and commercial projects surrounding City Hall. The project completed construction in 2022.

These projects represent an average of 25 units per acre, and based on the regional nature of housing in the Coachella Valley, are reflective of the density that the City can expect for future housing projects. On this basis, Table C-4 has been calculated at a density of 25 units per acre.

For purposes of the No Net Loss Law and Program 1.3, the housing capacity of the eight nine sites is 708 1,105 housing units. This will accommodate all of the City’s lower income RHNA on sites zoned solely for residential development. As described below, however, the City also expects to see development of affordable housing on lands designated M-UC, which would add to the potential inventory of lower income sites in the City.

Table C-5 lists five M-UC zoned sites, a mixed-use zone that allows 100% residential at densities in the range of 20 to 30 dwelling units per acre. The M-UC Zone states that the City should encourage 100% residential projects to be built at the maximum density of 30 dus/ac. Assuming 100% residential development, the five sites can accommodate from 412 to 616 housing units.

It is possible that during the eight-year planning period that: 1) one or more sites could be developed as mixed-use, meaning less than 100% residential and 2) the sites could be developed at !100% residential and at a density greater than 20 dwelling units per acre.

The first circumstance would reduce the housing capacity of the M-UC zoned sites. The second circumstance, however, would increase the housing capacity of the M-UC zoned sites. To track how individual projects impact housing capacity, in June 2021, the City prepared a No Net Loss Monitoring Procedure modeled after HCD’s No Net Loss Capacity Calculation Tool.

In the event a project were to be approved at a capacity less than shown in Table C-5, the City will implement Program 1.3 No Net Loss Program.

Table C-4
City of Desert Hot Springs
Vacant Sites Accommodating the Lower Income Housing Need: 2021-2029 General Plan and Zoning Designation of R-H
Minimum Density 20 Dwelling Units Per Acre
Maximum Density 30 Dwelling Units Per Acre
Site Number Size Housing Capacity

APPENDIX C SITES INVENTORY AND ANALYSIS
C-15
APN (Acres) (@25 du/ac)
1 656050006 5.00 100125
2 657230028 3.65 7391
3 657220013 4.98 100125
4 657220016 4.97 99124
5 657290004 4.70 94118
6 657290005 4.78 96120
7 657290006 4.85 97121
8 657290008 2.44 4961
9 657280003 9 of 26 220
Total 35.37 7081,105

APPENDIX C SITES INVENTORY AND ANALYSIS
C-16
Exhibit C-3
Locations of Lower Income R-H Zoned Sites
In addition to the capacity provided in the R-H Zone, Table C-5 lists five M-UC zoned sites, a mixed-use zone that allows 100% residential at densities in the range of 20 to 30 dwelling units per acre. Although the City does not need mixed use sites to meet its lower income RHNA, as demonstrated above, development of residential units in the M-UC zone is also expected during the planning period. The M-UC Zone states that the City should encourage 100% residential projects to be built at the maximum density of 30 dus/ac. Assuming 100% residential development, the five sites can accommodate from 412 to 616 housing units.

It is possible that during the eight-year planning period that: 1) one or more sites could be developed as mixed-use, meaning less than 100% residential and 2) the sites could be developed at 100% residential and at a density greater than 20 dwelling units per acre. #9

APPENDIX C SITES INVENTORY AND ANALYSIS
C-17
The first circumstance would reduce the housing capacity of the M-UC zoned sites. The second circumstance, however, would increase the housing capacity of the M-UC zoned sites.The M-UC designation is new to the City, having been established in the recently approved General Plan.

There is no development history available yet to demonstrate the likelihood that these sites will develop for affordable housing. As described above, in the listing of affordable housing projects in other jurisdictions, mixed use development is beginning to be built in the Coachella Valley. In addition, Site #9, shown in Exhibit C-3, is a larger holding of 26 acres, which contains 9 acres of High Density land, and 17 acres of M-UC land. The City has been approached by the landowner, who wishes to develop at least 220 units of lower income housing on the RH portion, and may also provide additional lower income units on the M-UC portion of the parcel. The applications have not been submitted, but the City is confident in the landowner’s ability to perform. Therefore, M-UC sites shown in Table C-5 may develop as additional lower income housing, but are not required to assure that the City meets its RHNA allocation. To track how individual projects impact housing capacity, in June 2021, the City prepared a No Net Loss Monitoring Procedure modeled after HCD’s No Net Loss Capacity Calculation Tool.

In the event a project were to be approved at a capacity less than shown in Table C-5, the City will implement Program 1.3 No Net Loss Program.

Table C-5
City of Desert Hot Springs
Vacant Sites Accommodating the Lower Income Housing Need: 2021-2029 General Plan and Zoning Designation of MU-C
Minimum Density 20 Dwelling Units Per Acre
Maximum Density 30 Dwelling Units Per Acre
Site Number APN
Size
(Acres)
Housing Capacity
(@20 du/ac)
1 656050012 4.69 94
2 656050013 1.85 37
3 657230028 4.53 91
4 657280015 4.48 90
5 657280016 4.99 100
Total 20.54 412
In order to facilitate development of housing units to meet the RHNA, including units in both the R-H and MU-C zones, Program 2.3 is provided in Section II. It includes incentives, such as the waiver of development fees, deviations in development standards and other incentives to reduce costs and encourage lower income housing production. In addition, this program includes incentives for Site 9, to encourage its subdivision and development for lower income units.

APPENDIX C SITES INVENTORY AND ANALYSIS
C-18
Exhibit C-4
Locations of Lower Income M-UC Zoned Sites

APPENDIX C SITES INVENTORY AND ANALYSIS
C-19
F. SITES TO AFFIRMATIVELY FURTHER FAIR HOUSING
Government Code Section 65583.2(a) states that the inventory of land “shall be used to identify sites throughout the community” consistent with Section 65583(c)(9). The latter Section describes the duty to affirmatively further fair housing which includes an assessment of fair housing involving integration/segregation, racially/ethnically concentrated areas of poverty; access to opportunity; and disproportionate housing needs.

Section F evaluates how the identified sites affirmatively further fair housing. In addition, this section describes how the sites are located geographically in support of the City’s land use framework.

1. Land Use Framework and Geographical Distribution of Housing Sites The identified housing sites are located within the context of the adopted General Plan Land Use Framework. Exhibit C-5 shows the Land Use Framework which includes the Pierson Boulevard Corridor and the Palm Drive Corridor. The Skyborne and Tuscan Hills Specific Plans are located at the western and eastern ends, respectively, of the Pierson Boulevard Corridor.

The lower income housing sites are located along the Palm Drive Corridor. The General Plan Land Use Policy 2.7 states that the “Higher Residential Density Corridor” allows higher density residential and mixed uses along Palm Drive in closer proximity to infrastructure and transit services.

The Palm Drive Corridor Master Plan is the City’s conceptual plan of beautification and circulation improvements to the Palm Drive Corridor between Mission Lake Boulevard on the north and I-10 on the south. The Palm Drive Corridor is the primary gateway entrance to the City’s retail and spa centers. Under the Master Plan, the City intends to provide an array of beautification and circulation improvements to Palm Drive.

The lower income housing sites along Palm Drive are located in close proximity to the job opportunities that will be generated by the Desert Land Ventures Specific Plan. The Specific Plan Area serves as a gateway into Desert Hot Springs due to its high visibility and convenient access from I-10, and also due to its proximity to the Palm Drive Corridor and I-10 on-/off–ramp at Palm Drive.

The Specific Plan ultimately could support just over 1.5 million square feet of industrial uses, just under 360,000 square feet of commercial uses, and 150 hotel rooms. The sites inventory will help improve job-housing balance in the City and increase diverse housing opportunities near jobs, services and amenities to meet the various needs of different income level households.

APPENDIX C SITES INVENTORY AND ANALYSIS
C-20
Exhibit C-5
Land Use Framework

APPENDIX C SITES INVENTORY AND ANALYSIS
C-21

2. Integration/Segregation
a. Dissimilarity Index
The Dissimilarity Indices for the entire City of Desert Hot Springs shows that all racial/ethnic pairings are at a low level of segregation. A low segregation level is associated with a score of less than 40. Refer to Table C-6 below.

Table C-6
City of Desert Hot Springs
Index of Dissimilarity: 2010
Population Groups Score
White-Black/Black-White 21.1
White-Hispanic/Hispanic-White 26.3
White-Asian/Asian-White 11.4
Black-Hispanic/Hispanic-Black 11.6
Black-Asian/Asian-Black 10.4
Hispanic-Asian/Asian-Hispanic 17.0
Source: Brown University, Diversity and
Disparities, Residential Segregation, Index of
Dissimilarity, City of Desert Hot Springs
Because the racial/ethnic composition of the City in the 2015-2019 period is similar to that of 2010, the Dissimilarity Index should continue to show a low segregation level during the 5-year period. Refer to Table C-7. As discussed in Appendix B Section F.2, the City’s ethnic/racial composition does not deviate significantly from the County, and may have lower segregation levels compared to the County based on the Dissimilarity Index. The City’s sites inventory is not expected to negatively impact its Dissimilarity Index because sites are located throughout the community.

Table C-7
City of Desert Hot Springs
Population by Race and Ethnicity: 2010-2019
Race/Ethnicity 2010 2015-2019
Non-Hispanic White 34.4% 30.4%
Non-Hispanic Black 7.5% 9.2%
Hispanic 52.7% 54.5%
Asian 2.3% 3.0%
Other 3.1% 2.9%
Total 100.0% 100.0%
Source: U.S. Census 2010 and American Community
5-Year Estimates

APPENDIX C SITES INVENTORY AND ANALYSIS
C-22
b. Divergence Index
Another way to measure integration/segregation is UC Berkeley’s Divergence Index. The lowest possible value of the Divergence Index is "0" when the demographics of a geography does not differ, or diverge, from that of the larger geography, suggesting no segregation, whereas higher values suggest higher divergence, and hence higher segregation.

The UC Berkeley interactive mapping tool at the census tract level shows that Desert Hot Springs has a low to medium segregation level and is racially integratedin 2020, which primarily occurs between the two largest racial groups in the City in 2020: Hispanic (61%) and White (28%).

According to the AFFH Data Viewer, the majority of the above moderate and lower income level RHNA units occur in Hispanic Majority Tracts with a sizeable dominance value (3.20). Three lower income and two moderate income RHNA sites occur in Hispanic Majority Tracts with a predominant dominance value (30.65). The remaining above moderate and all moderate RHNA units occur in White Majority Tracts with a sizeable dominance value (16.04). In total, there are 1,105 low-income, 478 moderate-income, and 1,400-1,600 above moderate-income units located within Hispanic Majority tracts. The sites inventory will provide diverse housing opportunities in tracts with Hispanic majority populations and help foster integrated living patterns and an incorporated and diverse community.
c. Diversity Index
As discussed in detail in Section F.1 in Appendix B, the City’s diversity index pattern was similar between 2010 and 2018. Census tract 445.17, which overlaps with the Mission Lakes Country Club, has had the lowest score in the City. The highest diversity index scores are found in the central City along Palm Drive. Generally, the City has become more diverse from 2010 to 2018 as diversity index scores increased in many areas and areas with higher scores expanded.

The developed portion of CT 445.17 is mostly situated in unincorporated territory. The development is known as the Mountain View Country Estates Specific Plan or the Mission Lakes Country Club. Most of the land area in this Tract within the City is zoned Open Space – Conservation, with the remaining portion zoned as residential uses that allow up to 20 units per acre or Mixed-Use Neighborhood that allows 15 units per acre. Therefore, CT 445.17 has minimal potential for affordable housing development.

All sites designated for RHNA units in the inventory are located in areas with diversity index scores between 70-85, the most common score range in the City. The distribution of sites for lower income households provides up to 1,105 units along the Palm Drive corridor, which is the City’s commercial core for jobs and services, and which has the most access to transit. The different income level RHNA sites are neither located in the lowest diversity nor the highest diversity areas, and are not expected to exacerbate any segregation patterns because they will continue to expand housing opportunity for all income levels in already diverse areas. d. Isolation Index
As discussed in Section F.3 in Appendix B, the City’s isolation indices show that the average Hispanic lives in an area where over 56% of the residents are fellow Hispanic and that they are moderately segregated. However, Hispanics represented 55% of Desert Hot Spring’s total population in 2019. Because the isolation index value is similar to the Hispanic percentage in the total population, Hispanic residents are not considered to live in a heavily segregated

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neighborhood. The highest percentages (>81%) of non-White populations are seen in tracts south of Pierson Boulevard and along Palm Drive. There are three lower and two moderate income RHNA sites in these tracts. The majority of the above moderate and lower income level RHNA units occur in areas with 61.12% of total non-White population. The remaining above moderate and all moderate RHNA units occur in areas with 52.31% of total non-White population. As discussed above, there are 1,105 low-income, 478 moderate-income, and 1,400-1,600 above moderate-income units located within majority non-White tracts Therefore, the sites inventory will not exacerbate any segregation patterns but rather will provide diverse housing opportunities in areas with higher proportions of non-White populations and promote integrated and incorporated living patterns in the community.
e. TCAC/HCD Opportunity Mapping
Of the three integration/segregation methodologies that were used to prepare the Assessment of Fair Housing (Appendix B), only the TCAC/HCD methodology has identified census tracts that it deems highly segregated.

TCAC/HCD have identified designated six four census tractsblock groups that, according to its methodology, are as hHighly segregatedSegregation & Poverty:
§ CT 445.07 BG 1 & 2
§ CT 445.09 BG 1
§ CT 445.10 BG 1 & 2
§ CT 445.15 BG 1
None of the above moderate and lower income housing sites isare located in these census tracts/block groups. The Aventura Palms and Marbella Villas designated for moderate income units are located in CT 445.15, BG 1..

With regard to socio-economic patterns, the household incomes in CT 445.15, BG 1 increase as the moderate income housing of Aventura Palms and Marbella Villas are constructed and occupied. The census tract block group has 1,539 housing units of which 1,305 are occupied.

Mobile homes comprise 657 of the 1,539 housing units. Aventura Palms and Marbella Villas will add 517 478 moderate income housing units to CT 445.15 BG 1. The addition of moderate income units in this High Segregation & Poverty area will help foster an economically diverse community and integrated living patterns.

3. Racially/Ethically Concentrated Areas of Poverty
There are no R/ECAPs located in Desert Hot Springs. Both the HUD map and HCD’s AFFH Data Viewer show that two census tracts in Desert Hot Springs are designated as R/ECAPs (CT 445.07 and CT 445.09). However, the latest data source for both maps are 2009-2013. As analyzed in Section J.2 of Appendix B, according to the 2015-2019 ACS data, Eight eight of the nine census tracts in the City have minority populations exceeding 50%. However, none of the census tracts have a poverty rate equal to or more than the R/ECAP threshold of 40%.

Therefore, CT 445.07 and CT 445.09 may not be considerednone of the sites included in the land inventory are located in an R/ECAPs anymore after 2015 based on the HUD methodology. None of the inventory sites are located in CT 445.07 and CT 445.09, but Marbella Villas (402 moderate income RHNA site) and sites in the Tuscan Hills Specific Plan (995 moderate and 340 above moderate income RHNA sites) are located near these tracts. The location of lower income RHNA

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units well outside of potential R/ECAPs and moderate and above moderate income units near potential R/ECAPs will not exacerbate any existing concentration or segregation, but rather draw opportunities and improvements near potential R/ECAPs and encourage an economically diverse and integrated community.

4. Areas of Affluence
HCD defines “areas of affluence” as census tracts/neighborhoods in which 80% of the population is White, not Hispanic and the median household income is $125,000 or more. Desert Hot Springs does not have an area of affluence. In 2015-2019, there are 18 census tracts/neighborhoods located in the Region (Riverside County) in which 80% or more of the population is White, not Hispanic. However, only one census tract in the Region had a median household income of $125,000 or more: #CT 456.08 which is located in the City of La Quinta.

Therefore, none of the sites included in the land inventory are located in an area of affluence.

5. Access to Opportunity
a. Opportunity Mapping Tool
The TCAC/HCD Opportunity Mapping Tool is based on 12 indicators of access to opportunity.

Neighborhoods – meaning census tracts – located within the Inland Empire Region are designated into one of the following six categories of access to opportunity. § Highest
§ High
§ Moderate
§ Moderate (Rapidly Changing)
§ Low
§ High Segregation & Poverty
b. Opportunity Categories of Housing Sites
The “above moderate income” housing sites are located in Low and Moderate Resource census tracts:
§ Skyborne (1,400-1,600 units) CT 445.22 Low Resource
§ Tuscan Hills (340 units) CT 445.18 Moderate Resource
The “moderate income” housing sites are located Moderate and High Segregation and Poverty census tracts:
§ Tuscan Hills (995 units) CT 445.18 Moderate Resource
§ Aventura Palms (76 units) CT 445.15 High Segregation & Poverty § Marbella Villas (402 units) CT 445.15 High Segregation & Poverty Census tracts and rural block groups that have both a poverty rate of over 30% and that are designated as being racially segregated are filtered into the “High Segregation & Poverty” category. By definition, they have fewer resources and opportunities.

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The “lower income” housing sites are located in Low and Moderate Resource census tracts as listed below:
§ R-H Site 1 (125 units) CT 445.16 Moderate Resource
§ R-H Site 2 (91 units) CT 445.22 Low Resource
§ R-H Site 3 (125 units) CT 445.22 Low Resource
§ R-H Site 4 (124 units) CT 445.22 Low Resource
§ R-H Site 5 (118 units) CT 445.22 Low Resource
§ R-H Site 6 (120 units) CT 445.22 Low Resource
§ R-H Site 7 (121 units) CT 445.22 Low Resource
§ R-H Site 8 (61 units) CT 445.22 Low Resource
§ R-H Site 9 (220 units) CT 445.22 Low Resource
§ MU-C Site 1 (94 units) CT 445.16 Moderate Resource
§ MU-C Site 2 (37 units) CT 445.2216 Moderate Resource
§ MU-C Site 3 (91 units) CT 445.22 Low Resource
§ MU-C Site 4 (90 units) CT 445.22 Low Resource
§ MU-C Site 5 (100 units) CT 445.22 Low Resource
The first R-H zoned site listed above is located in census tract 445.16. The other seven sites are located in census tract 445.22.

The first two MU-C zoned sites listed above are located in census tract 445.16. The other three sites are located in census tract 445.22.

In 2020 census tract 445.16 was classified as “high” opportunity. In 2021 the same census tract is designated as “moderate” opportunity.

In 2020 census tract 445.22 was classified as “moderate’ opportunity. In 2021 the same census tract is designated as “low” opportunity.

According to the 2021 draft opportunity mapping methodology:

Tracts and rural block groups may shift opportunity categories during annual map updates for multiple reasons, including changes in their underlying data, changes in other parts of the region or rural county against which they are compared (i.e., even if conditions in a particular tract have not changed, if other tracts have experienced significant changes that may shift a given tract’s relative scoring), and changes in the mapping methodology.

The specifics of why the two census tract had shifts in their opportunity categories are unknown to the City. Internal changes within each tract are unlikely because there has not been much housing development in Desert Hot Springs during the 2014-2018 period. The ACS 2014-2018 data was used to calculate many of the numbers in the opportunity tool, which was released as a draft in December 2020. The 2015-2019 ACS data was released in the first week of December 2020.

The TCAC regulations allow a project applicant to use the resource category in effect at the time of the application for the next seven years. Therefore, if an affordable housing developer had submitted an LIHTC application in 2019 for a project located in census tract 445.16, the “high” resource would continue to be in effect until 2026.

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The TCAC/HCD opportunity mapping designates census tract 445.17 as the one “high” opportunity census tract located in Desert Hot Springs. However, the developed portion of the census tract is primarily situated in unincorporated territory. The development is known as the Mountain View Country Estates Specific Plan or the Mission Lakes Country Club. Most of the land area within the City is zoned Open Space – Conservation. Refer to Exhibit C-46.

The Upper Mission Creek/Big Morongo Canyon Conservation area is located primarily north of the City. A “special provision area” spans the middle of the City and is considered part of the Mission Creek area. This is generally the Morongo Wash that flows from the Little San Bernardino Mountains located to the north.

The RHNA sites for all income levels are dispersed in Low and Moderate Resources areas, and there is no concentration of affordable housing sites in Low Resource or High Segregation & Poverty areas. Overall, the sites inventory will encourage integrated living patterns for different income level households and have positive impacts on any segregation patterns or potential in the community.

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Exhibit C-6
Census Tract 445.17

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c. TCAC Reliance on Census Tract Opportunity Categories In making decisions on awarding low income housing tax credits to specific projects, TCAC does not use the opportunity mapping as an absolute criterion. The majority of developed and approved LIHTC projects are not located in the “high” and “highest” resource neighborhoods. The Termer Center found that 21% of the new construction 9% LIHTC projects built between 2008 and 2019 was located in the “highest” and “high” resource census tracts. However, 27.9% of the projects were located in high segregation and poverty census tracts. § Highest Resource 10.1%
§ High Resource 11.1%
§ Moderate Resource 19.4%
§ Low Resource 31.2%
§ High Segregation and Poverty 27.9%
More recently, 63 applications were submitted to TCAC in the 2020 Round 1. Five of the 63 applications were located in either a Highest or High resource census tract. Three of the five projects were awarded funding and they are located in Reedley, Santa Monica, and Alpine.

Consequently, based on past history and practice, it is possible that a tax credit application for a project located in census tract 445.15 could be awarded low income housing tax credits by TCAC.

6. Disproportionate Housing Needs
The impact on disproportionate housing needs of affordable housing developments at the lower income housing sites cannot be foreseen because of two reasons: 1) the types of affordable housing that will be developed are unknown; and 2) the race and ethnicity of future occupants is unknown.

The types of projects awarded Low Income Housing Tax Credits provide insights on the housing types that could be built on the lower income housing sites. In the past five years, tax credits have helped to finance the following housing types:
§ Large Family 47.8%
§ Special Needs 27.4%
§ Seniors 15.5%
§ At-Risk 8.5%
§ SRO 0.8%
It can be assumed that the affordable housing developments will reduce the cost burdens of all fair housing classes that occupy the housing.

G. AVAILABILITY OF INFRASTRUCTURE

1. Water and Sewer
Realistic site development potential indicated in the sites inventory for the three income groups is consistent with the development capacity reported in the General Plan Mobility and Infrastructure Element. Full urban-level services are available within urbanized areas of the City. Specifically, water and sewer service are available or are programmed to be made available for all the sites included in the inventory, indicating the capacity to accommodate the City’s total share of the RHNA.

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The Mission Springs Water District (MSWD) is the primary water service provider in Desert Hot Springs. The District’s service area encompasses 135 square miles including the City of Desert Hot Springs, 10 smaller communities in Riverside County, and communities in the City of Palm Springs.

The MSWD 2015 Urban Water Management Plan (UWMP) projects a population growth of 13,000 persons between 2020 and 2030, of which 94% would occur in the City of Desert Hot Springs.

The MSWD Water Master Plan identifies a variety of improvements to be implemented over the next 15 years. This includes improvements to over 169,000 linear feet of distribution pipelines, seven booster stations, storage tanks capacity of 34.5 million gallons, and 29,000 gallons per minute of supply.

The MSWD 2015 UWMP concludes that adequate water supply will be available to meet demand through 2030 under normal, single dry, and multiple dry rainfall conditions. Demand generated by housing built to accommodate the lower income RHNA is included in the estimated demand increase between 2020 and 2030.

The MSWD and Coachella Valley Water District (CVWD) also provide sewer service in the City.

Desert Hot Springs properties historically have been served by individual septic systems. Recent figures estimated 55% of households are currently served by septic systems.

Two assessment districts (AD11 and AD12) fund the construction of wastewater collection and treatment facilities to abate the threat septic systems pose to the area’s groundwater and to support suburban type development.

MSWD has an ongoing program to connect existing residences currently on septic systems to sewer collectors that have been constructed or are in the process of being constructed. Since 2005, 3,520 parcels in the service area have been converted from septic to sewer service for a total of 7,700 parcels.

The Horton Wastewater Treatment Plant (Horton WWTP), located on Verbena Drive about onehalf mile south of Two Bunch Palms Trail, has a capacity of 2.3 million gallons per day. The Desert Crest Wastewater Treatment Plant, located about one-half mile southeast of the intersection of Dillon Road and Long Canyon Road, has a capacity of 0.18 million gallons/day and serves a country club development and mobile home park.

The Horton Wastewater Treatment Plant, located on Verbena Drive south of Two Bunch Palms Trail, is the primary wastewater treatment facility for MSWD. To accommodate the type and scale of development planned in the City, substantial expansion of wastewater treatment facilities will be required. Continued efforts to expand sewer facilities will reduce and eliminate the adverse impact of septic systems.

Over the long-term, sewer and treatment expansion is guided by the Wastewater System Comprehensive Master Plan. To provide for the type and scale of development planned in the City, substantial expansion of wastewater facilities will be necessary.

General Plan infrastructure goals and policies emphasize consultation and coordination with service providers to ensure that regional collection and treatment facilities have sufficient capacity to meet future wastewater treatment needs. The infrastructure goals and policies also emphasize a continuation of capital improvements planning to fund and prioritize infrastructure projects.

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2. Access to Distribution Facilities
a. Skyborne Specific Plan

1. Water
The Skyborne project is within the service area of the Mission Springs Water District (MSWD).

The owner has entered into a Second Amendment to the “Public Water System Improvement and Water Service Connection Fee Credit/Reimbursement Agreement” with MSWD. The site is currently served with the recent construction of two well sites (34 and 35), a reservoir site, and several miles of transmission and distribution lines. Future construction of additional wells and reservoirs will be built to the satisfaction of MSWD to assure adequate water supply. The owner is fully in compliance with its agreement with MSWD.

2. Sewer Plan
Sanitary sewer facilities are provided by Mission Springs Water District (MSWD) Several miles of off-site and on-site sewer main construction has assured adequate infrastructure exists for the completion of the project. The development will continue to extend this backbone system to serve individual development phases. Wastewater is treated at the Horton Wastewater Treatment Plant located in Desert Hot Springs.

3. Electrical
Southern California Edison (SCE) provides electric facilities to the City. The Garnett Substation located north of Interstate 10 and east of Indian Canyon Drive is the facility through which the project will receive its electrical power. This substation distributes 115KV, 33KV and 12KV lines throughout the general area. A 12 KV O/H(Overhead) distribution line is located on the south side of Pierson Boulevard. There is an 115KV transmission line along the east side of Diablo Road which goes through the westerly portion of the project within a 40’ easement. There is also a 33KV O/H line at Karen Avenue that runs diagonal across the site to Mission Lakes Boulevard and follows the Mollies Road alignment.

SCE has developed plans for service to Skyborne and construction has occurred for the existing developed portions of the Specific Plan area. The development of the remaining Villages will continue with the system in place to the satisfaction of SCE.

4. Other Utilities
The Southern California Gas Company provides natural gas services to the site. An 8” medium pressure main is located approximately ½ mile east of the site at Mission Lakes Boulevard and Western Avenue. A 6” high pressure gas main is also located ½ mile east of the site on Scenic Drive and Western Avenue. There is also a 16” high pressure Questar natural gas line that runs west of and parallel to Worsley Road approximately 55’ west of the existing western edge of the pavement. The Gas Company currently serves the site and plans are prepared for the continuation of construction.

Verizon provides telephone service to the area and has developed plans for the existing homes sites within Skyborne. There is a direct buried underground main located on the south side of Pierson Boulevard. An underground main is also located on the southwest side of Mollies Road and on the west side of Worsley Road. Their infrastructure will continue to be developed with new construction.

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Time Warner Cable provides cable television and internet service to the City and Specific Plan area. There are cable lines on the south side of Pierson Boulevard.

Desert Valley Disposal provides waste disposal service to the project site. Plans for incorporating construction waste and recycling facilities will be considered with the development. b. Tuscan Hills Specific Plan

1. Water
Development will be served by the Mission Springs Water District (MSWD). Precise alignments and sizing of water facilities shall be determined prior to final engineering and construction in accordance with the Mission Springs Water District and City standards.

The pressure will be adequate to provide service to the development and will be required to have minimum flow rates to meet Riverside County Fire Department requirements. The removal of the golf course from the original plan will greatly reduce the water demand for the Specific Plan area and the installation of drought-tolerant landscaping will further produce a more desert friendly development.

2. Sewer
The site will be serviced by the MSWD, Horton Treatment Plant located of Verbena Road, south of Two Bunch Palms Trail. The conceptual plans show 8-inch sewer throughout the development which flow southwest and will tie into the existing (MSWD) 8-inch line running under Pierson Boulevard. A Condition of Approval of the Specific Plan is that prior to recordation of the Final Tract Map the developer will work the MSWD and the City Engineer on final plans for the future sewer system.

3. Other Utilities
Public utilities including electricity, gas, telephone, Cable TV, and solid waste are available and need to be extended onto the property. Within the Tuscan Hills development, specific utilities can be underground or as designated by the providing utility company.

Desert Valley Disposal Inc. will provide solid waste disposal for the Tuscan Hills Specific Plan area. As identified in the General Plan, the City shall continue its efforts to comply with State mandates to reduce the amount of solid waste disposal in landfills. c. Palm Drive Corridor
Water and sewer connection locations are available to Marbella Villas, an entitled 402-unit development located at Palm Drive and 15th Street.

According to the MSWD, while the 16” water main along Palm Drive has adequate capacity, the 12” sanitary and subsequent downstream sewers may require upgrades depending on the size of the housing development
Sites south of Dillon Road will have distribution facilities midway through the 8-year planning period as MSWD does not have facilities along Palm Drive south of Dillon Road.

The MSWD is in the process of updating the Water and Sewer Master Plans.

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H. DRY UTILITIES
Electricity services are provided by Southern California Edison (SCE). The company has two transmission substations within Desert Hot Springs and it’s Sphere-of-Influence. Electric power is primarily generated outside the Coachella Valley; however, SCE purchases wind-generated power from local producers. The City is served by the Devers Substation, north of Dillon Road in the southwestern portion of the City’s Sphere, and the Coffee Substation, located on Camino Aventura west of Palm Drive, just south of city limits.

Additional dry utilities include:
§ Natural gas (Southern California Gas Company)
§ Telecommunications facilities (Frontier Communications) § Cable service (Charter Communications)
§ Solid waste (Desert Valley Disposal)
All sites in the land use inventory have access to full dry utilities. The majority of sites are located adjacent to developed areas and/or major roadways.

For capacity in specific plan areas, adopted specific plans address infrastructure provision.

General Plan policies emphasize the provision of adequate funding, service levels, equitable planning, and maintenance of utility services and physical infrastructures.

I. ENVIRONMENTAL CONSTRAINTS
The sites inventory analysis responds to land use designations and densities established in the General Plan Land Use Element. Thus, any large-scale environmental constraints that would lower the potential yield (e.g., habitat conservation, flooding or steep slopes) have already been accounted for in the General Plan Land Use Map and policies and the Program Environmental Impact Report.

Parts of the City lie within the Coachella Valley Multi-Species Habitat Conservation Plan (CVMSHCP), which identifies the most valuable resource protection areas in and around the City and establishes a permanent habitat reserve and perpetual land management program while accommodating adjacent urban development and recreational uses.

To account for any type of conservation activity, any parcel in the sites inventory that is within the CVMSHCP area has a reduced capacity. Any additional constraints that would occur on a more detailed site review basis would be addressed as part of the individual project review process.

The City’s capacity to meet the 2021-2029 RHNA is not constrained by any environmental conditions.

APPENDIX D GOVERNMENTAL CONSTRAINTS ANALYSIS
D-1

APPENDIX D GOVERNMENTAL CONSTRAINGS ANALYSIS
A. SCOPE OF THE GOVERNMENTAL CONSTRAINTS ANALYSIS

1. Introduction
Government Code 65583(a)(5) requires -
An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, local processing and permit procedures, and any locally adopted ordinances that directly impact the cost and supply of residential development. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the localityfrom meeting its share of the regional housing need in accordance with Section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7). [Emphasis added] Government Code Section 65583(c)(1) identifies the “types of housing” that must be permitted by the City’s Zoning Ordinance:
§ Multifamily rental housing
§ Factory-built housing
§ Mobilehomes
§ Housing for agricultural employees
§ Supportive housing
§ Single-room occupancy units
§ Emergency shelters
§ Transitional housing
Government Code Section 65583(a)(7) requires –
An analysis of any special housing needs, such as those of …persons with disabilities, including a developmental disability ….

In addition to the previously mentioned types of housing, Government Code Sections 65852.2 and 65852.22 provide for the creation of accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs).

Finally, Government Code Section 65660 et. seq. requires that local jurisdictions allow “low barrier navigation centers” by right in areas zoned for mixed use and in non-residential zones permitting multifamily residential uses, if they meet the requirements specified in Government Code Section 65662.

The Government Code requirements provide an outline for the governmental constraints analysis as follows:
• Zone Districts Permitting a Variety of Housing Types (Part B) • Land Use Controls - Residential Zones and Specific Plans (Part C)

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• Building Codes and Their Enforcement (Part D)
• On- and Off-Site Improvements (Part E)
• Fees and Other Exactions (Part F)
• City Processing and Permit Procedures (Part G)
• Analysis of Adopted Ordinances that Directly Impact the Cost and Supply of Housing (Part H)
• Description of Efforts to Remove Governmental Constraints that Hinder the City from Meeting its Share of the Regional Housing Need (Part I) • Description of Efforts to Remove Governmental Constraints that Hinder the City from Meeting Special Housing Needs (Part J)

2. Local Early Action Planning (LEAP) Grant Funding to Remove Governmental Constraints
With Local Early Action Planning (LEAP) grant funding, the City will update its municipal code to revise zoning and development standards to accelerate housing production.On October 14, 2021 the City issued an RFP for an update of the Zoning Ordinance. The selection of a consultant is scheduled for December 16, 2021. The selected consultant will ensure that scope of work at a minimum will include the following:
§ Review and identify Goals, Objectives, and Implementation strategies to ensure the two documents, new Zoning Ordinance and General Plan Update, will be consistent and complementary of each other;
§ A thorough review of the existing Zoning Ordinance and eliminate contradictions and provide a reader friendly Zoning Ordinance;
§ In cooperation with City staff, assess the advantages, shortcomings, and gaps to the existing Zoning Ordinance to assist in clarifying needed areas of updating.

A key objective of the update is to contain specific criteria for as many commonly identified land uses as possible to eliminate or minimize the need for discretionary review, thereby reducing the time associated with processing development applications where discretionary approval is needed.

B. ZONE DISTRICTS PERMITTING A VARIETY OF HOUSING TYPES Table D-1 shows that the Zoning Ordinance allows for development of a variety of housing types.

The Zoning Ordinance provides for the following residential and mixed use zones:
§ R-RD, Residential Rural
§ R-L, Residential Low
§ R-M, Residential-Medium
§ R-H, Residential-High
§ MU-N, Mixed-Use Neighborhood
§ MU-C, Mixed-Use Corridor

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1. Zone Districts Permitting Residential Uses
The Zoning Ordinance describes the purpose and intent of each zone district as follows:

R-RD (Residential Rural Desert): The district is intended to allow for low-density, rural residential uses at a maximum density of one dwelling unit per five acres in a manner that will eliminate or minimize impacts on the natural landscape and will encourage conservation.

R-L (Residential Low): The district is intended to promote the development of low-density, singlefamily residential uses at a maximum density of six dwelling units per acre. Clustered development can occur and is encouraged where needed to respect on-site natural resource areas.

R-M (Residential Medium): The district is intended to promote the development of detached and attached residential uses at a maximum density of 20 dwelling units per acre. Small-lot subdivisions are permitted.

R-H (Residential High): The district is intended to provide multiple unit residential developments at a minimum density of 20 dwelling units per acre up to a maximum of 30 dwelling units per acre, with a variety of on-site amenities.

MU-N (Mixed-Use Neighborhood): The district is intended to provide local- and neighborhoodsupporting mixed-use activity centers with maximum residential densities of 15 dwelling units per acre and/or nonresidential intensity with a maximum floor area ratio (FAR) of 1.0. Commercial retail uses are the primary uses allowed on the ground floor. Professional office and residential uses are also allowed, either integrated with a commercial use or as separate, free-standing use.

Easy walkable access from residential neighborhoods and pedestrian orientation are key considerations in the location and site design of mixed-use developments in this zone.

MU-C (Mixed-Use Corridor): The district is intended to provide higher-intensity, commercially oriented activity with maximum residential densities of 30 dwelling units per acre and/or maximum nonresidential intensities of 1.50 FAR. This district provides for integrated commercialretail, professional office, residential, and civic uses. Commercial retail uses are the preferred uses allowed on the ground floor. Residential development is allowed, either as part of a mixed- use project or as a freestanding use and are encouraged to be developed at the highest allowable density. Convenient public transportation access, innovative housing options, and pedestrianoriented design are key considerations in the location and site design of mixed-use developments in this zone.

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Table D-1
City of Desert Hot Springs
Permitted Uses in Residential Zones
Standard R-RD R-L R-M R-H
Accessory Dwelling Unit P P P P
Residential Care Facilities P P P P
Emergency Shelter X X C P
Manufactured Housing P P P P
Mobile Home Parks X X C C
Multi-Family Dwellings X X P P
Low Barrier Navigation Center* X X X X
Planned Residential Development X C C X
Single Family Dwellings P P P P
Supportive/ Transitional Housing** P P P P
Single Room Occupancy (SRO) X X X C
Source: City of Desert Hot Springs, Zoning Ordinance 17.08.020, 2020 Notes:

P = Permitted by Right; A = Accessory Use; C = Conditional Use Permit; X = Not Permitted. *Consistent with AB 101 which requires that Low-Barrier Navigation Centers are a use by right inareas zoned for mixed use and nonresidential zones permitting multifamily uses. **Supportive and transitional housing constitute a residential use and are subject only to those restrictions that apply to other residential uses of the same type in the same district.

2. Accessory Dwelling Units/Junior Accessory Dwelling Units The City Council approved an ADU ordinance on September 15, 2020 (Section 17.08.170 of the Zoning Ordinance). The ordinance provides for the ministerial approval of ADU applications within 60 days from the date the City receives a completed application.

On the same day, the City Council also approved a JADU ordinance (Section 17.08.175 of the Zoning Ordinance).

HCD reviewed the ordinances and recommended revisions. The City Council approved the second reading of the Ordinance revisions on October 19, 2021.

3. Residential Care Facilities
California requires that many types of licensed facilities serving six persons or fewer be treated for zoning purposes like single-family homes. Except in extraordinary cases in which even a single-family home requires a conditional use permit, these laws bar conditional use permits for facilities that serve six or fewer persons.

Residential care facilities located in a home are permitted by right in all residential zones: R- RD, Residential Rural Desert; R-L, Residential Low; R-M, Residential Medium; and R-H, Residential High. These facilities are not subject to a CUP if they serve seven or more persons.

4. Emergency Shelters
“Emergency shelter” means housing with minimal supportive services for homeless persons that is limited to occupancy for six months or less by a homeless person. No individual or household

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may be denied emergency shelter because of an inability to pay, or as may be amended via Health and Safety Code section 50801. Emergency shelters are permitted by right in the R-H Residential-High zone and permitted with a conditional use permit in the R-M-ResidentialMedium zone.

There are at least 95 acres of vacant R-H zoned land. The land is located in the eastern part of the City, in and near the most developed areas of Desert Hot Springs. The vacant parcels are located on or within 1/3 mile of the City’s main streets and highways (Pierson Boulevard and Palm Drive) ensuring access to transit and available services. The availability of land can easily accommodate shelters for the City’s 68 unsheltered homeless persons identified by the City during the 2020 Point-In-Time Homeless Count.

5. Low Barrier Navigation Centers
Government Code Section 65660 states:
(a) “Low Barrier Navigation Center” means a Housing First, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing. “Low Barrier” means best practices to reduce barriers to entry, and may include, but is not limited to, the following:
(1) The presence of partners if it is not a population-specific site, such as for survivors of domestic violence or sexual assault, women, or youth.
(2) Pets.
(3) The storage of possessions.
(4) Privacy, such as partitions around beds in a dormitory setting or in larger rooms containing more than two beds, or private rooms.

Government Code Section 65662 states:

A Low Barrier Navigation Center development is a use by right in areas zoned for mixed use and nonresidential zones permitting multifamily uses, if it meets the requirements of this article. A local jurisdiction shall permit a Low Barrier Navigation Center development provided that it meets the following requirements:
(a) It offers services to connect people to permanent housing through a services plan that identifies services staffing.
(b) It is linked to a coordinated entry system, so that staff in the interim facility or staffs who colocate in the facility may conduct assessments and provide services to connect people to permanent housing. “Coordinated entry system” means a centralized or coordinated assessment system developed pursuant to Section 576.400(d) or Section 578.7(a)(8), as applicable, of Title 24 of the Code of Federal Regulations, as those sections read on January 1, 2020, and any related requirements, designed to coordinate program participant intake, assessment, and referrals.
(c) It complies with Chapter 6.5 (commencing with Section 8255) of Division 8 of the Welfare and Institutions Code.
(d) It has a system for entering information regarding client stays, client demographics, client income, and exit destination through the local Homeless Management Information System as defined by Section 578.3 of Title 24 of the Code of Federal Regulations.

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Government Code Section 65664 states:

Within 30 days of receipt of an application for a Low Barrier Navigation Center development, the local jurisdiction shall notify a developer whether the developer’s application is complete pursuant to Section 65943. Within 60 days of receipt of a completed application for a Low Barrier Navigation Center development, the local jurisdiction shall act upon its review of the application.

The Zoning Ordinance contains a definition of low barrier navigation center that is consistent with the Government Code requirements.

Low barrier navigation centers are permitted by right in the following zones:
§ MU-N, Mixed-Use Neighborhood
§ MU-C, Mixed-Use Corridor
§ VS-M, Visitor Serving Mixed
§ VS-C, Visitor Serving Commercial

6. Supportive Housing and Transitional Housing
According to HCD:

Supportive housing and transitional housing are considered a residential use of property and are subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).)
The Government Code defines these housing types as follows:

Supportive housing is defined as “housing with no limit on length of stay, that is occupied by the target population, and that is linked to onsite or offsite services that assists the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community.” (Gov.

Code, § 65582, subd. (g).)
Transitional housing is defined as “buildings configured as rental housing developments, but operated under program requirements that require the termination of assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance.” (Gov. Code, § 65582, subd. (j).)
The Zoning Code specifies that transitional and supportive housing constitute a residential use and are subject only to those restrictions that apply to other residential uses of the same type in the same district. (Zoning Code Section 17.04.050). Transitional and supportive housing are permitted in all residential zones and are subject only to those restrictions that apply to other residential uses of the same type in the same district.

Effective January 1, 2019, AB 2162 (Supportive Housing Streamlining Act) requires supportive housing to be considered a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses, if the proposed housing development meets specified criteria. The law prohibits the local government from imposing anyminimum parking requirement for units occupied by supportive housing residents if the development is

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located within a half-mile of a public transit stop. AB 2162 also require local entities to streamline the approval of housing projects containing a minimum amount of supportive housing by providing a ministerial approval process, removing the requirement for CEQA analysis and removing the requirement for Conditional Use Authorization or other similar discretionary entitlements.

The City permits supportive housing by right in the non-residential zones that allow multi-family housing (MU- C, MU-N and VS-M) consistent with AB 2162.

7. Single Room Occupancy Housing (SROs)
SROs are permitted in the R-H Residential-High and MU-C Mixed Use Corridor zones and are treated as a multi-family use.

8. Agricultural Employee Housing
HCD has stated that California Health and Safety Code Sections 17021.5 and 17021.6 generally require agricultural employee housing to be permitted by-right, without a conditional use permit (CUP), in single-family zones for six or fewer persons and in agricultural zones with no more than 12 units or 36 beds.

The City’s Zoning Ordinance does not have an Agricultural Zone but does conditionally allow “agricultural uses” in the R-RD (Residential Rural Desert), R-L (Residential Low) and R-M (Residential-Medium) zones.

The Zoning Code will be amended to provide for “employee housing” as required by Sections 17021.5 and 17021.6 of the Health and Safety Code. The amendments will include adding a definitionof employee housing. In addition, the Zoning Ordinance will provide for employee housing occupied by six or fewer employees in a single-family structure to be treated the same as any other single-family dwelling in the same zone.

9. Manufactured Housing
State law requires local governments to permit manufactured or mobile homes meeting federal safety and construction standards on a permanent foundation in all single-family residential zones (Government Code Section 65852.3). Consistent with state law, manufactured/factory- built housing is considered to be a single-family detached dwelling unit and is treated as such.

10. Mixed-Use
The City has adopted two new mixed-use designations to encourage infill development at the City’s core that is compact and walkable, offers a mix of uses, and creates a sense of place. The two mixed use zones are described on page D-3.

C. LAND USE CONTROLS

1. General Plan/Zoning Designations
a. Residential Zones
The City adopted a new General Plan on May 26, 2020. The General Plan sets forth policies that guide new development, including new residential development and includes strategies for

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increasing residential development. The Plan includes increased residential densities within key developed districts, including areas adjacent to commercial centers, transit, downtown, and major corridors.

Table D-2 summarizes the General Plan land use designations within the City that allowresidential uses, as well as their permitted densities (without density bonus). The table also identifies the consistent zones that were adopted concurrently.

Table D-2
City of Desert Hot Springs
General Plan Land Use Designations and Zones
Residential Land Use Designation
Maximum Densities
(dwelling units per acre) Zones
Residential Designations
Residential Rural Desert (R-RD) 1 du/5 ac Residential Rural Desert Residential Low (R-L) 6 du/ac Residential Low
Residential Medium (R-M) 20 du/ac Residential Medium
Residential High (R-H) 30 du/ac Residential High
Residential Specific Plan (R-SP) varies Residential Specific Plan Mixed-Use Designations
Mixed-Use Neighborhood (MU-N) 15 du/ac Mixed-Use Neighborhood Mixed-Use Corridor (MU-C) 30 du/ac Mixed-Use Corridor
Source: City of Desert Hot Springs General Plan Land Use Element and Zoning Ordinance, 2020. b. Specific Plans

1. Highland Falls
Highland Falls is a sub-area of the Rancho Royale Specific Plan. The Specific Plan provides for the development of 2,145 single family housing units.

2. Skyborne Specific Plan
Skyborne is a community of traditional single family neighborhoods with proposed and optional active adult residential villages. Standard single family residential lots of varying sizes range from 5,500 to 19,000 square feet. Active adult (55+) neighborhoods include smaller lots ranging in size from 3,400 to 4,500 square feet.

The Specific Plan provides for the development of 1,786 single-family homes.

3. Sunset Ridge Specific Plan
The Specific Plan provides for the development of 499 single family housing units.

4. Two Bunch Palms Specific Plan
The approved Specific Plan includes five residential neighborhoods ranging in size from 33 housing units to 260 housing units. Four neighborhoods provide for single family homes to be developed at densities of 4.0 to 4.6 dwelling units per acre. The Specific Plan provides for the development of 588 single family homes.

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5. Tuscan Hills Specific Plan
The Specific Plan provides for the development of 340 single family housing units at very low and low densities.

2. Development Standards
a. Residential Zones and Mixed-Use Zones
Desert Hot Springs regulates the type, location, density, and scale of residential development to protect and promote the health, safety, and general welfare of residents, as well as implement General Plan policies. The Zoning Ordinance establishes restrictions on setbacks, lot coverage, building height, parking, and minimum unit size. Corresponding zones for the General Plan designations were adopted concurrent with Housing Element.

Table D-3
City of Desert Hot SpringsDevelopment Standards
Standard R-RD R-L R-M R-H MU-N MU-C
Max. Density: Unit/Gross Acre 1/5 ac 6 20 30 15 30
Lot Width (Min. feet) Flag Lot 600 70 (5) 45 45 100 100 Cul-de-sacs 30 25 25 25 --- ---
--- 30 25 25 --- ---
Min. Lot Depth (Min. feet) 1,200 75 90 90 --- ---
Front Setback (Min. feet) 100 20 20 5 10 5
Rear Setback (Min. feet) 100 25 20 15 10-15 10-15
Side Yard Setback (Min. feet) 100 5 10 0 5-10 0-10
Street Side Setback 100 10 10 15 10 5
Bldg. Lot Coverage (Max. %) 5% 60% 65% 70% 60% 70%
Min. Private Open Space (s.f.) --- --- 200 s.f 100 s.f. --- 300 s.f Min. Common Open Space (s.f.) --- --- 25% 20% 30% 30%
Maximum Height in Stories/Feet 2/30 2/30 2-4/30-55 2-4/30-55 3/45 4/60 Source: City of Desert Hot Springs Zoning Ordinance, 2020 1Maximum Lot Coverage for mixed Use zones apply only to stand-alone residential The development of 30 dwelling units per acre in the R-H Zone is realistic given the minimal setback requirements, the maximum lot coverage of 70%, and the maximum building height limit of four stories.
b. Parking Standards for Residential, Mixed Use Development and Special Needs Housing City parking standards for residential developments are tailored to vehicle ownership patterns associated with different residential uses. While these standards may affect development costs, they are considered necessary to assure certain quality standards for multifamily housing. The Zoning Ordinance allows for reduced parking standards for senior citizen apartments/congregate care housing; see Table D-4. The parking requirements for this housing type may be adjusted on an individual project basis, subject to a parking study based on project location and proximity to services for senior citizens including, but not limited to, medical offices, shopping areas, and bus stops.

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As part of a comprehensive development code update, the City will evaluate, and modify if necessary, parking standards to ensure that they do not constrain the development of housing, specifically senior housing and multi-family housing.

Table D-4
City of Desert Hot Springs
Parking Requirements in Residential Zones
Residential Type Off-Street Parking Standards
Planned residential developments, includingsingle-family dwellings and condominiums
2 covered spaces within an
enclosed garage and 1
uncovered off-street guest
parking space for every 5 units
Multi-Family Units:

Studio and 1-bedroom

1.5 covered spaces and 1
uncovered guest space for
every 5 units
2-bedrooms
2 covered spaces and 1
uncovered guest space forevery
5 units
3-bedrooms

2.5 covered spaces and 1
uncovered guest space forevery
5 units
Mixed-Use Developments
The total number of parking spaces shall comply with the requirements of Chapter 17.48. A mixed-use project may be required to submit a parking study for review and approval by the City to allow a different requirement through a conditional use permit.

Special Needs Housing
Senior Housing
1 covered space for each unit,
plus 1 uncovered space for 5
units for guest parking
Senior Congregate Care 0.75 covered space for eachunit
Residential Day Care 2 spaces in addition to those
required for primary residence

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c. Parking for Emergency Shelters
Government Code 65583(a)(4)(A)(ii) requires that emergency shelters provide “Sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone.”
The City Attorney has prepared an ordinance amending Land Use Table 17.08.01 to require that emergency shelters shall have sufficient parking to accommodate staff. The second reading of the Ordinance was approved by the City Council on October 19, 2021.

D. BUILDING CODES AND THEIR ENFORCEMENT
The City adopted the 2019 Building Code on November 5, 2019 with only minor amendments that do not adversely impact the cost of housing. The administrative amendments to the Code address time limit of applications, code compliance time limits, fees for work commencing without permits, and re-inspection fees. The Building Code amendments are limited to adoption of several appendices covering agricultural buildings, rodent proofing, patio covers, and grading.

The City's codes are considered to be the minimum necessary to protect the public health, safety and welfare. The codes, which are based on the State housing law and uniform codes, are adopted by many cities throughout Southern California and do not pose a constraint to residential development.

The City’s code compliance program seeks enforcement of all Municipal Code requirements, various State and local laws, and Health and Safety regulations as they relate to conditions or activity within the City. The City’s program is complaint based. The City has implemented a reporting application to make it easier to report code violations. Violation and/or complaints can be reported by phone, the City’s website, or a special app “myDesertHotSprings” available for smart phones. Complaints can be submitted anonymously.

From 2014 to 2017, the City opened an average of 540 new code enforcement cases, the majority of which were for single-family residential structures. During this time frame, only one case was related to a mobile home park (exterior issue).

Code compliance officers are trained to be as helpful as possible in correcting or complying with the standards. Whenever possible, the City makes every reasonable effort to obtain voluntary compliance. In situations where a property owner does not have the resources to address violations, the City will provide assistance. For minor violations; for example related to debris removal, the City will offer available services at no charge. For major violations, code compliance officers will work with property owners to either defer billing for work completed by the City or have the property owners grant consent to be charged for the abatement costs associated with the cleanup of the property or add the cost to the property’s tax roll. The City willalso reach out to property owners for community clean up days or for available resources outside of the City, such as paint and weatherproofing supplies available through serviceproviders such as Habitat for Humanity.

E. ON- AND OFF-SITE IMPROVEMENTS
Site improvements and property dedications are important components of new developmentand contribute to the creation of decent housing. In Desert Hot Springs, site improvements vary depending on the existing condition of each project. Typically, site improvements are requested

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during the plan check process or as conditions of approval. New subdivisions typically require a certain level of public improvements and circulation improvements for the orderly and efficient development of the community.

As stated in the Municipal Code (Section 16.04), site improvements for residential subdivisions include:
§ Grading, drainage, and drainage structures necessary to proper use § Storm drains, conduits, and channels
§ Domestic water supply in compliance with the requirements of the applicable water district § Adequate sanitary sewer facilities, either within and/or outside the subdivision, in compliance with the policies and procedures of the Department of Public Works/City Engineer and the public service purveyor
§ Undergrounding of all existing and proposed utility distribution or transmission facilities § Dedication for streets and alleys, including access rights and abutters rights, drainage, public open space, trails, scenic easements, public utility easements, and other public easements
§ Street trees
§ Land for local transit facilities (e.g., shelters or bus turn outs) § Wind erosion mitigation in areas subject to wind erosion For subdivisions of four or fewer parcels, frontage improvements may be deferred when deemed appropriate by the City Engineer. Deferral may be allowed when the City Engineer finds that construction is impractical due to physical constraints, or the surrounding neighborhood is absent similar improvements. When improvements are deferred, the subdivider enters into an agreement with the City for the installation of all frontage improvements at a future date.

There are no unusual site improvement requirements that increase the cost of housing within the City. The City maintains consistency with legal requirements that require a nexus between the impacts created by a development project and the conditions of approval that are placed on that development. Thus, although development is required to pay its way, new development is not required to subsidize improvements required by past development. In cases where oversizing of facilities is necessary to facilitate future development, reimbursement agreements or similar mechanisms are entered into to ensure that developers pay their fair shares of required improvements.

F. FEES AND OTHER EXACTIONS
Housing construction imposes certain short- and long- term costs upon local government, such as the cost of providing planning services and inspections. As a result, the City relies upon various planning and development fees to recoup costs and ensure that essential services and infrastructure are available when needed. Development impact fees are required to provide essential services and infrastructure to serve new residents. Impact fees are governed by State law and must demonstrate a nexus between development and potential impacts. State law also requires the proportionality test to ensure the pro rata share of costs to provide services and infrastructure by individual developments is reasonable.

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Table D-5 lists the fees for single- and multi-family housing. A fee summary is presented below:

Single-Family Multi-Family
City Fees $13,203 $10,010
Non-City Fees – Other $10,554 $6,344
Developer (School) Fees $8,160 $4,080
Developer (school) fees are the highest individual fees at $8,160 and $4,080.On a percentage basis, the fee breakdown is as follows:

Single-Family Multi-Family
City Fees 41.4% 49.0%
Non-City Fees – Other 33.1% 31.0 %
Developer (School) Fees 25.5% 20.0%
City fees represent approximately 41% and 49% of the total fees for single- and multi-family housing, respectively. The City fees as a percentage of housing development costs is estimated below:

Single-Family
$300,000 4.4%
$350,000 3.8%
$375,000 3.5%
Multi-Family
$200,000 5.0%
$225,000 4.4%
$250,000 4.0%
City fees comprise a small share of the development costs of single-family and multi-family housing. They do not represent a constraint to new residential development.

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Table D-5
City of Desert Hot SpringsFee Schedule
Fee Type Single Family Multi-Family
Fire Protection Impact Fee $362.00 $207.00
Law Enforcement Facilities Impact Fee $362.00 $1,652.00 General Facilities Impact Fee $749.00 $749.00
Circulation System Impact Fee $2,165.00 $2,891.00
Storm Drain Impact Fee $789.00 $460.59
Community Center Impact Fee $1,660.00 $1,438.00
Parkland Impact Fee $2,795.00 $2,421.00
Aquatic Center Impact Fee $221.00 $192.00
Building Plan Check Fee $2,500.00 See note
Building Permit Fee $1,600.00 See note
Total City Fees $13,203.00 $10,010.00
Water Connection Fee1 $4,353.00 $2,423.00
Sewer Connection Fee $2,520.00 $2,020.00
Multiple Species Habitat Conservation (MSHCP) or LDMF3 $1,371.00 $571.00 Transportation Uniform Mitigation fee (TUMF)4 $2,310.00 $1,330.00 Developer Fee $8,160.00 $4,080.00
Total Non-City Fees $18,714.00 $10,424.00
Total Fees $31,917.00 $20,434.00
Note; The Building Department was unable to provide a standard fee because the multi-family fees are valuation based; the valuation is based on occupancy types and square footages of the development.

Therefore, the total multi-family fees are under estimated. 1Mission Springs Water District water connection fee – 3/4 inch meter size for single-family and 1 inch for multi-family tri-plex.

Water Connection Charges apply to the construction of the water transmission lines, well sites for production, reservoirs for storage, and/or the water distribution line running adjacent to a properties frontage 2Mission Springs Water District sewer connection fee
3Fee Subject to change per CVCC
4Fees Subject to change per CVAG
5Palm Springs Unified School District developer fee of $4.08/Sf. Single family fee based on 2,000 SF dwelling size.

Multifamily developer fee based on 1,000 SF dwelling size.

G. CITY PROCESSING AND PERMIT PROCEDURES

1. Development Review Process and Timelines
Development of single family residential subdivisions can take up to three months for processing.

A Tentative Tract Map requires Planning Commission approval for entitlements. Planning Staff serves as the Architectural Review Board and can make recommendations for approval at the same time a subdivision is proposedas part of its function in reviewing applications, analyzes each project’s compliance with the City’s Zoning Ordinance. Multifamily family projects require a Development Review permit, which is approved by the Planning Commission. The City does not have an Architectural Review Board, because City staff is responsible for the review of applications for consistency with Zoning standards. The Planning Commission is the final reviewing authority for Development Permits for multifamily projects. Once entitlements are obtained processing time for building permits can be as short as 30 days for plan check review.

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Multi-family development is processed through a Development Permit which requires Planning Commission approval, and usually takes about 4 months to process. Planning Staff is the Architectural Review Board for multi-family development as well and can recommend approval to the Planning Commission for proposed multi-family development.

The processing time for a Development Permit can be administrative if CEQA clearance is not required. For larger multi-family development where CEQA is required it can be as short as three months as well. By having Planning Staff serve as the Architectural Review Boardproposed housing developments, single family or multi-family, there is no additional approvals required prior to taking proposed housing developments to the Planning Commission for review and approval.

The City complies with the Permit Streamlining Act (1977), which imposes time limits within which state and local government agencies must either approve or disapprove permits. While the City attempts to process development applications in a timely and efficient manner, some delays are outside the control of the City. Delays in processing can occur if environmental review, pursuant to California Environmental Quality Act (CEQA), requires an EIR or MND to be prepared. At times, approval from State or other agencies may also be required for certain typesof projects.

2. Development Permit and Findings
A Development Permit (DP) functions like a site development permit in other cities and applies to all new construction, including the models for single family tract development and multifamily projects, and would be the only permit, other than building permits, required by the City. A DP can be approved by the Planning Director and is required to ensure that new development is carried out in accordance with the Zoning Ordinance, the goals and objectives of the General Plan, and any other adopted plans and guidelines. Unlike a Conditional Use Permit (which is not required for multifamily projects in the City), the DP is a review for consistency with Zoning standards and requirements. The following findings are required for approval of a Development Permit:

1. That the proposed use is permitted within the subject land use district and complies with all of the applicable provisions of this Zoning Ordinance, including prescribed development standards and design guidelines;

2. That the subject site is physically suitable for the type and intensity of the land use being proposed;

3. That the proposed development would be compatible with existing and future developments within the land use district and general area;

4. That there are adequate provisions for water, sanitation, and public utilities and services to ensure that the proposed use is not detrimental to public health and safety;

5. That there is adequate public access and roadway capacity to serve the subject proposal;

6. That there are no significant harmful effects upon environmental quality and natural resources;

7. That any negative impacts of the proposed use can and shall be mitigated;

8. That the proposed use is consistent with the General Plan; and

9. That the proposed location, size, design, and operational characteristics of the planned use are not detrimental to the public interest, health, safety, convenience, or welfare of the City.

The findings are generally limited to objective standards and consistency with the General Plan, Zoning and the requirements of the California Environmental Quality Act (CEQA). The City, as part of a comprehensive Zoning Ordinance update, expects to update the Development Permit process to simplify, improve efficiency, and eliminate unnecessary steps. Any future changes will be compliant with all pertinent housing-related laws.Finding 2 refers only to physical constraints,

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such as slope hazards and washes and channels, and is not subjective. However, findings 3 and 9 can be considered subjective, and could pose a constraint to the development of housing during the planning period. In order to remove this constraint, Program 3.1 requires that findings 3 and 9 be removed from the Zoning Ordinance as part of the comprehensive update currently being undertaken by the City.

H. ANALYSIS OF ADOPTED ORDINANCES THAT DIRECTLY IMPACT ING THE COST

AND SUPPLY OF HOUSING
The City has no growth control measures or urban growth limit line. The City has no local ordinances that directly impact the cost and supply of residential development such as inclusionary ordinances, short- term rental ordinances, or moratoriums on specific development type.

The City has adopted an ADU ordinance. ADUs provide the opportunity to lower housing production costs because no land costs are involved and housing unit sizes can be smaller than the average one- and two-bedroom units.

JADUs provide the opportunity to add to the existing housing supply with the living space of an existing unit.

The City’s Density Bonus Ordinance offers the opportunity to reduce per housing unit land costs and parking improvement costs.

I. DESCRIPTION OF EFFORTS TO REMOVE GOVERNMENTAL CONSTRAINTS THAT

HINDER THE CITY FROM MEETING ITS SHARE OF THE REGIONAL HOUSING NEED The City has designated sufficient land to accommodate the 2021-2029 RHNA. Concurrent with an improving economy and increased demand for housing, the City staff will expedite and streamline housing development applications. As previously noted, the comprehensive Zoning Ordinance update will seek to streamline the development permit process.

J. DESCRIPTION OF EFFORTS TO REMOVE GOVERNMENTAL CONSTRAINTS THAT

HINDER THE CITY FROM MEETING SPECIAL HOUSING NEEDS

1. Reasonable Accommodation Procedure
Building and development standards may constrain the ability of persons with disabilities to live in housing units that are suited to their needs. Reasonable accommodation refers to flexibility in standards and policies to accommodate the needs of persons with disabilities. The Zoning Ordinanceallows for special provisions that meet the needs of persons with disabilities without the need forvariances. The Reasonable Accommodation Ordinance is codified in Chapter 17.220 of the Zoning Code, and copies of the City’s reasonable accommodation brochure and application form are provided on the City’s website in both English and Spanish (Program 3.2). Section

17.220 reads, in part, as follows:

2. Reasonable Accommodation Procedure Application/Brochure The application requirements for reasonable accommodation are detailed in Section 17.220.030

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of the Zoning Code as follows.
“A. A request for reasonable accommodation shall be filed on the application form provided by the Planning Department. If necessary to ensure accessibility, the applicant may request an alternative format. The applicant may be the person with the disability or his or her representative.

No fee shall be required for a request for reasonable accommodation, but if the project requires another discretionary permit, then the prescribed fee shall be paid for all other discretionary permits. The application shall be signed by the owner of the property and shall provide the following information:

1. Applicant’s name and contact information;

2. Property address;

3. Current use of the property;

4. Basis for the claim that the individual is considered disabled under Fair Housing Laws;

5. The zoning code provision, regulation or policy from which reasonable accommodation is being requested;

6. Explanation why the reasonable accommodation is necessary to make the specific property accessible to the individual; and

7. Plans showing the details of the proposal.”
Approval authority rests with the Planning Director, who can grant or deny the reasonable accommodation based on the findings described below. The Director is also required to engage in an interactive process with the applicant to consider alternatives if the accommodation would impose an undue financial burden on the City, or require a fundamental alteration to the proposal, if the Director intends to deny the proposed accommodation. The Ordinance also provides specific factors required for analysis of an accommodation:

Factor 1: Is the housing, which is the subject of the request for reasonable accommodation, to be used by an individual protected under the Act? An individual is protected under the Act if he or she meets the definition of disability.

Additionally, if the specific housing is for people with disabilities, this prerequisite is met.

Factor 2: Is the request for accommodation necessary to make specific housing available to an individual protected under the Act?
Under the Act, cities and counties have an affirmative duty to provide individuals with disabilities reasonable accommodations to “rules, policies, practices, or services, when such accommodation may be necessary to afford such persons equal opportunity to use and enjoy a dwelling.” Whether an accommodation is necessary requires a “fact-specific inquiry regarding each such request.” Failure to make reasonable accommodation is a violation of the Act.

Factor 3: Whether the requested accommodation would impose an undue financial or administrative burden on the jurisdiction?
Once an individual establishes that an accommodation is necessary for equal access to housing, then the jurisdiction must provide the requested accommodation unless they present evidence that granting the accommodation would impose an undue financial or administrative burden on the jurisdiction. The analysis is a fact-specific inquiry. If the jurisdiction establishes an undue burden, then the accommodation is not reasonable and

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should not be granted by local government. In the land use and zoning context, many requests for accommodation will be a request to modify or waive a regulation or procedure.

It costs a jurisdiction nothing to waive a rule, meaning that “. . . the accommodation request amounts to nothing more than a request for non-enforcement of a rule.” In those instances, a jurisdiction would not be likely to demonstrate undue burden.

Factor 4: Whether the requested accommodation would require a fundamental alteration in the nature of a program?
The findings for approval are consistent with State law, and do not result in a constraint to disabled persons seeking the accommodation.

A. The housing, which is the subject of the request, will be used by an individual disabled under the Federal Fair Housing Act and the California Fair Employment and HousingAct.

B. The requested reasonable accommodation is necessary to make specific housing available to an individual with a disability under the Federal Fair Housing Act and the California Fair Employment and Housing Act.

C. The requested reasonable accommodation would not impose an undue financial or administrative burden on the City.

D. The requested reasonable accommodation would not require a fundamental alteration in the nature of a City program or law, including, but not limited to, land use and zoning. (Ord. 679 2-19-19)
Section 17.220.040 addresses appeals to Director decisions: “Any decision of the Director or designee may be appealed by the applicant to the Planning Commission. The appeal shall be made in writing and filed with the Director within 15 days following the final decision. The appeal shall clearly state the reasons for the appeal. Where the request for accommodation is in conjunction with an application for another approval, permit or entitlement, the appeal procedures for such other approval, permit or entitlement shall control. (Ord. 679 2-19-19)” Review authority
A. If an application under this chapter is filed without any accompanying application for another approval, permit or entitlement under this title, the Director shall make a written determination and either grant, grant with modifications or deny a request for reasonable accommodation. The Director shall engage in an interactive process with the applicant to determine whether there is an alternative accommodation, which does not pose an undue financial or administrative burden on the City, or require a fundamental alteration that would effectively address the applicant’s disability-related need, prior to denying a request for reasonable accommodation.

B. If an application under this chapter is filed with an application for another approval, permit or entitlement under this title, it shall be heard and acted upon at the same time and in the same manner as such other application, and shall be subject to all of the same procedures. The relevant review authority shall engage in an interactive process with the applicant to determine whether there is an alternative accommodation, which does not pose an undue financial or administrative burden on the City, or require a fundamental alteration, that would effectively address the applicant’s disability-related need, prior to

APPENDIX D GOVERNMENTAL CONSTRAINTS ANALYSIS
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denying a request for reasonable accommodation. (Ord. 679 2-19-19) § Findings and Decision
Any decision on an application shall be supported by written findings addressing the criteria set forth in the procedure. An application for a reasonable accommodation shall be granted if all of the following findings are made:
o The housing, which is the subject of the request, will be used by an individual disabled under the Federal Fair Housing Act and the California Fair Employment and HousingAct.
o The requested reasonable accommodation is necessary to make specific housing available to an individual with a disability under the Federal Fair Housing Act and the California Fair Employment and Housing Act.
o The requested reasonable accommodation would not impose an undue financial or administrative burden on the City.
o The requested reasonable accommodation would not require a fundamental alteration in the nature of a City program or law, including, but not limited to, land use and zoning. (Ord. 679 2-19-19)
§ Appeals
Any decision of the Director or designee may be appealed by the applicant to the Planning Commission. The appeal shall be made in writing and filed with the Director within 15 days following the final decision. The appeal shall clearly state the reasons for the appeal.

Where the request for accommodation is in conjunction with an application for another approval, permit or entitlement, the appeal procedures for such other approval, permit or entitlement shall control. (Ord. 679 2-19-19)
§ Factors for Considering Requests for ReasonableAccommodation When evaluating applications for a reasonable accommodation, the City staff uses the following factors:

Factor 1: Is the housing, which is the subject of the request for reasonable accommodation, to be used by an individual protected under the Act? An individual is protected under the Act if he or she meets the definition of disability.

Additionally, if the specific housing is for people with disabilities, this prerequisite is met.

Factor 2: Is the request for accommodation necessary to make specific housing available to an individual protected under the Act?
Under the Act, cities and counties have an affirmative duty to provide individuals with disabilities reasonable accommodations to “rules, policies, practices, or services, when such accommodation may be necessary to afford such persons equal opportunity to use and enjoy a dwelling.” Whether an accommodation is necessary requires a “fact-specific inquiry regarding each such request.” Failure to make reasonable accommodation is a violation of the Act.

Factor 3: Whether the requested accommodation would impose an undue financial or

APPENDIX D GOVERNMENTAL CONSTRAINTS ANALYSIS
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administrative burden on the jurisdiction?
Once an individual establishes that an accommodation is necessary for equal access to housing, then the jurisdiction must provide the requested accommodation unless they present evidence that granting the accommodation would impose an undue financial or administrative burden on the jurisdiction. The analysis is a fact-specific inquiry. If the jurisdiction establishes an undue burden, then the accommodation is not reasonable and should not be granted by local government. In the land use and zoning context, many requests for accommodation will be a request to modify or waive a regulation or procedure.

It costs a jurisdiction nothing to waive a rule, meaning that “. . . the accommodation request amounts to nothing more than a request for non-enforcement of a rule.” In those instances, a jurisdiction would not be likely to demonstrate undue burden.

Factor 4: Whether the requested accommodation would require a fundamental alteration in the nature of a program?
As described above, the City’s procedures are in place to provide for reasonable accommodations for its residents, and the requirements and procedures do not pose a constraint to disabled residents.In addition to not imposing an undue financial or administrative burden, a reasonable accommodation must also not result in the fundamental alteration in the nature of a program. “Fundamental alteration” has been defined as, “(1) a substantial change in the primary purpose or benefit of a program or activity; or (2) a substantial impairment of necessary or practical components required to achieve a program or activity’s primary purpose or benefit.” In the land use and zoning context, “fundamental alteration in the nature of the program” means an alteration so far reaching that it would change the essential zoning scheme of a municipality. The case law indicates that in most instances granting a request to modify or waive a zoning policy or procedure, does not result in a fundamental alteration in the nature of a program.

Source: Mental Health Advocacy Services, Inc., Model Ordinance for Providing Reasonable Accommodations under the Fair Housing Act, December 1997 § Reasonable Accommodation Procedure Application/Brochure Reasonable Accommodation Procedure Application/Brochure The application requirements for reasonable accommodation are detailed in Section 17.220.030 of the Zoning Code as follows.

A. A request for reasonable accommodation shall be filed on the application form provided by the Planning Department. If necessary to ensure accessibility, the applicant may request an alternative format. The applicant may be the person with the disability or his or her representative.

No fee shall be required for a request for reasonable accommodation, but if the project requires another discretionary permit, then the prescribed fee shall be paid for all other discretionary permits. The application shall be signed by the owner of the property and shall provide the following information:

1. Applicant’s name and contact information;

2. Property address;

3. Current use of the property;

4. Basis for the claim that the individual is considered disabled under Fair Housing Laws;

5. The zoning code provision, regulation or policy from which reasonable accommodation is

APPENDIX D GOVERNMENTAL CONSTRAINTS ANALYSIS
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being requested;

6. Explanation why the reasonable accommodation is necessary to make the specific property accessible to the individual; and

7. Plans showing the details of the proposal.

B. If the project for which the request for reasonable accommodation is being made also requires some other discretionary approval under this title (including, but not limited to, a Conditional Use Permit, Variance, or Zoning Amendment), the application for reasonable accommodation shall be submitted and reviewed at the same time as the related applications. (Ord. 679 2-19-19)
The City will has prepared an application and brochure describing the Reasonable Accommodation Procedure. The application and brochure will beis available in English and Spanish and posted on the City’s website on the Community Development Department page. The City is actively working to get the application translated and posted alongside the brochure on its website (Program 3.2).

2.3. Housing for Persons with Disabilities
Residential care facilities in a home are permitted by rights in all residential zones: R-RD, Residential Rural Desert; R-L, Residential Low; R-M, Residential Medium; and R-H, Residential High. These facilities are not subject to a CUP if they serve seven or more persons.

These facilities are subject to the same development standards and permit processing standards as other residential uses in those zones, pursuant to the California LantermanDevelopmental Disabilities Services Act. The City has no distancing requirements for group homes for persons with disabilities.

K. GOVERNMENT CODE SECTION 65940.1
Government Code Section 65940.1 requires cities with an internet website to make available on their websites a variety of housing development information such as, but not limited, to: fees and exactions; zoning, design, and development standards; annual fee reports; and impact fee nexus studies.

This information is found on the webpages of City departments. For example:
§ Building Division: forms, building permit application, fee schedule § Planning Division: forms, applications, General Plan, Zoning Map, fee schedule § Finance Department: User Fee Study April 2020, Development Impact Fee Study – City limits, Development Impact Fee Study – Sphere of Influence, fee schedule § City Clerk: Municipal Code – Zoning Ordinance
The Community Development Department will complete a full assessment of what, if any actions are necessary to meet the requirements of Government Code Section 65940.

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APPENDIX E. ANALYSIS OF NONGOVERNMENTAL CONSTRAINTS
A. INTRODUCTION
Government Code Section 65583(a)(6) requires -
An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels… The analysis must examine the following:
§ Availability of financing
§ Price of Land
§ Cost of construction
§ Requests to develop housing at densities below those stated in the sites inventory and analysis (Government Code 65583.2)(c)
§ Length of time between receiving approval for a housing development and submittal of an application for building permits
§ Efforts to remove nongovernmental constraints creating a gap between the planning for and construction of housing
In addition, information is presented on housing prices and rents.

B. AVAILABILITY OF FINANCING
The analysis of the availability of financing is based on the Home Mortgage Disclosure Act (HMDA) data on FHA and conventional loan applications made by borrowers to buy a home in Desert Hot Springs. The data provide the basis to calculate loan denial rates by loan type, borrower income, race/ethnicity, and census tract. The HMDA data analysis covers calendar years 2018 and 2019. The 2020 data will not available until September 2021.

1. Analysis of Home Purchase Loan Applications
During the two-year period 655 loan applications were made of which 12.8% were denied and

87.2% were approved. The loan denial rates for conventional loan applications were slightly higher than for FHA loan applications: 13.4% to 12.6%. Refer to Table E-1.

Overall, the vast majority – almost nine of every 10 loan applications - are approved.

FHA loan applications dominate the market as they comprise 68% of all loan applications.

Table E-2 reports on loan denial rates by loan type and income. Generally speaking, lower and higher income borrowers have the highest loan denial rates. Borrowers in the middle income groups seem to have the lowest denial rates.

The major reasons for loan denial are poor credit history and high debt to income ratios. These could be reasons for the higher than average denial rates of both the lower and higher income groups.

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Table E-3 shows the loan denial rates by race and ethnicity. Black borrowers experience the highest loan denial rates at 23%. Black borrowers submitted only 21 applications, indicating that a small increase in approvals would significantly alter the denial percentage.

The “other” borrowers also had a higher than average loan denial rate of almost 16%.

The Hispanic and White borrowers experience similar denial rates of about 12%. None of the six Asian loan applications were denied.

Table E-3 also shows that Hispanic borrowers comprise 54% of all borrowers. The White, nonHispanic borrowers comprise 28% of all borrowers. Consequently, three of every four loan applicants are either Hispanic or White, non-Hispanic.

Table E-1
City of Desert Hot Springs
FHA/VA/FSA and Conventional
Loan Applications and Denial Rates: 2018 and 2019
Type of Application
2018
Number/Percent
2019
Number/Percent
Total
Number/Percent

FHA/VA/FSA
Total Applications 221 225 446
Number Denied 23 33 56
Percent Denied 10.4% 14.7% 12.6%
Conventional Loans
Total Applications 111 98 209
Number Denied 14 14 28
Percent Denied 12.6% 14.3% 13.4%
All Loans
Total Applications 332 323 655
Number Denied 37 47 84
Percent Denied 11.1% 14.6% 12.8%
Source: Federal Financial Institutions Examination Council (FFIEC), Home Mortgage Disclosure Act (HMDA) Website HMDA Data Browser

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Table E-2
City of Desert Hot Springs
FHA/VA/FSA and Conventional Loan Denial Rates
by Household Income: 2018 and 2019
Loan Type and Income
Total
Applications
Total
Denied
Percent
Denied
FHA/VA/FSA Loans
<$30,000 23 4 0.0%
$30,000-$39,999 48 12 25.0%
$40,000-$49,999 95 6 6.3%
$50,000-$59,999 97 10 10.3%
$60,000-$69,999 67 7 10.4%
$70,000-$79,999 48 6 12.5%
$80,000-$89,999 31 3 9.7%
$90,000-$99,999 16 2 12.5%
$100,000+ 21 6 28.6%
Total 446 56 12.6%
Conventional Loans
<$30,000 22 7 31.8%
$30,000-$39,999 17 1 5.9%
$40,000-$49,999 39 4 10.3%
$50,000-$59,999 37 4 10.8%
$60,000-$69,999 31 1 3.2%
$70,000-$79,999 18 3 16.7%
$80,000-$89,999 11 1 9.1%
$90,000-$99,999 10 3 30.0%
$100,000+ 23 4 17.4%
Income Not Available 1 0 0.0%
Total 209 28 13.4%
All Loans
<$30,000 45 11 24.4%
$30,000-$39,999 65 13 20.0%
$40,000-$49,999 134 10 7.5%
$50,000-$59,999 134 14 10.4%
$60,000-$69,999 98 8 8.2%
$70,000-$79,999 66 9 13.6%
$80,000-$89,999 42 4 9.5%
$90,000-$99,999 26 5 19.2%
$100,000+ 44 10 22.7%
Income Not Available 0 0 0.0%
Total 655 84 12.8%
Source: Federal Financial Institutions Examination Council (FFIEC), Home Mortgage Disclosure Act (HMDA) Website HMDA Data Browser

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Table E-3
City of Desert Hot Springs
FHA/VA and Conventional Loan Denial Rates
By Race and Ethnicity: 2018 and 2019
Race/Ethnicity
Total
Applications
Total
Denied
Percent
Denied
FHA/VA/FSA Loans
Hispanic 264 32 12.1%
White, Non-Hispanic 99 12 12.1%
Black 19 4 21.1%
Asian 4 0 0.0%
All Other1 60 8 13.3%
Total 446 56 12.6%
Conventional Loans
Hispanic 92 11 12.0%
White, Non-Hispanic 85 10 11.8%
Black 2 1 50.0%
Asian 2 0 0.0%
All Other1 28 6 21.4%
Total 209 28 13.4%
All Loans
Hispanic 356 43 12.1%
White, Non-Hispanic 184 22 12.0%
Black 21 5 23.8%
Asian 6 0 0.0%
All Other1 88 14 15.9%
Total 655 84 12.8%
1Includes all other races and applications where race and/or ethnicity were not available
Source: Federal Financial Institutions Examination Council (FFIEC), Home Mortgage Disclosure Act (HMDA) Website HMDA Data Browser

2. Redlining/Financing Availability by Census Tract
Redlining describes a situation where mortgage services are denied or limited for two specific reasons:
§ The racial and/or ethnic composition of an area’s residents § The age of an area’s properties
Redlining is when lenders used discriminatory and unfair lending practices that result in reduced lending accessibility for borrowers in the areas that show high populations of racial minorities, regardless of the credit worthiness of each individual borrower. The word redlining comes from the practice of outlining in red those geographical areas that were perceived to pose a higher mortgage risk. Redlining can affect a particular street, block, census tract, or an entire city.

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According to the U.S. Department of Housing and Urban Development (HUD), the analysis of loan denial rates by census tract will help to identify if there are underserved neighborhoods.

HMDA data was assembled for five census tracts that are located entirely or predominantly within the City. Table E-4 shows that four of the five census tracts had denial rates between 12.0% and

14.1%. One census tract – 445.15 – had a denial rate of 9%. This latter census tract had the fewest loan applications at 67.

Overall, the loan denial/loan approval rates are similar and no individual census tract appears to be underserved.

Table E-4
City of Desert Hot Springs
FHA/VA and Conventional Loan Denial Rates by Census Tract: 2018 and 2019 Census
Tract
FHA/VA/FSA Loans Conventional Loans All Loans
Total
Apps.

Total
Denied
Percent
Denied
Total
Apps.

Total
Denied
Percent
Denied
Total
Apps.

Total
Denied
Percent
Denied
445.07 109 12 11.0% 41 6 14.6% 150 18 12.0%
445.09 49 8 16.3% 22 1 4.5% 71 9 12.7%
445.10 113 18 15.9% 29 2 6.9% 142 20 14.1%
445.15 50 4 8.0% 17 2 11.8% 67 6 9.0%
448.18 125 14 11.2% 100 17 17.0% 225 31 13.8%
Total 446 56 12.6% 209 28 13.4% 655 84 12.8%
Source: Federal Financial Institutions Examination Council (FFIEC), Home Mortgage Disclosure Act (HMDA) Website HMDA Data Browser

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C. PRICE OF LAND

1. Single Family Lots
Land costs have a demonstrable influence on the cost and availability of affordable housing. Due to location and an ample supply of vacant land, housing costs in Desert Hot Springs have generally remained lower than in other suburban and urban areas of the State.

The vast majority of single family residential development will occur in neighborhoods with approved Specific Plans. An example of the cost of land is provided by one listing on the active market. The parcel size is 17.1 acres and consists of 77 semi-finished single family lots. The list price is $1,540,000 or $20,000 per lot. The parcel is located in a neighborhood of 153 total lots, of which 76 have been sold.

There are numerous scattered lots for sale that vary greatly in terms of size and asking prices.

2. Multifamily Land
On the active market there is a 7.51 acre lot for sale with an asking price of $1,950,000. The zoning permits housing at a density ranging from 20 to 30 dwelling units per acre.

At a density of 30 dwellings per acre, the average per unit land cost is $8,666.

At a density of 20 dwelling units per acre, the average per unit land cost is $13,000.

At a density of 15 dwelling units per acre, the average per unit land cost is $17,310.

At either density, land costs would comprise a small share of the total development costs.

D. COST OF CONSTRUCTION
Construction costs for housing can vary significantly depending on the type of housing, such as single-family, townhomes, and apartments. However, even within a particular building type, construction costs vary by unit size and amenities. The difficulty of developing awkward infill sites can also add to costs. Another factor related to construction costs is the number of units built at one time. As the number increase, overall costs generally decrease as builders can benefit from the economies of scale.

For standard housing construction, costs may average $124 to $157 per square foot for singlefamily residences depending on the level of amenities provided, and $114 to $169 per square foot for multifamily residential structure, depending on construction type and excluding parking (International Code Council Building Valuation Data, August 2020).

It should be noted that, when using BVD data, these are “average” costs based on typical construction methods for each occupancy group and type of construction. The average costs include foundation work, structural and nonstructural building components, electrical, plumbing, mechanical and interior finish material. The data is a national average and does not take into account any regional cost differences. As such, the use of Regional Cost Modifiers is subject to the authority having jurisdiction over the issuing of building permits. The City does not apply a Regional Cost Modifier.

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E. COMPONENTS OF TOTAL DEVELOPMENT COSTS
According to the Terner Center:

Total development costs are made up of a lot of different line items, including land or property acquisition costs, construction costs, architectural/engineering costs, local development fees, as well as fees associated with the “soft” costs of development (e.g., legal fees, appraisals, and insurance).

Source: Terner Center for Housing Innovation, The Costs of Affordable Housing Production:

Insights from California’s 9% Low-Income Housing Tax Credit Program, March 2020, page 8 (Author: Carolina Reid)
Research completed by the Terner Center found that between 2008 and 2018, the hard costs of building apartment housing in California increased by $68 per square foot. The research shows that hard construction costs (material and labor) are the primary driver of rising development costs. The shortage in the construction labor market and higher prices for general contractors (as well as the subcontractors they hire) is affecting affordable housing development — just as this shortage impacts market-rate development.

Source: Terner Center for Housing Innovation, The Hard Costs of Construction: Recent Trends in Labor and Material Costs for Apartment Buildings in California, March 2020, 25 pages (Authors:

Hayley Raetz, Teddy Forscher, Elizabeth Kneebone, and Carolina Reid) F. COST OF AFFORDABLE HOUSING
The development costs associated with affordable housing are high and often exceed those of market rate projects. In many cities the cost of single family homes are less than those of individual apartments in an affordable housing development. The cost of new affordable housing is neither low cost nor cheap.

The United States Government Accounting Office (GAO) determined that in California the 2015 average per apartment unit development cost financed by Low Income Housing Tax Credits (LIHTC) was $335,727. The 2015 average cost was 10% higher than in 2011.

Source: United States Government Accountability Office, Low-Income Housing Tax Credit:

Improved Data and Oversight Would Strengthen Cost Assessment and Fraud Risk Management, September 2018, page 116
Affordable housing developments provide housing primarily for lower income households – that is, households whose annual income is 80% or less the County median income.

However, because 1) the development costs of tax credit projects have increased since 2015 and 2) they provide housing for extremely low and very low income households, the affordable rents usually supports 10% or less of the total development costs. HCD has reported that the average percentage shares of funding sources for an affordable housing development are as follows:
§ State housing tax credits 11%
§ Federal housing tax credits 43%
§ Private bank loans 9%
§ Federal HOME funds 5%

APPENDIX E ANALYSIS OF NONGOVERNMENTAL CONSTRAINTS
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§ Federal Home Loan Bank Affordable Housing Program 3%
§ State housing funds e.g. Veterans Housing and Homeless Prevention Program 19% § State Mental Health Services Act Housing funds 6%
G. HOUSING PRICES AND RENTS

1. Housing Prices
The American Community Survey (ACS) collects data on the owner’s estimate of a home’s value if it were for sale. According to the ACS:

Value is the respondent's estimate of how much the property (house and lot, mobile home and lot (if lot owned), or condominium unit) would sell for if it were for sale. If the house was owned or being bought, but the land on which it sits was not, the respondent was asked to estimate the combined value of the house and the land. For vacant units, value was the price asked for the property. Value was tabulated separately for all owner-occupied and vacant-forsale and sold, not occupied housing units, as well as owner-occupied mobile homes.

Table E-5 reports the median home values of cities located in the Coachella Valley. The median home values range from a low of $194,500 (Desert Hot Springs) to a high of $772,500 (Indian Wells).

Table E-5
Coachella Valley
Median Home Values by City (in Rank Order): 2015-2019
City Median Home Value
Desert Hot Springs $194,500
Coachella $219,400
Cathedral City $279,500
Indio $281,400
Palm Desert $350,400
Palm Springs $389,800
La Quinta $398,200
Rancho Mirage $498,700
Indian Wells $772,500
Source: American Community Survey, 2015-2019
5-Year Estimates, Table B25077 Median Home
Value (Dollars)
Based on the owner estimates, more than one-half (52.5%) of the homes in Desert Hot Springs had a value of less than $200,000. An estimated 33.5% had values in the range of $200,000 to $299,000. The balance of homes – 14% - had estimated values of $300,000 or more. The home value data demonstrate the affordability of existing homes in Desert Hot Springs. Refer to Table E-6.

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Table E-6
City of Desert Hot Springs
Value of Housing Units: 2015-2019
Value Number Percent
Less than $100,000 470 10.1%
$100,000 to $124,999 462 9.9%
$125,000 to $149,999 365 7.8%
$150,000 to $174,999 592 12.7%
$175,000 to $199,999 559 12.0%
$200,000 to $249,999 1,015 21.8%
$250,000 to $299,999 544 11.7%
$300,000 to $399,999 408 8.8%
$400,000 to $499,999 137 2.9%
$500,000 to $749,999 17 0.4%
$750,000 to $999,999 51 1.1%
$1,000,000 to $1,499,999 14 0.3%
$1,500,000 to $1,999,999 0 0.0%
$2,000,000 or more 18 0.4%
Total 4,652 100.0%
Source: 2015-2019 American Community Survey 5-Year
Estimates, Table B25075 Value Occupancy
Table E-7 shows the prices of home sold in the City in the first eight months of 2021. During this period, 418 homes were sold. Sales prices in 2021 exceed the owner’s estimate of value in 2019.

The median sales price was $319,900. In fact, 12% of the homes sold for between $400,000 and $499,999. Another 3.1% sold for more than $500,000.

The California Association of Realtors’ (C.A.R.) Housing Affordability Index (HAI) measures the percentage of households that can afford to purchase a median-priced, single-family home in California. C.A.R. also reports affordability indices for regions and select counties within the state as well as by race and ethnicity. The index is considered the most fundamental measure of housing well-being for home buyers in the state.

The C.A.R. report for Riverside County indicates that $85,600 is the minimum household income need to buy a median-priced ($460,000) existing single-family home. The percentage of households who could afford to buy the home is listed below:
§ White, Non-Hispanic 50%
§ Asian 56%
§ Hispanic 40%
§ Black 43%
Existing homes in Desert Hot Springs are among the most affordable in Riverside County.

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Table E-7
City of Desert Hot Springs
Home Sales by Number of Bedrooms January 1, 2021 through August 13, 2021 Price
Number of Bedrooms
Percent
Cumulativ
1 2 3 4 5 Total e Percent
Less than
$200,000 3 14 3 0 0 20 4.8% 4.8%
$200,000-
$249,999 0 18 26 3 0 47 11.2% 16.0%
$250,000-
$299,999 1 11 64 17 0 93 22.2% 38.3%
$300,000-
$349,999 0 5 84 34 0 123 29.4% 67.7%
$350,000-
$399,999 0 1 42 25 4 72 17.2% 84.9%
$400,000-
$449,999 1 2 25 8 4 40 9.6% 94.5%
$450,000-
$499,999 0 1 4 5 0 10 2.4% 96.9%
$500,000+ 0 2 3 4 4 13 3.1% 100.0%
Total 5 54 251 96 12 418 100.0%
Source: Pacific Association of Realtors, Combined Regional Multiple Listing Services (CRMLS) August 13, 2021.

2. Housing Rents
The ACS collects data on the gross rents of renter-occupied housing units. Gross rents include the contract rent plus utilities. According to the ACS:

Contract rent is the monthly rent agreed to or contracted for, regardless of any furnishings, utilities, fees, meals, or services that may be included. For vacant units, it is the monthly rent asked for the rental unit at the time of interview.

Gross rent is the contract rent plus the estimated average monthly cost of utilities (electricity, gas, and water and sewer) and fuels (oil, coal, kerosene, wood, etc.) if these are paid by the renter (or paid for the renter by someone else). Gross rent is intended to eliminate differentials that result from varying practices with respect to the inclusion of utilities and fuels as part of the rental payment. Renter units occupied without payment of rent are shown separately as “No rent paid” in the tabulations.

Table E-8 reports on the median gross rents of cities located in Coachella Valley. The median gross rents range from a low of $788 (Indian Wells) to a high of $1,449 (La Quinta). Almost all of Indian Wells’ rental housing is located in an affordable housing development.

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Table E-8
Coachella Valley
Median Gross Rent by City
(In Rank Order): 2015-2019
City Median Rent
Indian Wells $788
Coachella $879
Desert Hot
Springs $963
Indio $1,084
Palm Springs $1,114
Rancho Mirage $1,191
Cathedral City $1,193
Palm Desert $1,319
La Quinta $1,449
Source:American Community Survey,
2015-2019 5-Year Estimates, Table
B25064 Median Gross Rent (Dollars)
According to Table E-9, rental units with three or more bedrooms comprise almost 41% of the stock. The reason is that just over 2,600 renters live in single-family detached dwellings.

Approximately one-third of the renter occupied housing units have monthly rents in the range of $1,000 to $1,499. Many of these units are probably renter-occupied single-family detached homes.

Approximately one in every eight rental units has monthly rents of $1,500 or more.

The majority (55%+) of renter-occupied units have monthly rents of $999 or less.

The monthly rents are relatively affordable. However, to afford a $900 monthly rent with 30% of income still requires an annual household income of $36,000.

Table E-10 shows the median gross rents by number of bedrooms. The median gross rent of a 2-bedroom unit is $917. The median gross rent of 4-bedroom unit is almost $500 more than a 2- bedroom unit. As noted before, a large percentage of renters occupy single-family dwellings.

APPENDIX E ANALYSIS OF NONGOVERNMENTAL CONSTRAINTS
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Table E-9
City of Desert Hot Springs
Bedrooms by Monthly Gross Rent: 2015-2019
Monthly Gross Rent
No 1 2 3+
Bedroom Bedroom Bedrooms Bedrooms Total Percent
Less than $300 0 0 0 0 0 0.0%
$300-$499 10 84 0 11 105 1.9%
$500-$749 286 431 207 109 1,033 18.3%
$750-$999 0 359 1252 373 1,984 35.1%
$1,000-$1,499 17 46 569 1210 1,842 32.6%
$1,500 or more 0 0 79 609 688 12.2%
Total 313 920 2,107 2,312 5,652 100.0%
Percent 5.5% 16.3% 37.3% 40.9% 100.0%
Note: 172 renter households have no cash rent
Source: 2015-2019 American Community Survey 5-Year Estimates, Table B25068: Bedrooms by Gross Rent
Table E-10
City of Desert Hot Springs
Median Gross Rent by Bedrooms: 2015-2019
Number of Bedrooms Median Gross Rent
No bedroom $578
1 bedroom $710
2 bedrooms $917
3 bedrooms $1,231
4 bedrooms $1,404
Source: American Community Survey, 2015-2019 5-Year Estimates, Table B25031 Median Gross Rent by Bedrooms
H. REQUESTS TO DEVELOP HOUSING AT DENSITIES BELOW THOSE STATED IN THE SITES INVENTORY AND ANALYSIS (GOVERNMENT CODE 65583.2(C) The City has received no request to reduce the density of a site included in the land inventory of the 2013-2021 Housing Element. Development approval of projects with densities lower than what is anticipated in the 2021-2019 Housing Element is not expected during the 6th Cycle planning period. In general, and based on recent development in the City, most development applications aim for densities close to what is allowed by zoning.

I. LENGTH OF TIME BETWEEN RECEIVING APPROVAL FOR A HOUSING

DEVELOPMENT AND SUBMITTAL OF AN APPLICATION FOR BUILDING PERMITS The cost of development can be affected by delays in the land development process. Market factors outside of the City approval process can drive up the costs and risks of private development. In Desert Hot Springs, City staff estimates that most residential development projects have received project approval concurrent with building permit applications except in the case of developments with tract maps. Most commonly, incompleteness of applications can affect this time frame.

APPENDIX E ANALYSIS OF NONGOVERNMENTAL CONSTRAINTS
E-13
J. EFFORTS TO REMOVE NONGOVERNMENTAL CONSTRAINTS CREATING A GAP

BETWEEN THE PLANNING FOR AND CONSTRUCTION OF HOUSING
The City approved several Specific Plans prior to the Great Recession. The downturn in the economy and the COVID-19 Pandemic has combined to stall the development of new housing in the approved Specific Plan areas. Recently, building permits have begun to be pulled for development in the Specific Plan areas.

In addition, the City adopted an Economic Development Element in 2020. The Element provides guidance on efforts to spur the demand for new housing: for example, the development of employment-generating industry clusters; workforce development; and marketing, promotion and economic development.

APPENDIX F HOUSING RESOURCES
F-1

APPENDIX F HOUSING RESOURCES
Appendix F describes housing financial and administrative resources. Some of the resources provide assistance that could help address the City’s housing needs. The availability of land resources to accommodate the City’s share of the regional housing need was described in Appendix C - Sites Inventory and Analysis.

A. FINANCIAL RESOURCES

1. Financial Resources Available to the City
a. Community Development Block Grant Funds (CDBG)
The City is a cooperating city in the County of Riverside Urban County CDBG Program. The County’s 2019-2024 Consolidated Plan allocates $4,235,710 to the Homeowner Housing Rehabilitation Program. The 5-year goal is the rehabilitation of 125 owner-occupied housing units.

Desert Hot Springs home owners may apply for the financial assistance provided by this program.

Desert Hot Springs is not eligible to receive CDBG funds directly from HUD. The County’s CDBG allocation formula annually allocates funds to Desert Hot Springs. These funds are allocated by the City to CDBG-eligible activities.
b. Permanent Local Housing Allocation (PLHA) Program
SB 2 created a dedicated revenue source for affordable housing and directed the HCD to make available 70% of the moneys in the Building Homes and Jobs Trust Fund, collected on and after January 1, 2019, to local governments. Ninety percent of the moneys available will be allocated based on the formula used under Federal law to allocate CDBG funds to CDBG entitlement jurisdictions within California. Ten percent of the funds will be distributed to non-entitlement jurisdictions through a competitive grant program.

The PLHA funds are received directly by the County of Riverside. HCD estimates that the County of Riverside will receive $24 million over a 5-year period.

Desert Hot Springs is eligible to receive a share of the PLHA funds received by the County.

2. Home Investment Partnership Program (HOME)
Desert Hot Springs is not eligible to receive HOME funds directly from HUD. Annually, HUD allocates HOME funds to the County of Riverside. The County’s 2019-2024 Consolidated Plan allocates funds to the following projects:
§ First Time Homebuyer Assistance $4,353,170 100 households assisted § Rental Units Constructed $2,353,170 200 housing units § Rental Units Rehabilitated $1,000,000 50 housing units Income eligible households may apply for FTHB assistance to buy a home located in Desert Hot Springs.

APPENDIX F HOUSING RESOURCES
F-2

3. Section 8 Rental Assistance
The Housing Authority of the County of Riverside administers this program. Rental assistance covers the difference between the market rent and the rent that income-eligible renters can afford based on 30% of their monthly income.

As of September 2021, the program assists 370 Desert Hot Springs residents of which 104 are elderly and 165 are disabled.

Additionally, 1,680 residents are on the Section 8 Waiting List of which 223 are elderly and 443 are disabled.

An explanation of how the Section 8 program works is provided on the next page.

Table F-1 lists the maximum income limits, adjusted by household size, to be eligible for Section 8 rental assistance.

4. Low Income Housing Tax Credits
This program provides equity for the development of affordable housing. The City does not have direct access to this funding, which is awarded by the California Tax Credit Allocation Committee (TCAC) to experienced non-profit and for-profit developers on a competitive basis.

Six affordable housing developments located in Desert Hot Springs have obtained Low Income Housing Tax Credits:
§ Desert Horizons Apartments
§ Arroyo de Paz I Apartments
§ Arroyo de Paz II Apartments
§ Brisas de Paz
§ Hacienda Crossing Apartments
§ Verbena Crossing Apartments
An introduction to the Low Income Housing Tax Credit Program is available at:
https://fas.org/sgp/crs/misc/RS22389.pdf

5. Affordable Housing and Sustainable Communities Program (AHSC) The AHSC Program reduces greenhouse gas (GHG) emissions through projects implementing land-use, housing, transportation, and agricultural land preservation practices that support infill and compact development. Funding for the AHSC Program is provided from the Greenhouse Gas Reduction Fund (GGRF), an account established to receive Cap-and-Trade auction proceeds.

APPENDIX F HOUSING RESOURCES
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How the Section 8 Voucher Program Works
The Housing Authority provides two basic types of rental assistance. The largest program is the Section 8 Housing Choice Voucher Program. The applicant receives a Housing Choice Voucher once they have met all eligibility requirements.

The program participant can select an appropriate rental unit (house or apartment) and live where they wish.

The unit that is selected must:
§ Meet housing quality standards
§ Must have an appropriate number of bedrooms
§ The rent must be reasonable with regard to current market rents § Must also be affordable to the participant
The participant pays part of the rent and the Housing Authority pays part of the rent. The participant pays between 30% and 40% of their monthly income for rent. Depending on the income of the family, the Housing Authority may pay all or a very small portion of the rent.

The two examples listed below are for the same family size with only income differences. There are adjustment factors to the income that will not be discussed in these examples. All of the information below provides examples only and are not to be considered as actual amounts.

Example One:
§ Mother and two minor children
§ Mother’s income is $6.25/hour 20 hrs per week
§ The rent on a two-bedroom apartment is $625 with the tenant paying gas and electricity.

The tenant would pay $94 per month to the landlord
§ The Housing Authority would pay $531 per month to the landlord.

Example Two:
§ Mother and two minor children
§ Mother’s income is $10.00/hr 40 hours per week.
§ The rent on a two-bedroom apartment is $625 with the tenant paying gas and electricity.

The tenant would pay $451 per month to the landlord.
§ The Housing Authority would pay $174 per month to the landlord.

The amount of rent is limited because the participant may not pay over 40% of their adjusted income toward rent and utilities. If the tenant’s share exceeds 40% on a specific unit, the Housing Authority would not approve the lease.

APPENDIX F HOUSING RESOURCES
F-4
Table F-1
Riverside County Maximum Gross Income Limits
Effective 04/01/2020
# of Family
Members
Housing Choice Voucher Program
Extremely Low Income Limits
(30% of median)
Housing Choice Voucher Program
Very Low Income limits
(50% of median)
in household Annual Monthly Annual Monthly
1 $15,800 $1,320 $26,400 $2,200
2 $18,100 $1,508 $30,150 $2,512
3 $21,720 $1,810 $33,900 $2,825
4 $26,200 $2,183 $37,650 $3,137
5 $30,680 $2,556 $40,700 $3,391
6 $35,160 $2,930 $43,700 $3,641
7 $39,640 $3,303 $46,700 $3,891
8 $44,120 $3,676 $49,700 $4,141
9 $48,600 $4,050 $52,750 $4,395
10 $53,080 $4,423 $55,750 $4,645
11 $57,560 $4,796 $58,750 $4,895
12 $61,750 $5,145 $61,750 $5,145
13 $64,800 $5,400 $64,800 $5,400
14 $67,800 $5,650 $67,800 $5,650
Source: County of Riverside Housing Authority

6. CalHFA Multifamily Mixed Income Program
The CalHFA Mixed-Income Program (MIP) provides long-term subordinate financing for new construction of multifamily housing projects which restrict units at a mix between 30% and 120% of the Area Median Income. The program was created after Senate Bill 2 (SB2), the Building Homes and Jobs Act which was signed into law in 2017, established an annual appropriation to the Agency for the purpose of creating mixed income multifamily residential housing for lower to moderate income households. CalHFA receives 15% of the Building Homes and Jobs Act Fund for this purpose.

CalHFA expects to have a total of $60 million available for MIP subordinate financing in 2021.

For 2021, the Agency has also made available funds provided through Assembly Bill 101. The bill directs the funding to CalHFA to be used to finance low- and moderate-income housing.

7. CalHFA Homebuyer Programs
The agency offers a variety of loan programs to purchasers of a home: conventional loans, government insured loans (FHA, VA), down payment assistance programs, and Mortgage Credit Certificates (MCCs).

8. CalHFA Multifamily Programs
CalHFA's Taxable, Tax-Exempt, or CalHFA funded Permanent Loan programs provide competitive long-term financing for affordable multifamily rental housing projects. Eligible projects